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4.6. SR 08-28-2000ITEI~ /-I..6. City of River MEMORANDUM TO: Mayor and Council FROM: DAli:: Marc Nevinski, Assistant Director of Economic Development August 28, 2000 SUBJECT: Development Agreement for TIF District No. 21 /ssue Attached you will find the development agreement for TIF District No. 21, which outlines the terms and conditions for the collection and disbursement of tax increment dollars for the SoftPac/Opus project. Incorporated into the development agreement is the business subsidy agreement, which outlines the goals for the project and the public purposes it serves. The goals and public purposes were reviewed at the public hearing on August 21, 2000 and are also addressed in the previous memo. Action Requested Staff requests that council consider the development agreement for TIF District No. 21 and then consider adopting the attached resolution approving and authorizing the execution of the development agreement. Attachments · Development Agreement For TIF District No. 21 · Resolution Approving and Authorizing Execution of the Development Agreement 13065 Orono Parkway · P.O. Box 490 · Elk River, MN 55330 · TDD & Phone (763) 441-7420 · Fax (763) 441-7425 8/23/00 Draft DEVELOPMENT ASSISTANCE AGREEMENT By and Among THE CITY OF ELK RIVER, MINNESOTA, OPUS NORTHWEST, L.L.C. And SOFTPAC, INC. This document drafted by: BRIGGS AND MORGAN (JOM) Professional Association 2200 First National Bank Building 332 Minnesota Street St. Paul, Minnesota 55101 Tel: (651) 223-6600 Fax: (651) 223-6450 1198072.2 TABLE OF CONTENTS ARTICLE I - Definitions .................... 1 Section 1.1. Definitions ................ 1 ARTICLE II - Representations, Warranties and Covenants .... 4 Section 2.1. Representations, Warranties and Covenants by the City ................ 4 Section 2.2. Representations, Warranties and Covenants by the Company ............... 4 ARTICLE III - Completion of Improvements; Reimbursement of Certain Costs ................ 6 Section 3.1. Section 3.2. Section 3.3. Section 3.4. Section 3.5. Completion of Improvements by the Company 6 Reimbursement by City of Certain Costs 6 Release and Indemnification Covenants 8 Certificate of Completion ......... 9 Business Subsidy Agreement; Possible Repayment of Assistance .......... 9 ARTICLE IV - Events of Default 12 Section 4.1. Events of Default Defined ........ 12 Section 4.2. Remedies on Default ........... 12 Section 4.3. No Remedy Exclusive .... . . . . . . . 13 Section 4.4. No Additional Waiver Implied by One Waiver .................. 13 ARTICLE V - Additional Provisions .............. 14 Section 5.1. Titles of Articles and Sections ..... 14 Section 5.2. Notices and Demands ........... 14 Section 5.3. Counterparts ............... 14 Section 5.4. Law Governing .............. 14 ARTICLE VI - Termination of Agreement; Expiration; Limitation on Assignments ................. 15 Section 6.1. The City's Option to Terminate ...... 15 Section 6.2. Expiration ................ 15 Section 6.3. Effect of Termination or Expiration 15 Section 6.4. No Third Party Beneficiaries; Execution Hereof by SoftPac ............ 15 Section 6.5 Limitations on Transfer of Property and Assignment of Agreement ......... 16 EXHIBIT A - LEGAL DESCRIPTION OF DEVELOPMENT PROPERTY .... A-1 EXHIBIT B - FORM OF TIF BOND ................ B-1 EXHIBIT C - CERTIFICATE OF COMPLETION ............ C-1 EXHIBIT D - BUSINESS SUBSIDY REPORT ............. D-1 1198072.2 DEVELOPMENT ASSISTANCE AGREEMENT THIS AGREEMENT is dated as of August 28, 2000; is by and between the City of Elk River, Minnesota and Opus Northwest, L.L.C., a Delaware limited liability company, and is subscribed in part, as described in Section 6.4(b) hereof, by SoftPac, Inc., a Minnesota corporation; and provides as follows: ARTICLE I Definitions Section 1.1. Definitions As used in this Agreement, the following terms have the following respective meanings: "Administrative Expenses" means "administrative expenses," as defined in Section 469.174, Subdivision 14, of the TIF Act, at any time actually incurred by the City with respect to the TIF District, subject to the 10% statutory maximum provided in Section 469.176, Subdivision 3, of the TIF Act. "Agreement" means this Development Assistance Agreement, as the same may be amended. "City" means the City of Elk River, Minnesota. "Company" means Opus Northwest, L.L.C., a Delaware limited liability company, or permitted successors or assigns. "Development Costs" means the Company's allocable costs of acquiring the Development Property (and no other property), as further specified in and limited by Section 3.2(b) . All Development Costs must be costs of such property acquisition of the Development Property. "Development Property" means the real property described in Exhibit A of this Agreement, being the property comprising the TIF District, as originally established. "Event of Default" means an event of default defined in Section 4.1 of this Agreement. "Improvements" means the approximately 73,000 square foot manufacturing/packaging/warehousing/distribution facility to be constructed by the Company on the Development Property, including all utility, site improvement, parking and related improvements on the Development Property. "Party" means either the Company or the City. "Parties" means the Company and the City. ~8072.2 1 "Project" means the Development Property and the Improvements. "SoftPac" means SoftPac, Inc., a Minnesota corporation. "SoftPac Lease" means that certain lease and/or similar agreement(s) (together with any amendments, supplements or successors thereto) pursuant to which the Company, as lessor thereunder, inter alia, leases the Project to SoftPac, as lessee thereunder, for SoftPac's occupancy and use in its manufacturing and related operations. "Tax Increments" means those tax increments generated by the Project which the City shall be entitled to receive and retain, and which the City shall have actually received, from Sherburne County from time to time from the TIF District pursuant to the TIF Act; provided that the term "Tax Increments" shall specifically not include any amounts of tax increment generated by the TIF District which pursuant to the applicable terms of the TIF Act (as it may exist or be amended from time to time) may be required to be paid to or reserved for the State of Minnesota, Sherburne County, or any other entity or official; and "Available Tax Increments" means, as further defined in Section 3.2, the portion of the Tax Increments which shall be available to pay the City's obligations under the TIF Bond. "Term" means the period beginning on the date of this Agreement and ending (1) on the date, if any, on which the City shall have paid all amounts payable on the TIF Bond, (2) the last of the scheduled "Payment Dates" defined in the TIF Bond, or (3) on such date (if any) as the City shall have terminated this Agreement pursuant to its terms, whichever shall occur earliest. "TIF Act" means the Minnesota Tax Increment Financing Act, that is, Minnesota Statutes, Sections 469.174 through 469.179, as the same may be amended or supplemented. "TIF Bond" means the tax increment revenue bond of the City in the form of the attached Exhibit B, as further described in Section 3.2. "TIF District" means the City's Tax Increment Financing District No. 21 within its Development District No. 1, as the same may be amended. "TIF Plan" means the tax increment financing plan for the TIF District, as provided in that certain City document entitled in part "Modifications to the Development Program for Development District No. 1," dated as adopted August 28, 2000, as the same may be amended. "Unavoidable Delays" means any delay outside the control of the Party claiming its occurrence which is the direct result of 1198072.2 2 strikes, other labor troubles, unusually severe or prolonged bad weather, unavailability of materials, Acts of God, fire or other casualty to the Improvements, litigation (including without limitation bankruptcy proceedings) and which directly results in delays; or acts of any federal, state or local governmental unit which directly result in delays. 