HomeMy Public PortalAboutStaff Consultant ReportSTAFF AND CONSULT ANT REPORT TO
THE CITY OF JEFFERSON CITY COUNCIL
TRUMAN HOTEL
TAX INCREMENT FINANCING PLAN
CITY COUNCIL PUBLIC HEARING DATE: SEPTEMBER 6, 2016
INTRODUCTION
On January 21, 2016 , Puri Group of Enterprises, Inc. ("Applicant"), submitted an application for
tax increment financing ("TIF") in the form of the Truman Hotel Tax Increment Financing Plan
(the "TIF Plan"). A TIF Commission hearing was originally scheduled for April 11 , 20 16;
however, due to concerns raised by the Jefferson City Public Schools and an issue with published
notices, that hearing was cancelled. In early May 2016, after receiving some guidance from the
City Council regarding a revised approach to the proposed agreement to provide incentives, the
City's staff and consultants presented to the Applicant an option that would reduce the incentives
burden placed on property taxing jurisdictions. This option involved a pledge of a portion of the
City's lodging tax revenues generated by the hotels proposed to be built within the proposed
Redevelopment Area; provided however, that the Applicant would annex into the City limits
certain of its hotel properties located in proximity to the City. A revised plan contemplating this
approach was submitted to the City's staff and consultants for review on May 25, 2016. As a
result, a TIF Commission hearing scheduled for May 31 was opened and continued to June 23 to
allow adequate time to review the revised plan.
The proposed Redevelopment Area established in the TIF Plan consists of approximately 8.65
acres of land located in Jefferson City, Missouri in an area generally bounded by Jefferson Street
to the southeast, an access road for offices of the Missouri Department of Transportation
("MoDOT") and Highway Patrol to the southwest, Southridge Drive to the northwest, and
Zumwalt Road to the northeast, all in Jefferson City, Cole County, Missouri. The
Redevelopment Area comprises all parcels in thi s block except for the one containing the
aforementioned MoDOT and Highway Patrol offices. For your reference, the Redevelopment
Area is depicted on the maps in Section 1 (pages 1-3) ofthe TIF Plan.
As described in the TIF Plan with supporting documentation from the Blight Study, which can be
found at Appendix B of the TIF Plan, the proposed Redevelopment Area is blighted. This is
primarily because the Truman Hotel and its supporting structures are approximately 50 years old,
and as such have become outdated and obsolete. The TIF Plan states that "several of the
buildings are completely unusable, due to their poor condition, and the others are not able to
generate enough income to produce a profit." As a result , the existing area creates an increase in
the need for public safety services while producing little or no economic value to the community.
According to Appendix C of the TIF Plan, the Redevelopment Project would consist of two
Redevelopment Project Areas ("RP As"). The first RP A occupies approximately five acres at the
southwest end of the Redevelopment Area. This project involves the demolition of three existing
hotel buildings and the construction of a new 5-story, 121 room business class hotel with an
indoor pool and restaurant. The Applicant also proposes to reconfigure the parking lots and
ingress/egress points for better traffic circulation. The estimated cost of RP A 1 is
$22 ,095 ,5 00.00.
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The second RP A occupies the remaining approximately three and one-half acres at the northeast
end of the Redevelopment Area. This project involves the demolition of the remaining buildings
and the construction of a new 4-story, 125 room business class hotel. The Applicant also
proposes to renovate the existing conference space into an updated 20,000fe conference ,
meeting, and event space and will connect the hotels and conference space with new breezeways.
The estimated cost of RP A 2 is $34,702,800.00. The total estimated project costs for completing
the Redevelopment Projects is $56,798,300.
The Applicant is seeking reimbursement from public sources, which includes TIF revenues (i.e.,
Payments in Lieu of Taxes ("PILOTs") and Economic Activity Taxes ("EATs")) and lodging tax
revenue , for a total of $8,889,468.00 (15.65%), plus financing and interest costs. Broken out by
project, the Applicant is reque sting $3,577 ,853 in TIF reimbursement from RP A 1 and an
additional $5,311,615 from RP A 2, plus financing and interest costs. The requested
reimbursements would be made upon certification by the City on a pay-as-you-go basi s, which
means that reimbursement cou ld only be made from tax revenues actually generated by the
Redevelopment Projects.
