01-29-2008 Work Session
WORK SESSION OF THE ISLE OF WIGHT COUNTY BOARD OF
SUPERVISORS HELD THE TWENTY-NINTH DAY OF JANUARY IN
THE YEAR TWO THOUSAND AND EIGHT
PRESENT: Stan D. Clark, Chairman
James B. Brown, Jr., Vice-Chairman
Phillip A. Bradshaw
Al Casteen
Thomas J. Wright, III
Also Attending: A. Paul Burton, Interim County Attorney
W. Douglas Caskey, County Administrator
Patrick J. Small, Assistant County Administrator
Carey Mills Storm, Clerk
Chairman Clark called the meeting to order at 1:30 p.m. for the
purpose of conducting a work session on a proposed Community
Development Authority associated with the Benn?s Grant development.
//
Supervisor Bradshaw delivered the invocation.
//
The Pledge of Allegiance was conducted.
//
Chairman Clark called for Approval of the Agenda.
Supervisor Brown moved that the agenda be approved with the
exception of Item (A), the application of Isle of Wight Materials Company,
Inc. and Item (B), the application of Benn?s Church Properties, which will
be tabled until February 5, 2008 at 4:00 p.m. The motion was adopted with
Supervisors Bradshaw, Brown, Casteen, Clark and Wright voting in favor of
the motion and no Supervisors voting against the motion.
Chairman Clark moved that at the conclusion of this meeting today,
the meeting will be continued until February 5, 2008 at 4:00 p.m. The
motion was adopted with Supervisors Bradshaw, Brown, Casteen, Clark and
Wright voting in favor of the motion and no Supervisors voting against the
motion.
//
Mark Williamson, Attorney with McGuire Woods, briefed the Board
on the background of the first Community Development Authority (CDA),
1
which was created in 1998. He advised that CDA?s are a political
subdivision of the Commonwealth governed by a five (5) member Board
that is appointed by the Board of Supervisors. He stated the County?s Board
is composed of W. Douglas Caskey, Liesl R. DeVary, Lee Winslow, Robert
C. Claud, Sr. and Donald T. Robertson, all of which would serve a two (2)
year term. He stated that once the process is followed for the creation of a
CDA, which includes a petition from the applicant and an ordinance, the
CDA, by statute, has certain powers to do certain things to assist with the
development of infrastructure for substantial real estate projects, such as the
ability to issue bonds at a tax-free interest rate. He advised that while the
CDA has the power to issue bonds, it does not have the power to levy and
collect the taxes that form the revenue stream to pay off the bonds. He
stated that will be the responsibility of the Board and staff. He stated
because the Board is considering a rezoning application in conjunction with
a CDA application, he has structured the CDA in such a way that should the
Board not approve the CDA application, it will be clear that the CDA does
not bind the County in any way with respect to the rezoning application. He
stated that the trend of CDA?s over the last five (5) years has been to place
residential, commercial and office uses together. He advised that proceeds
from issued bonds can be used to finance the infrastructure affiliated with a
project, to include roads, parking facilities, curb/gutters, stormwater
retention features and parks and landscaping, as well as finance abutting
improvements such as off-site road improvements which are adjacent or feed
into the CDA District.
Supervisor Casteen inquired if the applicant could utilize the CDA if
the Board approved the CDA application, but did not approve the rezoning
application.
Attorney Williamson advised that the statute states that after an
ordinance is adopted, the applicant has thirty (30) days to withdraw their
petition. He stated that he has been working under the assumption that if
the Board adopts a petition for the CDA, but does not adopt the rezoning
application, the applicant would withdraw the CDA petition within that
thirty (30) day time period. He stated if for whatever reason the applicant
did not withdrawn their CDA petition, then there would be a CDA with
nothing to do because there is not a project that needs substantial
infrastructure improvements. He reminded the Board that a CDA itself has
no authority to levy, collect and assess taxes and it does not have the ability
to do any sort of financing without the full consent and approval of the
Board. He advised that there are currently CDA?s in existence that have
never been used, but if the Board is uncomfortable about a CDA being in
existence that is not being used, it can take action to dissolve it.
Supervisor Brown inquired what, if any, specific requirements are
associated with a CDA Board.