1198072.2 3 ARTICLE II Representations, Warranties and Covenants Section 2.1. Representations, Warranties and Covenants by the City. The City represents and warrants that it is authorized to enter into and perform its obligations under this Agreement. Section 2.2. Representations, Warranties and Covenants by the Company. The Company represents and warrants that: (a) The Company is a limited liability company duly organized and in good standing under the laws of the State of Delaware, is authorized to conduct its business activities in the State of Minnesota, is not in violation of any provisions of its organizational documents or the laws of the State of Minnesota or the State of Delaware and is authorized to enter into and perform its obligations under this Agreement. (b) The execution and delivery of this Agreement, the consummation of the transactions contemplated hereby and the fulfillment of or compliance with the terms and conditions of this Agreement are not prevented or limited by and will not conflict with or result in a breach of any provision or requirement applicable to the Company or of any provision of any evidence of indebtedness, agreement or instrument of whatever nature to which the Company is now a party or by which it is bound. (c) The Company, with respect to its construction, operation and maintenance of the Improvements upon the Development Property, will cause the same to occur in accordance with this Agreement and all local, state and federal laws and regulations (including without limitation environmental, zoning, building code and public health laws and regulations). (d) The Company has received no notice or communication from any local, state or federal official or body that any activities of the Company respecting the Development Property contemplated by this Agreement, including the construction of the Improvements on the Development Property, may be or will be in violation of any law or regulation. (e) The Company will obtain, in a timely manner, all required permits, licenses and approvals, and to meet, in a timely manner, all requirements of all applicable local, state and federal laws and regulations which must be obtained or met before the Improvements may be lawfully constructed and completed. 1198072.2 4 (f) To the best knowledge and belief of the Company, the construction of the Improvements on the Development Property within the reasonably foreseeable future is conditioned on the assistance and benefit provided for in this Agreement. It is also the belief of the Company that the level and expected duration of the cash flow assistance to be provided pursuant to the TIF Bond are essential in order to make feasible the financing and initial operation of the Improvements due to the fact that SoftPac has indicated to the Company that it would not enter into the SoftPac Lease without such assistance, and absent the SoftPac Lease, the Company would definitely not proceed with the Project. (g) The Company represents that it expects to enter into an option or similar agreement pursuant to which the Company will have the right to purchase the Development Property and that said agreement (if executed prior to the City Council's public hearing on and approval of the TIF District and the TIF Plan) will be contingent upon the receipt of tax increment assistance for the Project. (h) The City represents, and the Company acknowledges, that the City intends to finance its assistance provided under this Agreement through tax increments derived from the Project and that the City has established the Development Property as the TIF District, and more particularly as an "economic development district" within the meaning of Minnesota Statutes, Section 469.174, Subdivision 12. For purposes of establishing compliance with the limitations provided in Minnesota Statutes, Section 469.176, Subdivision 4c, the Company hereby represents to and covenants with the City that not less than 85% of the buildings and facilities comprising the Improvements (determined on the basis of square footage) are to be used and will be used during the Term for one or more of the following purposes: (1) the manufacturing of tangible personal property, including processing resulting in the change in condition of the property; (2) warehousing, storage and distribution of tangible personal property, excluding retail sales; and (3) space necessary for and related to the activities described in (1) and (2) of this subsection. (i) In particular, the Company covenants that the Project will throughout the Term be leased to (or occupied by) SoftPac and used by SoftPac in its manufacturing and related operations. 1198072 .2 5 ARTICLE III Completion of Improvements; Reimbursement of Certain Costs Section 3.1. Completion of Improvements by the Company. Subject to Unavoidable Delays, the Company shall have substantially completed the Improvements by December 31, 2001. It is the non- binding expectation of the Company that substantial progress will be made in the year 2000 on constructing the Improvements such as will add assessor's market value to the Development Property as of January 2, 2001, and will generate Tax Increments payable in 2002. Section 3.2. Reimbursement by City of Certain Costs. The Company hereby represents to the City that the Company will incur and pay significant Development Costs. The City hereby agrees to defray up to $700,000 of the Development Costs by issuing the TIF Bond to the Company (or to its designee, and the Company hereby authorizes and directs the City to issue the TIF Bond directly to SoftPac), as registered owner thereof, substantially in the form of Exhibit B to this Agreement, the issuance of which TIF Bond is hereby authorized and approved. The TIF Bond and all potential payments thereon shall be subject to the following conditions and limitations: (a) The TIF Bond shall be dated, issued and delivered on or as soon as practicable following the date of execution and delivery of this Agreement, provided no Event of Default shall have occurred and be at the time continuing. (b) As conditions to such reimbursement