leelanau county brownfield redevelopment authority (lcbra) · 2015-10-09 · stepped out of the...

The LCBRA will meet Tuesday, April 21, 2015 at 9:30 am at the Government Center.

DRAFT AGENDA PLEASE TURN OFF ALL CELL PHONES

CALL TO ORDER & PLEDGE OF ALLEGIANCE

ROLL CALL

CONSIDERATION OF AGENDA

CONFLICT OF INTEREST

CONSIDERATION OF March 17, 2015 Minutes pgs 2‐9

PUBLIC COMMENT

DIRECTOR COMMENTS pgs 10‐13

Consent Agenda Items of a routine nature to be voted on with one motion ‐ no discussion. Upon request, members may remove any item and place elsewhere on the agenda, with no vote of the commission. Members will vote on remaining items on the Consent Agenda, after the item removed has been placed elsewhere on the agenda. 1. Envirologic – General Consulting Monthly Update pgs 14‐152. Envirologic ‐ Brownfield Assessment Monthly Update pgs 16‐17

REPORTS 1. Executive Committee (Chair, Vice‐Chair & Secretary/Treasurer)

UNFINISHED BUSINESS 1. Update on Leland site (Janik)

NEW BUSINESS 1. B2015‐01 Traverse City Housing Commission, Elmwood Twn site – Work Order #17 pgs 18‐20 2. B2015‐02 Smith application – Vacant Car wash/oil change, Suttons Bay Twn. Site pgs 21‐48

FINANCIALS 1. Claims & Accounts ($5,740.50) pgs 49‐61

2. Post Audit, Budget Amendments, Transfers

CORRESPONDENCE/COMMUNICATION ITEMS 1. Copy of new Fee Schedule pgs 62‐63

PUBLIC COMMENT DIRECTOR COMMENTS MEMBER COMMENTS/ CHAIRPERSON COMMENTS ADJOURN

Leelanau County Brownfield Redevelopment Authority (LCBRA)County website: www.leelanau.cc

8527 E. Government Center Dr. Suite 108 Suttons Bay MI 49682

Phone: (231) 256‐9812 or Toll Free (866) 256‐9711, Ext. 6 Fax:(231)256‐0174

Leelanau County Brownfield

Redevelopment Authority (LCBRA)

Members Mark Walter, Chairman Kathy Egan, Vice-Chair

Karen Zemaitis, Treasurer Robert Bunek

Emerson Hilton Chet Janik

Carolyn (Peachy) Rentenbach

Director Trudy Galla

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A regular meeting of the Leelanau County Brownfield Redevelopment Authority was held on Tuesday, March 17, 2015 at the Leelanau County Government Center. Call to Order: Meeting was called to order at 9:30 am by Chairman Walter who led the Pledge of Allegiance. Members Present: M. Walter, R. Bunek, E. Hilton, C. Janik, C. Rentenbach, K. Zemaitis Director: T. Galla Public: J. Hawkins, P. Jackson, D. VanHaaren, Pam Vin Members Excused: K. Egan Consideration of Agenda Add M-22 Partners site/former Zephyr Oil to Unfinished Business. It was moved by Zemaitis, seconded by Janik to accept the agenda as modified. Motion Carried 6-0. Conflict of Interest - none Consideration of February 17, 2015 Minutes It was moved by Rentenbach, seconded by Bunek to accept the minutes as presented. Motion Carried 6-0. Public Comment - none Director Comments – Galla handed out the Criteria that LCBRA had previously approved for review of projects. New Business items need to be reviewed according to the criteria. Consent Agenda It was moved by Janik, seconded by Bunek to approve consent agenda. Motion Carried 6-0. Reports Executive Committee – Chairman Walter stated the Executive Committee has met regarding the Fee Schedule and it will be discussed later on the agenda. Unfinished Business Fee Schedule Galla made changes to the Fee Schedule as recommended last month, and then the Executive Committee reviewed it. There was a question on the dollar amount that the LCBRA wanted for the Part II application. Zemaitis agreed that $500 was the amount agreed to, and Janik also supported that. Hilton questioned the cost for amendments and wanted to make sure that we are covered and Zemaitis said that it was noted on page 2 of the document. VanHaaren noted that it is also listed under the bulleted items on the next page – for Brownfield Plans and Act 381 Work Plans (including amendments). Zemaitis pointed out that the LCBRA still has the right to waive the fees, if determined to be necessary. Hilton pointed out a typo: the word ‘grand’ should be ‘grant’.

