HomeMy WebLinkAbout02 19 2013 EDA 7C Business Plan Vision Strategic O � PRIp�
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Prior Lake_ MN 55372
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ECONOMIC DEVELOPMENT AUTHORITY AGENDA REPORT
MEETING DATE: February 19, 2013
AGENDA #: 7C
PREPARED BY: Dan Rogness, Community & Economic Development Director
AGENDA ITEM: EDA BUSINESS PLAN AND 2030 VISION & STRATEGIC PLAN
DISCUSSION: Introduction
The City Council adopted the 2030 Vision & Strategic Plan on February 21,
2012, and it adopted the EDA Business Plan on September 24, 2012. The
council will be discussing the 2030 Strategic Plan at a Work Session on March
11 th , so staff is asking the EDA to review and discuss both documents in order
to evaluate: (1) the Economic & Community Development strategic element
goals, and (2) the 2012/2013 implementation plan in the EDA Business Plan.
Histor
The EDA spent considerable time in on its Business Plan during 2012. It should
discuss the implementation of this plan periodically, including the first meeting of
the year. The EDA's business plan also ties into the 2030 Vision & Strategic
Plan, so the EDA should be reviewing both documents.
Current Circumstances
The EDA's Business Plan include five implementation actions related to: (1)
broadband, (2) technology village, (3) property supply and demand, (4) targeted
areas for development assistance, and (5) city codes and fees. The 2030 Vision
& Strategic Plan identified five goals related to: (1) community-wide fiber net-
work, (2) technology viltage/incubator, (3) data center with fiber optic access, (4)
redevelopment plan, and (5) city code impact on economic development objec-
tives. Some key areas overlap, including broadband/fiber, technology vil-
lage/incubator, and city codes (for business friendly changes).
Conclusion
The first meeting of the year is a good time to evaluate progress toward stated
economic development goals and objectives. It is also important to identify key
actions that are important to get underway in 2013. Discussion can continue to
the EDA's next meeting on February 19 (Tuesday).
ISSUES: During 2012, the EDA made progrees in various strategic areas.
A broadband project has been initiated which will be a partnership be-
tween the city, county and one or more private vendors. This project, in
addition to serving four presently unserved city buildings, will bring high-
speed data capabilities to five business areas in the city. In addition the
EDA has directed the Broadband Advisory Committee (BAC) to examine
current technology changes in the industry to assess their impact in the
city's ultimate goal to provide this service citywide.
A significant step in revising city codes was undertaken with the modifi-
cation of certain parts of the city's zoning ordinance so it is more compa-
rable to that of sourrounding cities. The EDA has also recommended,
and the city council approved, an enhanced fee deferment program both
for city and regional sewer/water fees.
Technology Village is occupied by one business and soon will have two
more. It is believed that up to two more businesses could occupy this
space. Consequently the EDA may wish to retain this effort on its 2013
list.
No real progress has been made in getting a data center into the com-
munity. However, the improvements contemplated to the Wecome Ave-
nue area bring sewer and water to a 40-acre annexation area which is on
a major highway and can be served by potentially two electrical sources.
The EDA may want to continue support of this effort and perhaps con-
template other efforts along this line.
As part of a Resilient Communities Project applied for by the city, a pro-
ject is intended for completion which would provide for a"Master Plan -
County Road 42 Corridor". This area has approxiamately 650 acres of
property and represents the city's single largest area for commerce and
industry. EDA participation in this project is desirable as is the participa-
tion of major property owners in the area.
Another study in the above referenced project will evealuate how the city
might take better advantage of the fact that it has the second largest na-
tive American Casino and associated business enterprises within our
corporate limits. Together, we must better encourage economic devel-
opment for Prior Lake and adjacent communities. Here again, the EDA
may wish to include this in the 2013 objectives and plan for how it might
best participate.
An activity which has not yet started within the EDA plan is making com-
mercial/Industrial properties pad-ready. A good place to start such a pro-
ject, if the EDA is inclined, is to define what "pad-ready" means and what
are the options that would lead to the most productive steps the EDA
could take to accomplish this objective.
FINANCIAL The EDA has resources available to help achieve economic development goals
IMPACT: and objectives, including:
1. Business revolving loan accounts (approximately $200,000).
2. TIF 1-1 redevelopment fund (approximately $200,000).
3. Technology Village budget ($50,000 with 2013 budget amendment).
4. 2013 EDA budget for professional services ($60,000).