In addition, pursuant to Sections 99.820.1(12) and 99.835.1 RSMo , revenues from the PILOTs
attributable to property located within the Redevelopment Area in an amount equal to 50% of the
lodging tax revenues generated within the Redevelopment Project Areas would be declared as
surplus by the City. Any declared surplus would be distributed in the same manner and
proportion as the most recent distribution to the affected districts of real property taxes from real
property within the Redevelopment Area.
Finally, upon completion of the TIF Plan and the payment of all Reimbursable Project Costs, tax
revenue from the proposed Redevelopment Area would be paid to all taxing jurisdictions within
such area in the same manner and proportion as other real property taxes.
REVIEW PROCESS OF THE TIF APPLICATION
In accordance with the City 's adopted TIF procedures, the Applicant has submitted an executed
funding agreement to the City to provide a funding so urce for costs incurred by the City in
reviewing and considering it s portion of the TIF Plan. The City, on behalf of the TIF
Commission, mailed the statutorily required 45 day notice of the TIF Commission public he arin g
to the affected taxing jurisdictions. Statutorily required notices were, published in the newspaper
and were mailed to affected property owners. The City also, on behalf of the TIF Commission,
solicited proposals from other applicants to develop the area , as is required by statute. The only
proposal received was the proposal by the Applicant. The application was received and
reviewed by City staff and determined to be consistent with applicable City policies and
requirements, except as noted in this staff report.
As part of City staffs due diligence in reviewing the application for TIF assistance, the City has
utili ze d Springsted Incorporated, as the City 's financial advisor. A s part of its services related to
review of the proposed TIF , Springsted performed an independent "but for" test in the form of an
internal rate of return analysis of the proposal by reviewing and analyzing the Applicant's
estimated costs and operating revenues. Springs ted has prepared a separate report regarding thi s
issue that is included with your materials.
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Certified Appraiser Andrew Baker, MAl, of Val bridge Property Advisors prepared a blight study
of the proposed Redevelopment Area for the Applicant. In order for the TIF Plan to be adopted,
state statutes require that the City Council make the following six findings:
1. The Redevelopment Area on the whole is a blighted area, a conservation area, or an
economic development area, and has not been subject to growth and development through
investment by private enterprise and would not reasonably be anticipated to be developed
without the adoption of tax increment financing. Such a finding shall include, but not be
limited to, a detailed description of the factors that qualify the redevelopment area or project
pursuant to this subdivision and an affidavit, signed by the developer and submitted with the
redevelopment plan, attesting that the provisions of this subdivision have been met;
2. The redevelopment plan conforms to the comprehensive plan for the development of the
municipality as a whole;
3. The estimated dates, which shall not be more than twenty-three years from the adoption of
the ordinance approving a redevelopment project within a redevelopment area, of completion
of any redevelopment project and retirement of obligations incurred to finance
redevelopment project costs have been stated, provided that no ordinance approving a
redevelopment project shall be adopted later than ten years from the adoption of the
ordinance approving the redevelopment plan under which such project is authorized and
provided that no property for a redevelopment project shall be acquired by eminent domain
later than five years from the adoption of the ordinance approving such redevelopment
project;
4. A plan has been developed for relocation assistance for businesses and residences ;
5. A cost-benefit analysis showing the economic impact of the plan on each taxing district
which is at least partially within the boundaries of the redevelopment area. The analysis shall
show the impact on the economy if the project is not built, and is built pursuant to the
redevelopment plan under consideration. The cost-benefit analysis shall include a fi scal
impact study on every affected political subdivision, and sufficient information from the for
the commission established in section 99.820 to evaluate whether the project as proposed is
financially feasible;
6. A finding that the TIF Plan does not include the initial development or development of any
gambling establishment.
On 1 une 23, 2016 , the TIF Commission held a public hearing at which it heard and considered all
protests, objections, comments and other evidence presented. The TIF Commission voted on all
propos ed redevelopment plans , redevelopment projects and designations of redevelopment areas
within thirty days of the hearing. The TIF Commission made recommendations to the governing
body within ninety days of the close of the public hearing concerning the adoption of
redevelopment plans and redevelopment projects, and the designation of redevelopment areas .
Based on the evidence presented to it , the TIF Commission unanimously recommended in
oppositio11 to the adoption of the redevelopment plans and redevelopment projects, and the
designation of redevelopment areas. Pursuant to state statute, the City Council may follow the
recommendation of the Commission; or, if the City Council wishes to approve the TIF Plan, it
may do so upon a two-thirds majority vote.
