HomeMy WebLinkAbout041404 Work Session16200 Eagle Creek Avenue S.E.
Prior Lake, MN 55372-1714
TO:
SUBJECT:
April 14, 2004
MAYOR HAUGEN AND CITY COUNCILMEMBERS
April 19, 2004 Work Session
Attached is an agenda for the work session which I've briefly outlined below:
"Little Lord Fletchers"- Ed Flaherty d/b/a Lariat Companies has proposed a 3000 sq. ft.
restaurant with public / private marina, off-street parking and a 64 unit three-story
condominium on property adjacent to Quincy Avenue and CSAH 21. Attached is information
provided by Mr. Flaherty. At the work session, Mr. Flaherty will share graphics of the proposed
project. There are numerous issues associated with this project which Mr. Flaherty would like
to discuss with the Council. Among them are: (1) acquisition of property, (2) use of park land,
(3) public/private partnerships, (4) shoreland density, (5) causeway, (6) CSAH 21.
Disposal of Existinq Post Office Property- The Postal Service wishes to know whether the
City would have an interest in acquiring their 60,000 sq. ft. property at Anna Trail and TH13
which includes a 5800 sq. ft. building. The estimated cost of the property is $478,500.
Attached is an information sheet. If non of the public entities express an interest, the Postal
Service will then see private buyers. Don Rye will be prepared to review permitted, permitted
with condition, and conditional uses which could be developed on this property.
Discussion of EDA / City Council Powers - The City Attorney and Community Development
Director will discuss with the Council the powers of EDAs, HRAs and City Councils to facilitate
b;#~,,~,a final determination of which bodies are most appropriate for Prior Lake's future needs.
www. cityofpriorlake, com
Phone 952.447.4230 / Fax 952.447.4245
16200 Eagle Creek Avenue S.E.
Prior Lake,-MN 55372'1714
2
3,
Dinner
Presentation Regarding Possible Lake ~~.~'~
Restaurant (Ed Flaherty) ~' ~'~' ~* ~°°~*' ~~-~ ~
Disposal of Existing Post Office Building and
Parcel.
1
,
Discussion Regarding EDA / City Council Powers
as Set Forth by State Statute, Bylaws and
Enabling Resolution
Other Business~
~ Please note that the City Council reserves the right to add or delete items from the agenda based
upon time availability.
www. cityofpriorlake. Corn
Phone 952,447.4230 / Fax 952.447.4245
WALSH BISHOP
FACILITY
DEVELOPMENT
& CONSULTING
900 Second Avenue South, Suite 300
Minneapohs, Minnesota 55402-3380
TEL 612 338-8799
FAX 612 337-5785
WWW.WALSH-BISHOP. COM
MEMO TO: Ed Flaherty
11800 Singletree Lane
suite 210
Eden Prairie, Mn. 55344
FROM: Gary Lampman
SUBJECT: Restaurant / Homing / Marina / Prior Lake Mn.
DATE: 7/14/03
Dear Ed,
The fonowing is a listing of some data relevant to the Prior Lake proposal
RESTAURANT [ as shown ]
Main level [el. 920.50 ]
2.7 acres.
5400s.f. [ 60'x90' ] . ._
~g- 3000s.f. [ 150 people ~ 20 s.f./person. ]
Deck sea~g :fi~._
Food prep./Support: 2400 s.f. [ .80 x 3000 s.f. ]
Lower level [el. 905.0 ]
5400 s.f. + / -. Banquet hall / bar etc.
Boat slips: 48 [ 20'x24' / 2 boats ea. ]
2~chitec~al style: Prairie school.
Parking {[174 ears. Reqd. upper 108 [ 1/50 s.f. ]. Reqd. lower 1/3 seats.
Setback f¢~ lake -5'. DNR setback reqd. 75'
Raingarden 2900 s.f. in parking lot.
HOUSING [ as shown ]
Main level [ el. 922.00 ] 3 levels / 49'.
2.5 acres
Ea. level 25000 s.f.
21 units/level [ 700- 1600 s.f. ] 63 total shown. 25.2 units / acre. [ 15-30 typical ]
Parking: 58 cars / level. 116 cars total inside. [ 2 cars per unit typical ] [ d. 904.00
lower / el. 913.00 upper ].
6 visitor spaces exterior.
Document in Microsoft Intemet Explorer
WALSH
BISHOP
FACILITY
DEVELOPMENT
& CONSULTING
Boat slips' 50
Setback From lake 55'. DNR setback reqd. 75'. From road r.o.w. 25'.
Detention pond 5750 s.f.
General reformation/issues.
No protected left mm from cnty.rd 21. The roadway is being studied by the cnty.
Dredging for boat docks reqd. DNR permit very difficult.
Height restriction at 75' From lake - 35'. 49' as shown.
Normal water level 904.00.
DNR will have concerns about the ¢¢ of boat slips and attendant congestion.
Prior Lake has a" low appetite for eminent dom".
Public will likely use parking lot and boat docks for fishing.
Porous paving may mitigate the.~mount of infiltration basin and ponding reqd.
Finger of land is privately owned. Asking price may be exhorbitant.
Boat hunch at the N.E. comer of the housing site was not discussed
Sunfish Road is slated for widening in the future.
Further evaluation suggests the proiect will generate an excess of soil.
The housing portion of this project is "noncomparable". Boat slips will likely ~)~,-r J--r~l'
generate high end for sale units. . a- '
Land cost data. ~ ~c~,~ ~'~",-- O~o ' /
Rental: 5-10 k per uni~- io~.¥~ 5220 k per unit ' high. -
For sale: 15 k per mt - low. 50 - 60 k per unit - high.
Rental- 10%- 15% of holt cost.
Fo, 20o/0- 300/0
cc. De~ W~h
.
Z~<
REALTY ASSET MANAGEMENT
uNrrED S"i'/~TES
PO~ ~/'~.
NOTICE OF AVAILABILITY
EXCESS REAL PROPERTY
,,
To:
Local Governments
Joe Zieska
Acting Mayor
16200 Eagle Creek Avenue, SE
Prior Lake, MN' 55372-1714
From:
Gloria M. Charlson
Date: March 23, 2004
Subject:
Disposal of Existing Main Post Office
The United States Postal Service (USPS) has declared the real property
described on the enclosed fact sheet as excess and available for disposal. This
is notice that state and local governments may make an offer to purchase.
Any government entity desiring to purchase this property will be given a 30-day
preferential screening period from March 23, 2004 through April 29, 2004.