5. Regional and Local sewer/water fee deferment program.
6. City Staff.
ALTERNATIVES: For discussion only.
RECOMMENDED N/A
MOTION:
ATTACHMENTS: 1. EDA Business Plan
2. 2030 Vision & Strategic Plan (Econ. and Comm. Dev. element only)
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"A Wonderful Place to Live, Work and Play for a Lifetime"
PRIOR LAKE ECONOMIC DEVELOPMENT AUTHORITY (EDA)
BUSINESS PLAN — APPROVED SEPTEMBER 24, 2012
Purpose
The City's mission, as stated in 2030 Vision and Strategic Plan, is to "enhance the quality of life for
current and future citizens by providing quality services which result in a safe and healthy
community; recreation and leisure opportunities; preservation and effective use of lakes, parks and
other natural resources; economic vitality; and the promotion of partnerships, volunteerism and civic
pride for the community's diverse population." This business plan will guide the Prior Lake Economic
Development Authority (EDA) as it develops and implements strategic initiatives in 2012-2013 and
beyond to 2020 and 2030.
Primary "economic vitality" goals relate to: (1) job creation/retention, (2) services for businesses and
residents, and (3) a stable and reliable tax base. Prior Lake is very desirable for many reasons, but the
city needs an active and entrepreneurial entity such as the EDA to work directly with new and existing
businesses to fulfill Prior Lake's vision as a wonderful place to live, work and play. This business plan
begins to develop a framework for the EDA, which will be reviewed and approved by the EDA and City
Council annually.
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Page 1 of 9
Achievement Goals — Jobs, Businesses, Values and Taxes
Considering the city's strengths and challenges, the following goals are established for Prior Lake
related to jobs, businesses and taxable market value increases. The "Base" figures are estimates
based on the past ten year history of commercial and industrial development. These base projections
assume jobs and businesses will be added due to normal market demand. "New" goals show an
increase in jobs, new businesses and market value, over and above the historical average. These new
goals assume an increased public investment by the EDA and City Council (i.e., public financing
assistance, business incubation, public land sales). With increased public investment in commercial
and industrial development, the new goals show an estimated increase of 50%o above the Base
figures. All figures are considered to be conservative for estimating economic growth in Prior Lake.
5-Year Time Base Jobs Plus Base Plus New Base Value Plus
Periods Created New Jobs Businesses Businesses Increase New Value
(Historical) Created Added Added (Historical) Increase
2000-10 235 XXX 10 XXX $17 M XXX
5-YearAvg.
2011-2015 250 125 10 5 $20 M $10 M
2016-2020 350 175 15 8 $25 M $12 M
2021-2025 300 150 12 6 $22 M $11 M
2026-2030 300 150 13 6 $23 M $12 M
Total 2011+ 1,200 600 50 25 $90 M $45 M
Assumqtions: 1. 2000-10'Base' information is based on city building permit activity reports for new commercial and
industrial construction, not including public facilities and multi-family rental housing.
2. Annual increases in base jobs, businesses and value continue trends from 2000-2010.
3. Estimated increases due to Economic Development ('New') uses the Base times 1.5.
4. Total city/county/school taxes below are estimated using $2.75 per square foot of building space.
5-Year Time Base Taxes Plus Total City Portion
Periods Created E.D. Taxes Estimated 30%
(Historical) Created New Taxes Estimate
2000-10 Avg. x $g5 K XXX $85 K $25.5 K
5 Yrs.
2011-2015 $100 K $50 K $150 K $45.0 K
2016-2020 $130 K $65 K $195 K $58.5 K
2021-2025 $120 K $60 K $180 K $54.0 K
2026-2030 $120 K $60 K $180 K $54.0 K
Total 2011+ $470 K $235 K $705 K $211.5 K
2012/2013 Implementation Plan
The following actions shall be accomplished during 2012 and 2013 as key initiatives of the EDA. All
initiatives can work together to support a business community that is focused on technology and
Prior Lake's strengths in entertainment and recreation. The EDA will also be developing specific
business plans for each initiative, similar to one for the Technology Village.