of Development Costs pursuant to the TIF Bond, the Company shall have completed the Improvements and shall have submitted (from time to time) such written proofs and other documentation as may be reasonably satisfactory to the City of the exact nature and amount of the particular Development Costs for which the Company is seeking reimbursement, together with such other information and documentation necessary to enable the City to substantiate its tax increment expenditures and/or to comply with its tax increment reporting obligations to the State Commissioner of Revenue, the Office of the State Auditor or other applicable official. The documentation shall include documentary proofs of the allocable cost of acquiring the Development Property and shall include paid invoices, copies of remittances and/or other suitable documentary proofs of the Company's payment thereof. The maximum aggregate principal amount of Development Costs which may be added to the TIF Bond is $700,000. (c) Subject to the provisions thereof, the TIF Bond shall be payable on each July 15 and December 15 during the 1198072.2 6 Term (or at least 15 days after receipt from Sherburne County of the respective settlements of Tax Increments), commencing July 15, 2002 (the "Payment Dates"), in the respective amount or amounts described in this subsection. The sole source of funds available for payment of the City's obligations under this Section and correspondingly under the TIF Bond shall be the Available Tax Increments, hereby defined to be, for each calendar year, the Tax Increments respecting taxes payable in that year, provided that the City may deduct from the Tax Increments its then-unpaid Administrative Expenses, including without limitation the City's costs of establishing, implementing and administering the TIF District. The principal amount of the TIF Bond shall be the lesser of $700,000 and the sum of the amounts certified by the Company and accepted by the City pursuant to Section 3.2(b). All payments made on the TIF Bond shall be applied first to accrued and unpaid interest thereon and second toward payment of the principal thereof. All amounts of Tax Increments which are not Available Tax Increments are not subject to this Agreement, and the City retains full discretion as to any authorized application thereof, regardless of whether the Available Tax Increments are sufficient to reimburse the Company in full for the above-described costs. To the extent that the Available Tax Increments are insufficient, through the final Payment Date, to pay all amounts otherwise due on the TIF Bond, said unpaid amounts shall then cease to be any debt or obligation of the City whatsoever. (d) The unpaid principal of the TIF Bond shall bear simple, non-compounded interest at 8.00% per annum from the date of execution of the Certificate of Completion. Interest shall be computed on the basis of a 360-day year consisting of 12 months of 30 days each. (e) The City shall not endeavor to issue the TIF Bond so that the interest thereon shall be exempt from federal or State income taxation, and the Parties accordingly anticipate that the TIF Bond will be a "taxable" obligation. (f) The TIF Bond shall be a special and limited revenue obligation of the City and not a general or moral obligation of the City, and only Available Tax Increments shall be used to pay the amounts due on the TIF Bond. (g) The City's obligation to make payments on the TIF Bond shall be conditioned upon the requirement that there shall not at the time have occurred and be continuing an Event of Default; provided, however, that (unless the City shall have terminated this Agreement) if such Event of Default shall subsequently have been cured to the reasonable satisfaction of ~98072.2 7 the City, such unpaid obligations shall thereupon reinstated and thereby become due and payable. be (h) The TIF Bond shall be governed by and payable pursuant to the additional terms thereof, as set forth in Exhibit B. (i) Following any termination of this Agreement by the City pursuant to Section 4.2 hereof, no further or unpaid amounts of the TIF Bond shall then or thereafter be due and payable by the City under this Section or the TIF Bond but shall thereupon be extinguished. (j) As of each Payment Date, the SoftPac Lease shall have been executed, delivered and in effect, and SoftPac shall then be continuing to occupy the Project and to use it in its manufacturing and related operations. Section 3.3. Release and Indemnification Covenants. (a) The Company releases from and covenants and agrees that the City and the governing body members, officers, agents, including its independent contractors, consultants and legal counsel, servants and employees thereof (hereinafter, for purposes of this Section, collectively the "Indemnified Parties") shall not be liable for and agrees to indemnify and hold harmless the Indemnified Parties against any loss or damage to property or any injury to or death of any person occurring at, about or in connection with the Improvements, or the Company's undertaking and completion thereof, or resulting from any defect therein, except to the extent such loss, damage or death is caused by the negligence or other wrongful acts of the Indemnified Parties. (b) Except for any willful misrepresentation or any willful or wanton misconduct or negligence of the Indemnified Parties, the Company agrees to protect and defend the Indemnified Parties, now and forever, and further agrees to hold the aforesaid harmless from any claim, demand, suit, action or other proceeding whatsoever by any person or entity whatsoever arising or purportedly arising from this Agreement, or the transactions contemplated hereby or the acquisition, construction, installation, ownership, and operation of the Improvements, provided, that this indemnification shall not apply to the warranties made or obligations undertaken by the City in this Agreement. (c) Ail covenants, stipulations, promises, agreements and obligations of the City contained herein shall be deemed to be the covenants, stipulations, promises, agreements and obligations of the City and not of any governing body member, officer, agent or employee of the City. 1198072.2 8 (d) This Agreement shall not create nor be construed to create any partnership, joint venture, agency, or employment relationship between the Parties. Section 3.4. Certificate of Completion. (a) Promptly after completion of the Improvements in accordance with the provisions of this Agreement, and upon written request made to the City by the Company, the City will execute the Certificate of Completion in the form attached hereto as Exhibit C, which shall then be a conclusive determination of satisfaction and termination of the agreements and covenants in this Agreement with respect to the completion of the Improvements. The following shall be conditions precedent to the City's obligation to execute the Certificate of Completion: (i) There shall exist no Event of Default hereunder, and the Improvements shall have been completed in substantial conformity to the terms of this Agreement; and (ii) The City shall have