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6.3. SR 02-11-2013 City of Ells = REQUEST FOR ACTION River` TO ITEM NUMBER Mayor and City Council 6.3 AGENDA SECTION MEETING DATE PREPARED BY Work Session February 11, 2013 Jeremy Barnhart, Planning Manager Clay Wilfahrt,Assistant Director of Economic Development ITEM DESCRIPTION REVIEWED By Concept Review of Blackhawk Woods Suzanne Fischer, Community Operations & Development Director REVIEWED BY Cal Portner, City Administrator ACTION REQUESTED Provide informal,non-binding feedback on the proposed: A. Use of the West Oaks plat for a 60-unit senior housing development. B. Use of Tax Increment Financing to assist the project. The applicant has requested the Council's initial reaction and feedback on the project prior to making a substantial initial investment. BACKGROUND/DISCUSSION Senior 30,LLC has approached the city to develop the remaining portions of the West Oaks plat into a 60-unit, single level rental senior townhome neighborhood. The initial phase will be 40-units,with the remaining 20-units in a future phase. West Oaks was originally platted in 2003 and included 115 single family and 124 multiple family townhomes. The single family homes and approximately 24 of the townhome units have been constructed. Infrastructure has been installed,including 183TdAvenue,Yankton Street,Xerxes Street, and several private drives. Land Use The proposed use of the land is consistent with its approved use and will require no rezoning or land use amendment. The zoning ordinance does not regulate age limits on development. For this project, there will be a deed restriction as part of the financing addressing the age issue. Phase 2 will need to be platted prior to construction. Tax Increment Financing The developer inquired about possibly utilizing Tax Increment Financing (TIF) for Blackhawk Woods. Staff briefly reviewed the proposed project and the TIF policy and upon preliminary review,the project appears to meet objectives and qualifications. P 0 W I R 1 0 6Y I IV AU The project meets the objective of creating opportunities for affordable housing. The project would also increase the city's tax base. Market demand has been demonstrated for the project via the Comprehensive Housing and Market Analysis conducted by the Housing and Redevelopment Authority in July 2012. The analysis found that by 2017 there will be a need for 40 senior few-service housing units, the type of housing proposed in the Blackhawk Woods project. The project is still subject to more rigorous analysis,including a but-for test, but initially it appears to meet all project qualifications and objectives of the TIF policy. FINANCIAL IMPACT None ATTACHMENTS ■ 2,4,6 unit floor plans ■ West Oaks Plat ■ TIF Policy Action Motion by Second by Vote Follow Up N:\Public Bodies\City Council\Council RCA\Agenda Packet\02-11-2013\Blackbawk Woods.docx ® �O 9 N ° pc ~ 9 S kp i i O r s a W V Z S IL Y 4' m _ q i f e q q �a N ' ill, 0n ° i I I I I q„ffiTy, In Y �a W in Leg] re fi ® Q n `------ W E p Y iu I IL 0 RY Y3 Y g a e� x g} Y w V-01 W-01 1'-a I•. 6.0 sGo 9'- 7'•l0 i 1 I 1 88066.7 I 6 0 b86 981066 7 EAT RM CAM OWNERS GREAT R 4 BEDRM BEDRM 6, b � v DINING - b '0 7.0 6.0 7. Q 67 j wic wic 9 DINING? �� 6N �.p BATH 6� 4 � KITCHEN w KITCHEN L a n p1Nf � oal77'c h -- DEN/ DEN EM 1E17 1.0 EDRM BEDRM E,7 e_ SD ® 74 7.0 P®1N 1°V 16R 7-4 7.0 .&T IWF 0 m 89666.7 1 90666 7 y J7'6 Ia .. .. ® 77ao ,.... _ ! '� !,:: rs7do OTORAGE all A I� ] L_ i i •la a •-r a 6• 6•r a I,. '-a 10'•a •-a 364 6a PT e Windsor The Windsor- 441®a Pr. GARAGE ¢ 999 �T. sts .�T. 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I _ - � :• \ v\ (';c"t of � 1 - O �°IO 1M � t� -------------------------------------- ;.gi - L _90 ' p � � -✓ ,rte-_ -i • r 1�4 ir9 X05 j9 7 '! � •p ` - -J I 03 T 9H FI END m I h I i of o. m l IN C\l co ;- 1 ^I 3 9 ^ '1 Aa DNI'SIN3VUSIANI 2 1?S w NA'aOA18 NM JO),13 -ail'ib.r 'CE S)I.VO IS], bu V ----------------------- -------- --------------------- ------ -------------- --------------- ------------ - ,5 mid 1 J. It ......... o, MIL\ N�IV11131ld ma lvid 2 'I 7N jo 'Vo 'S. Senior 3 , LLC 5001 American Blvd W.,#501 * Bloomington, MN 55437 *952.830.0161 x326 Fax: 952.831.1215 November 14,2012 City of Elk River Annie Deckert Director of Economic Development 13065 Orono Parkway Elk River, MN 55330 Dear Annie, Please find attached our narrative describing Blackhawk Woods, a 40 unit, one-level rental townhome development that we propose to build for Senior Citizens with low and moderate incomes under the HUD Section 42 tax credit program. I talked