Page 2 of 9
1. Broadband (Communitv Fiber Network). The EDA hired a consultant, Lookout Point
Communications, to move this initiative forward. A subcommittee was formed to work with
the consultant in order to fully evaluate options and work with local incumbent service
providers in order to provide fiber to homes and businesses throughout Prior Lake, including
Mystic Lake Casino/Hotel and other tribal property.
• Accomplishment: Prior Lake will be more competitive economically by connecting
existing/future businesses and residents to high-speed fiber network.
• Timeline: The subcommittee will make a recommendation to the EDA, and the EDA will
make its recommendation to the City Council by 12/31/12; a decision to move forward
fully or partially should be made by the EDA and City Council during its 2013 or 2014
budget deliberations.
• Budget: $80,000 was budgeted by the EDA for consulting services in 2012.
• Metrics: New business/job growth as a result of fiber availability, including an estimated
10 new businesses and 225 new jobs by 2020.
2. TechnologV Villa�e (Business Incubator) and Venture Fair. The EDA formed a subcommittee
to explore opportunities in Prior Lake to create and/or support a new business incubator.
Options were evaluated in terms of space, location, partnerships and funding. The EDA also
initiated, but postponed a Business Venture Fair during 2012 in order to explore angel
investing opportunities in Prior Lake and surrounding areas.
• Accomplishment: Business incubator space will strengthen Prior Lake as a place to start
and grow small software/technology businesses with local investment resources.
• Timeline: The subcommittee made its recommendation to the EDA followed by an EDA
recommendation to the City Council. The Council approved a$50,000 budget amendment
for start-up costs in 2012. A Venture Fair event may occur in late 2012 or in 2013.
• Budget: $50,000 estimated city support in the first year of operations as start-up costs;
business rents will support operational costs years 2-3 in Phase 1 at City Hall. $10,000
estimated cost for the Venture Fair.
• Metrics: New business/job growth in incubator location, including an estimated 10 new
businesses and 100 newjobs by 2020.
3. Propertv Supplv and Demand. The EDA has compiled a commercial and industrial land
inventory in order to determine the availability of pad-ready sites. The 2011 Maxfield C/I
demand analysis report has been used to establish a projected demand for sites based on
building size and acreage through 2030. An evaluation will be made to determine necessary
steps to ensure that Prior Lake has an adequate supply of pad-ready sites.
• Accomplishment: Prior Lake will have more pad-ready commercial and industrial sites
starting in 2013 or 2014.
• Timeline: The EDA should deliberate actions necessary with corresponding costs that will
move more nearly pad-ready sites into pad-ready condition in preparation of making a
recommendation to the City Council in 2013.
• Budget: Unknown.
• Metrics: New business/job growth and tax base increase on available sites, including an
estimated 10 new businesses and 300 new jobs by 2020.
Page 3 of 9
4. Tar�eted Geo�raphic Areas for Development Assistance. The EDA will help evaluate ways
to achieve development goals in targeted areas of the city. For example, the EDA has begun
discussions with property owners in Deerfield Business Park in order to create a stronger
partnership. A feasibility report has been completed for Welcome Avenue Industrial Park to
identify costs associated with providing water, sewer and streets to all parcels. Large tracts
of prime vacant commercial and business park property are ideal for future development
along the County Highway 42 corridor, which are currently being farmed rather than owned
by developers. Redevelopment opportunities exist in areas such as the Digger's site and
downtown Prior Lake.
� Accomplishment: The City will consider partnership opportunities within targeted
commercial/industrial locations in order to assist and market business opportunities.
• Timeline: Complete a process to identify target areas and corresponding levels of public
support by 12/31/12.
• Budget: Unknown.
• Metrics: New business/job growth and retention, and tax base increase on the improved
industrial property, including an estimated 8 new businesses and 275 newjobs by 2020.
5. Citv Codes & Fees. The EDA will complete a comprehensive analysis of city codes and fees
in light of making Prior Lake more "business friendly". Examples in this analysis will include
design standards in the zoning code and a comparison of permit fees with a rationale nexus,
as well as an evaluation of the internal application/permit review process. Staff will develop
initial recommendations for EDA consideration, with an initial review by the EDAC.
� Accomplishment: Prior Lake will be more business friendly by making changes to city
codes, fees and/or processes that help achieve development in Prior Lake.
• Timeline: The EDAC will provide preliminary recommendations to the EDA by 12/31/12.
• Budget: Unknown.