Page 1 LCBRA DRAFT minutes March 17, 2015

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It was moved by Janik, seconded by Zemaitis to approve Fee schedule as presented. Motion Carried 6-0. Update on Leland Site Hawkins stated that he has been passing information back and forth with their designers, architects, etc. and there needs to be a more thorough plan before it is presented to the LCBRA. They have 120 days for due diligence and are about 35 days or so into that time period. Things are moving forward and we think we will be back in front of you in April with a request to modify the original work that we had proposed. Zemaitis asked if there would be an increase for the work order and Hawkins said yes, that was anticipated. The funding mechanisms and tools have to be identified as to what would be put toward the project. The developer is working hand and hand with the township for plan review and have things to complete with Leland Township. Bunek asked if it is our plan to continue moving forward with this even if the developer backs out within the 120 days. Hawkins said the original work of Phase I and BEA is lower cost and coming in under the RLF. The next stage will be a bigger cost. We will need to review your questions with the next request for a work order to see if you are comfortable with it. We can’t speak for the developer, but they seem pretty intent on moving forward and have much interest with the project. Janik gave an update on the townhouse units. There is considerable interest in the units and they have been shown to prospective buyers. He was optimistic that there could be an offer coming in the near future. M-22 Partners VanHaaren gave an update on the former Zephyr Oil site, called M-22 Partners. He had also provided updates throughout last year. The partnership/LLC that acquired the property last year was in negotiations for redevelopment of the site. They have every intention to redevelop the site and had a major tenant that was going to be on the site, but those negotiations fell through within the last 45 days or so. VanHaaren met with owners last week to discuss plans for moving forward and they still plan on developing the site. Extensive Phase I and BEA and Phase II have been done on the site. Part of the design for the new development had proposed additional Phase II sampling (Due care sampling). Development fell through and the main reason was because of the unknowns. There used to be an active oil transmission line on the site and it is still in place; plus there are other areas on the site that have elevated concentrations of contaminants. They intend to apply next month with the LCBRA, now that you have your assessment grant in place, and apply for assistance for due care sampling and maybe pre-demolition survey to evaluate design concepts and whether or not they need asbestos abatement for demolition of the building. This is an update on their effort and will most likely be coming through to you next month for request for funds. Rentenbach questioned them moving forward without a tenant and VanHaaren said that the tenant stepped out of the site. Right now we are talking about getting the site ready and addressing these issues in order for the next tenant to better understand the property. Bunek asked why one tenant got away if Brownfield was not already involved and VanHaaren responded they were not ready to go public on a Brownfield project yet, but we talked with them about assessment grant and RLF and removing the transmission line. We have had numerous meetings with the tenant and