to the Assessors' office the other day and got more accurate information to compute the TIF amount, which is shown below. They can give exact numbers after they have had a chance to review the building plans. Assessors' estimate: 0 Assumed Market Value per Unit: $135,000 ® Estimate of Non-Homestead Real Estate tax: $2,283 ® Rate for subsidized rental projects (Apartment 4-D): 75%x$2,283 =$1,712 m Increment=$1,712 less existing tax of$380=$1,332 0 10%of the increment is retained by City($133) ® TIF amount/Unit: $1,332-$133 =$1,199 ® Estimated TIF amount/Project: $1,199 x 40 units=$47,960 ® Note: The Project will still pay the existing real estate taxes plus 10%of the increment Please call me after you have had a chance to review the narrative, so we can discuss our next step. Thank you, in rely, o er Dern-k Chief Manager enclosures: Narrative, Site Plan Narrative Senior 30, LLC would like to construct Blackhawk Woods, a 40 unit, one-level rental townhome development for Seniors with low and moderate incomes in the West Oaks subdivision located just south and west of Highway 10 and Waco Street. Please see attached site plan. Senior 30, LLC is associated with Cottage Homesteads at West Oaks, LLC who already owns the property. We propose building 2 Bedroom, one-level townhomes with attached single or double garages to serve area Seniors whose income is limited primarily to social security payments. The market study for the City, done by Maxfield Research, shows a need for subsidized independent living Senior housing. If the City wants our project to proceed, we will commission Maxfield Research to do a new market study focused specifically on our proposed project. • Serving Seniors 55 years and older • Independent living one-level townhome apartments with no medical staff or assisted living personnel on site, although individual assistance can be contracted for through Guardian Angels or others. • Serving Seniors with Incomes at$40,320 or less (2 persons); $35,280 or less (1 person) • Townhome rent maximums: 0 50% of apartments at or below the 60% level published by MHFA (2BR; $1,134/mo including utilities) 0 50% of apartments at or below the 50% level published by MHFA (2BR; $945/mo including utilities) There are many older folks in the area who feel trapped in their houses because they have nowhere to move to that feels safe and secure and where they can associate with people their own age. Blackhawk Woods Townhome Apartments will provide them with their own separate front door and attached garage, so they can easily come and go and won't have to worry about climbing stairs or doing the exterior maintenance that their old houses constantly require. Section 42 low and moderate income housing projects utilize Government financing programs that can provide equity and mortgage financing. The equity, consisting of 25% of the project cost, is provided by Syndicators who market the low and moderate income housing tax credits provided for the project to Corporate Investors. The mortgage is obtained through a HUD FHA low interest loan. Section 42 projects have building cost constraints, tenant income limitations and rent ceilings that are imposed and monitored by HUD and Minnesota Housing Finance Agency (MHFA). The 4%tax credit program that we will be utilizing does not require winning a MHFA competition, like the 9% program does, but still must adhere to MHFA scoring requirements. Although Section 42 Senior housing projects have not usually been financially feasible, the economic problems facing the housing industry can actually help in this instance because costs can be significantly reduced. The developer that originally sold us the lots is willing to discount them by more than 50%. The subcontractors are able to give us exceptionally good prices because they need the work and the mortgage interest rates are less than 41, an all-time low. The project also requires TIF assistance to achieve the targeted rents and is actually required by MHFA in order to meet scoring requirements for the 4%tax credits. We have developed 17 one-level Senior projects during the past 20 years including Elk Run Village in Elk River. Six projects have been Section 42 tax credit projects similar to the one we are now proposing. In summary, we are requesting from the City approval of our proposed Dlackhawk Woods Senior development. We are familiar with the City's standards for building design and products and will meet those standards. The property is already platted into townhouse lots, which will accommodate our design, so no further zoning or platting