issued a Certificate of Occupancy for all of the Improvements. (b) If the City determines that it cannot execute the Certificate of Completion, it shall, within 20 days after written request therefor, provide a written statement indicating in adequate detail why it cannot do so and also indicating what measures or acts it will be necessary to be taken or performed in order to permit execution of the Certificate of Completion. Section 3.5. Business Subsidy Agreement; Possible Repayment of Assistance. The City, the Company and SoftPac recognize and agree that the assistance under this Agreement is a "business subsidy,, under Minnesota Statutes, Sections 116J.993 through 116J.995, as amended (the "Subsidy Law"), and is subject to the provisions thereof, including without limitation reporting requirements and five year commitment by SoftPac. Accordingly, it is agreed: (a) The estimated fair market value of the subsidy is $700,000. The type of the subsidy is tax increment financing from an "economic development,, tax increment district in the form of deferred reimbursement, with interest, via the TIF Bond, of land acquisition expenses. (b) The public purposes of the subsidy are to further development of the City's industrial and tax base and to create jobs. 1198072 .2 9 (c) For purposes of Section 116J.994, Subdivision 3, of the Subsidy Law, the goals of the subsidy are completion of the Improvements and leasing thereof to SoftPac for at least five years after the "Benefit Date" of the subsidy, as defined in the Subsidy Law, which is hereby determined to be the date of execution of the Certificate of Completion. (d) For purposes of the Subsidy Law, the subsidy shall be considered to be a forgivable loan to SoftPac from the City. It is agreed, as required by Section 116J.994, Subdivision 6, if SoftPac is in default under this Section 3.5, subject to any remedial provisions of the Subsidy Law as may be applicable, SoftPac shall be obligated to repay all amounts paid under the TIF Bond (whether for principal thereof or interest thereon) plus interest on all such amounts at the implicit price deflator, as defined under Minnesota Statutes, Section 275.70, Subdivision 2. If SoftPac meets some but not all of its Job Goals hereinafter defined, SoftPac may request in writing, and City may agree in the absolute discretion of the City Council, that the subsidy be repaid by SoftPac pro rata, e.g., if SoftPac created only 50 of the 60 jobs at the Project, SoftPac would repay one-sixth of the assistance paid to SoftPac, plus accrued interest thereon. The subsidy is needed in order to induce SoftPac to lease and occupy the Project in the City. SoftPac covenants that it will continue to lease the Project from the Company for at least five years after the Benefit Date. (e) SoftPac represents that it has no parent corporations. (f) SoftPac represents that the following are all of the State of Minnesota and "local government agency" grants (other than the subsidy hereunder) to the Project: Grantor Value ($) Grantor Value ($) (g) SoftPac represents that it is not in default on the date hereof on any subsidy agreement entered into by SoftPac under the Subsidy Law. (h) For its "Job Goals" under this Section 3.5, SoftPac covenants that it will provide at the Project 60 full-time equivalent permanent employee positions within two years of the Benefit Date, with these jobs having wage levels of at least $10.00 per hour, exclusive of benefits. ~9s072.2 10 (i) SoftPac shall complete and file with the City from time to time the report in the form of the attached Exhibit D. The Subsidy Law provides that if SoftPac does not make such reports, when due, the City must mail SoftPac a warning within one week of the required filing date, and if, after 14 days after the postmark date of that warning, SoftPac continues to fail to report, then SoftPac is required to and shall pay the City a penalty of $100 for each subsequent day until the report is filed, up to a maximum of $1,000. SoftPac shall file these reports with the City, in care of its Director of Economic Development, (1) on March 1 of each year, beginning with the March 1 immediately following the Benefit Date, and (2) within 30 days after the "Compliance Date," hereby defined to be the date which is two years after the Benefit Date. Each March 1 report shall report on the prior calendar year, and each other report shall report on the period since the last reporting period. (j) This Section 3.5 is intended to be the "subsidy agreement" required by Section 116J.994, Subdivision 3, of the Subsidy Law. In the event that any provision of this Section 3.5 in inconsistent or in conflict with any provision of the Subsidy Law, and in the event that any provision of the Subsidy Law provides additional requirements, the provisions of the Subsidy Law shall apply and govern. In addition to all reporting obligations of the Company under this Section 3.5 and Exhibit D, SoftPac agrees to provide the City with any additional information which may be required in order for the City to comply with its reporting requirements, as they may exist or be amended from time to time, under the Subsidy Law. (k) Nothing in this Section 3.5 is intended to limit or otherwise amend the other terms of this Agreement. To the extent that provisions in this Section 3.5 are more extensive or restrictive than any related term elsewhere in this Agreement, the provisions hereof shall govern. The above commitment of SoftPac to lease the Project for at least five years from the Benefit Date is a requirement of the Subsidy Law (subject to procedures therein allowing relaxation or waiver of said requirement) and shall apply and govern. By the same token, however, said five year commitment shall not limit a longer commitment made elsewhere in this Agreement, e.g., see Section 2.2(i) hereof. 1198072.2 11 ARTICLE IV Events of Default Section 4.1. Events of Default Defined. Events of Default under this Agreement: The following are (a) There shall have occurred a failure in the observance, performance or continued existence, as the case may be, of any covenant, condition, obligation or agreement to be observed or performed or to exist under this Agreement or any other agreement respecting the Improvements, including without limitation the failure to exist of any condition or requirement herein relating to SoftPac's occupancy, use and creation of specified employment levels of or respecting the Project. (b) There shall have occurred a failure in payment, when due, of any property tax, special assessment, or other governmental imposition respecting the Development Property, subject to statutory or other legal rights to contest or defer payment of the same. (c) There shall have been filed a petition in bankruptcy by or against the Company or SoftPac under the United States Bankruptcy Code; or there shall occur a failure by the Company or SoftPac within 90 days to have discharged any execution, garnishment or attachment of such consequence as would impair the ability of the Company or SoftPac to carry on its operations respecting the Improvements; or there shall occur an