2
Attorney Williamson responded that the CDA Board is required to fill
out specific forms.
Supervisor Bradshaw inquired if the only method for abolishing a
CDA is through action of the Board.
Attorney Williamson replied that a CDA can also be abolished by a
petitioner withdrawing their application within thirty (30) days following the
Board adopting the ordinance.
Supervisor Casteen inquired if all of the property under discussion was
rezoned in 2004.
Beverly H. Walkup, Director of Planning and Zoning, advised that the
property was designated as mixed-use development by the Comprehensive
Plan in 2004. She explained that the Comprehensive Plan assigns an
appropriate land use according to the County?s general guidelines for
development in the County and a rezoning is what puts the use of a property
in place.
Supervisor Brown requested clarification of ?abutting? roads.
Attorney Williamson advised that abutting roads are physically
contiguous with or connected to the CDA district. He stated if the County
has road improvements that are contiguous to the CDA district, or they feed
into the CDA district, they can be financed with CDA bonds. He stated if
the County has an intersection that is located a half a mile down the road
from the CDA district that is not physically improved from where those
improvements were made to the CDA district, then it would not be
physically abutting and could not be financed by CDA bonds.
Supervisor Brown inquired what if the development adversely affects
the road.
Attorney Williamson responded that if there is a road that is improved
in a contiguous fashion so that if you took a stretch of road and at the end of
the day you improved that stretch of road and it came to the CDA district, it
could be financed by the CDA bonds. He added that if there is a gap so that
it is not physically connected with the CDA district, then the abutting rule
would not be satisfied.
Supervisor Casteen stated if the County improved Route 10 at the
intersection with Route 258, it could conceivably improve Route 10 all the
way to Suffolk as long as every foot in between was done.
Supervisor Bradshaw stated his understanding of abutting is property
owners along that road, which can qualify for a special tax assessment.
3
Attorney Williamson stated that the special taxing district falls on
property within the CDA district.
Supervisor Bradshaw stated that his understanding of the Attorney
General?s opinion is that the property owners that adjoin Muddy Cross Road
can be taxed through the special tax assessment of the CDA and, if that
property owner owns 100 acres and another 100 acres and then 50 acres, all
of that falls in a special tax district.
Attorney Williamson stated under Supervisor Bradshaw?s example
that landowner would not be located in the CDA district.
Supervisor Bradshaw stated that it did not matter according to the
Attorney General, who distinguishes the Supreme Court?s decision in Taylor
vs. Board of Supervisors, Northumberland County, 243 Va. 9416 (1992).
He stated that the case had been upheld.
Attorney Williamson stated that the Board has a petition that contains
a defined CDA district and outlines the properties that are going to be put in
that district. He stated that the Board has the authority and controls the
process to create and define the CDA district. He stated that the Board
could place other property in the district, but it has not chosen to in this
case. He stated that this CDA district is limited to the 600 acres of this
project, less the Riverside piece.
Supervisor Bradshaw stated that according to State law, abutting is
property owners who could be located on Route 10 that would benefit from
the road improvements or those on Muddy Cross Drive or any other roads.
He stated roads do not have to be located in the CDA.
Attorney Williamson responded that the statute is clear that the Board
has the authority to define the property to be located in the CDA district and
the CDA district is the only property that can be taxed. He stated that he is
not aware of any law that can operate to expand the jurisdictional lines of
the CDA. He stated that the abutting rule applies to the type of
improvements that can be financed, not what other property can be brought
into the district.
Supervisor Brown inquired if the developer and the Board could
mutually agree to include a certain area because of the adverse affect on it
by the development.
Attorney Williamson responded that the Board currently has a petition
with a narrow legal description that defines the CDA district. He stated if
the Board wished to come back and amend the petition to include other
property, then that would be up to the Board. He stated that currently the
CDA petition defines the property that can be taxed, as well as the
improvements that can be financed with the CDA bonds and any
4
enlargement of that would require that someone come back to the Board and
get approval.
Chairman Clark inquired if Routes 10/258 would be considered
abutting to the extent that Routes 10/258 could be improved away from the
development toward Bartlett.