approvals will be necessary. We will need tax increment financing approval from the City, which will provide the project with necessary resources to meet the requirements of MHFA. This would be a pay as you go TIF program so would not require a financial commitment from the City. The existing lot taxes would continue to be paid and in addition,the City would collect 10% of the increment amount. Because there will be no children living in the development,there will be no negative impact on schools or parks. Thank you for considering our proposal. Respes fully, G /;?c, er Derrick g k Senior 30, LLC Chief Manager City Of Tax Increment Policy & Application Amended: May 2006 Amended: March 2000 Adopted: August 1991 City of Elk River Economic Development Division 13065 Orono Parkway Elk River,MN 55330 763.635.1040 Table of Contents 1. Policy Purpose 11. Objectives of ax Increment Financing M. City ®f Elk River Policies for the Use of TIF IV. Project Qualifications V. Application Process f®r TIF I. Application f®r TIF 7 Applicant Information 7 Project Information 8 Public Purpose 8 Sources&Uses 9 Checklist&Additional Information 10 Vi l. Sample But-For Analysis I I Ill. Application Review Worksheet 12 IX City ®f Elk River Business Subsidy Policy I City of Elk River Tax Increment Policy&Application Amended May 2006 Page 2 of 13 1. POLICY For the purposes of this document, the term "City"shall include the Elk River City Council, Economic DevelopmeratAuthori�, and Housing and RedeveloplventAuthorzty. The purpose of this policy is to establish the City of Elk River's position relating to the use of'-fax Increment Financing(TIF) for private development above and beyond the requirements and limitations set forth by State Law. This policy shall be used as a guide in the processing and review of applications requesting tax increment assistance. The fundamental purpose of tax increment financing in Elk River is to encourage desirable development or redevelopment that would not otherwise occur but for the assistance provided through TIF. The City of Elk River is granted the power to utilize TIF by the Minnesota Tax Increment Financing Act, as amended. It is the intent of the City to provide the minimum amount of TIF, as well as other incentives,at the shortest term required for the project to proceed. The City reseives the right to approve or reject projects on a case by case basis, taking into consideration established policies,project criteria, and demand on city services in relation to the potential benefits from the project. Meeting policy criteria does not guarantee the award of TIF to the project. Approval or denial of one project is not intended to set precedent for approval or denial of another project. li. OBJECTIVES As a matter of adopted policy,the City will consider using TIF to assist private development projects to achieve one or more of the following objectives: • To retain local jobs and/or increase the number and diversity of jobs that offer stable employment and/or attractive wages and benefits as defined in the City's Business Subsidy Policy. • To encourage additional unsubsidized private development in the area, either directly or indirectly through "spin off' development. • To facilitate the development process and to achieve development on sites which would not be developed without TIF assistance. • To remove blight and/or encourage redevelopment of commercial and industrial areas in the city that result in high quality redevelopment and private reinvestment. • To offset increased costs of redevelopment (i.e. contaminated site clean up) over and above the costs normally incurred in development. • To create opportunities for affordable housing. • To contribute to the implementation of other public policies, as adopted by the city from time to time, such as the promotion of quality urban or architectural design, energy conservation,and decreasing capital and/or operating costs of local government. City of Ella River Tax Increment Policy&Application Amended May 2006 Page 3 of 13 • To enhance and diversify the City of Elk River's economic base. • To significantly increase the City of Elk River's tax base. III. POLICIES FOR THE USE OF TIF a. When possible,TIF shall be used to finance public improvements associated with the project. The priority for the use of TIF finds is: 1. Public improvements,legal,administrative, and engineering costs. 2. Site preparation, site improvement,land purchase,and demolition. 