assignment by the Company or SoftPac for the benefit of creditors or the entry by the Company or SoftPac into an agreement of composition with creditors. (d) The SoftPac Lease shall have expired or been terminated and SoftPac shall have ceased its occupancy or operation of the Project. (e) A default under Section 3.5 shall have occurred. An Event of Default shall also include any occurrence which would with the passage of time or giving of notice become an Event of Default as defined hereinabove. Section 4.2. Remedies on Default. Whenever any Event of Default occurs, in addition to all other remedies specified herein (e.g., repayment of the assistance pursuant to Section 3.5) or available to the City at law or in equity, the City (1) may without notice suspend its performance under this Agreement until it receives assurances from the Company, deemed adequate by the City, that the Company has cured its default and will continue its performance under this Agreement, and (2) may, after provision of ~9so72.2 12 60 days written notice to the Company and SoftPac of the Event of Default, but only if the Event of Default has not been cured within said 60 days, or if the Event of Default cannot be cured within 60 days, the Company does not provide assurances to the City reasonably satisfactory to the City that the Event of Default will be cured as soon as reasonably possible, terminate this Agreement, without further obligation whatsoever hereunder to the Company. Upon the occurrence of any Event of Default, the Company shall reimburse the City for all expenses and liabilities resulting therefrom, including without limitation all reasonable attorney or consultant fees. Section 4.3. No Remedy Exclusive. No remedy herein conferred upon or reserved to the either Party is intended to be exclusive of any other available remedy or remedies, but each and every such remedy shall be cumulative and shall be in addition to every other remedy given under this Agreement or now or hereafter existing at law or in equity. No delay or omission to exercise any right or power accruing upon any default shall impair any such right or power or shall be construed to be a waiver thereof, but any such right and power may be exercised from time to time and as often as may be deemed expedient. Section 4.4. No Additional Waiver Implied by One Waiver. If any agreement contained in this Agreement should be breached by either Party and thereafter waived by the other Party, such waiver shall be limited to the particular breach so waived and shall not be deemed to waive any other concurrent, previous or subsequent breach hereunder. ~98072.2 13 ARTICLE V Additional Provisions Section 5.1. Titles of Articles and Sections. Any titles of the several parts, Articles and Sections of this Agreement are inserted for convenience of reference only and shall be disregarded in construing or interpreting any of the provisions hereof. Section 5.2. Notices and Demands. Except as otherwise expressly provided in this Agreement, a notice, demand or other communication under the Agreement by either Party to the other shall be sufficiently given or delivered if sent by first class mail, postage prepaid, or delivered personally or telecopied; and, (a) in the case of the Company, to Opus Northwest, L.L.C., 10350 Bren Road West, Minnetonka, Minnesota 55343, with a copy to SoftPac, Inc., Attention: (and any notices directed to SoftPac shall also be copied to the Company); and (b) in.the case of the City, to the City of Elk River, Minnesota, at the Elk River City Hall, 13065 Orono Parkway, P.O. Box 490, Elk River, Minnesota 55330-0490, Attention: Director of Economic Development. or at such other address with respect to either such Party as that Party may, from time to time, designate in writing and forward to the other as provided in this Section. Section 5.3. Counterparts. This Agreement may be executed in any number of counterparts, each of which shall constitute an original hereof. Section 5.4. Law Governing. The Parties agree that this Agreement shall be governed and construed in accordance with the laws of the State of Minnesota. 1198072.2 14 ARTICLE VI Termination of Agreement; Expiration; Limitation on Assignments. Section 6.1. The City's Option to Terminate. As provided and under the conditions specified in Section 4.2, the City may terminate this Agreement if an Event of Default shall have occurred hereunder and be continuing. Nothing in that or in this Section shall affect the City's right, should the City not so elect to terminate this Agreement and as recourse against the Company, to insist on performance hereunder by the Company (or SoftPac, as the case may be). Section 6.2. end of the Term. Expiration. This Agreement shall expire at the Section 6.3. Effect of Termination or Expiration. No termination or expiration of this Agreement pursuant to the terms hereof shall terminate (i) any rights or remedies of the City arising hereunder due to an Event of Default occurring prior to such termination or expiration or (ii) the provisions of Section 3.3 hereof. Section 6.4. by SoftPac. No Third Party Beneficiaries; Execution Hereof (a) There shall, as against the City, be no third party beneficiaries to this Agreement. More specifically, the City enters into this Agreement, and intends that the consummation of the City obligations contemplated hereby shall be, for the sole and exclusive benefit of the Company, and notwithstanding the fact that any other "persons" may ultimately participate in or have an interest in the Improvements, the City does not intend that any party other than the Company shall have, as alleged third party beneficiary or otherwise, any rights or interests hereunder as against the City, and no such other party shall have standing to complain of the City's exercise of, or alleged failure to exercise, its rights and obligations, or of the City's performance or alleged lack thereof, under this Agreement. The provisions of this Section 6.4(a) do not apply to SoftPac. (b) The Company, SoftPac and the City acknowledge and agree that SoftPac is a beneficiary of the assistance under this Agreement and that there may arise hereunder monetary obligations payable to the City ("Monetary Obligations"), including without limitation such obligations as may arise pursuant to the indemnification provisions of Section 3.3, the repayment provisions of Section 3.5 or the occurrence of an Event of Default and/or the City's exercise of any remedies specified hereunder or otherwise available to the City at law or in equity. SoftPac hereby agrees to pay any and all such Monetary Obligations to the City, upon written demand, and the City agrees that it will look only to SoftPac (and not to the Company, even if SoftPac fails to pay the same) for payment and satisfaction of all such Monetary Obligations. SoftPac represents to the City that is has reviewed, understands and consents to the terms of this Agreement (including without limitation the issuance of the TIF Bond to SoftPac) and that it is duly authorized to undertake and discharge its obligations under this section 6.4(b). Without limitation, SoftPac