Attorney Williamson replied that Routes 10/258 would be abutting at
the ?T? in the intersection, but if the improvements continuously went away
from the ?T? then they would be considered parcels of the same project. He
stated that while the petition defines what the improvements are, it does not
say it will be developed to a certain point. He stated the second step is a
Memorandum of Understanding and if the Board saw improvements going
too far out that it was not comfortable with, then the Board would have the
right to say it is not willing to finance that. He stated in addition to the
abutting rule, there is also a rule that the improvements have to benefit the
district. He stated if improvements are made five (5) miles away, then there
is the question of whether or not they benefit the district.
Supervisor Bradshaw inquired if the project builds out in 10-15 years
and there is a 15% tax rate assessment on this property and none of the
current Board members are still on the Board, can those citizens petition the
Board to say that they should not be paying this special tax rate because
other people are benefiting from it.
Attorney Williamson responded that the CDA district is defined as
certain property and there is no one else that can be brought into the CDA
district without an affirmative action by the Board.
Supervisor Bradshaw commented that he believes that the CDA Board
has the authority to do it. He stated based on his understanding of State law,
the CDA Board has the authority to tax outside of that district because they
are abutting landowners and they are benefiting from the improvements.
Attorney Williamson replied that the CDA Board does not have that
authority. He stated that the abutting rule deals with the improvements that
can be financed outside the district.
Supervisor Bradshaw stated according to the Attorney General?s
opinion, these landowners can be taxed if the CDA desires them to be taxed.
Attorney Williamson responded that the Board of Supervisors sets the
tax rate, not the CDA Board. He stated that the Board of Supervisors has
the ability to set the assessment that is going to govern everything involved.
Supervisor Casteen inquired what tax rate would result from a $35
million CDA.
5
Attorney Williamson responded that a $35 million bond issue in hard
costs equates to an additional $.30 to $.40 per $100 of assessed value on the
residential property.
Jimmy Sanderson, Davenport & Company, advised that a CDA has
two (2) different statutory authorities. He stated that the first is the special
tax that can be asked for up to $.25 per $1,000, but no one has asked this
Board to levy the special tax, which is just a number up to $.25. He stated
secondly, the statute allows the CDA to request the Board levy a special
assessment. He pointed out that the figures offered above are preliminary
estimates and interest rates can change making the figures higher or lower
when the bond issuance actually takes place. He stated that the actual cost
of this project is $71 million, not $35 million, and the underwriting analysis
at a preliminary level reveals that while there is $71 million of
infrastructure, they did not believe that the residential property can absorb
that and would drive the tax rates up too high. He stated that 100% of the
infrastructure is not being finance and based on the preliminary numbers it
is more like half of the infrastructure cost.
Chairman Clark inquired how infrastructure is defined.
Attorney Williamson replied that infrastructure is defined as roads,
sewer and public facilities that benefit more than one. He stated that the
petition specifies the categories of infrastructure that are proposed to be
financed for this project.
Supervisor Bradshaw inquired if the County could recap its
administrative costs.
Attorney Williamson replied that there is a preference of the tax
revenues from the district that go to pay administrative expense. He stated
that the Memorandum of Understanding, which is a three (3) party
agreement between the applicant, the CDA and the jurisdiction, traditionally
states that the County?s administrative fees come off the top. He stated that
there are also two (2) types of administrative fees.
Supervisor Wright inquired what happens to the CDA bonds if a CDA
is created, homes are built and then there is a boom.
Attorney Williamson responded that first there is the assessment
against the property and the Memorandum of Understanding would state
that the County would invoke their statutory mechanism to enforce a tax lien
against that parcel. He stated ultimately the County could sell the property
and the proceeds would be remitted. He stated that the priority can be
determined by the Board wherein the County is paid before the CDA. He
stated if there is no money, then the bond holders would suffer the loss.
6
Supervisor Wright inquired if the CDA under consideration is the
largest known consisting of commercial and residential development.
Mr. Sanderson advised that a residential/commercial CDA had been
formed in New Kent County that had a bond issue of $86 million. He stated
that residential CDA?s have begun to decrease due to the real estate market
and that most of the CDA?s created in the last year had been commercial in
nature.
Supervisor Wright stated that 17% of the proposed development is
supposed to be workforce housing and the County has been asked to waive
hook-up and connection fees. He stated to turn around and place a $.40 to
$.50 per $100 tax on these homeowners causes him concern.