3. Capitalized interest, bonding costs. b. It is the City's policy to establish the following types of TIF districts: 1. Economic Development Districts • It is desired that the project result in a minimum creation of one full time job per$25,000 of TIF, or • Result in a significant increase in the tax base. 2. Redevelopment Districts ® The market value of a redeveloped site shall increase by a minimum of 50% of the current market value. Other types of TIF districts,along with specific criteria,may be considered on a case-by-case basis. c. TIF assistance will be provided to the developer upon receipt of the increment by the City, otherwise referred to as the phi-as:)iougo method. Requests for up front financing will be considered on a case-by-case basis. d. A maximum of ten percent (10%) of any tax increment received from the district may be retained by the City to reimburse administrative costs. e. Any developer receiving TIF assistance shall provide a minimum of ten percent (10%) owner cash equity investment in the project. f. TIF will not be used in circumstances where land and/or property price is in excess of fair market value. g. Developer shall be able to demonstrate a market demand for a proposed project. TIF shall not be used to support purely speculative projects. h. TIF will not be utilized in cases where it would create an unfair and significant competitive financial advantage over other projects in the area. i. TIF shall not be used for projects that would place extraordinary demands on city services or for projects that would generate significant environmental impacts. j. The developer must provide adequate financial guarantees to ensure completion of the project,including,but not limited to: minimum assessment agreements,letters of credit,personal guaranties, and etcetera. City of Elk River Tax Increment Policy&Application Amended May 2006 Page 4 of 13 k. The developer shall adequately demonstrate, to the City's sole satisfaction,an ability to complete the proposed project based on past development experience,general reputation,and credit history,among other factors, including the size and scope of the proposed project. 1. For the purposes of underwriting the proposal, the developer shall provide any requested market, financial, environmental, or other data requested by the City or its consultants. m. All TIF proposals shall optimize the private development potential of a site. IV. PROJECT QUALIFICATIONS All TIF projects considered by the City of Elk River must meet each of the following requirements: a. To be eligible for TIF,a project shall result in: i. The new construction of a minimum of 25,000 square feet; ii. A minimum increase of$37,500 per year,excluding the state portion in property taxes;and, iii. Have a market value of at least$1,250,000 upon completion. b. The project shall meet at least one of the objectives set forth in Section II and satisf T all the provisions set forth in Section III of this document. c. The developer shall demonstrate that the project is not financially feasible Gut for the use of TIF. d. The project shall comply with all provisions set forth in the Tax Increment Financing Act,Minnesota Statutes 469.124 to 469.134,inclusive, as amended, and Statutes 469.174 to 469.1799,inclusive,as amended. e. The project must be consistent with the City's Comprehensive Plan,Land Use Plan,and Zoning Ordinances. f. The project shall serve at least two of the following public purposes: ® Creation of jobs with livable wages and benefits. ® Significantly increase the City's tax base. ® Enhancement or diversification of the city's economic base. ® Industrial development that will spur additional private investment in the area. ® Fulfillment of defined city objectives such as those identified in the City's Comprehensive Plan and the City's Economic Development Strategic Plan,among others. ® Removal of blight or the rehabilitation of a high profile or priority site. City of Elk River Tax Increment Policy&Application Amended May 2006 Page 5 of 13 V. APPLICATION PROCESS FOR TIF 1. Applicant submits the completed application along with a non-refundable $10,000 application deposit. The application deposit will be used toward the cost of services provided in the evaluation of financial feasibility, establishment or modification of the TIF district, and preparation of legal documents and agreements. An additional deposit of$10,000 will be required for projects the require meeting statutory eminent domain and/or redevelopment substandard tests. Projects that demand professional services in excess of the initial deposit shall be required to reimburse the City for the additional expenses. 