Please note this property will not be available until OctOber 31,20041..iUpor] ·
receipt of such notice, the USPS will promptly supply the interested party with a
Purchase and Sale Agreement and advise them of the ~ce.s~aw .to
acquire the Property. Please contact Gloria Charlson a ([..~~220-6562,~ you
need additional information.
Attachment
Dist: Manager, Administrative Services
8055 E TUFTS AVE ¢¢.400
DENVER CO 80237-2881
(303) 220-6562 (303) 220-6536 FAX
,qloria.m. charlsont'~,us ps.,qov
FACT SHEET
1. PROPERTY IDENTIFICATION
2. PROPERTY ADDRESS
3. NAME OF HOLDING AGENCY
4. CUSTODIAN
5. LAND/BLDG SIZE
6. HOLDING AGENCY USE.
7. RANGE OF POSSIBLE USE
8. UTILITIES
9. PUBLIC TRANSPORTATION
10. OUTSTANDING INTERESTS
11. LIMITATIONS ON USE
12. OCCUPANCY
13. PAYMENT
14. HISTORIC STATUS
EXISTING MAlt 'OST OFFICE
16535 ANNA TF IL SE,
PRIOR LAKE, 55372
ASSET
U.S. POSTAL
8O55 E. TUFTS
DENVER CO 8
, STE 4OO
GAYLE
(952) 447-1062
POSTMASTER
LAND - APPR(
BLDG - APPR~
60,000 SQUARE FEET
5,815 SQUARE FEET
US POSTAL
NONE i '
EASEMENTS ANI~ MATTERS OF
RECORD
ZONING - C-1
COMMERCIAL
APPROXIMATE
CASH AT CLO,~
N
L~
NOT HISTORIC
-'iGHBORHOOD
;E DISTRICT
OCTOBER, 2004
Date of Photograph:
February 13, 2004
View of subject from east side of Highway # 13
CITY OF PRIOR LAKE AUTHORITIES/POWERS
CITY COUNCIL
ECONOMIC DEVELOPMENT AUTHORITY
Establish ED Districts
Acquire property
Enter contracts
Eminent Domain
Be limited partner in a partnership
May sell or lease land held by EDA for ED in Economic
Development District
May apply to Federal Government to establish foreign
trade zones
Issue revenue bonds and industrial revenue bonds
Operate public parkway or other public facility to
promote development in Economic Development District
Article Ill/Bylaws State CC is EDA
Conduct studies analysis and research
Join trade association
Public relations
HOUSING & REDEVELOPMENT AUTHORITY
§ 469.003: cannot transact any business or exercise any
powers until and unless City Council conducts a public
hearing and subsequently passes a resolution finding
that in that City (1) substandard, slum, or blighted areas
exist which cannot be redeveloped without government
assistance, or (2) there is a shortage of decent, safe, and
sanitary dwelling accommodations available to persons o
flow income and their families at rentals they can afford,
and shall declare that there is need for a housing and
redevelopment authority to function in that city.
DN: 217447
Accept conveyance of land from other public entities
Undertake site and infrastructure development to make
land attractive for economic development
Authorize bonds and borrow money
*Make loans to private sector for economic
developments; sell loan to investors
Participate with public or private entities to provide seed
money or venture capital
- Make loans from venture capital fund
Issue general obligation bonds
Issue revenue bonds
Impose tax levies for operation of EDA
EDA can issue HRA levy outside levy limits
Advance general fund $ without interest
DN: 217447 2
ECONOMIC DEVELOPMENT AUTHORITIES
Responding to the requests of many Minnesota cities for broader powers in the area of
economic development, in 1986 the Minnesota Legislature passed a law authorizing home rule
charter or statutory cities to establish economic development authorities. In 1987, the
Legislature recodified the statutes pertaining to economic development into one large chapter,
Chapter 469. Economic Development Authorities may draw on the purposes and powers
contained in several different sections of Chapter 469. Sections 469.091 to 469.108 constitute the
principal body of legislation pertinent to EDA's.
This memo addresses many of the questions cities have raised concerning the formation,
uses, and powers of economic development authorities (referred to herein as an "EDA" or an
"Authority"). The statutes concerning EDAs are complicated and somewhat ambiguous, and the
various "cross-fertilization" provisions used in the EDA sections of Chapter 469, allowing the
EDA to exercise powers granted to other entities for a wide variety of purposes, lead to further
confusion and uncertainty. Nevertheless, we believe the underlying purpose of the law - the
promotion of economic development - is clear and that reasoned conclusions can be drown about
the scope and intent of the law. The following is an effort to outline the steps that must be taken
to form and operate an EDA, the powers that an EDA may exercise once formed, and the
constitutional concerns that may arise in connection with the use of EDA powers.
A. FORMATION AND OPERATION OF AN EDA
1. Reasons for Forming an EDA. Forming an economic development authority (the
"Authority" or "EDA") will provide a great deal of flexibility to a City to pursue economic
development. Economic development authorities may exercise their own powers, the powers of
housing and redevelopment authorities, the powers of cities in connection with city development
districts and the powers of municipalities or redevelopment agencies in connection with
municipal industrial development. The purpose for which these powers may be exercised is
expanded to embrace economic development throughout a City and not just in areas which may
be deemed to be blighted. The concentration of various economic development powers and
purposes in one Authority therefore provides a valuable tool to a City for the promotion and
financing of economic development.
Procedure for Establishing an EDA.
The City Council creates an Economic Development Authority by passing a written
resolution called an enabling resolution. Before adopting an enabling resolution, the City
Council must conduct a public hearing. Notice of the time and place of hearing, a statement of
the purpose of the hearing and a summary of the resolution must be published in a newspaper of
general circulation within the city once a week for two consecutive weeks, with the first
publication appearing less than thirty days from the date of the public hearing. Minn. Stat.
{}469.093.
Each year, prior to the anniversary of the passing of the enabling resolution, the EDA
must submit a report to the City Council stating whether and in what respects the enabling
resolution should be modified. Within thirty days of receipt of the report, the City Council must
consider the recommendations and make any modifications it deems appropriate. Minn. Stat.
§469.092, Subd. 3. Modifications to the enabling resolution must be by written resolution and
may be adopted only after notice and public hearing as required for the adoption of the original
enabling resolution. Minn. Stat. §469.093, Subd 2.
