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6.5 EDSR 08-21-2017 Cit of 4„, Request for Action River To Item Number Economic Development Authority 6.5 Agenda Section Meeting Date Prepared by General Business August 21,2017 Amanda Othoudt, EDD Item Description Reviewed by Modification to the EDA Business Microloan Fund Cal Portner,City Administrator Policy Reviewed by Action Requested Approve,by motion, a modification to the EDA Business Microloan Policy Background/Discussion Staff has received feedback from applicants wishing to apply for the Industrial Incentive Loan through the EDA's Business Microloan Fund program. The purpose of the Industrial Incenrive Loan program is to encourage industrial and high technology business development that supports the tax base and brings quality jobs to the city. � The maximum amount available per applicant through this program is currently$100,000. However, staff has received feedback from potential applicants to increase the amount of this loan to $200,000 to help assist applicants with large equipment purchases. The current cash balance of the General Micro Loan Fund is $643,970 as of August 3,2017. Financial Impact None Attachments • EDA Business Microloan Fund Policy 11 / EIEI 11 [NATUJI?E city of Elk411%.„1, Powered by Nature Economic Development Business Microloan Fund Guidelines, Policy & Application Amended: May 2011 November 2013 July 2014 November 2014 December 2016 April 2017 City of Elk River Economic Development Division 13065 Orono Parkway Elk River,MN 55330 763.635.1040 11TiEIEI or Page 2 of 22 EDA&City Council Approved April 17,2017 ELK RIVER ECONOMIC DEVELOPMENT BUSINESS MICROLOAN FUND GUIDELINES, POLICY & APPLICATION POLICY PURPOSE The Economic Development Authority for the city of Elk River (EDA) recognizes the need to stimulate private sector investment into manufacturing and certain commercial facilities and equipment in order to create new jobs,boost productivity and retain existing jobs for local residents.Additionally, the need exists to encourage investment in the expansion and/or rehabilitation of commercial and retail buildings in order to maintain the economic viability of the city and in the Downtown District. Subsequently,the purpose of this microloan program is to provide low interest,long- term (i.e. greater than one year) loans as incentives for new industrial and commercial development within the city of Elk River and to encourage commercial and retail business owners in the Downtown District to rehabilitate their existing buildings. 2. ELIGIBLE BUSINESSES Any project located or proposed to be located within the city limits of Elk River as defined by this microloan program,may be eligible for a Microloan as further defined herein: • Unless otherwise stated,business must be a for-profit corporation, partnership,or sole proprietorship. • Business must be a small business as defined by the Small Business Administration (SBA). • Religious,political, and pornographic enterprises are not eligible. 3. MICROLOAN FUND TERMS & CONDITIONS Loan Structure All Economic Development Microloans shall be structured as direct loans unless otherwise approved by the EDA Finance Committee. If a participation loan is requested, an agreement will be signed by the borrower,primary lender and the EDA. The EDA may require additional agreements to be signed by the borrower (i.e. security agreement,personal guarantees,business subsidy agreement). Simultaneous Microloans The simultaneous use of different EDA microloan programs by any one borrower or for any one project is prohibited. Loan Repayment Jobs Incentive funds,including principal and interest received may not be used to support restaurant,retail, casinos, or sports facilities. IPOVERED � r Page 3 of 22 EDA&City Council Approved April 17,2017 � Call of Loan A loan shall become due and payable in full if a business relocates outside of the city of Elk River prior to the maturity date of the loan. Late Payment Charge A late payment charge of 8% of the installment amount will be enforced following a grace period of 10 calendar days. 4. REGULATION FOR NEW CONSTRUCTION AND IMPROVEMENTS All buildings which public funds will be used for construction or renovation are to be brought into conformance with city ordinances and state building codes. 5. LOAN SECURITY AND GUARANTEES Applicant must be able to secure the loan by providing the EDA with a minimum of a subordinate mortgage upon the building and/or assets or other approved collateral equal to the amount of the loan. Applicant must demonstrate the financial means to repay the loans,as determined by the EDA. Whenever possible,personal,corporate,and/or entity guarantees will be made part of any loan agreement. Key person life insurance may be required as determined by the EDA Finance Committee based on loan amount and company ownership partners. 