Attorney Williamson advised that the assessment has to be uniform
throughout the district and there is no legal option to exclude the workforce
housing.
Ms. Walkup advised that it would be up to the developer to make
those units affordable and it may be that there has to be more gap financing
provided in order to make the individuals who purchase these properties be
able to afford them. She stated affordability is when a person is not paying
more than 32% of their monthly gross income into a mortgage minus taxes,
insurance and homeowners? association. She stated that she did not believe
that the additional taxes associated with a CDA would affect the
affordability of the homes, but that she would do additional research to
ensure that.
Supervisor Casteen commented that there is also an option for each
parcel to opt out of the CDA at the time that the parcel is sold.
Attorney Williamson added that it is not uncommon in certain
circumstances for the buyer to absorb that cost, which could be prepaid at
any time. He stated that how the cost would be absorbed would be based on
market conditions.
Chairman Clark commented that it is the Board that sets the
geographical limits of the CDA and the Board could also create an island for
the affordable housing. He stated as it exists now, the affordable housing is
spread throughout the development, but that could be changed.
Attorney Williamson advised that the district could be reconfigured,
but that it would require a new petition and legal description.
Supervisor Bradshaw inquired who will be responsible for payment of
the bonds.
7
Attorney Williamson advised that it is the obligation of the CDA, but
it is limited to the revenues collected. He stated that the CDA will be a
separate legal entity from the County. He stated that the statute is clear that
the bonds do not represent any sort of credit obligation of a jurisdiction and
it is payable solely from the revenues that the CDA is able to generate. He
stated if these revenues are short, the only option available would be to go
against the property, not the County.
David Rose, Davenport and Company, stated that CDA monies will be
segregated and the County will not be able to use those monies to pay for
other things. He stated there will also be certain taxes that are already on
those properties and those other monies will be monies that will be
exclusively available to the County and not the CDA.
Supervisor Bradshaw stated that the County will be required to send in
an annual report to the State Auditor of Public Accounts, to include a
financial report. He asked if taxes collected by the CDA have to be included
in the County?s report.
Mr. Rose replied that he thought taxes collected by the CDA would
have to be included in the County?s financial report.
Supervisor Bradshaw stated, if so, administrative costs associated with
the Commissioner of Revenue, the Treasurer and the County would show an
increase on the County?s part.
Mr. Rose stated that he did not know how that would be reflected in
the County?s financial report. He stated there clearly will be an increase of
cost by the County and the County will need to be sure that it gets that like
amount back to address that cost.
Supervisor Bradshaw pointed out that the key measurement for
County spending is the report generated by the State Auditor of Public
Accounts annually. He stated that the CDA will increase the County?s
administrative costs, even though it is not a function of the County. He
stated that the County?s costs per 1,000 citizens will be higher than any
other locality that does not have a CDA. He stated that revenues are not an
issue with this because the emphasis is on how much money the County is
spending, which also gets reported in the local newspapers. He stated that
the bond market is also looking at those expenses, as well as the State
Auditor of Public Accounts? report.
Mr. Rose stated that the Commissioner of Revenue and Treasurer?s
offices will incur extra work and expenses, but the reason we are going
through all this is because if the CDA is approved and the bonds get sold,
they will be sold because there is a strong enough likelihood that there will
be sufficient revenue from the first or second year on that there will be more
than positive cash flow. He advised that rating agencies are looking at
8
growing revenue streams over and above the expenses that all localities
have. He advised that Wall Street is going to look at more of the big picture
seeing that there is a natural growth in overall revenues and that there is an
expenditure line and there is a sufficient cash flow that addresses those
growing expenditures. He stated that all the localities around the County are
entertaining the idea of CDA?s and the County will not be alone in saying
that the County has extra expenses by virtue of having a CDA.
Supervisor Bradshaw inquired if the County?s audit statement shows
the CDA separately.
Mr. Rose advised that the CDA would have a separate audit from the
County?s.
Supervisor Bradshaw stated if the County is the fiscal agent, then the
CDA monies are going to be incorporated into the County?s audit and
included in the State Auditor of Public Accounts? report. He stated that
while the County was not compared to any counties to its west and the
County?s cost on a per-thousand number of citizens is going to increase.