Once established, an EDA is a public body corporate and politic and a political
subdivision of the State. It may sue or be sued in its own right. Section 469.091, Subd. 2
characterizes an EDA as a body which "carries out an essential governmental function when it
exercises its power .... "Nevertheless, sovereign immunity does not apply- an EDA is not
immune from liability because of its function.
2. Limiting the Powers of the Authority.
(a) The City, through the enabling resolution, .may impose the following limits upon the
actions of the Authority:
1,
The enabling resolution may provide that the EDA may not exercise any specified
power contained in the EDA law or that the EDA may not exercise a specified
power without the prior approval of the City Council;
ge
The City Council may require that any unpledged reserves generated by activities
of the EDA and not needed for its successful operation be transferred to the Debt
Service Fund of the City and be used to reduce tax levies for bonded
indebtedness;
.
The City Council may require that the EDA obtain City approval before selling
any bonds or obligations issued by the EDA (and prior approval is required in any
case for general obligation bonds);
.
The City may impose other limitations on an EDA's budget process, administration
and management, and other activities, and may require an EDA to comply with the
City's comprehensive plan, and may impose any other limitation the City Council
deems appropriate.
Minn. Stat. §469.092
(b) There are, in addition to the above limitations, other means by which a City Council
may limit the powers of the Authority:
A. City. Council as Commissioners of Authority. The authorizing legislation
states that at least one (and in some cases, two) city council members must be included
among the EDA commissioners. A City Council can provide in the enabling resolution,
however, that the members of the City Council shall serve as all the commissioners of the
Authority. This approach would ensure absolute City Council control over EDA
activities. If a City elected to take this route, it could establish a separate advisory
committee to assist it with economic development matters. As an alternative, a City
Council could provide (as is provided in the proposed enabling resolution) that some but
not all (in this case two) commissioners be city council members.
B. Limitations on EDA Powers. If a City Council chooses not to act as the
goveming body of the Authority, it may, in the enabling resolution, place specific
restrictions on the exercise of powers by the EDA. These restrictions could take several
forms.
(i) Restrictions on Exercise of Powers. The enabling resolution may
provide that the Authority may not exercise certain specified powers without the
prior approval of the City Council. Such a restriction might be placed on the
power to issue general obligation or revenue bonds on the power to grant or loan
EDA funds, on the power to enter into limited partnerships, or any other specific
power over which the City Council wishes to exercise control.
(ii) Budgetary Control. The EDA law already requires that the EDA
annually submit to the City its budget. Apart from the obvious control the City
Council has in appropriating city money to help fund the budget, the enabling
resolution may require City Council approval of the Authority budget, and
compliance with the budget as approved (as provided in the proposed enabling
resolution).
(iii) Other Monetary Restrictions. A City may place monetary limits on
exercise of EDA powers. Monetary limitations could be imposed on a per-project
basis, or may be placed on aggregate spending on projects by the EDA. Project
based limitations would require approval by the Cityl Council of expenditures on
any proposed project over a certain monetary amount. An aggregate restriction
would provide for City Council approval once the Authority had expended its
aggregate approved amount in a fiscal year.
(iv) Other Controls. In addition to the foregoing controls, an enabling
resolution may also provide for City Council control of EDA activity by the
following means:
(a) All official actions of the Authority must be consistent with the
adopted Comprehensive Plan of the City and any official controls (e.g.,
zoning ordinances) implementing the Comprehensive Plan.
(b) The Authority shall submit all planned activities for
influencing the action of other govemrnental agencies, subdivisions, or
bodies to the City Council for approval.
(c) The Authority shall submit its administrative structure and
management practices to the City Council for approval.
3. Commissioners.
The Economic Development Authority governing body may consist of 3, 5 or 7
commissioners. The enabling resolution must state the number of commissioners. The mayor
appoints the commissioners with the approval of the City Council. A 3 member authority must
include at least one member of the City Council, and a five or seven member authority must
include at least two members of the City Council. Members of the City Council in numbers
greater than those mentioned above may serve as the commissioners of the EDA. The enabling
resolution may provide that the members of the City Council shall serve as the commissioners.
Further, an EDA may be increased from three to five or seven or from five to seven members by
resolution of the City Council following the same notice and hearing procedures required for
adoption of the enabling resolution.
Original appointees to the EDA serve for terms varying from one to five years, and
subsequent commissioners serve six year terms. Commissioners may be paid for attending
meetings of the EDA in an amount determined by the City Council. Commissioners may be
removed for cause following written notice and hearing on the matter. Minn. Stat. § 469.095.
4. Officers.
The EDA may adopt bylaws and rules of procedure and must adopt an official seal. The
EDA must elect a President, a Vice President, a Treasurer, a Secretary, and an Assistant
Treasurer. The Authority must elect the President, Treasurer, and Secretary annually. Although
a commissioner can not serve as President and Vice President at the same time, the other offices
may be held by the same commissioner. Further, the offices of Secretary and Assistant Treasurer
need not be held by a commissioner. Minn. Stat. 9469.096.
5. Employees.
The Authority may employ an Executive Director, a Chief Engineer, other technical
experts and agents, and other emploYees as it requires, and it may determine their duties,
qualifica-tions, and compensation. Further, the Authority may contract for the services of
consultants, agents, public accountants, and other persons needed to perform its duties and'
exercise its powers. The Authority may use the services of the City Attorney or hire a general
counsel for its legal needs. Minn. Stat. § 469.097.
6. Ci.ty Facilities~ Services.
The City may finm/sh offices, structures, space, clerical, engineering, or other assistance
to the Authority. The Authority may use the City's purchasing department in connection with
construction wok and to purchase equipment, supplies or materials. Minn. Stat. § 469.097.
7. Existing Development Agencies and Proiects.
The City may divide any economic, housing or redevelopment powers granted under the
I-IRA and EDA sections of Chapter 469 between the Authority and any other authority or
commission established under statutes or City Charter for economic development, housing, or
redevelopment. Minn. Stat. § 469.094. The City may also, by resolution, transfer the control,
authority and operation of any project as defined in the Municipal Industrial Development
sections of Chapter 469 or program authorized by the HRA or Municipal Development District
sections of Chapter 469 from the agency that established the project to the Authority.
8. Budgets and Reports.
The Authority must submit an annual budget to the.City including a detailed written
estimate of the amount of money the Authority expects to need from the City during the next
fiscal year. The Authority must also submit to the City a detailed account of its activities, and its
receipts and expenditures during the preceding calendar year. The Authority's financial
statements must be audited annually, and the audits must be filed with the State Auditor. Minn.