2. City staff reviews the application and completes the Application Review Worksheet. The Application and Application Review Worksheet is primarily designed to score the desirability of an industrial project. Redevelopment and Housing projects will be evaluated on a case-by-case basis and as the projects meet the city's desired objectives. 3. Results of the Worksheet are submitted to the appropriate governing authorities (EDA or HRA) for recommendation to the City Council of approval or denial of the request. 4. If preliminary approval is granted, the Tax Increment Financing Plan, along with all necessary notices,resolutions are prepared by City staff and/or consultants. 5. Notices are published and sent to the county and school board. 6. Public hearing(s) on the proposed request are held. 7. The City Council grants final approval or denial of the request. City of Elk River Tax Increment Policy&application Amended May 2006 Page 6 of 13 I. APPLICATION FOR TAX INCREMENT FINANCING A. APPLICANT INFORMATION Name of Corporation/Partnership Address Primary Contact Address Phone Fax Email Brief description of the corporation/partnership's business,including history,principal product or service: Brief description of the proposed project: Attorney Name Address Phone Fax Email Accountant Name Address Phone Fax Email Contractor Name Address Phone Fax Email Engineer Name Address Phone Fax Email Architect Name Address Phone Fax Email City of Elk River Tax Increment Policy&Application Amended May 2006 Page 7 of 13 B. PROJECT INFORMATION 1. The project will be: Industrial Greenfield: New Construction Expansion Commercial Redevelopment: New Construction Rehabilitation Industrial Redevelopment: New Construction Rehabilitation Other 2. The project will be: _Owner Occupied Leased Space 3. Project Address Legal Description&Parcel Identification Number(s) 4. Site Plan and Preliminary Construction Plans Attached: Yes No 5. Amount of Tax Increment Requested for: Land Purchase $ Public Improvement$ Site Improvement$ 6. Current Real Estate Taxes on Project Site: $ Estimated Real Estate Taxes upon Completion: Phase 1 $ Phase II $ 7. Construction Start Date: Construction Completion Datc: If Phased Project: Year % Completed Year % Completed C. PUBLIC It is the police of the City of Elk River that the use of Tax Increment Financing should result in a benefit to the public. Please indicate how this project will serve a public purpose. Job Creation/Retention: Number of existing jobs Number of jobs created by project .?average hourly wage of jobs created/retained New industrial development,which will result in additional private investment in the area. _Enhancement or diversification of the city's economic base. _The project contributes to the fulfillment of the City's Economic Development Strategic Plan. _Removal of blight or the rehabilitation of a high profile or prioritjT site. _Significantly increase the City's tax base. Other: City of Elk River Tax Increment Policy&Application Amended May 2006 Page 8 of 13 D. SOURCES & USES SOURCES NAME AMOUNT Bank Loan $ Other Private Funds $ Owner Cash Equity $ Fed Grant/Loan $ State Grant/Loan $ EDA Micro Loan $ Tax Increment $ ID Bonds $ TOTAL $ USES AMOUNT Land Acquisition $ Site Development $ Constriction $ Machinery&Equipment $ Architectural&Engineering Fees $ Legal Fees $ Interest During Construction $ Debt Service Reserve $ Contingencies $ TOTAL $ i City of Elk River Tax Increment Policy&Application Amended May 2006 Page 9 of 13 E. ADDITIONAL DOCUMENTATION AND CHECKLIST Applicants will also be required to provide the following documentation. A) Written business plan,including a description of the business, ownership/management, date established, products and sciiTices,and future plans B) Financial Statements for Past Two Years Profit&Loss Statement Balance Sheet C) Current Financial Statements Profit&Loss Statement to Date Balance Sheet to Date D) Two Year Financial Projections E) Personal Financial Statements of all Major Shareholders Profit&Loss Current Tax Return F) Letter of Commitment from Applicant Pledging to Complete During the Proposed Project Duration G) Letter of Commitment from the Other Sources of Financing, Stating Terms and Conditions of their Participation in Project II) Non-refundable application deposit of$10,000 I) Construction Plans and Itemized Project Construction Statement J) Attach the following documentation as Exhibits Exhibit A—Corporation/Partnership Description Exhibit B—Description of Project Exhibit C—List of Shareholders/Partners Exhibit D—But-Far Analysis Exhibit E—List of Prospective Lessees Exhibit F—Legal