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While the TIF Plan is legally sound and likely beneficial to the City, the City and the Applicant
have been unable to agree to the terms of a redevelopment agreement, which is the document
that would implement the TIF Plan should it be approved. It is common and a prudent practice
for cities that are considering the approval of a TIF Plan to require either a terms sheet
establishing critical deal points or a fully negotiated redevelopment agreement to be approved
prior to or simultaneously with the consideration of approval of a TIF Plan. The purpose of a
redevelopment agreement is to establish the terms by which a TIF Plan will be implemented.
For example , such an agreement would establish how reimbursements are requested and
processed by the City.
The City and the Applicant had mutually agreed-to a terms sheet regarding the proposed TIF
Plan as it was originally submitted in January for the planned April 11 hearing. The City 's staff
and consultants requested a revised terms sheet for the revised plan that was submitted on May
25; however, the Applicant indicated that they would rather negotiate the full TIF redevelopment
agreement for consideration by the City Council concurrently with the TIF Plan. The City's staff
and consultant's submitted a first draft of the proposed redevelopment agreement for the
Applicant's review on June 9 , 2016. A second draft of this agreement was delivered to the
Applicant on July 2. On July 11 the City's staff and consultants received the first response from
the Applicants regarding the proposed terms of the redevelopment agreement. The City 's staff
and consultants provided comments on that response on July 19.
On July 22 City staff members met with the Applicant to discuss each party 's concerns about the
agreement-including specifically the issue of timing and assurances that the Applicant would
annex its two existing hotels into the City. The Applicant offered to provide the City with a
sample agreement separate from the redevelopment agreement to address the annexations. This
represented an alternative approach to the City staff and consultants ' preference of including the
annexation of the hotels as a condition precedent to the Appli cant's obligation to redevelop the
project and the City 's obligation to provide reimbursement for redevelopment until the
annexation of the hotels could be completed. The Applicant submitted a proposed separate
annexation agreement for the City 's review on July 27. Upon review of the proposed annexation
agreement, the City 's staff and consultants believe that it does not provide adequate assurances
that the annexation will be completed at any point, and it also includes terms that amount to
alternative approach to TIF reimbursement which were never previously discussed by the parties.
As a result, the City's staff and consultants sent to the Applicant on August 11 a letter rejecting
their proposed approach. For the Council 's benefit, we have included the most recent versions of
each party 's contract for your review and consideration.
Due to the importance of the hotel annexation to the City's willingness to pledge lodging tax
revenues to offset the property taxing jurisdictions' burden to contribute incentives, we believe it
is not in the City's best interest or the other taxing jurisdictions best interest to proceed with the
proposed redevelopment plan without a meeting of the minds on the timing and assurances that
the annexation of the hotels will occur. We further believe that the staff and consultants'
preferred "one-contract" approach represents a fair way for the parties to share the risk that the
annexations will not occur. Under that approach the TIF Plan and redevelopment could be
approved and the annexation of the hotels could be completed . If the annexation is not
completed, the Applicant would be under no obligation to redevelop the proposed
Redevelopment Area and the City would have no obligation to reimburse the Applicant for doing
so. Similar conditions precedent are used in other TIF redevelopment deals that involve the
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issuance of TIF revenue bonds. In that situation neither party can know at the time of the TIF
plan and redevelopment agreement approval whether the market will allow the bonds to be
sold-thus each party is protected from its obl igations until that fact can be ascertained.
Likewise here, neither party can know at this time whether the annexation wi ll be completed.
Thus, each party should be protected from its obli gations until that fact can be ascertained.
Because there has been no meeting of the minds between the Applicant and the City 's staff and
consultants w ith respect to the timing and assurances of the hotel annexation, and thus no terms
sheet or mutually agreed-to redevelopment agreement exists, it is our op ini on that the T IF Plan
sho uld not be approved.
ANALYSIS OF REQUIRED STATUTORY FINDINGS
FINDING # 1 -A finding must be made that the development area is a blighted area, a
conservation area, or an economic development area and as a whole has not been subject to
growth and development through investment by private enterprise and would not reasonably
be anticipated to be developed without the adoption of tax increment financing.