6. TIMING OF PROJECT EXPENSES No project should commence until the EDA has approved the loan application. Any costs incurred prior to the approval of the loan application are not eligible expenditures. No building construction should commence until the required city permits are secured. The applicant will be responsible for all legal,recording,and other fees required for protection of a security interest in the loan,payable by a$2,000 processing fee,which is paid at the time of application. In addition to the processing fee,all legal and filing fees shall be paid by the borrower at loan closing. Closing of the Microloan should be simultaneous with the borrower's primary funding. The EDA should be given two weeks'notice before closing. 7. PROCEDURAL GUIDELINES FOR APPLICATION AND APPROVAL rlIERE1 11 Page 4 of 22 EDA&City Council Approved April 17,2017 NATURE 1. All applicants shall first contact a primary lending institution to determine if additional equity is needed, and if so,how much (if applicable). `-' 2. The a pp licant shall then meet with ci ty staff to obtain inf o rm atio n about the microloan program, discuss the project,and obtain application forms. 3. The applicant shall complete and submit an application form to the city, along with a $2,000 processing fee. The fee is used to cover processing expenses and any remaining funds will be returned to the applicant. The applicant must provide evidence of their ability to meet the 10% equity requirements or provide a letter of commitment for conventional financing from the primary lending institution. 4. The EDA is a governmental entity and as such must provide public access to public data it receives. Data deemed by Applicant to be nonpublic data under State law should be so designated or marked by Applicant. See Minn. Sat. Sections 13.59, Subd. 1,respectively. 5. The application will be reviewed by the city staff to determine if it conforms to all city policies and ordinances and to consider the following: a. The availability and applicability of other governmental grants and/or microloan programs. b. Whether the proposed project will result in conformance with building and zoning codes. c. Whether it is desirous and in the best interests of the public to provide funding for the project. 6. The EDA Finance Committee and EDA Commissioners will review each application in terms of its consistency with the goals of the city's Comprehensive Plan and Economic Development Strategic Plan and in relation to the project's overall impact on the community's economy. Downtown Revitalization Loan applications will also be reviewed by a Housing&Redevelopment Authority Commissioner in conjunction with the EDA Finance Committee. Energy Efficiency Improvement Loan applications will also be reviewed by an Energy City Commissioner in conjunction with the EDA Finance Committee. The EDA Finance Committee will evaluate the project application in terms of the following: a. Project Design-Evaluation of project design will include review of proposed activities, time lines and a capacity to implement the project. b. Financial Feasibility-Availability of funds,private involvement, financial packaging and cost effectiveness. • Appropriate ratio of private funds to Microloan funds. • Sufficient cash flow to cover proposed debt service as demonstrated P ® r E t E ® I r Page 5 of 22 EDA&City Council Approved April 17,2017 NATURE by financial statements and projections. • Letter of Commitment from applicant pledging to complete the project during proposed project duration,if the loan application is ^° j gp ro p ose p roj approved. • Letter of Commitment from other financing sources stating terms and conditions of their participation in the project if applicable. • Sufficient collateral. c. All other information as required in the application and/or additional information as may be requested by the Economic Development staff. d. Project compliance with all city codes and policies. e. Microloan Objectives - In addition to quality job and wage creation/retention requirements, the applicant must meet all Microloan Fund criteria and demonstrate how the proposed activities will meet at least one of the following objectives: • The project contributes to the fulfillment of the city's approved and adopted economic development and/or redevelopment plans. • The project prevents or eliminates slums and blight. • The project increases the local tax base. • The project brings a structure into compliance with an existing building code violation. 