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they, and their consultant, were very skittish about this. Bunek asked if they didn’t want to do it. VanHaaren said that it is manageable but the water table is high and that needs to be addressed. Bunek responded by saying that if VanHaaren could get some grant money to take care of those things and if there is a prospective buyer, it seems like they would come to us. Janik said there could have been other issues as well. New Business Phase I & Phase II Application – Suttons Bay Marketplace Pam Leonard of the Suttons Bay Marketplace, LLC. and member of the LLC, is the current owner of the property at 119 St. Joseph St. in Suttons Bay which is the former SilverTree Deli site. Leonard is also the owner of the adjacent property to the west that is vacant, which is shown as parking. VanHaaren reviewed history of the site and LCBRA, under previous assessment grants, and conducted Phase I and Phase II for the previous owner and an asbestos & lead based paint survey was done on SilverTree Deli. Envirologic, also under assessment grant, conducted Phase I and Phase II investigations on the vacant property. SilverTree Deli was not identified for contaminants but asbestos was identified on the second floor. The first floor was not assessed because it was occupied at the time. Asbestos is mainly in the window glazing and caulk of the old windows, as well as lead based paint on the second floor. On vacant property to the west, there is some environmental impact in shallow soils with a petroleum impact. The SilverTree Deli project fell through, the business closed, and the Suttons Bay Marketplace is the current owner and developer of the site. Leonard described the intended use of the site, also described in Part I of the application. Leonard stated that we have, in a way, taken our time with the site to determine the highest and best use and we are committed to doing a nice job here, although we are not developers. We have put it out for bid and had some sticker shock when it came back. It is economically not feasible. We own 12 units up the road and know what can be made on those units, seasonal end. That’s why we wanted to go to 24 units on this site. It is still a big number, about $7 million to redo that property and that does not include the parking property. We have taken a step back and want to do it in phases, but would like to get some assistance for the infrastructure and we need to redo the footings on the property. According to our engineers and architects, the footings have to be redone if we want to do anything on the second floor. Also, looking at wine tasting, plans are being submitted to the building department so we can start on the floor work. Inside we have a condo space to the north where old SilverTree Deli was located. We are not doing too much different from that. We want a nice deli, a bakery, a wine license, and to package liquor. The big thing will be an old fashioned soda and lunch counter, as well as coffee shop. Part of the other section will be a place for selling local products, and a space for people to rent to sell their wares. We would partner with local people to get people in the door and get started with their business. To the south would be the tasting room, done by Steve Kozelko. Wine tasting and food from the deli would be brought over and this would be the first stage. We have the ability to build out to the alley which would accommodate a new kitchen and an elevator. The kitchen has no support under it and there is a mezzanine on the upper level. We are confined to height restrictions and we still may stick to just one level of rooms. We have designs done right now within the height restrictions and we have a rooftop deck design for small events which could be for the lodging events or for small private parties. We were required to have parking so we bought parking in the back and it supports the 24 rooms and the visitors to the site. We are also looking at some housing in the garage area. VanHaaren added that for environmental activities, we would have to look at demolition, asbestos abatement, lead based paint (LBP) abatement, and also look at different options for the basement area of the building and feasibility of expanding the footprint of the existing building. The current kitchen has