Blight Designation
Appendix B of the TIF Plan contains a blight study, dated October 1, 2015, prepared for the
Appli cant by Certifi ed Appraiser Andrew Baker, MAl, of Valbridge Property Advisors. This
study concluded that the area as a who le met the TIF statutory requirements for blight due to the
predomin ance of the following primary blighting factors in the redevelopment area:
1) Defective or inadequate street layout:
a. Poor vehicular access and/or internal circulation ;
b. Substandard driveway definition and parking lot layout;
c. Offset or irregular intersections ;
d. Substandard or nonexistent pedestrian circulation; and
e. Lack of signage.
2) Unsanitary and unsafe conditions resulting from:
a . Defective and inadequate street layout leads to unsafe conditions;
b. Black mold infestati on;
c. Crumbling brick near gas lines;
d. Cracked and uneven parking areas ; and
e. Outdated building systems.
3) Deterioration of site improvements:
a. Potholes, cracks , and otherwise damaged parking areas ; and
b . Deteriorating curbs and pool deck.
4) Improper subdivision or obsolete platting (NOTE: this factor was NOT found):
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5) Existence of conditions which endanger life or property by fire and other causes:
a. Lack of fire sprinkler system in any area, including the kitchen area.
While the TIF Act requires that either an economic or social liability be found , the study
concludes that these blighting factors have resulted in both an economic and social liability,
which means the area meets the statutory requirements to be declared a blighted area.
"But For" Test
The "but for" test requires that a finding be made that the proposed Redevelopment Area has not
been subject to growth and development through investment by private enterprise and would not
reasonably be anticipated to be developed without the adoption of tax increment financing ; i.e.,
"but for" the use ofTIF, the area is not anticipated to be developed .
As required by the TIF statute, Appendix H of the TIF Plan includes an affidavit from Dr. Ravi
K. Puri , as a representative of the owner, Puri Group of Enterprises, Inc., the Applicant, attesting
that the statutory requirements for blight for the area on the whole and the "but for " test have
been met; i.e., that without TIF assistance the Redevelopment Project would not be reasonably
expected to occur on the designated site and that the project would not be economically viable
for the Applicant without such assistance.
In addition, Springsted's independent analysis concludes that the projected internal rate of return
for the Applicant would be 8.61% without TIF assistance, which is an unacceptable rate of return
for a redevelopment of this type in the current marketplace. Springsted calculates the
Applicant's internal rate of return at 10.6% with TIF assistance. Springsted estimates that the
internal rate of return necessary to motivate a developer to undertake a project of the type and
size proposed for the proposed Redevelopment Project within the current marketplace is 8.50%
to 13.00%, with an average return of 10.48 %. As the Applicant's estimated rate of return
without TIF is at the very low end of the range and below th e average return, it is concluded that
the Project would not likely occur without TIF in the current marketplace.
Staff and Consultant Recommendation: There is sufficient evidence for the City
Council to find that: 1) the proposed Redevelopment Area is a "Blighted Area"
as described by state statutes; and 2) the proposed Redevelopment Area has not
been subject to growth and development through investment by private
enterprise, and would not reasonably be anticipated to be developed without the
adoption of tax increment financing and that the Applicant has submitted the
required affidavit to that effect.
FINDING # 2 -A finding must be made that the proposed TIF Plan conforms to the
comprehensive plan for the development of the City as a whole.
The City 's comprehensive plan i s titled the Comprehensive Plan Update for the City of
Jefferson, Missouri, originally adopted in June 1996. The Development Plan Map within the
Comprehensive Plan Update was last adopted b y the Mayor and City Council in March 2013.
The Development Plan Map indicates that the Truman Hotel Redevelopment Area may be
developed with commercial land uses , including hotel , conference center, and incidental uses.
Based on th e proposed uses outlined by the applicant in the TIF Plan, the TIF Plan conforms to
the City 's Comprehensive Plan for the area. A certificate of compliance is sued by the C ity 's
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Director of Planning and Protective Services , Janice McMillan, is provided at Appendix E of the
TIF Plan.
Staff and Consultant Recommendation: There is sufficient evidence for the City
Council to find that the proposed TIF Plan is in conformance with the City's
Comprehensive Plan.