• Metrics: New business/job growth based on a more business friendly codes and the
corresponding permit review process, all in support of the business and job figures
identified in 1-4 shown above.
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Page 4 of 9
Unique Challenges for Prior Lake
1. Historical Investments in Commercial/Industrial Development. The city has invested much of
its public resources in supporting a healthy and vibrant residential lake community, which has
been very successful. Residential property values are well above average as a result, but the
value of commercial/industrial (C/I) property is below average. For example, Prior Lake's
percent of C/I market value showed a small increase from 4.36% in 2002 to 4.84% in 2011.
This compares to an increase in Savage from 9.85% to 15.07% during that same time period.
2. Direct Access to Maior Principal Arterial Transportation Svstems. Prior Lake's location outside
of the metro's major highway system results in limited access to Interstate, US and State
Highways. Businesses look elsewhere when highway access is important. Important
improvements have occurred recently on County Highway 21 north and east, resulting in
much better access to and from Prior Lake. In addition, rail service is absent in Prior Lake, and
there is no high-speed fiber network throughout the city to help compensate for its lack of
highway and rail infrastructure.
3. Pad-Readv Commercial/Industrial Sites. Prior Lake has a healthy overall supply of property
guided for commercial, business park, and industrial development. However, a very small
percentage of that designated land can be made ready for development within 30-90 days,
which is considered to be pad-ready. Prior Lake has nearly 200 acres of vacant commercial
property with only 20 acres being pad-ready (10%). The city has nearly 240 acres of vacant
business park/industrial property with only 12 acres being pad-ready (5%).
4. Stron� Corporate Business Identitv or Focus. Prior Lake is home to the county's largest
employer, Mystic Lake Casino and Hotel. However, Prior Lake seems to share Mystic's
"home" location with Shakopee based on public perception. No other significant business
presence in the Twin Cities calls Prior Lake its home despite the city's unique presence related
to recreation and entertainment. There is no high-speed fiber network throughout the city to
help attract a corporate office here.
5. Direct Business Connection or Link to the Lakes. Prior Lake is known for its fourteen lakes as
an extremely important asset for city residents. However, it has very little lake connections
for the business community. With one restaurant and few commercial marinas located here,
people don't spend much money associated with commerce or business-related ventures
located on Prior or Spring Lakes.
Summary of Funding Needs and Resources
Bud�et Premise: The following key premises are accepted by the EDA for future budgeting:
➢ Support one-half of the Community & Economic Development Director position.
➢ Provide other necessary operational expense support (e.g., legal, communications, training).
➢ Utilize professional services to move certain initiatives forward closer to implementation.
➢ Maintain a reserve balance allowing the EDA to be entrepreneurial in assisting C/I growth.
Page 5 of 9
Economic Development Resources. The EDA has evaluated funding resources that are available and
necessary to assist businesses and help it achieve economic development objectives. Example
resources include tax increment financing, revolving loan funds, and the EDA budget. The EDA will
use current resources shown below to assist businesses, and it will establish a permanent funding
source for EDA operations starting in 2013.
2012 EDA Special Revenue Fund Budget $ 167,750
2012 General Fund Economic Development Budget $ 24,000
Business Revolving Loan Fund (Federal) $ 112,500
Business Revolving Loan Fund (State) $ 87,500
TIF District 1-1 Excess Increment $ 200,000
TOTAL $ 591,750
2012 EDA and Economic Development Bud�et (Approvedl:
o Expenses = $191,750 (includes budget amendment)
• 0.5 ED Director salary/benefits ($62,700);
• Commissioner per diem ($5,000);
• Professional services ($80,000) related to fiber feasibility study;
• Venture Fair ($10,000); and
• Legal/training/misc. ($39,050).
o Revenue = $191,750 (includes budget amendment)
• $40,000 tax levy + $132,000 reserves + $15,000 grant + $4,750 interest
2013 EDA Bud�et (Estimatedl:
TOTAL EXPENSES = $278,450
o General Expenses = $151,450
• 0.5 ED Director salary/benefits ($66,000);
• Commissioner per diem ($6,500);
• Professional services ($60,000) for pad-ready site analysis, marketing,
business events, and targeted development planning and assistance;
• Legal/training/misc. ($12,500);
• Business incubator operations ($6,450); and
o Special Project Expenses = $127,000
• Redevelopment project assistance ($75,000); and
• Revolving loan fund assistance ($50,000) & expenses ($2,000).