Mr. Rose stated that the County?s audit is going to show that the
reason why this is being done is because the County is going to have a net
revenue figure that will be substantial enough that the audit will demonstrate
that the County is going to be over and above and the pressure will be less
because we are going to be looking at sales taxes that are far in excess of not
only expenses, but in excess of those taxes that are going to be in the
district. He stated that you must look at the overall audit for the County,
which will unequivocally show that the County is better off three years later
by virtue of having this project. He offered to discuss Loudon County?s
CDA with its Treasurer and report back to the Board at its next meeting
relative to any impacts.
Supervisor Bradshaw stated that the State Auditor of Public Accounts
report reveals expenditures only for every locality in the State and how
localities are trending. He stated once a CDA is formed, the County?s trend
is going to increase and there will not be a footnote at the end of the report
advising that the County?s expenses are increasing because of a CDA.
Supervisor Bradshaw inquired if user fees could be collected.
Attorney Williamson replied that he did not see any authorization in
the statute to assess or collect user fees. He stated that currently Riverside
Hospital is excluded from the district and, depending upon certain
negotiations, it may or may not join the CDA. He advised that anything
conveyed to the County is automatically backed out of the CDA. He stated
the perceived policy benefits are that it allows for the financing of the
infrastructure in a comprehensive and upfront fashion instead of a project
that is developed in phases; the ability to extend a lower interest rate to the
9
developer by using a tax exempt bond; and, that by creating the CDA does
not mean that the Board has authorized the assessment.
Supervisor Wright inquired what affect the CDA will have on the
County?s bond rating.
Mr. Rose stated that this debt is the kind of debt that rating agencies
consider as overlapping debt. He stated in order to ensure that the County?s
credit rating is not negatively impacted, the County may wish to put on a
limitation for the amount of special tax indebtedness and that the Board will
not approve the CDA until certain criteria is met by the developer that is
contained in a Memorandum of Understanding. He recommended that when
he and other County officials travel to New York to discuss the overall credit
rating of the County, the CDA policy will be presented. He stated that the
Board needs to be aware that the Hampton Roads Transportation Authority
is considered as overlapping debt of all the participants and the rating
agencies want to ensure that the Board truly understands where the revenues
are, where the vulnerabilities are and where the pressures are on the citizens
and that you are careful to live within the County?s other policies so that it
does not allow these other things to overtake the County.
Supervisor Casteen questioned that if the infrastructure is built upfront
and the planned rate of sale is held up due to market conditions, will that be
a liability as the money has been spent and interest must be paid on that
money.
Mr. Rose stated that is a risk of the bondholders. He stated that the
Memorandum of Understanding can stipulate that the County will not allow
bonds to be issued until certain percentages or certain things are done to
satisfy the County that the reasonable likelihood of success is present.
Supervisor Bradshaw referred to the State Code Section 15.2-5114
which states that the CDA has the power to charge and collect user fees.
Attorney Williamson offered to memorialize in the Memorandum of
Understanding any concerns of Supervisor Bradshaw with respect to user
fees.
Supervisor Bradshaw expressed a concern that the CDA would not fall
under the Public Procurement Act. He inquired if the Industrial
Development Authority is exempt from this Act.
Interim County Attorney Burton replied that there are a number of
things that the Industrial Development Authority is exempt from under the
Public Procurement Act. He stated that he recalls there have been some
financings that the Authority has not followed under the Public Procurement
Act.
10
Attorney Williamson stated that the main contract that the CDA has is
with the developer because the CDA itself is not directly contracting with
general and subcontractors to build the infrastructure.
Supervisor Bradshaw inquired where the administrator would be
housed that would be hired by the County and where would the CDA Board
meet.
Attorney Williamson responded that the CDA Board could meet
wherever the government authority provides an available conference room.
Supervisor Brown requested that Mr. Rose, when he makes his visit,
obtain an approximate cost from Loudon County associated with its CDA.
Mr. Rose offered to send the information to Supervisor Brown via
email.
Supervisor Bradshaw inquired if the Board approves the CDA, would
it be setting a precedent for future developments.