FINDING # 3-A finding must be made that the estimated dates for the completion of projects
and retirement of obligations incurred to finance the development do not exceed twenty-three
years from the time the first project is authorized, that the first project is scheduled to be
authorized within ten years of the adoption of the TIF Plan, and that no property will be
secured by eminent domain later than five years from the adoption of the ordinance approving
the development project.
As indicated on page 8 of the TIF Plan, the Redevelopment Projects are expected to be
completed in two phases. RP A 1, which includes demolition of several buildings and
construction of the new 5-story, 121 room business class hotel with an indoor pool and
restaurant, was originally estimated to begin in Spring 2016 with completion by Fall 2017. RP A
2, which includes construction of the new 4-story, 125 room business class hotel , renovation of
the existing conference space, and construction of the breezeways, was originally expected to
commence in Fall 2018 with completion in Spring 2020. Thus, the estimated date of completion
of the entire Redevelopment Project established in the TIF Plan is approximately June of 2020,
which does not exceed twenty-three years from the anticipated date that the project i s authorized
(the estimated completion date would be subject to change).
The Applicant is not requesting the City (or a separate entity at the City's request) to issue
obligations to borrow public funds for the implementation of this proposed TIF Plan. Without
the existence of obligations, there can be no estimated date for retirement of obligations incurred
to finance the redevelopment costs of the proposed redevelopment project. In the event that
obligations were issued, the TIF Plan states, and the C ity would follow, the statutory requirement
that such obligations would be scheduled to be retired not more than 23 year s after the adoption
of the ordinance to approve the redevelopment project.
Appendix D indicates that tax increment financing revenues would become available for
Redevelopment Project Area l beginning in 2017 to begin reimbursement of the Reimbursable
Project Cos t s for that project, which is anticipated to be fully reimbursed in 2038 (22 years).
Likewise, tax increment financing revenues would become available for Redevelopment Project
Area 2 beginning in 2019 to begin reimbursement of the Reimbursable Project Costs for that
project, which is anticipated to be fully reimbursed in 2041 (23 years). Based on the forgo ing,
the TIF Plan anticipates that the TIF Projects would be completed and fully reimbursed (as
requested) within ten years after the adoption of the proposed TIF Plan.
All of the property included in the Applicant's proposed Redevelopment Area i s owned by the
Applicant. It would not be neces sary to acquire the parcels not owned by the applicant to
complete the Redevelopment Project. Therefore, it is not anticipated that any property within the
Applicant's proposed Redevelopment Area would need to be acquired by eminent domain.
Nevertheless, the TIF Act s pecifically prohibits the acquisition of property by eminent domain
later than five years from the adoption of an ordinance approving the redevelopment project.
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Staff and Consultant Recommendation: There is sufficient evidence for the City
Council to find 1) the TIF Plan contains information that dates for completion of
projects and retirement of obligations incurred to finance the development are
not more than twenty-three years from the adoption of the ordinance approving
a development project within the development area, 2) no project is scheduled or
permitted to begin more than ten years after the adoption of the ordinance
authorizing the TIF Plan, and 3) the proposed plan meets the statutory
requirement regarding the acquisition of property by eminent domain.
FINDING # 4 -A finding must be made that a plan has been developed for relocation
assistance for businesses and residences.
The TIF Plan includes a relocation policy for businesses and residences within the TIF Plan and
Redevelopment Project Area, which satisfies the requirement for this finding. The City and the
Applicant do not anticipate that re location assistance would be needed in the Redeve lopment
Area; however, in case such relocation assistance is needed, a plan has been prov ided m
accordance with the TIF Act.
Staff and Consultant Recommendation: There is sufficient evidence for the City
Council to find that the Applicant has developed a plan to provide relocation
assistance for businesses and residences affected by the TIF Plan.
FINDING # 5 -A finding must be made that a cost-benefit analysis has been prepared
showing the economic impact of the TIF Plan on each taxing district which is at least partially
within the boundaries of the development area, that the analysis shows the impact 011 the
economy if the project is not built, as well as if it is built pursuant to the development plan
under consideration, that the cost-benefit analysis includes a fiscal impact study on every
affected political subdivision, and that there is sufficient information from the developer for
the commission to evaluate whether the project as proposed is financially feasible.