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to be demolished because there is no good footing for it and there is an estimate of about $250,000 to address all those activities. To help and support economically, we have a work order under an assessment grant for the Brownfield Plan and Act 381 work plans to allow for TIF financing for those activities. Those would be out of pocket costs for the developer and then reimbursement would be through TIF financing. We are also looking at additional support from the state of Michigan through the CDBG block grant which is job base related. We have a meeting at 2:00 pm today with the Village, MEDC and Galla and planned to talk with MEDC about the potential for TIF financing and a CDBG grant to help with this project. Part of that process includes environmental review of the project which is the Phase I and Historical properties review and NEPA (flood plain, noise, etc. that is required by the Feds). Those are eligible under assessment grants. Phase I has already been conducted but it has to be updated and HUD components have to be added in: SHPO, flood plain, wetland review, noise, etc. That is the second work order for you for today for consideration. Janik said that he read about the project in the newspaper and is wondering where the approval process is with the Village. Leonard added that Wally Delamater has been working with them on it and was sorry that it has taken them this long. They bought it at the auction and Leonard did not believe that it had to go back to the Village for approval. Janik said the Village adopted a Downtown Development Authority (DDA) and he has gone to conferences on this. Statewide there have been controversies on DDA and TIF captured by LCBRA. Janik wonders how that will work. VanHaaren said that DDA will have to forego some of their capture to allow for this and he has talked with MEDC about that and will confirm that later today. Janik said, but DDA has not done that yet? VanHaaren responded with, no not yet. Janik stated that is a critical point for consideration and shouldn’t we confirm that first because we would hate to commit to something and have it not work out. It did not go well in Leelanau County previously on the DDA and virtually all other units opted out of the Suttons Bay Village DDA because there was no flexibility. Will the Village commit to this project and TIF capture? VanHaaren said that it has to be part of the Brownfield Plan. Bunek responded with the fact that we can make it contingent and Janik stated that, that was his point and that we would hate to commit to this if we don’t have confirmation. Zemaitis had the same thought and mentioned that this is a lot to finance. Although, Leonard was commended on the plan and thought that we should look at all the different options for funding and she liked the design and thought it would be a wonderful asset to the community. But, we don’t want to get into a situation like previous developments where it gets started and then fails and we are stuck with paying back money or not get our funds back. VanHaaren said that we are not looking at a grant or loan with DEQ like there was with the Leland Site and we are looking at funds under an assessment grant. This work order would allow us to formally approach the DDA and see what it would take to move it forward and also move forward with CDBG. Janik asked for assistance in understanding this and wondered if it would make sense to go forward and have DDA commit to this. He also wondered what protection there would be for us if they were to not commit. VanHaaren actually recommended that it be done and said that Janik could approve work orders and have them commit. Janik said that without DDA approval he wasn’t sure that this board would be willing to move forward. From last years’ experience, and statewide, there is controversy with DDAs and TIF collection.


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Galla asked if they could move forward with the assessment grant request and get an answer for the LCBRA on the DDA. Walter added that the assessment doesn’t hinge on the TIF capture. VanHaaren stated that both of these costs hinge on moving into the Brownfield Plan so that recapture can occur. We can start on environmental review which will take 30 days to conduct. The Brownfield Plan takes a couple months, especially with an Act 381 work plan. Janik said that if we did that, it would give Suttons Bay’s DDA plenty of time to take action. Hilton expressed concern for approving these work orders prior to getting an answer on the TIF. Walter said that we have grant dollars for assessment and need to expend those. Grant dollars are granted to the county for projects like this. There were projects where we spent dollars on the sites in the past and did not get those back. The idea is to spend the money in the grant and whether it is tied to the work plan or TIF dollars, it is not coming from our RLF fund. Galla clarified that the grant applications submitted specified that we would use methods to recapture funds expended so they could be ‘revolved’ and used again for future projects. That is for the RLF (loans), as well as for the assessment grants. She explained that EPA had informed her these funds are supposed to be seed money and we are to determine a method to be able to re-use the funds, and not just keep applying every year. The total amount of funds from EPA is getting smaller and competition is tougher so we want to re-use these funds and not just give them away. Galla also noted the grant applications are very difficult to write. It is important that we use TIF or a reimbursement agreement or loan document with a developer to recapture dollars. We do not want to keep writing grants to get more money. Zemaitis asked what dollars were left and a way to track them. Galla said she would work on a chart to show what has been requested, what has been approved or denied, and how much is left. Janik stated that if the DDA is not supportive of this project that sends a big message. It is a good project for the community and the county, but important to have DDA’s support here. Members are in agreement that this is a good project, but want DDA’s support as well. Bunek asked how many jobs will be created and Leonard felt 15 full time and 20 part time. Janik asked if there was not a timeline in place for Leonard right now and Leonard said that they were going through with the first phase of the project. Janik stated that the DDA could act quickly and bring it back to this board. Bunek asked if we could just support the application, which will give you some ammo to move forward? Is there anything we can do to expedite it? He wondered if we could offer less money than we are willing to risk. Bunek noted the $250,000 was mentioned. VanHaaren clarified that they are asking for the two work orders; $19,000 on one and $3,500 on the other and are not looking to spend all those other funds. $250,000 is the TIF that they are talking about. Zemaitis mentioned that the total request of both work orders is $22,500 and she thought that they could be approved today, conditionally on meeting with DDA and acquiring their approval. That way, we don’t need any more meetings and they are good to go. Hilton asked what exactly are we conditioning it on because that is his concern. Janik agreed and said they may only approve 25% of the funds or something. We need to hear from them.