Description and PID Number(s) Note:All Major shareholders will be required to sign personal guarantees if up front financing of the project is required. The undersigned certifies that all information provided in this application is true and correct to the best of the undersigned's knowledge. The undersigned authorizes the City of Elk River to check credit references and verify financial and other information. The undersigned also agrees to provide any additional information as may be requested by the City after the filing of this application. Applicant Name Date City of Elk River Tax Increment Policy&Application Amended May 2006 Page 10 of 13 VIA. SAMPLE BUT-FOR WITH NO WITH TAX INCREMENT TAX INCREMENT SOURCES AND USES SOURCES AND USES SOURCES SOURCES Mortgage 9,600,000 8,667,000 Equity 2,400,000 2,400,00 Tax Increment Financing 0 933,000 TOTAL SOURCES 12,000,000 12,000,000 USES USES Land 1,500,000 1,500,000 Site Work 300,000 300,000 Soil Correction 468,000 468,000 Demolition 100,000 100,000 Relocation 65,000 65,000 Subtotal Land Costs 2,433,000 2,433,000 Construction 6,750,000 6,750,000 Finish Manufacturing 250,000 250,000 Subtotal Construction Costs 7,000,000 7,000,000 Soft Costs 350,000 350,000 Taxes 35,000 35,000 Finance Fees 850,000 850,000 Project Manager 542,000 542,000 Developer Fee 540,000 540,000 Contingency 250,000 250,000 Subtotal Soft Costs 2,567,000 2,567,000 TOTAL USES 12,000,000 12,000,000 Income Statement Income Statement Sq. Ft. Per Sq. Ft. Sq. Ft. Per Sq. Ft. Rent-Space 1 100,000 38.00 800,000 100,000 $8.00 800,000 Rent-Space 2 25,000 $8.50 212,500 25,000 $8.50 212,500 Rent-Space 3 25,000 $9.00 225,000 25,000 $9.00 225,000 Other 0 $0.00 0 0 $0.00 0 1,237,500 1,237,500 Mortgage 20 Term 1,051,646 20 Term 949,439 9,00%Interest 9.00%Interest 9,600,000 Principal 8,667,000 Principal Net Income 185,854 288,061 Total Return on Equity 7.74% 12.00% City of Elk River Tax Increment Policy&Application Amended May 2006 Page 11 of 13 Ill. TAX INCREMENT FINANCING APPLICATION REVIEW WORKSHEET TO BE COMPLETED BY CITY STAFF 1. The project meets the criteria set forth in Section IV of the City's Tax Increment Financing policy. a) Meets minimum thresholds for size,value, and tax revenue. b) Meets at least one of the objectives in Section II and satisfies the provision set forth in Section III. c) Demonstrates need for TIF with the but-fog°analysis. e) Consistent with all city plans and ordinances. 0 Serves at least two public purposes as defined in Section IV. 2. Ratio of Private to All Public Investment in Project: Points: $ Private investment 5:1 5 $ Public Investment 4:1 4 Ratio Private : Public Financing 3:1 3 2:1 2 Less than 2:1 1 3. Job Creation in the City of Elk River: Points: Number of new jobs as a result of the project. 40+ 5 Number of existing/retained jobs divided by 10. 30+ 4 Total 20+ 3 10+ 2 Less than 10 1 4. Ratio of Public Investment to Job Creation: Points: $ Public Investment $15,000 or less 5 Number of ue)v jobs created/retained $20,000 or less 4 $ Public Investment per new job $22,000 or less 3 $25,000 or less 2 Over$25,000 1 5. Wage Level of new jobs created/retained: Points: Minimum hourly wage Over$21/ hour 5 of jobs created/retained: $18-21 / hour 4 $14-17 / hour 3 $10-13 / hour 2 Under$10 / hour 1 6. Project size: Points: The project will result in the construction 80,000+ 5 of square feet 65,000+ 4 50,000+ 3 35,000+ 2 25,000+ 1 City of EU River Tax Increment Policy&Application Amended May 2006 Page 12 of 13 7. Market Value/Tax Base Generation: Points: The project will result in a per square foot Industrial Commercial estimated market value (land and building) $80/sf+ $110 1sf+ 5 of $70/sf+ $100/sf+ 4 $60/sf+ $90/sf+ 3 $50/sf+ $80/sf+ 2 $40/sf+ $70/sf+ 1 8. Type of Project: Points: 100% Owner Occupied 5 Mix Owner Occupied &Investment 4 Investment Property 3 9. Use: Points: Manufacturing 5 Research&Development 4 Commercial Redevelopment 3 Warehouse/Distribution 2 Housing 1 10. Likelihood that the project will result in Points: unsubsidized, spin-off development. High 5 Moderate 3 Low 1 Sub -Total Points: of a possible 45 points. 11. Bonus Points Bonus Points: The project will be 100% Pay-asyougo TIF. 3 points The project contributes to the goals of E1aeigy 00. 2 points ® Product promotes sensible use of energy,OR ® Project utilizes significant energy efficient design&/or materials in construction. Total Points: Overall project analysis: High 45-38 points Moderate 37-29 points Low 28-20 points Not Eligible 19-0 points City of Elk River Tax Increment Policy&Application Amended May 2006 Page 13 of 13