Stat. § 469.100.
9. Conflict of Interest.
An independent anti-conflict-of-interest provision applies to EDA. It prohibits any
commissioner, employee or agent of an EDA from having any direct or indirect financial interest
in any project (or property included in a project) or in any contract for materials or supplier in
connection with a project.
B. POWERS OF AN EDA
The Authority is granted several different types of powers in the EDA statutes. First, it is
granted powers that it may exercise only within or in conjunction with an economic development
district. Second, the EDA sections of Ch. 469 grant directly powers that the Authority may
exercise outside an economic development district. Finally, the statutes grant the Authority by
cross-reference the powers that may be exercised by housing and redevelopment authorities .
("HRAs"), cities in connection with Development Districts, or municipalities or redevelopment
agencies in connection with Municipal Industrial Development. The broadest of these powers
are those contained in the HRA and the Industrial Development sections of Chapter 469, making
the "crossfertilization" in Chapter 469 invaluable to Economic Development Authorities.
1. Powers that must be exercised within or in
Conjunction with an Economic Development District.
The following is a list of the specific powers granted to the Authority which must be
exercised within or in coniunction with ah economic development d/strict. These powers allow
the Authority to create an economic development district, acquire land by various means within
that district, improve the land to make it suitable for development, sell the land so acquired (with
development stipulations) or develop the land itself as a public facility.
(a) Creation of Economic Development District.
The Authority may create, following notice and hearing, an economic
development district at any place within the city. Under Minn. Stat. § 469.101 Subd. 1,
the district must satisfy the requirements of section 469.174 Subd. 10 (a provision which
is part of the Tax Increment Financing Law), except that district boundaries must be
contiguous. Section 469.175, Subd. 10 defines a "redevelopment project" and, in general,
requires structurally substandard buildings, health or safety hazards, deficient soil
conditions, underutilized air fights, vacant or underutilized railroad property or an
industrial park with a contaminated sewage lagoon.
(b) Acquisition of Property.
In order to create an economic development-district, the Authority may acquire by
lease, purchase, gift, demise or condemnation proceedings any necessary right, title or
interest in property. Property acquired for this purpose is exempt from taxation by the
state or political subdivisions, except to the extent that the property is subject to sales and
use tax, but only while the Authority holds the property for its own use. Minn. Stat.
§469.101, Subd. 2.
(c) Acquisition of Rights and Easements.
The Authority may acquire rights and easements for development of an economic
development district. Minn. Stat. § 469.101 Subd. 7.
(d) Receipt of Assistance.
The Authority may accept land, money or other assistance from the federal or
state government or an agency of either to acquire and develop an economic development
district. Minn. Stat. § 469.101 Subd. 9.
(e) Sale or Lease of Land.
The Authority may sell or lease land held by the Authority in economic
development districts. Minn. Stat. § 469.101, Subd. 10.
The Authority may, after notice of hearing, sell property owned by it if the sale or
conveyance is in the best interest of the City and furthers the Authority's general plan of
economic development. The sale may be by private or public sale. The terms of the sale
of property must include the intended use of the land and may not be consummated until
the purchaser delivers the plans and specifications covering the development of the
property to the Authority for approval. If the purchaser fails to devote the property to its
intended use or fails to begin work on improvements in one year from the date of the
purchase, the Authority may cancel the sale, and title to the property will revert to the
Authority. The Authority may extend the one year deadline for good cause. The
purchaser of the land may not transfer title within one year after the sale without the
consent of the Authority. Minn. Stat. § 469.105.
(f) Public Facilities.
The Authority may maintain and operate a public parking facility or other public
facilities to promote development in an economic development district. Minn. Stat. §
469.101, Subd. 13.
(g) Government Agent.
The Authority may cooperate with or act as an agent for the federal or state
government in the area of economic development district improvement. Minn. Stat. §
469.101, Subd. 14.
(h) Acceptance of Public Land.
The Authority may accept conveyances of land from all other public agencies,
commissions, or other units of government if the land can be properly used by the
Authority in an economic development district. Minn. Stat. § 469.101, Subd. 17.
(i) Development and Improvement.
The Authority may carry out EDA law to develop and improve land in an
economic development district. The Authority may fill, grade and protect property and
do anything necessary and expedient after acquiring property in an economic
development district to make it suitable and attractive for development. Minn. Stat. §
469.102 Subd. 18.
2. Powers that need not be exercised within or
in con]unction with an Economic Development District.
The Act also grants to Authorities various powers that need not be exercised within or in
conjunction with an economic development district. These powers are a great deal broader than
those outlined above, and they represent the true value of an economic development authority to
a City. These powers include not only those granted directly by the EDA sections of Chapter
469, but also those granted to an Authority by cross-reference to other sections of Chapter 469.
The Authority also has the power to issue various types of obligations.
(a) Eminent Domain.
The Authority may exercise the power of Eminent Domain. Minn. Stat. §"
469.101 Subd. 4.
(b) Power to Contract.
The Authority may enter into contracts for the purpose of economic development
and may contract to purchase and sell real and personal property. Any obligation or
expense of the Authority may not be incurred unless there is an existing appropriation
and reasonably expected revenue of the Authority from other sources sufficient to
discharge the obligation or pay the expense when due. Minn. Stat. § 469.101 Subd. 5
(c) Limited Parmer.
The Authority may act as a limited partner in a partnership whose purpose is
consistent with the Authority's purposes. Thus, the Authority may invest directly in a
business and will be protected from liability because of the form of the investment. The
Authority's liability will be limited to the amount of contributions it has made to the
partnership. Limited partner status, however will prevent the Authority from taking an
active role in the operation and management of the business. Minn. Stat. {} 469.101,
Subd. 6.
(d) Supplies and Materials.
The Authority may buy the supplies and materials it needs to carry out economic
development. Minn. Stat. § 469.101 Subd. 8.
(e) Foreign Trade Zone.
The Authority may apply for Foreign Trade Zone powers alone or with another
Authority. Minn. Stat. {}469.101, Subd. 11.
(f) Studies, Analysis, Research.
An Authority may study and analyze economic development needs in the City and
ways to meet the needs and may engage in research and disseminate information on
economic develop-ment within the City. Minn. Stat. § 469.101, subd. 15.
(g) Cross-Fertilization.