7. A written request for an extension shall be accompanied by a copy of current financial statements and a$500 upfront processing fee. The processing fee is used to cover processing expenses. The application for an extension beyond the original term should include a letter of denial from a conventional lender. 8. The EDA Finance Committee will recommend the approval, denial, or request a resubmission. A recommendation from the Finance Committee will be forwarded to the EDA for recommendation of approval, denial to the City Council for final action. 8. MICROLOAN POLICY REVIEW The above criteria will be reviewed on an annual basis to ensure that the policies reflected in this document are consistent with the economic development goals set forth by the city. 9. RIGHT OF REFUSAL The EDA may deny any application if it is found not consistent with the goals of the city's Comprehensive Plan and Economic Development Strategic Plan and in relation to the project's overall impact on the community's economy. f'TEIEI 1 1 Page 6 of 22 EDA&City Council Approved April 17,2017 NATURE 10. COMPLIANCE WITH MN BUSINESS SUBSIDY LAW All developers/businesses receiving financial assistance from the City of Elk River shall be subject to the provisions and requirements set forth by the City's Business Subsidy Policy as amended and Minnesota Statutes Sections 116J.993 to 1161995 (the "Minnesota Business Subsidy Law") if applicable. I I. Agreement to Pay Costs of Review It is the policy of the city of Elk River to require applicants to pay costs incurred by the city in reviewing and acting upon applications, so that these costs are not borne by the taxpayers of the city. These costs include all of the city's out-of-pocket costs for expenses,including the city's costs for review of the application by the city's Financial Consultant and City Attorney,or other consultants,recording fees, and necessary publication costs. The application processing fees cover anticipated costs; costs incurred above the application fee will be invoiced as they are incurred,and payment will be due within thirty (30) days. Any unused portion of the application fee will be returned to the applicant. If payment is not received as required by this agreement, the city may suspend the application review process and may deny the application for failure to comply with the requirements for processing the application. Payment for costs will be required whether the application is granted or denied. 12. Microloan Programs In order to meet the economic and community development objectives of the EDA, five distinct microloan programs exist within the Business Microloan Fund. Industrial Incentive Loan Purpose: The purpose of the Industrial Incentive Loan is to encourage industrial and high technology business development that supports the tax base and brings quality jobs to the city. Amount: Up to $2100,000 of secondary financing not to exceed 20% of the total project cost. Remaining Principal: Must have private-sector commitments for 50% of the project cost. Borrower must provide 10% or more of project financing. Rate: Fixed at 3% Term: Loans must mature within 5 years,but must be amortized over a longer period of time.The balloon payment must not be longer than the balloon payment of the participating bank if applicable. Loans may be amortized up to the following limits: 20 years on real estate uses; rP . IEIEP Ir Page 7 of 22 EDA&City Council Approved April 17,2017 NATURE 10 years on equipment uses. Extension: In the event that the Borrower is unable to payoff the loan or refinance the Microloan at the end of five years, the loan may be extended up to two additional years at 3%interest. Criteria: Borrower must be an industrial or high technology business and create or retain one new full-time job for each$20,000 loaned within 2 years. Said jobs must pay a minimum wage of$15.00 per hour excluding benefits required by law. Loans of$75,000 or more shall meet the city of Elk River Business Subsidy Policy for the creation of new jobs at a minimum wage of$15.00 per hour excluding benefits required by law, as well as a 5-year location requirement. In the case where multiple sources of public financing are requested (e.g. Microloan and Tax Increment Financing) job creation goals shall not be double-counted. Borrower must comply with the provisions of the city's Industrial and Business Park zoning ordinances as applicable. Permitted Fund Uses: a. Building construction b. Land acquisition -� c. Machinery d. Furniture, fixtures, and equipment (FF&E) e. Renovation and