specifically confirms the representations and endorses the covenants of Sections 2.2(h) and (i). The Company, SoftPac and the City agree that SoftPac's execution and delivery of this Agreement is solely for the purpose of binding itself to the provisions of this Section 6.4 (b) . Section 6.5. Limitations on Transfer of Property and Assignment of Agreement. The Company covenants and agrees that prior to the expiration or earlier termination of this Agreement, except only by way of security for the purpose of obtaining financing necessary to enable the Company to acquire the Development Property and complete the Improvements (and any future expansion of the Company's operations on the Development Property), the Company (except as so authorized) has not made or created and will not make or create or suffer to be made or created any total or partial sale, assignment, conveyance, or lease (excepting the SoftPac Lease), or any trust or power, or any transfer in any other mode or form, of or with respect to this Agreement or the Project or any part thereof or any interest therein, or any contract or agreement to do any of the same, without the prior written approval of the City (which approval the City may withhold in its sole discretion). The City shall be entitled to require, except as otherwise provided in the Agreement, as conditions to any such approval that: (a) Any proposed transferee shall have the qualifications and financial responsibility, in the reasonable judgment of the City, necessary and adequate to fulfill the obligations undertaken in this Agreement by the Company. (b) Any proposed transferee, by instrument in writing reasonably satisfactory to the City, shall, for itself and its successors and assigns, and expressly for the benefit of the City, have expressly assumed all of the obligations of the Company under this Agreement and agreed to be subject to all ~8072.2 16 the conditions and restrictions to which the Company and the Project are subject (including the SoftPac Lease) unless the Company agrees to continue to fulfill those obligations, in which case the preceding provisions of this Section 6.5(b) shall not apply. The City may also require the transferor Company to execute such agreements to the extent deemed reasonably necessary by the City in order to clarify the respective rights and obligations, or absence thereof, of the transferor, the transferee and/or the City, as the case may be. (c) There shall be submitted to the City for prior review all instruments and other legal documents proposed to be executed in effectin~ the transfer of any such interest in this A~reement or the Project. A sale of the Project and/or assignment of this A~reement to SoftPac shall not be prohibited by this Section 6.5 and shall not be subject to discretionary approval by the City, provided the conditions in (b) and (c) above are observed and satisfied. A sale of the Project and/or assignment of this A~reement to a party other than SoftPac shall also not be prohibited by this Section 6.5 and shall not be subject to discretionary approval by the City, provided the conditions in (b) and (c) above are observed and satisfied, and provided further that the Certificate of Completion shall have been issued hereunder. IN WITNESS WHEREOF, the City and the Company have caused this A~reement to be executed by their duly authorized representatives. CITY OF ELK RIVER, MINNESOTA By Its Mayor By Its City Administrator (SEAL) [Execution of this Development Assistance Northwest, L.L.C., and SoftPac Industries, following pa~e.] Agreement by Opus Inc. appears on the 1198072.2 17 OPUS NORTHWEST, L.L.C., a Delaware Limited Liability Company By Its By Its SOFTPAC, INC., a Minnesota Corporat ion By Its By Its [Execution Page to Development Assistance Agreement between the City of Elk River, Minnesota, and the above-named parties.] 1198072.2 18 EXHIBIT A LEGAL DESCRIPTION OF DEVELOPMENT PROPERTY The Development Property consists of the following property located in the City of Elk River, Sherburne County, Minnesota: 1198072.2 A-1 CITY OF ELK RIVER, COUNTRY CROSSING BUSINESS CENTER THIRD ADD/T/ON PLAT:AREA /- -~ -- T- -- -'~ ___~.£ ! \ . \ ' ~1~,'x, " __ ~~,,.~ ~ _ .... _L _ -- ,.,. j If ..... ~"'~":'""~':" c'.%~.. ,,,, ,:. '"':'~"~','; · ""~/3,'.., __ __ '5 BLOCK 1 PU^~ ^RE,A: 608,599 $.F,, ,Dr 1197 ,Ac'/- fl ~. -::(X ..... 1': '- .,? \ ~ '~''~ --'~ -'~ -- --" ~"~':-'" ~"-"' - - - .:: :;'" ' ' -~, /, ,, ",, I ~,i' I ..... SHERBURNE COUNTY, MN. LEGAL DESCRIPTION Country Crossing Business Center Third Addition, Lot 1, Block 1 No. R-1 EXHIBIT B FORM OF TIF BOND UNITED STATES OF AMERICA STATE OF MINNESOTA COUNTY OF SHERBURNE CITY OF ELK RIVER, MINNESOTA TAXABLE TAX INCREMENT REVENUE BOND OF 2000 (SOFTPAC PROJECT) [1] The City of Elk River, Minnesota (the "City"), hereby acknowledges itself to be indebted and, for value received, hereby promises to pay to SoftPac, Inc., a Minnesota corporation, or its registered assigns (the "Registered Owner"), but only in the manner, at the times, from the sources of revenue, and to the extent hereinafter provided, the Principal Amount of this Bond (as defined in paragraph [2] hereof) and to pay interest on the unpaid portions of the Principal Amount of this Bond at the rate of interest of eight and no hundredths percent (8.00%) per annum. Interest shall accrue from the date of the Certificate of Completion (as defined in the Development Agreement hereinafter described) and shall be computed on the basis of a 360-day year consisting of 12 30-day months. This Bond is the "TIF Bond" described and defined in that certain Development Assistance Agreement, dated as of August 28, 2000 (as the same may be amended from time to time, the "Development Agreement"), between the City and Opus Northwest, L.L.C., a Delaware limited liability company, as the initial Company under the Development Agreement, and also subscribed in part by SoftPac Industries, Inc., a Delaware limited liability company. Each capitalized term which is used but not otherwise defined in this Bond shall have the meaning given to that term in the Development Agreement. [2] The Principal Amount of this Bond shall be the lesser of $700,000 and the sum of the amounts certified to the City by the Company and acceptable to the City pursuant to Section 3.2(b) of the Development Agreement. [3] Subject to the terms hereof, amounts due on this Bond shall be payable on each July 15 and December 15 (or at least 15 days after receipt from Sherburne County of the respective settlements of Tax Increments), commencing July 15, 2002, and continuing through December 15 of the year which is eight years ~8072.2 B-1 after the year in which the TIF District first generates Tax Increments (the "Payment Dates") . [4] On each Payment Date (or, if not a business day of the city, the first business day thereafter) the City shall pay by check or draft mailed to the person that was the Regist@red Owner of this Bond at the close of the last business day of the City preceding such Payment Date an amount equal to the lesser of (1) the Available Tax Increments received by the City since the preceding said