An Authority may exercise the powers and duties of a redevelopment agency
under sections 469.152 to 469.165 (Municipal Industrial Development) for a purpose in
sections 469.001 to 469.047 (Housing and Redevelopment Authorities) or 469.090 to
469.108 (Economic Development Authorities). The Authority may also use the powers
and duties in sections 469.001 to 469.047 (Housing and Redevelopment Authorities) and
469.090 to 469.108 (Economic Development Authorities) for a purpose in sections
469.152 to 469.165 (Municipal Industrial Development). The Authority also has the
powers of a City under sections 469.124 to 469.134 (City Develop-ment Districts).
Minn. Stat. §§ 469.091,469.101, subd. 12. A summary of the purposes and powers, of
Housing and Redevelopment Authorities, City Development Districts and Municipal
Industrial Development will follow.
(h) Levy of Taxes for Economic. Development Authority.
The City may, at the request of the Authority, levy a tax in any year for the
benefit of the Authority in an amount not more than 0.01813 percent of taxable market
value. An increase in the levy is allowed if the City follows certain procedures and
subject to reverse referendum. The levy may be increased by resolution of the City
Council after published notice. The resolution is not effective if a petition requesting a
referendum is filed with the City Clerk within 30 days after publication of the resolution.
The petition must be signed by voters equalling at least 5% of the vote cast in the last
general election. The election called for by to the referendum must be held as specified
in section 275.58. Minn. Stat. § 469.107.
(i) Advances.
An Authority may advance (loan) its general fund money or credit without
interest, for the objects and purposes of the Act. The advances must be repaid from the
sale or lease of land. If the money advanced for the development or redevelopment was
obtained from the sale of the Authority's general obligation bonds, then the advances
must have not less than the average annual interest rate on the AuthorityVs general
obligation bonds that are outstanding at the time the advances are made. Advances made
to acquire land and to construct liabilities for recreation purposes, if authorized by law,
need not be reimbursed. Minn. Stat. § 469.106. The repayment provisions of this section
imply that advances can only be made by way of an installment sale or financing lease,
which necessarily limits the type of costs which can be financed under this provision to
property susceptible of being leased or sold.
3. Issuance of obligations.
(a) Issuance of General Obligation Bonds.
The Authority may issue general obligation bonds in anticipation of income from
any source, in the principal amount authorized by a two thirds vote of the City Council,
for the purpose of acquiring property or for any other purpose set forth in the Act. The
form of the bonds and interest rate must be set by the City Council. The issuance of the
bonds is 'governed by the Act, except for matters that are-not covered in the Act, which
are governed by Chapter 475 (Public Indebtedness). An election is required for the
issuance of the general obligation bonds unless the bonds otherwise qualify for an
exception from the election requirement under the provisions of Chapter 475. The
election requirement may only be avoided for general obligation bonds if at least 20% of
the debt service will be paid from tax increments, in which case the proCedures of the Tax
Increment Financing Law must be followed. The bonds must mature within 30 years
from the date of issuance. The City Council must, by ordinance, give specific consent to
the pledge of its full faith and credit to the bonds. The bonds are payable from taxes
levied by the Authority on all taxable property in the city, Which taxes must be in an
annual amount at least 5% in excess of the annual principal and interest on the bonds.
Minn. Stat. § 469.102.
(b) Issuance of Revenue Bonds.
Revenue Bonds may be issued by the Authority to acquire land, to purchase or
construct facilities, to purchase, install or furnish capital equipment, or to extend,
improve, or enlarge a project under its control. The bonds issue :may also include a
reserve to secure the payment of principal and interest on the bonds. The bonds must
mature within 20 years from the date of issuance, may be sold at public or private sale
and may be secured by any revenue from the facility financed by the bonds. Revenue
bonds are not a debt of the Authority or the City but are payable only from the revenues
pledged to their payment. If the revenue bonds are taxable bonds, the project financed
with them does not have to be approved by the Energy and Economic Development
Authority and certain public hearing and reporting requirements under the industrial
development bond provision of Ch. 469 do not apply. In addition, the industrial
development bond provisions of Chapter 469 which prohibit the financing of property to
be sold for housing facilities to be rented or used as permanent residence do not apply.
Minn. Stat. § 469.103. However, the bonds will be subject to the limitations set forth in
Sections 462C.01-462C.07.
(c) Tax Increment Bonds.
Under Minn. Stat. 9 469.103, Subd. 8, the Authority may issue tax increment
bonds payable from tax increment revenues. The issuance of tax increment bonds are
subject to the provisions of the Minnesota Tax Increment Financing Act. Minn. stat. 9
469.174 to 469.179. The proceeds of tax increment bonds are subject to the same use
limitations as tax increments. Minn. Stat. 9 469.176, subd. 4.
(d) Pledge of Revenues.
The Authority may pledge and grant a lien on revenues of the Authority to secure
the payment of its general obligation or revenue bonds. The revenue must come from the
facility to be acquired, constructed or improved with bond proceeds or from other
facilities named in the resolution authorizing the bonds. Minn. Stat. 9 469.103, Subd. 5.
(e) Borrowing Money.
After authorizing general obligation or revenue bonds, the Authority may borrow
money for the purpose for which the bonds are to be issued in an amount not to exceed
the amount of the bonds to be issued. The loans must be evidenced by negotiable notes
due not more than 12 months after the date of the loan, which notes are to be repaid from
the proceeds of the bonds. Minn. Stat. 9 469.101, Subd. 19.
4. Optional Use by Existing Port Authorities.
Any city that has established a pert authority by special law or that has been granted the
power to establish a port authority by special law may elect to use any of the powers granted in
the Act, however, the provisions of the Act must be used exclusively and, upon an election to use
the power set forth in the Act, any powers granted in the'special law may no longer be used.
5. Cross-Fertilization Powers.
As noted previously, the Authority may exercise Industrial Development powers
(contained in 99 469.152 to 469.165) for HRA or EDA purposes, and it may also use HRA or
EDA powers for Industrial Development purposes. The Authority may also exercise the powers
of a City contained in §§ 469.124 to 469.134 (City Development Districts). This
"cross-fertilization" gives Authorities great latitude in using the various powers contained in the
statutes for various purposes within the statutes.
A. Purposes
1. HRA Purposes
The purposes of HRAs are to provide adequate housing and to clear and redevelop
blighted areas. Minn. Stat. 9 469.001 et seq. A "blighted area" means an area with buildings or
improvements which are detrimental to the safety, health, morals or welfare of the community.
Minn. Stat. 9 469.002, subd. 11.