Mr. Rose advised that CDA?s are formed for major projects and it is
rare that a CDA is created for infrastructure-related costs under
$10,000,000.
Supervisor Casteen inquired if the Board is granting an advantage to
the developer in utilizing the CDA because he does not have upfront costs.
Lou Haddad, Armada Hoffler, responded that the proposed project
requires an extraordinary amount of upfront investment, so much so that it
can not occur in the conventional method, even when the market is good,
because there is so much off-site work to be done upfront, i.e., a
$10,000,000 intersection; an Industrial Development Authority park below
cost; 50+ acres of recreational facilities; 17% affordable housing; traditional
neighborhood design where the garages have to be rear-loaded; canals; and,
serpentine walls. He stated what the CDA does is get the County all those
things that it wants and it also gets Armada Hoffler additional dollars
essentially for the same price, which comes at a lower interest rate and a
longer time to pay. He stated that where Armada Hoffler might be able to
afford $15 million worth of infrastructure upfront traditionally, it will now
be able to afford $35 million worth of infrastructure upfront by virtue of a
CDA.
Supervisor Wright inquired what would happen if the County did not
want the industrial development office park, but did want the recreational
area.
Mr. Haddad replied that the landowners would be happy about that as
they are having to sell it to Armada Hoffler and then Armada Hoffler will
11
give it to the County for less than the purchase price of the rest of the
acreage. He stated that being an office park developer, he would take a hard
look at attempting to build an office park there.
Supervisor Wright expressed concern about the area intended for an
office park because it has been mined and all the good material has been
sold. He inquired if the County will need to install pilings for any proposed
building.
Mr. Haddad replied that the cost Supervisor Wright is concerned about
can be recaptured. He stated the County has consultants that can evaluate
the cost and determine if it is still a good deal.
Supervisor Bradshaw inquired if Armada Hoffler is going to take
liability for any environmental issues at the site if the County accepts the
property.
Mr. Haddad replied that Armada Hoffler will not purchase the
property until it is satisfied. He stated that Armada Hoffler will have to
show its banks that an environmental study has been performed and the land
is clean.
Supervisor Wright commented that his concern is how much a
foundation is going to cost at that location over and above what it would
cost elsewhere.
Supervisor Casteen recalled that staff had reported at an earlier
Planning Commission meeting that borings done at the prospective office
park had revealed a question of whether or not even a one (1) story building
could be supported.
Patrick J. Small, Assistant County Administrator, reported that the
necessary studies have been completed and the Department of Economic
Development is satisfied that the soils can be constructed upon.
Chairman Clark moved that staff be directed to distribute to the Board
all soil and geological reports and staff comments that are available relative
to the site?s viability for construction at the Board?s next meeting, to include
Mr. Wright?s report to the Planning Commission. The motion was adopted
with Supervisors Bradshaw, Brown, Casteen, Clark and Wright voting in
favor of the motion and no Supervisors voting against the motion.
Supervisor Bradshaw commented that to him this is a special taxing
district that is being proposed and the Board is going against what it always
stood for which is that the entire County would be taxed the same
throughout and that the Board would not set up special taxing districts.
12
Chairman Clark moved that staff be directed to ask the Community
Development Authority legal counsel and economic advisor (Davenport) to
attend the Board?s work session on February 5, 2008 at 4:00 p.m. to discuss
CDA?s in more detail. If this discussion does not consume the entire
meeting, the Board may proceed with discussing the economic impact of the
Benn?s Grant proposal. The motion was adopted with Supervisors
Bradshaw, Brown, Casteen, Clark and Wright voting in favor of the motion
and no Supervisors voting against the motion.
Supervisor Bradshaw stated that the Board has tried to protect the
agricultural farmlands and rural character of the County. He stated that he
did not want to classify a major development as traditional for the County.
Chairman Clark added that the focus of the County?s Comprehensive
Plan is to ensure that the bulk of the County remains rural. He stated that
the Development Service District is the concept, by law, that the County
must have to ensure that the remainder of the County remains rural. He
stated that traditional is rural in the County, but the Development Service
District concept ensures that.
Supervisor Bradshaw advised that the report from Kristen Mazur,
County Engineer, regarding paving of Muddy Cross Road, is to be included
as a report at such time as other transportation matters and concerns relative
to the Benn?s Grant development are addressed.