TOTAL REVENUE _ $283,700
o General Revenue = $154,700
•$150,000 EDA tax levy +$2,700 incubator leases +$2,000 revolving loan
administration
o Special Project Revenue = $129,000
•$75,000 TIF 1-1 +$50,000 revolving loans +$4,000 loan repayments
Page 6 of 9
2014+ Future Proiected EDA Bud�ets:
TOTAL EXPENSES = $280,350
o General Expenses = $153,350
• 0.5 ED Director salary/benefits ($68,000);
• Commissioner per diem ($6,500);
• Professional services ($60,000) related to pad-ready site analysis, city
marketing, business venture event, and targeted development planning
and assistance;
• Legal/training/misc. ($12,500);
• Business incubator operations ($6,350); and
o Special Project Expenses = $127,000
• Redevelopment project assistance ($75,000); and
• Revolving loan fund assistance ($50,000) & expenses ($2,000).
TOTAL REVENUE _ $292,150
o General Revenue = $159,150
•$150,000 EDA tax levy +$6,150 incubator leases +$2,000 revolving loan
administration + $1,000 interest
o Special Project Revenue = $133,000
• $75,000 TIF 1-1 +$50,000 revolving loans +$8,000 loan repayments
Measuring Success (Metrics)
The EDA will develop performance measurements that allow continuous reporting on important
aspects of its services, programs and processes. The use of inetrics is being utilized for all city
operations in Prior Lake beginning in 2012, and therefore, metrics will be incorporated into the EDA
Business Plan. To begin this process, the following key economic development objectives are being
identified and prioritized one through five:
1. Assist in the creation of desirable employment opportunities for the citizens of Prior Lake;
2. Identify opportunities where the EDA can assist in attracting and developing new businesses
within the community;
3. Provide the necessary support mechanisms to retain and aid the expansion of existing
businesses;
4. Broaden and diversify Prior Lake's tax base; and
5. Develop a foundation which will establish Prior Lake as a community full of economic
opportunity now and well into the future by embracing the motto; Prior Lake: A
Wonderful Place to Live, Work and Play for a Lifetime.
In order to measure progress toward achieving these objectives, the following metrics will be used for
measurement purposes:
• Track building permits issued for commercial/industrial projects; determine business and job
growth that may tie to each permit. [monthly evaluation]
Page 7 of 9
• Track residential permits and remaining lot inventory. [quarterly evaluation]
• Track lease inventory of available commercial/industrial building space; determine business
and job growth that may tie to newly leased space. [quarterly evaluation]
• Track business membership with the local Chamber of Commerce in order to assess additional
business and job growth. [quarterly evaluation]
• Track change in commercial/industrial market value using County data [annual evaluation].
• Track the number and acreage of pad-ready commercial/industrial sites [annual evaluation].
• Track zoning permit approval process associated with commercial/industrial projects.
[quarterly evaluation]
• Track speed of processing development/zoning applications (bi-annual evaluation).
Employment
With job and employment growth being key factors for economic development success, it is
important to understand the current status within Prior Lake. Data from the Metropolitan Council
and the Minnesota Department of Employment and Economic Development (DEED) show the
following employment and business characteristics for 2011. City staff has estimated the number of
total employees that work for the Shakopee Mdewakanton Sioux Community (SMSC).
Industry Employees Percent SMSC Est.
Construction 352 4.5% 25
Wholesale Trade 112 1.4%
Retail Trade 353 4.5%
Finance, Insurance and Real Estate 223 2.9%
Professional and Technical Services 162 2.1% 25
Management, Admin. and Other Services 659 8.4% 25
Accommodation and Food Service 3,533 45.2% 3,250
Arts, Entertainment and Recreation 149 1.9% 75
Public Administration 919 11.7%
Other 1,361 17.4% 400
TOTAL EMPLOYEES 7,823 100% 3,800
Industry Establishments Percent
Construction 93 16.6%
Trade, Transportation and Utilities 101 18.0%
Financial Activities 72 12.9%
Professional and Business Services 120 21.4%o
Education and Health Services 59 10.5%
Leisure and Hospitality 29 5.2%
Other Services 52 9.3%
Public Administration 4 0.7%
Other 30 5.4%
TOTAL BUSINESS ESTABLISHMENTS 560 100%
Page 8 of 9
Looking Ahead — 2020 and 2030
2014-2020 Timeframe Goals:
1. Continue the successful implementation of a Technology Village Incubator program in
partnership with existing commercial office building owners in Prior Lake, and develop
a plan to expand this to a larger Technology Village campus.