2. EDA Purposes
The purposes of EDAs are not made altogether clear by the statutes. Although the
statutes make frequent references to EDA purposes, the statutes do not :specify those purposes; in
fact, the Legislature entangled, almost inextricably, the concept of purposes with the concept of
powers. However, it does appear that one purpose of an EDA is to make land suitable and
available for economic development uses and purposes and to encourage the location or
expansion of economic development facilities.
3. Industrial Development Purposes
The broadest purposes are those which underlie municipal industrial development. Those
purposes are the active promotion, attraction, encouragement and development of economically
sound industry and commerce through governmental action for the purpose of preventing the
emergence of blighted and marginal lands and areas of chronic unemployment. In essence,
industrial development purposes are those necessary to encourage economic development.
B. Powers
Because the list of powers that may be exercised by a given Authority is so long, only
those powers which seem most suited to economic development will be listed below.
1. HRA Powers
The HRA statutes give powers to both the HR~ and the City to exercise in connection
with redevelopment.
(a) HRA Powers as to Projects.
The schedule of powers contained in the HRA law states that an authority shall have all
the powers necessary or convenient to carry out the purposes of the HRA law. Those powers
include the power:
(1) To establish a redevelopment project under Minn. Stat. § 469.002, subd. 14, which
may be to conduct an "urban renewal project" for elimination or prevention of blighted or
deteriorated areas. The term project may be applied to all real and personal property, assets,
cash, or other funds, held or used in connection with the development or operation of the project.
To establish a redevelopment project, the Authority must prepare a redevelopment plan,
which the City must then approve. Minn. Stat. § 469.028. The City may approve the
redevelopment plan after a public heating for which at least ten (10) but not more than thirty (30)
days published notice was given. The City must make the following findings in connection with
its approval of the plan:
(i) the land in the project area would not be made available for redevelopment
without the fmancial aid to be sought;
(ii) the redevelopment plans for the redevelopment areas in the locality will
afford maximum opportunity, consistent with the needs of the locality as a whole, for the
redevelopment of the areas by private enterprise; and
(iii) the redevelopment plan conforms to a general plan for the development of the
locality as a whole.
Minn. Stat. § 469.028, subd.2
(2) To undertake, prepare, carry out, and operate projects and to provide for the
construction, reconstruction, improvement, extension, alteration, or repair of any project or any
part thereof; Minn. Stat. § 469.012, Subd. 1(4);
(3) To give, sell, transfer, convey or otherwise dispose of real or personal property or
any interest therein and to execute leases, deeds, conveyances, negotiable instruments, purchase
agreements, and other contracts or instruments and take action that is necessary or convenient to
carry out the purposes in the HRA law; Minn. Stat. § 469.012, Subd. 1(5);
(4) To acquire real or personal property or any interest therein by gifts, gran.ts, purchase,
exchange, lease, transfer, bequest, or otherwise, and by the exercise of the power of eminent
domain; Minn. Stat. § 469.012, Subd. 1(6);
(5) To borrow money or other property and accept contributions, grants, gifts, services or
other assistance from the federal government, the state government, state public bodies, or from
any other public or private sources; Minn. Stat. § 469.012, Subd. 1(13);
(6) To issue bonds of a type determined by the Authority for any of its corporate ..
purposes. The Authority may secure the bonds by mortgages upon property held or to be held by
the Authority or by pledge of its revenues, or a pledge of grants or contributions from the federal
government or any other source; Minn. Stat. § 469.012, Subd. 1(15), § 469.034;
(7) To develop and administer an interest reduction program to assist the financing of the
construction, rehabilitation, and purchase of housing units which are intended primarily for
occupancy by individuals of low or moderate income and related and subordinate facilities.
Minn. Stat. § 469.012, Subd. 7. The authority to authorize payment of interest reduction
assistance expires on January 1, 1989; Minn. Stat. § 469.012, Subd. 10;
(8) To levy a special tax each year upon all property, both real and personal, within the
taxing district (which includes all of the territory included within the area of operation of the
Authority). The taxes will be kept in a separate fund known as the "housing and redevelopment
project fund". The money in the fund may be used for HRA purposes and no other purpose. The
tax may not exceed ten cents on each $100 of taxable valuation in the area of operation; Minn.
Stat. § 469.033, Subd. 6;
(9) An HKA may exercise the powers of a City under Sections 459.31 to 959.33 if the
City, by ordinance, authorizes it. Under Sections 459.31 to 459.33, a city may establish and
provide for the administration of a commercial building loan program to rehabilitate and
preserve small and medium sized commercial buildings within its boundaries.
(b) City Powers as to Projects.
A state public body (which includes cities) may aid-and cooperate in the planning,
undertaking, construction or operation of projects by doing any of the following things:
(i) Dedicate, sell, convey, or lease any of its interest in any property or grant
easements, licenses or other rights or privileges therein to an Authority; Minn. Stat. §
469.041 (1).
(ii) Pay the bonds of or make loans or contributions for redevelopment projects;
Minn. Stat. § 469.041 (1).
(iii) Do any and all things necessary or convenient to aid and cooperate in the
planning, undertaking, construction or operation of projects; and
(iv) Furnish funds available to i.t from any source, including the proceeds of
bonds, to an authority to pay all or any part of the cost to the authority of the activities
authorized by section 469.012, subd. 1, clause (7) (acquiring real property, demolishing,
removing or rehabilitating, or reconstructing the buildings or improvements, constructing
new buildings or improvements thereon, or to prepare the site for improvements), Minn.
Stat. § 469.041 (9).
2. EDA Powers
See Section B, 1-5 of this outline.
3. City Development District Powers
A city may designate development districts within
the city boundaries. After consulting with its planning agency and conducting a public hearing
within a development district, the city may adopt a development program, acquire land or
easements through negotiation or powers of eminent domain, adopt ordinances regulating traffic
(pedestrian or automobile) in facilities constructed within the development district, and exercise
certain other powers. Minn. Stat. § 469.126.
4. Industrial Development Powers
A municipality or redevelopment agency may:
(a) acquire, conStruct and hold any lands, buildings, easements, water and air
rights, improvements to land and buildings, and capital equipment to be located
permanently or used exclusively on a designated site and solid Waste disposal or pollution
control equipment and inventory, regardless of where located, that are deemed necessary
in connection with a project to be situated within the state and construct, reconstruct,
improve, better and extend the project (Minn. Stat. § 469.155, Subd. 2);
(b) pay part or all of the cost of an acquisition and construction by a contracting
party under a revenue agreement (Minn. Stat. § 469.155, Subd. 2);
(c) enter into revenue agreements with any public or private entity to ensure
revenue sufficient to pay principal interest on bonds issued under the statute (Minn. Stat.