modernization of buildings f. Public infrastructure needed for economic development expansions g. Investment real estate with a minimum of 50% of the space pre-leased Ineligible Fund Uses: a. Expenditures for the construction and/or renovation of residential units b. Inventory c. Refinancing of existing debt d. Working capital Downtown Revitalization Financing Loan Purpose: The Downtown Revitalization Financing Loan is available to business and property owners in the Downtown Area primarily for the rehabilitation and restoration of older buildings, as well as new business development. Non-profit organizations may be considered. The Downtown Area shall be described as that area in the attached in Exhibit A. Amount: Up to $74,999 of secondary financing not to exceed 20% of the total rE . E . 1 Page 8 of 22 EDA&City Council Approved April 17,2017 NATURE project cost. Remaining �' Princi p le: Must have private-sector commitments for 50% of the project cost. Borrower must provide 10% or more of project cost. Rate: Fixed at 3%. Term: Financing with a balloon payment in up to 5-years. Loans may be amortized up to the following limits: 20 years on real estate uses; 10 years on equipment uses. Extension: In the event that the Borrower is unable to payoff the loan or refinance the Microloan at the end of five years, the loan may be extended up to two additional years at 3%interest. Criteria: At a minimum, 20% of Microloan dollars must be used for the improvement of the building facade,with exceptions to be considered when it appears the facade improvements are not necessary. Financing of leasehold improvements will be considered at a limit of$25,000. Permitted Fund Uses: a. Building construction b. Renovation and modernization of buildings \._. c. Furniture, fixtures, and equipment (FF&E) d. Exterior renovation of retail or commercial buildings e. Financing of leasehold improvements including facade improvements will be considered at a limit of$25,000 f. Expenditures for the construction and/or renovation of residential units Ineligible Fund Uses: a. Inventory b. Refinancing of existing debt c. Working capital Energy Efficiency Improvement Loan Purpose: The Energy Efficiency Improvements Loan is available to property owners of commercial or industrial buildings in Elk River to provide low interest loans to businesses to invest in energy efficiency and improve their profitability through reduced energy costs. In addition, the microloan program helps the city of Elk River use energy conservation as an economic development tool. Non-profit organizations may be considered. Amount: Applicants may apply for the cost of improvements up to $74,999 IPOILIED I r Page 9 of 22 EDA&City Council Approved April 17,2017 NATURE Equity: Must have a minimum of 10%equity provided by the borrower. Rate: Fixed at 3% Term: The maximum maturity date of the loan will be determined by the useful life of the improvement and the energy payback achieved as determined by ERMU. For projects that have a shorter length of payback (2-5) years as calculated according to energy savings,the loans will have an initial maturity of up to 5 years from the date of closing. Longer life improvements (6-15 years) may apply for a longer maturity of up to 10 years. Criteria: Microloan funds shall be spent on energy efficiency improvements outlined below or related building improvement costs Applicant must agree to energy audits conducted under the utility company's Conservation Improvement Program (CIP). If warranted, engineering studies then are performed on facilities with conservation opportunities under the utility company's CIP Program. Energy efficiency is defined as improvements that are rebatable by the Elk River Municipal Utilities (ERMU) o r th e utility p rovider for the property if not ERMU. Proposed energy efficiency improvements that do not qualify for the utility's prescriptive rebate program will be reviewed and approved by the utility company servicing the upgrade measures (e.g. Elk River Municipal Utilities, Connexus, CenterPoint) along with a letter indicating eligible utility rebates. Utility rebates as applicable will be assigned to the Elk River EDA and applied toward principal repayment of the loan. An Elk River Energy City Commission member will be asked to participate in the EDA Finance Committee review. The loans will be secured by personal and corporate guarantees, and if applicable a lien on equipment financed and subordinate mortgage on the property. Installation must be certified through a licensed contractor and electrician. New construction is eligible when participating with a utility company rebate