Payment Date (or, in the case of the first Payment Date, since the date of this Bond) and (2) the sum of (i) the accrued and unpaid interest hereon and (ii) the aggregate amount of the unpaid principal of this Bond. All payments made by the City under this Bond shall be applied first to pay accrued and unpaid interest on this Bond and second toward payment of principal hereof. [5] This Bond shall terminate and be of no further force and effect on any date upon which the City shall have terminated the Development Agreement, on the last Payment Date following payment thereon of the Available Tax Increments then due, or on the date that all amounts payable hereunder shall have been paid in full, whichever occurs earliest. [6] The City makes no representation or covenant, express or implied, that the revenues described herein will be sufficient to pay, in whole or in part, the amounts which are or may otherwise become due and payable hereunder. Any amounts which have not become due and payable on this Bond on or before the final Payment Date shall no longer be a debt or obligation of the City whatsoever. [7] The City's payment obligations hereunder shall be further conditioned on the Company's compliance with the terms and conditions of the Development Agreement and on the fact that there shall not at the time have occurred and be continuing an Event of Default under the Development Agreement, and, further, if pursuant to the occurrence of an Event of Default under the Development Agreement the City elects to terminate the Development Agreement, the City shall have no further debt or obligation under this Bond whatsoever. Reference is hereby made to the provisions of the Development Agreement for a complete statement of the obligations of the Company and of the rights of the City thereunder, and said provisions are hereby incorporated by reference into this Bond to the same extent as though set out in full herein. The execution and delivery of this Bond by the City, and the acceptance thereof by the Company, as the initial Registered Owner hereof, shall conclusively establish this Bond as the "TIF Bond" (and shall conclusively constitute discharge of the City's obligation to issue and deliver the same) under the Development Agreement. ~98072.2 B-2 [8] This Bond is not any obligation of any kind whatsoever of any public body, except that this Bond is a special and limited revenue obligation but not a general or moral obligation of the City and is payable by the City only from the sources and subject to the qualifications and limitations stated or referenced herein. Neither the full faith and credit nor the taxing powers of the City are pledged to or available for the payment of this Bond, and no property or other asset of the City, save and except the above referenced Available Tax Increments, is or shall constitute a source of payment of the City's obligations hereunder. [9] This Bond is issued by the City in aid of financing a project pursuant to and in full conformity with the Constitution and laws of the State of Minnesota, including Minnesota Statutes, Sections 469.174 through 469.179, and including specifically but without limitation Section 469.178, Subdivision 4, thereof. [10] This Bond may be assigned by the Registered Owner but upon such assignment the assignor shall promptly notify the City thereof in writing, and the assignee shall surrender this Bond to the City either in exchange for a new fully registered Bond or for transfer of this Bond on the registration records for the Bond maintained by the City. The Registered Owner, by accepting registration of this Bond, acknowledges that the City has not qualified or registered this Bond under any state or federal registration, securities or similar laws and the Registered Owner covenants to comply with all securities, anti-fraud, registration, and other state and federal laws and limitations applicable in connection with any such proposed transfer or sale of this Bond. Each such assignee shall take this Bond subject to the foregoing conditions and subject to all provisions stated or referenced herein. As a precondition to any such assignment or transfer of this Bond, the City shall have been provided with an opinion of counsel (from a firm reasonably acceptable to the City) or a certificate from the transferor, in a form and of a content satisfactory to the City (including, in the City's discretion, an SEC Regulation Deed certification), that such transfer is exempt from registration and prospectus delivery requirements of federal and state securities and similar laws and regulations. [11] This Bond has been issued as a taxable and not as a tax- exempt obligation, and the City makes no representation, express or implied, that the interest on this Bond is or may be excludable from gross or taxable net income of the Registered Owner for income tax purposes. ~98072.2 B-3 [12] IN WITNESS WHEREOF, the City of Elk River, Minnesota, has caused this Bond to be executed by the manual signatures of its Mayor and City Administrator, has caused the official seal of the City to be omitted herefrom, as permitted by law, and has caused this Bond to be issued and dated as of , 2000. Mayor City Administrator ~8072.2 B-4 CERTIFICATION OF REGISTRATION It is hereby certified that the foregoing Bond was as of the latest date listed below registered in the name of the last Registered Owner noted below, and that, at the request of said Registered Owner of this Bond, the undersigned has as of said applicable date registered this Bond as to principal and interest on the Bond in the name of such Registered Owner, as indicated in the registration blank below, on the books kept by the undersigned for such purposes. NAME OF REGISTERED OWNER DATE OF REGISTRATION SIGNATURE OF CITY FINANCE DIRECTOR SoftPac, Inc. , 2000 x~8072.2 B-5 EXHIBIT C CERTIFICATE OF COMPLETION WHEREAS, the City of Elk River, Minnesota (the "City"), and Opus Northwest, L.L.C., a Delaware limited liability company (the "Company"), have executed a Development Assistance Agreement, dated as of August 28, 2000 (the "Development Agreement"), with respect to the completion by the Company of certain improvements (the "Improvements,,), more specifically, an approximately 73,000 square foot manufacturing facility on certain land (the "Development Property") described in the Development Agreement; and WHEREAS, the Company has performed its obligation under the Development Agreement to substantially complete the Improvements in a manner deemed sufficient by the City to permit the execution of this certificate pursuant to Section 3.4 of the Development Agreement: NOW, THEREFORE, this is to certify that the Improvements have been completed on the Development Property in substantial conformance with the applicable terms of the Development Agreement. CITY OF ELK RIVER, MINNESOTA By Its Dated: , 200__. 