Supervisor Bradshaw advised that consideration of the adoption of
Guidelines for Community Development Authorities is to be a part of the
Board?s continued meeting of February 5, 2008.
//
At 4:00 p.m., Chairman Clark moved that the Board continue its work
session until February 5, 2008 at 4:00 p.m. at which time the Board will
continue its discussion on CDA?s. The motion was adopted with
Supervisors Bradshaw, Brown, Casteen, Clark and Wright voting in favor of
the motion and no Supervisors voting against the motion.
__________________________
Stan D. Clark, Chairman
______________________
Carey Mills Storm, Clerk
13
umlll!13l{:) ')'[JBI:) 'a UB1S
7~r
'UO!lOW :::l411SU!B8B 8UnOA SJos!AJ:::ldn S ou pUB
UO!lOW :::l41 JO JOABJ U! 8UpOA llfapM pUB :>JJBI:) 'U:::l:::llSB:) 'UM0.18 'MBl{SpB18
SlOS!AJ:::ldnS l[l!M p:::lldOpB SBM uonow :::ll[l 's,VO:) uo uo!ssn~s!p Sl! :::lnu!luo~
IBM PJB08 :::ll[l :::lWH l{~!qM lB 'w'd 00:17 lB 800Z '~ AJBnlq:::li{ I!lun UO!SS:::lS
)'[lOM Sl! :::lnuHuo~ plB08 :::ll{llBl{l p:::lAOW }(lBI:) UBWJ!Bl{:) "w'd 00:17 lV
ij
'800Z '~ A1BnJq:::ldJo ~UH:::l:::lW p:::lnU!lUO~ s,pmog
:::lql JO l-md B :::lq 01 S! Sd!lpoqlnv lUdwdoI:::lA:::lO Al!unwwo:) 10J S:::lu!18P!nD
JO UOpdOPB :::lql JO UOHBJdp!SUO~ lB41 p:::lS!APB MBqSpB18 Jos!AJ:::ldn S
'p:::lSS:::llpp..B :::lJB 1U:::lwdopA:::lp lUB1D s, UU:::l8 :::l4l 01
:::lAHBpJ SUJ:::l~UO~ pUB Sl:::lllBW UOHBlJodSUBJl J:::l4l0 SB :::lWH 4~ns 1B llod:::lJ B SU
p:::lpnpu! :::lq 01 S! 'pBOlI SSOJ:) Appnw JO 8U!ABd 8U!pJB881 '1:::l:::lU!8U3 Aluno:)
'JnZBW U81Sp)l WOlJ lJOddl :::ll{l lBl{l p:::lS!APB MB4SpBJ8 JOS!AJ:::ldnS
'lBl{l S:::lJnSU:::l ld:::l~UO~
PP1S!0 :::l~!AJ:::lS lU:::lwdOpA:::lO :::ll{l lnq 'Aluno:) :::lql U! IBJnl S! IBUO!l!PBJl
lBl..{l p:::llB1S:::lH 'IBJnJ SU!BW:::lJ Aluno:) :::ll{l JO J:::lPU!BW:::lJ :::ll{llBl{l :::lJnSU:::l 01 :::lAUq
lsnm Aluno:) :::ll{l lBl{l 'MBl Aq 'ld:::l~uo~ :::ll{l S! PP1S!0 :::l~!AJ:::lS lU:::lwdo(dA:::lQ
:::ll{llBl{l p:::llB1S:::lH 'IBJnJ SU!BW:::ll Aluno:) :::ll{l JO }(lnq :::ll{11B4l :::llnSU:::l 01 S! UBld
:::lA!su:::ll{:::lJdwo:) s,Aluno:) :::l41 JO sn~oJ ;;l411B41 p:::lpPB )'[lBI:) UBW1!B4:)
'Atuno:) :::ll{l JOJ IBUOH!PBJl SB lU:::lwdOI:::lA:::lP JOfBW 13 t\):!SSBP OllUBM 10U P!P
;;ll..{ lBl{l p:::llB1S:::lH 'Atuno:) :::ll{l JO J:::lPBlBl{~ IBlnJ pUB SPUBIWJBJ IBJnlIn~!J~B
T