§ 469.155, Subd. 5);
(d) pledge the revenues of one or more projects to payment of bonds, and it may
mortgage or permit to be mortgaged a project and its revenues in favor of the city or
authority, the bondholders, or a trustee therefor (Minn. Stat. § 469.155, Subd. 6 and
Subd. 7);
(e) make contracts, execute instruments, and do all things necessary or
convenient in the exercise of powers granted in the Municipal Industrial Development
section (Minn. Stat. § 469.155, Subd. 8).
It may not operate a project as a business, and it may not expend funds on a
project other than the revenues of the project or the proceeds of revenue bonds and notes
or other funds granted to the municipality or authority for industrial development
purposes. Since an EDA may exercise HRA powers for the purpose of industrial
development, and since an HRA has clear authority to operate a project, this limitation
has been overridden by other provisions of the statute.
C. Constitutional Concerns
1. Public Purpose Doctrine
Public funds may be used only for public purposes.
Minnesota Constitution, Article X, § 1. ("taxes shall be levied and~collected for public
purposes"). Minnesota Constitution, Article XII, § 1. ("The Legislature shall pass no local or
special law.., authorizing public taxation for a private purpose.")
The Minnesota Supreme Court has given a broad interpretation to the meaning of public
purpose, holding that such meaning "is ever evolving in light of contemporary conditions."
Minnesota Energy & Economic Development Authority v. Print),, 351 N.W.2d, 319, 338 (Minn.
1984). Moreover, legislative determinations of public purpose, while not binding on the courts,
are entitled to great weight. In fact, the Minnesota Supreme Court.has held that "a reviewing
court should overrule a legislative determination that a particular expenditure is made for a
public purpose only if that determination is manifestly arbitrary and capricious." R.E. Short Co.
v. City of Minneapolis, 269 N.W.2d, 331,337 (Minn. 1978).
In making its determination, the court need not consider "extraneous factors such as the
mode of financing", for such factors "have no bearing on the issue of public purpose. Lifteau
v. Metropolitan Sports Facilities Commission, 270 N.W.2d 749, 754 n.6. (Minn. 1978) Instead,
the court must focus on whether the expenditures will benefit the community as a whole and are
related to the functions of government. Visina v. Freeman, 252 Minn. 177, 184-85, 89 N.W.2d
635, 643 (1958).
2. "But for" Finding
In addition to finding a public purpose for a project'or program, it will be necessary to
determine that the proposed project would not go forward within the City "but for" the assistance
to be provided by the EDA. The City and/or Authority must demonstrate need for public
assistance to the private entity and must make specific findings supporting that need.
The public purpose and "but for" determinations will have to be made on a case by case
basis, looking at the particular facts of a proposed project or program.
3. Loan of Credit
Article XI, § 2 of the Minnesota Constitution provides that,
The credit of the state shall not be given or loaned in aid of any individual,
association or corporation...
The Minnesota Supreme Court has consistently held that this provision applies only to
the state, and not to its political subdivisions. Visina v. Freeman, 89 N.W.2d at 649; Davidson
v. County Commissioners of Ramsey County, 18 Minn. 482. Accordingly, an Authority need
not be concerned that a given project or program will be considered an impermissible loan of the
City's or Authority's credit.
D. Availability and Appropriate Utilization of Revenue Sources
An EDA has several options for funding its activities. These include use of excess tax
increments, general fund moneys of the City, proceeds of Bonds, proceeds from the levy of taxes
and others. Crucial to the use of any of these revenue sources is that the Authority be able-.to
find that "but for" such use, the economic development project the Authority is thereby trying to
facilitate would not have occurred.
1. Tax Increments. A city may use excess tax increments to fund its Economic
Development Authority. However, the use of such tax increments carries with it limitations that
make it somewhat less useful than other sources of funds.
a. Revision of Plan. First, revenues derived from tax ir.
only in accordance with a tax increment financing plan. This n
existing development programs and tax increment financing ph
to provide for use of tax increment by an Authority for the purl:
Authority.
b. Limitation on Use of Tax Increment. Further, revere
increments may only be used by an economic development autl
otherwise pay costs specifically listed in § 469.176, subd. 4, wi
.crements may be used
teans, at a minimum, that
ms may have to be revised
oses contemplated by the
derived from such tax
~ority to finance or
dch include:
(i) The "capital and administrative costs" for prqiects undertaken in a
"development district" created pursuant to the City Development District law.
Tax increments derived from any existing tax increment districts created by the
City would be subject to such a limitation. Unless the EDA could reconstitute the
development district as a "redevelopment project area" under HRA law, limitation
of the use of tax increments to the payment of "capital costs" would permit use of
tax increments to acquire a limited partnership ("equity") interest in a company
only if the money paid for the partnership interest were spent on a "capital cost"
of the project. Hence, the tax increments could not be used to fund working
capital loans, whether or not funded directly or through an "equity" investment.
(ii) The "cost of redevelopment" for prqiects undertaken in an "economic
development district" pursuant to the EDA law. The EDA law defines "cost of
redevelopment" to mean acquiring property, demolishing or removing structures
on acquired property, correcting soil deficiencies on acquired property,
construction or installing public improvements, providing relocation benefits to
occupants of acquired properties,, planning, engineering, legal and other services
necessary to carry out the above, and the allocated administrative expenses of the
authority for the project. Clearly such costs do not include working capital loans,
nor, for that matter, the cost of constructing or equipping a building.
Furthermore, such costs must be incurred in an economic development district
which in turn must satisfy, the stringent "redevelopment district" requirements of
the Tax Increment Financing Act.*
(iii) The "public costs of redevelopment" for prqjects undertaken pursuant
to the HRA law in a "project redevelopment area". Unlike the cost the projects
discussed above, the HRA restriction does not limit the use of tax increments to
capital costs. Thus, if the projects were undertaken pursuant to the HRA laws and
were qualified as "any work or undertaking to prov!de housing for persons of
moderate income and their families" or an "undertaking ..... for the
elimination or for the prevention of the development or spread of slums or
blighted or deteriorating areas" and if any underlying land to be acquired as part
of the public costs of redevelopment is either a "blighted area" or satisfies the
conditions set forth in Minnesota Statutes, Section 469.028, Subdivisions 3 or 4,
then there is little statutory restraint on how tax increments could be used to aid
such projects so long as appropriate heatings are held and findings as to need are
made by the City Council and the EDA.