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Bunek said that they are going to collect the money and Janik said that, that was his point and that we need their buy in first. Zemaitis felt that the $22,500 was a good investment in the long term. Hilton stated that they could take some informal support from us to the DDA, which moves them along. Hilton’s opinion is that when we don’t have the chart in front of us, it’s not a ton but $22,500 is a decent amount. Janik mentioned that Zemaitis brought up a good point. We want to be good neighbors, projects seem to be good, we are told that they are good, and they turn into financial obligations for us. Janik gave several examples of projects that the county had taken their word for, and then the financial obligation was on us. What’s wrong with waiting for DDA to take action and bring it back to us? Walter noted we meet again in 30 days, although we can call a special meeting if needed. Janik said the DDA should be in full support, but if not, that sends a strong message. Bunek said, they may not support us and Janik replied that would then be a long term financial obligation for us if they don’t support it. Janik explained he was being cautious, especially after going to the state training on this and this is a concern around the state. VanHaaren felt approval of the application would move them forward. The work orders and approval for funds could wait until next month. Bunek wanted to be sure that we are not holding things up. It was moved by Rentenbach, seconded by Janik to accept the application and delay action on work orders at this time, until we hear from DDA. Rentenbach stated that we may consider a special meeting, if necessary. Walter asked if we need some sort of message or communication to the DDA of what our concern is as far as the taxes and collection. Janik said, assuming we are approving this application that sends a strong message to the DDA. VanHaaren will keep Galla up to date and she is in on the meeting this afternoon. Walter said that the tax collection is something to be approved of by the county board, as well. Janik noted our action is that we are in support of this project. Bunek questioned about redoing the foundation and three stories and wondered if the three stories are above ground or if the basement is counted. Leonard said there are three stories, one level with the deli and the stores, elevator to the basement level but wasn’t sure if we can do that yet. There is an issue with the little building, Bonek Agency, next door so we have to be cautious with that. To go up three stories, we have to shore up the existing footing. Bunek was concerned about them doing the whole first floor and then try to repair footings. Leonard mentioned that we even thought about demolishing the whole building and that took us about 6 months. The existing footings are pretty good but going up three stories will require a lot of work on the footings. Question called. Motion Carried 6-0. Application from Traverse City Housing Commission (TCHC) Galla reviewed the application and information submitted by email from Andy Smits. There were no work orders on this project and you need to accept the application if you feel it meets the criteria, and also select a consultant to move forward, meet with TCHC, and then set up a work order for the next step. They might want to use RLF funds as well. Galla reviewed the August 2015 time frame on RLF and