A cost-benefit analysis has been submitted as Appendix G to the proposed TIF Plan to show the
economic impact of the TIF Plan on each taxing jurisdiction and political subdivision that is at
least partially within the boundaries of the proposed Redevelopment Area. As required by state
statute, this analys is shows the impact on the economy if the Redevelopment Project is not built,
or is built in accordance with the TIF Plan under consideration. This analysis also includes a
fiscal impact study on each affected political subdivision and provides suffi cient information to
evaluate whether the R edevelopmen t Project is financially feasible.
Appendix F includes a letter from Tim Hagenhoff, senior vice president at Mid America Bank,
expressing the bank's conditional approval of financing for the Redevelopment Project.
Appendix F also includes a letter from Dr. Ravi Puri, president and CEO of Puri Gro up of
E nterpri ses, expressing the company's conditional commitment to fund the Redevelopment
Project. The letters as a whole satisfy the statutory requirement of a "commitment to finance the
project costs" as indicated in Section 99.810.1 , RSMo. Additionally, it is important to note that
with a "pay-as-you-go" TIF such as this , the TIF Plan cannot be impl emented w ithout up-front
financing by the chosen Developer and/or its private lending institution, if applicable. Thus,
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financing will be committed well prior to the reimbursement of any Redevelopment Project
Costs from TIF revenues.
The financial structure of the Redevelopment Plan would be in part through the use of private
capital in the form of equity and debt financin g. The Redevelopment Project i s expected to
generate TIF revenues based upon the projections shown in Appendix D of the TIF Plan as well
as lodging tax revenues, which would be used to pay Reimbursable Project Costs. The specific
terms regarding the use of the TIF revenue stream and lodging tax revenues would be addressed
in a redevelopment agreement between the C it y and the developer. The redevelopment
agreement would normally be con s idered and approved by the City Counci l simultaneous ly with
its consideration ofthe TIF Plan or soon thereafter; however, because the City and the Applicant
have been unable to agree to the terms of a redevelopment agreement, one is not being pres ented
for consideration and approval at this time.
The Applicant has provided projections illustrating the financial feasibility of the proposed TIF
Plan and Redevelopment Project. Because reimbursement is expected to be on a pay-as-you-go
basis , the reimbursements actually provided would be limited to only that amount of revenue
received. Considering this, City staff and consultants conclude that the Applicant has provided
s ufficient information to evaluate the financial feasibility of the proposed TIF Plan .
Staff and Consultant Recommendation : There is sufficient evidence for the City
Council to find that 1) the Applicant has prepared a cost-benefit analysis
showing the economic impact of the TIF Plan on each taxing district which is at
least partially within the boundaries of the development area, 2) the analysis
shows the impact on the economy if the project is not built, as well as if it is built
pursuant to the development plan under consideration, 3) the cost-benefit
analysis includes a fiscal impact study on every affected political subdivision,
and 4) there is sufficient information for the City Council to determine if the
project is financially feasible.
FINDING # 6 -A finding must be made that the TIF Plan does not include the initial
development or development of any gambling establishment.
A review of the TIF Plan and proposed Redevelopment Project indicates that the initial
development or development of any gambling establishment is not included for either.
Staff and Consultant Recommendation: There is sufficient evidence for the City
Council to find that the TIF Plan does not include the initial development or
development of any gambling establishment.
CONCLUSION
The City staff and consultants' approach in reviewing requests for TIF assistance overall has
been to determine the amount of public benefit the TIF Plan will generate . Adoption and
implementation of this TIF Plan and Redevelopment Projects would benefit the public by
reducing or e liminating blighted conditions existing at the Truman Hotel which, in it s prime, was
a significant economic driver and gathering place for the City. In conducting a thorough review
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of the proposed TIF Plan and Redevelopment Projects along with the assistance of its financial
and legal consultants, it is City staffs conclusion that the Applicant has generally provided
sufficient information to demonstrate that the six statutorily required findings have been met and
that the City Council has received sufficient evidence to support approval of the proposed TIF
Plan and Redevelopment Projects. However, because the City and the Applicant have been
unable to agree to the terms of a redevelopment agreement, which, as previously stated , is the
document that would implement the TIF Plan, the TIF Plan is unable to be put in to effect at this
time. As a result, the City staff and consultants must concur with the TIF Commission and
recommend against approval of the proposed TIF Plan and Redevelopment Projects. Should the
City Council desire to approve the TIF Plan, a two -third majority vote is required by the TIF Act
because the TIF Commission recommended in opposition to the TIF Plan after their hearing on
June 23.
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