(iv) The cost of financing or otherwise paying premiums for insurance or
other security guaranteeing the payment when due of debt service on housing
revenue bonds issued under Chapter 462C or industrial or commercial
development revenue bonds issued under the Municipal Industrial Development
Act or to fund and maintain a debt reserve for such bonds (not to exceed after five
years from date of issuance 20% of the outstanding principal amount of such
bonds).
The "redevelopment district" requirements, which are already slx-ingent, may become even more so if
pending amendments to the Tax Increment Financing Act are enacted into law.
C. Transfer of Proiects. In order to allow the EDA to use tax increments
and
other
revenues derived from any development districts created under the Cit~ Development District
/
law or from projects undertaken by any City or HRA, a city may elect'by resolution of the City
Council, to transfer control of such projects and any underlying tax increment financing districts
to the EDA. After the transfer, the EDA may exercise all powers the City or HRA had with
respect to the project. The EDA must covenant and pledge to perform the terms, conditions and
covenants of the bond indenture or other agreements executed for the security of any bonds
issued by the City with respect to the program, and the EDA will become obligated on the bends
when the program is transferred. Such transfer, however, will not relieve the City of its full faith
and credit pledge and tax levying responsibilities with respect to the bonds issued by the City. If
the City should decide to retain jurisdiction over any development district, the City Council
could still transfer the tax increments to the EDA pursuant to the annua1 budget so long as the tax
increments are used in a manner consistent with the development district plan and tax increment
financing plan adopted by the City. I
2. General Fund Moneys of City. The Authority is required to Send its budget to the City
Council with an estimate of the amount of money the Authority expects to need from the City to
do Authority business during the next fiscal year. This is the procedure under which the City
may give to the Authority money from the City's general fund for the A~uthority to use. The
benefit of using City general fund moneys lies in the fact that such moneys are not as limited in
use as moneys from other sources. In short, general fund moneys may be contributed by the City
to the Authority and used for any economic development purpose, so l°ng as appropriate
findings are made and safeguards are imposed to show that such use will be made to promote
economic development within the City. Such use includes write-downs, grants or loans
(including working capital loans) to companies to induce them to locate or expand in the City
and the purchase of limited partnership interests.
3. Bonds. An Authority may use the proceeds of various types of bonds to fund its
activities.
a. Tax Supported General Obligation Non-Tax Increment Bonds of the City. The
City could issue tax supported general obligation ("G.O.") bond~ which are not secured
by tax increments and give the Authority the proceeds of its G.0. bonds to use in
connection with development activity. The bonds would be subject to approval pursuant
to an election. The bond proceeds could be used for any purpose for which the City's
general fund moneys may be used except the payment of any current expenses of the
Authority or the project. :
b. Tax Supported General Obligation Bonds Issued by the Authority. An
Authority could issue G.O. bonds which pledge the full faith and credit of the City, but
only if approved by an ordinance adopted by the City Council. while those bonds would
also be subject to the election require-ment, the proceeds could be used for any purpose
for which the City's general fund moneys may be used, including payment of current
expenses, so long as provision is made to reimburse the Authority for such expenditures,
plus interest at a rate equal to the average interest rate on the bonds.
c. Revenue Bonds of the Authority. The Authority could issue revenue bonds
and use those funds for any purpose for which the City's general fund moneys may be
used, without requirement for reimbursement. The revenues of the projects financed (and
other revenues of the Authority) would be pledged to the repayment of the bonds. The
Authority may also secure payment of the bonds by either a mortgage on certain
Authority properties or a pledge of the Authority's, but not the City's, full faith and credit,
or both. The Authority could also issue revenue bonds under the Municipal Industrial
Development Act or housing revenue bonds under Chapter 462C and use tax increments
to pay for any security guaranteeing payment of the bonds or to fund or maintain a
reserve therefor. See paragraph lc. above.
d. Tax Increment Bonds. Either a City or its Authority could issue either G.O.
bonds or tax increment revenue bonds secured by a pledge of tax increments without an
election. Use of the proceeds of tax increment bonds would be subject to the same
limitations as tax increment funds. (The Authority could also secure payment of the
bonds in the same fashion allowed for revenue bonds discussed above.)
e. Using Credit of Sister Authority. Under the Joint Powers Act, the Authority
could enter into a joint powers agreement with some other authority having substantially
common power (e.g., the St. Paul Port Authority) under which the other authority could
issue bonds and thereby lend its credit to finance a project in the City.
4. Tax Levy. An Authority may have its City levy a tax of 0.01813 percent of taxable
market value for the benefit of the Authority. The City may increase this levy by following the
"reverse referendum" procedure specified in the statute. In addition, the EDA could exercise its
~ powers and levy a tax of one th/rd of one mill times the assessed valuation of taxable
property in the City for the benefit of the Authority. This levy also requires City Council
approval. The money obtained from the levy could be used for any purpose for which the City's
general fund moneys could be used.
5. Reimbursement Tax Increment Money. Even if excess tax increments are restricted as
to use, that restriction is removed once the tax increments are used to reimburse the City for
general fund expenditures (including administrative costs) which could have been paid from tax
increments.
6. Utility Taxes. We are unaware of any authority under which the City may impose any
"utility tax" as a surcharge on rates and charges imposed for sewer and water to help finance
economic development projects. Rates and charges may be increased, however, or a surcharge
used, to raise the money required to expand the sewer and water system to accommodate
economic development. On the other hand there is at least some authority for including a
reasonable profit relating to the City's utility system. This "profit" could be transferred to the
City's general fund and in mm used in the same manner as other general fund monies. Similarly,
any franchise fee charged for the granting of a franchise to an investor owned utility (e.g., NSP)
could be contributed in the same manner as other general fund moneys could be used.
7. Miscellaneous Sources of Revenue. The City could use developer payments in lieu of
taxes or developer loan repayments for any purpose for which the City's general fund
moneys could be used'.
Despite the broad interpretation given the public pm-pose doctrine, it remains crucial to
demonstrate that public funds will be used for a public purpose. Public benefits such as the
addition of jobs, the retention ofjobs, the addition or retention of tax base, or the prevention or
cure of blight will demonstrate that a project has the requisite public purpose. In any given
project, providing for penalties if certain job or tax base criteria are not met will bolster a public
purpose argument.