program. Eligible costs shall include only incremental costs over industry design standards. Permitted Fund Uses: Page 10 of 22 EDA&City Council Approved April 17,2017 NATURE a. Energy efficiency measures installed in or on a building include: b. Facility systems optimization (commissioning/re-commissioning) c. Facility systems control improvements d. Process efficiency improvements (CenterPoint Energy) Y) e. lighting efficiency improvements f. Heating,ventilation and air conditioning system modifications g. Exterior envelope improvements h. Motor and pump efficiency improvements i. Ground-source heat pump systems used to heat or cool a facility j. Installation of equipment or devices that use renewable energy sources to generate electricity or heat or cool a building including solar electricity (photovoltaic),wind turbine or solar thermal. Ineligible Fund Uses: a. Inventory b. Refinancing of existing debt c. Working capital d. Expenditures for the construction and/or renovation of residential units Micro-Brewery Loan Purpose: The Micro-Brewery microloan is available to business and property owners located within the city of Elk River. Amount: Up to $74,999 of secondary financing not to exceed 20% of the Total project cost. �• Equity: Must have private-sector commitments for 50% of the project cost. Borrower must provide 10% or more of project financing. Rate: Fixed at 3%. Term: Financing with a balloon payment in up to 5-years. Loans may be amortized up to the following limits: 10 years on equipment uses Extension: In the event that the Borrower is unable to obtain conventional financing to replace the Microloan at the end of five years, the loan may be extended up to two additional years at a market rate of interest. Criteria: At a minimum, 50% of Microloan dollars must be used for the purchase of equipment. Loans must be supported by sufficient collateral,which will include personal guarantees. Page 11 of 22 EDA&City Council Approved April 17,2017 NATURE Permitted Fund Uses: e. Renovation and modernization of buildings f. Furniture, fixtures, and equipment (FF&E) g. Exterior renovation of retail or commercial buildings h. Financing of leasehold improvements including facade improvements will be considered at a limit of$25,000 Ineligible Fund Uses: a. Inventory b. Refinancing of existing debt c. Working capital f 'iiEIEI 11 Page 12 of 22 EDA&City Council Approved April 17,2017 Elk ..' Ver ELK RIVER ECONOMIC DEVELOPMENT MICROLOAN FUND APPLICATION I. CONTACT INFORMATION Legal Name of Business: Project Site Address: City / State / Zip Contact Person(s) Business Phone Fax Home Phone Email Check One: Proprietor Corporation Partnership Federal ID # State ID # 2. NATURE OF LOAN REQUEST Which Microloan Program are you applying for? Industrial Incenrive Loan Downtown Revitalization Financing Loan Energy Efficiency Improvement Loan Micro-Brewery Loan Amount Requested: $ Total Project Cost: $ Type of project: New construction for a start-up business New construction for an existing business On site expansion Equipment purchase Remodeling: (circle one)Commercial / Retail / Industrial Other Please give a brief summary of your business and its products or service: Page 13 of 22 ITIIEREI 11 I`�IATU�� Please give a brief summary of the project: Please describe how this loan will impact your project: 3. FINANCING Project Costs. Land $ � Site improvements $ Buildings (attach plans &costs) $ Equipment/Machinery/Fixtures (attach list and estimated costs) $ Remodeling $ Industrial Inventory/Working Capital $ Other (attach description) $ Total Costs $ Comments: Proposed Sources of Financing Page 14 of 22 ITSIEIEI 11 1`rIAfiU�E SOURCE NAME TERMS AMOUNT �— Bank Loan $ Bank Loan $ Other Private Funds $ Applicant Contribution $ Other $ Fed Grant/Loan $ State Grant/Loan $ EDA Microloan $ Tax Increment Financing $ Tax Abatement $ Total Financing $ Collateral Assignments Lien Description of Collateral Position To Bank 1 To Bank 2 To Private Sources To Other Sources To Federal Govt To State To EDA Microloan Page 15 of 22 F 1ll E 1 E 1 IT NATURE Value of Collateral Book Value Cost Existing Liens Land $ $ $ Buildings $ $ $ Machinery&Equip. $ $ $ Other $ $ $ Other $ $ $ 4. JOB & WAGE GOALS Present# of Employees, Total Payroll Jobs To Be Created* Please provide the following information on jobs you expect to create within 2-years. Average Are the Jobs Expected Number Hourly Annual Permanent or Hiring Job Title of Jobs Wage Salary Temporary? Date *If loan is for job retention only,please explain in Business Plan. Microloan Program Objectives. (Check all that apply) The project contributes to the fulfillment of the city's