2. Complete the full build-out of a community-wide (ultra-high-speed) fiber optic
network system to all residents and businesses in Prior Lake in cooperation with SMSC;
utilize system to support a data center proposal.
3. Work in partnership with major property owners in the CR 42 corridor to begin
implementing a plan to have pad-ready commercial and business park property
available for development.
4. Work in partnership with property owners in the Deerfield and Welcome Ave.
industrial areas to fully develop these areas to their maximum potential.
5. Begin to implement actions necessary to redevelop key opportunity areas as identified
in a Redevelopment Plan for Prior Lake.
6. Cooperate with a private developer to attract a data center facility to Prior Lake, which
has the advantage of siting this center in a location that is not on a major
transportation system.
2021-2030 Timeframe Goals:
1. Continue to implement and expand upon all stages of economic development
strategies that were underway from 2014-2025.
2. Successfully attain a strong business presence within the Twin Cities as a community
full of smaller high technology that have built their home base around a place with
numerous amenities and a desirable lifestyle.
3. Fulfill many aspects of the 2030 Vision Statement for Prior Lake.
4. Complete all supporting infrastructure improvements that results in over 100 acres
being developed as commercial and business park uses.
5. Develop plans for the expansion of commercial and industrial development in the
Southwest annexation area of Spring Lake Township.
6. Achieve key redevelopment objectives within the city related to the downtown area
and other priority redevelopment sites.
Additional Reaorts:
1. Fiber Optic Network Feasibility Report for Prior Lake, June 2012
2. Business Plan, Technology Village, Prior Lake, 2012
3. 2030 Vision and Strategic Plan, City of Prior Lake, February 21, 2012
4. Report of the SCALE Economic Development Strategy Group,lune 20, 2011
5. Economic Landscape of Prior Lake
Page9of9
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� ���:��0 THE SEVEN STRATEGIC ELEMENTS
� The following seven Strategic Elements �
make the Vision possible. Each includes an �°°°� �
introductory statement defining the Element '`°�..�a'
followed by the goals to be pursued relative to the Strategic
i
� Element. The goals reflect the community's leadership
priorities and provide direction forthe City and other entities { �� ` RATEGIC ELEMENTS �
toward implementing the Vision. J
; The goals within each Strategic Element have been prioritized Economic 8� Community Development
' with respect to its impact in accomplishing the vision. Strong Financial Management
While all of the Strategic Elements are important, the City Natural Resources
� Council identified the top three Elements as Economic and COmmunity Assets
( Community Development, Strong Financial Management $pfe and Healthy Community
and Natural Resources. Resources will be focused on these Transportation �
� Strategic E�ements. Communication
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; Included with each Strategic Element is an illustration showing =e ,.
part of an Implications Wheel� which helped define the
goais of that Element. The Wheels were used in exploring
� the implications and impacts of various positive or negative
' characteristics or actions that may or may not take place.
� Economic and Community
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The Prlor Lake Economic Development Authority's primary responslbliity is to
provide shops and services to residents, provide employment opportunitles for 4 � ^ Z
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residents and to ensure a strong, diverslfled tax base. Prlor Lake encourages 'r°��'°��°e°'�as°'^a. -
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� �� »�� �� plans with private parties to
� ���3' �` � !�' ��i� ��i� establish a technology village/incubator by Dec. 31, 2012. �
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� � `�� . .,i � �� ; � � . • • � � QOAL: Develop plans for a data center with fiber optic access by
�` � �� ��� � . �� June 30, 2012.
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�'.�� �,� �� � �� ��. �� QOAL: Develop a redevelopment pian, including priorities,
� -��� ��:�� timelines and incentives for the downtown area and for under-
� � - � � � � " �� � `� � ��` � ���� utilized commercial properties in the City by Sept. 30, 2012.
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' GOAL: Review the existing City Code and Zoning Ordinance provisions to assess their impact on achieving
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p� . v ? economic development objectives. Recommend modification of those which are inconsistent with City
�,` �'- obJectives by June 30, 2012. Repeat every five years.
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