1198072.2 C-1 EXHIBIT D BUSINESS SUBSIDY REPORT Report by SoftPac, as Recipient of Business Subsidy This report is required by Section 3.5 of that certain Development Assistance Agreement, dated as of August 28, 2000 (the "Agreement"), among the City of Elk River, Minnesota (the "City"), Opus Northwest, L.L.C., and SoftPac, Inc. ("SoftPac"), and as required by Minnesota Statutes, Section 116J.994, Subdivision 7, as amended. Capitalized terms which are used but not otherwise defined in this report have the meanings given to those terms under the Agreement. The City has under the Agreement granted a certain business subsidy to SoftPac. Under the Agreement, SoftPac is required to file reports with the City's Director of Economic Development (1) on March 1 of each year, beginning with the March 1 immediately following the date of the Certificate of Completion, being referred to herein as the Benefit Date, and (2) within 30 days after the Compliance Date, namely, the date which is two years after the Benefit Date. Each March 1 report is required to report on the prior calendar year, and each other report shall report on the period since the last reporting period. SoftPac's Jobs Goals under Section 3.5 of the Agreement are to create at the Project 60 permanent full-time equivalent jobs within two years from the Benefit Date. These jobs are required to have a wage of at least $10.00 per hour, exclusive of benefits. SoftPac hereby certifies to the City the following: (1) As provided in the Agreement, the fair market value of the subsidy is estimated to be $700,000, the type of subsidy is tax increment financing from an "economic development" tax increment district in the form of deferred reimbursement, with interest, of certain land acquisition costs, and the public purposes of the subsidy are to further development of the City's industrial and tax base and to create jobs. (2) The hourly wage of each permanent full-time equivalent job which has been created by SoftPac at the Project since the Benefit Date, with separate bands of wages, are as follows: ~98072.2 D-1 Number of Jobs Wage Levels per Hour (3) The cost of health insurance provided by SoftPac for the above-referenced jobs, separated by bands of wages, is as follows: Wa§e Level per Hour Cost of Health Insurance (4) If SoftPac has not already met the Job Goals, it reasonably expects that it will meet those goals on or before , 200 , and is taking the following steps to meet the Job Goals: (5) SoftPac's lease of the Project involved the relocation by SoftPac of its facilities located at 9480 Hemlock Lane North, Maple Grove, Minnesota 55369, due to lack of available and affordable production space at that previous site. (6) SoftPac has no parent corporations. (7) Other than the subsidy provided by the City under the Agreement, there are no other State of Minnesota or "local government agency" grants of subsidy to SoftPac for the Project, except for: Grantor Value ($) Grantor Value ($) (8) SoftPac hereby agrees to provide upon request such other information as the Commissioner of the Department of Trade and Economic Development of the State of Minnesota may ~98072.2 D-2 request the City or SoftPac to provide or as may be required by the Subsidy Law. (9) SoftPac represents that it has continuously leased the Project since its completion, that SoftPac has continuously used and occupied the Project, and SoftPac expects said lease and occupancy to continue for the foreseeable future. (10) SoftPac is not in default on the date hereof of its obligations under any subsidy agreement under the Subsidy Law. SOFTPAC, INC. By Its This report is to be filed with: City Elk River Elk River City Hall 13065 Orono Parkway P.O. Box 490 Elk River, Minnesota 55330-0490 Attn: Director of Economic Development ~8072.2 D-3 CITY OF ELK RIVER' COUNTY OF SHERBURNE STATE OF MINNESOTA RESOLUTION NO. A RESOLUTION APPROVING AND AUTHORIZING THE EXECUTION OF A DEVELOPMENT ASSISTANCE AGREEMENT RESPECTING SOFTPAC PROJECT BE IT RESOLVED by the City Council (the "Council") of the City of Elk River, Minnesota (the "City"), as follows: 1. Recitals. (a) The City has the powers provided in Minnesota Statutes, Sections 469.124 through 469.134 (the "Act"). (b) Pursuant to and in furtherance of the objectives of the Act, the City has undertaken a program to promote redevelopment of certain land within the City, and in this connection is engaged in carrying out its development project known as its Development District No. 1 (the "Development District") in an area (the "Project Area") located in the City. (c) There has been approved by the Council, pursuant to the Act, a Development Program for the Development District, as amended (the "Development Program"). (d) In order to achieve the objectives of the Development Program and particularly to make the land in the Project Area available for redevelopment by private enterprise in conformance with the Development Program, the City has determined to provide substantial aid and assistance in connection with the Development Program through the financing of certain of the public costs of development in the Project Area. (e) Opus Northwest, L.L.C. (the "Company"), has presented the City with a proposal for the construction within the Project Area of certain improvements, and a certain Development Assistance Agreement (the "Agreement") between the City and the Company, stating the terms and conditions of such development and the City's and the Company's responsibilities respecting the assistance thereof, has been presented to the Council for its consideration. 2. The Council hereby approves the Agreement substantially in the form presented to the Council and hereby authorizes the Mayor and City Clerk, in their discretion and at such time, if any, as 1198072. I they may deem appropriate, to execute the'same on behalf of the City, with such additions and modifications as those officers may deem desirable or necessary, as evidenced by their execution thereof. 3. Upon execution and delivery of the Agreement, the officers and employees of the City are hereby authorized and directed to take or cause to be taken such actions as may be necessary on behalf of the City to implement the Agreement, including without limitation the issuance of the TIF Bond thereunder. 4. The Council hereby determines that the execution and performance of the Agreement will help realize the public purposes of the Act and are in furtherance of the Development Program. Adopted on , 2000, by the Elk River City Council. 1198072.1 2 STATE OF MINNESOTA ) ) COUNTY OF SHERBURNE ) SS. CiTY CLERK'S CERTIFICATE I, the undersigned, being the duly qualified and acting City Clerk of the City of Elk River, Minnesota, (the "City"), hereby certify that I have carefully compared the attached and foregoing resolution with the original on file in my office and further certify that the same is a full, true and complete copy thereof, relating to the authorization by the City Council of the City of the execution of a certain Development Assistance Agreement between the City, and Opus Northwest, L.L.C., and SoftPac, Inc. I further certify that said resolution was duly adopted by said Council at a duly called and regularly held regular or special meeting thereof. Witness my hand officially as such City Clerk and the official seal of the City this day of , 2000. City Clerk Elk River, Minnesota (SEAL) 1198072.1 3