approved and adopted economic development and/or redevelopment plans. The project prevents or eliminates slums and blight. The project increases the local tax base. The project brings a structure into compliance with an existing building code violation. Page 16 of 22 ITTEIEI 1 / I`rIAT�E 5. PROJECT CONTACTS AttAttto Name Address Phone Accountant Name Address Phone Financing Sources (lenders,partners, etc...) Name Address Phone Name Address Phone Parent Company Name Address Phone Others Name Address Phone Name Address Phone Page 17of22 1 / ERE 1 11 NATURE 6. ATTACHMENTS CHECK LIST Please attach the following: A) Written Business Plan: 1. Description of Business 2. Ownership 3. Management 4. Date Established 5. Products/Services 6. Future Plans B) Financial Statements for Past Three Years and Year to Date 1. Profit&Loss Statements 2. Balance Sheets C) Financial Projections for up to Three Years D) A Project Proforma to include: 1. Projected revenues, 2. Operating expenses, 3. Net Operating Income,and 4. Annual Debt Service and Loan Payments. D) Resume of Owner/Management E) Personal Financial Statements of Proprietor,Partners, Guarantors 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 H) Processing Fee of$2,000 Page 18 of 22 I'rsiEIEa t 1 LNATUREI 7. AGREEMENT I / We certify that all information provided in this application is true and correct to the best �.. of my/our knowledge. I /We authorize the city of Elk River and the Finance Committee to check credit references and verify financial and other information. I /We agree to provide any additional information as may be requested by the city and the Finance Committee. The undersigned has received the city's policy regarding the payment of costs of review, understands that reimbursement to the city of costs incurred in reviewing the application will be required,agrees to reimburse the city as required in the policy and make payment when billed by the city, and agrees that the application may be denied for failure to reimburse the city for costs as provided in the policy. APPLICANT SIGNATURE BY DATE Page 19 of 22 VVOIEIEI 1 / INATUREI Exhibit A: Downtown Area .7 , ,II- � PARE i � � �,'� 4� _�,� �allk .''''' WILMI i I CENTER � �:� �.� 00;‘, son:IZ tIlik‘71;11:; 'e�K,,,f` N I :: ,� R Ali► OP Ne ti ti N -N �L. wa,, nnotFtaioot soca n ravtr eee�r ' ■` lk ST.s= =ii Eh ` r r t 7 � Of KIM nli llkilE '" i p - 0'04- '' *, ����® IJO/A 1'L EIBI E� of ELK PAM i, ' In INI AI x II�i4 L -iii PINE P mu .� 1 R © �u t imh.. k:`! 5 B Nrt;�K T . s� m ,,,,,..;.,N, 4th ST in( , k , U 5 A..rri /,' , 1� diil1? MII MII 111111 F. " y ; r �\nL, 11N RIM MI i 41 i , �-. � � �� � '��� 1111iile ADDITION ,�olitivr �,_�� .. our •• ,�� !®' MI l '■1., ' ' W." - PNER --,-- .: v - i Air ''''i; 1— -N44\AIIIIPMc-,Iti !1 nip '' , 1 i I -- 4:,-' \ 4%,\t,ik\1 AllilS° _- G s Z Q, 4 178TH lfc IP o 0 'ft. *∎ ` 177TH ■ _ Downtown Area River November 19,2013 1 Page 20 of 22 E P O V E R E I 1 1 NATURE MICROLOAN APPLICATION SCORING WORKSHEET � TO BE COMPLETED BY CITY STAFF 1.The project meets the criteria set forth in the appropriate the Microloan policy. a) Meets at least one of the microloan objectives in Section 7;6(e). c) Consistent with all city plans and ordinances. d) Meets the wage requirements as defined in the city's business subsidy policy. 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. 25+ 5 Number of existing/retained jobs 20+ 4 Total 15+ 3 10+ 2 Less than 10 1 4. Ratio of Public Investment to Job Creation: Points: $ Public Investment $8,000 or less 5 Number of new jobs created/retained $10,000 or less 4 $ of Public Investment per new job $12,000 or less 3 $15,000 or less 2 Over$15,000 1 5. Wage Level of jobs created/retained or relocated Points: Minimum hourly wage Over$21/ hour 5 of jobs created/retained: $18-21 / hour 4 $15 / hour 3 6. Project size: Points: The project will result in the construction 40,000+ 5 of square feet 30,000+ 4 20,000+ 3 10,000+ 2 10,000 or less 1 Page 21 of 22 ITTIEIEI�� 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/sf+ 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: Industrial or Business Park Project 5 Commercial/Retail Rehabilitation/Redevelopment 4 Downtown Revitalization or Microbrew 3 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. Point Adjustments Point Adjustments: The project contributes to the goals of Enemy City. 5 points • Product promotes sensible use of energy,OR • Project utilizes significant energy efficient design&/or materials in construction. Total Points: Overall p desirability:l ro' desirabili : High 50-35 points Moderate 34-29 points Low 28-20 points Not Eligible 19-0 points Page 22of22