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the importance of getting loan documents approved on a project, or projects, which would provide a better standing with EPA and possibly get an extension of the RLF. Without projects, we will not get an extension and funds will stay with EPA. It’s important to use the RLF funds and use them on the right projects. Members discussed Phase II, problems on the site, and the type of rental development currently on the site. Hawkins handed out a drawing of the area. Hilton said there is not a plan at this point but we know there is contamination and it needs to be addressed on the site. Bunek asked both consultants about their involvement on the site. VanHaaren noted Hawkins has been more involved in this site. Hawkins said there was previous environmental work on the site. He has had more discussions on the TCHC, and he had reached out to them because we were looking to use these RLF funds and not lose them. We had an initial discussion with them more than a year ago and nothing happened, and we weren’t sure how the RLF could be used. We went back to them again and asked about using RLF funds. For this site, you have to consider that the RLF is a loan program. We have had conversations with Galla on how we could utilize these funds in a more creative fashion so we don’t lose them. Obviously, when you enter into agreement with RLF dollars, it is intended for those dollars to capitalize a loan program and you re-use them by revolving them into future projects. We discussed with TCHC last year on how we can do a Brownfield Plan and recapture those dollars. There is Payment in Lieu of Taxes (PILT/PILOT) on that site. Hawkins checked with the state Treasurer and we can not capture the PILT/PILOT funds, as you might capture TIF. Envirologic came to you some time ago and suggested changing the RLF Work Plan to allow 10% of funds to explore health of community and plan for sites such as this one. The LCBRA and EPA both approved the change to the RLF Work Plan. We have experience in other communities where stipulated agreements are created and these funds are loaned out – particularly on a site like this where public good and public housing are created. Hawkins explained a stipulated agreement, the requirements for EPA and reporting after the RLF ends, and anticipation of repayment for funds that are loaned out under the RLF. A stipulated agreement might work similar to a forgivable loan. It all depends on the rate and terms that you, as the LCBRA, negotiate with a developer. Is there a way to work with Brownfield, TCHC, and an agreement to try and collect for a loan on the site? Bunek asked if we would still collect TIF and Hawkins replied, that there is no TIF but your expectation is that you will try to collect on any loan for this site. Bunek asked Galla for clarification on the RLF funds use and recapture of funds. Galla responded by pointing out the criteria the LCBRA has to weigh a project and its importance. This is a public project for affordable housing. Is it important to the community? You have an opportunity to use the RLF funds with the anticipation of bringing those dollars back in and revolving them, or not use the RLF and perhaps not expend RLF dollars in the county. Hawkins added you have to look at the possibility of request for funds of RLF for the Leland site, possibly SilverTree, maybe the Zephyr Oil site (M-22 Partners), and the TCHC site. Your criteria is used to determine what should be funded, and how much. Galla said that selecting a contractor and approving the application does not commit the LCBRA to any funds yet. They still have to come back with work orders. So, you have not expended any funds yet but it allows TCHC to move to the next step. Bunek asked Hawkins why no TIF would be collected and Hawkins said that they are tax exempt, there are no taxes on the property. Hilton said that there does sound like there is an opportunity to be creative and try to collect loan dollars back. Hawkins responded that you would need to draw up the loan documents and obligation with term and repayment. You would have that official documentation


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going forward. Behind that you would have a stipulated agreement that should the property ever have taxes that are paid, there is an obligation to repay the loan. Secondly, if they ever sell the property, they are also obligated to repay the loan, which is kind of a double agreement. Once obligation to EPA goes away, you would rely on the stipulated agreement with TCHC. Zemaitis asked about a time frame for an agreement like that and Hawkins said that by time we get this done, it’ll be about 60-90 days. The term of the loan agreement may be 10 years and 0 interest or low interest. It would be a sub agreement with them outside the loan agreement that runs through EPA. Galla noted that EPA had actually brought up the idea that we can do outside agreement with developers outside of the loan documents and set up what we want between LCBRA and the developer. It was moved by Rentenbach, seconded by Zemaitis to accept the application for Orchard View property from TCHC. Motion Carried 6-0. It was moved by Hilton, seconded by Bunek that in light of the discussion we just had with Jeff Hawkins, the LCBRA selects Envirologic Technologies, Inc. as the consultant for this project. Motion Carried 6-0. Claims & Accounts It was moved by Zemaitis, seconded by Rentenbach to pay Claims and Accounts in the amount of $2,259.60. Motion Carried 6-0. Public comment Hawkins introduced new member, Pam Jackson, for Envirologic Technologies, Inc. Director Comments Galla noted we have not yet advertised for the assessment grants and already have several applications. There is an uptick in permits according to Construction Codes office and we’ve had a lot of meetings and calls from developers in the last 6 months. Galla had anticipated there would be an upswing and we would be getting more applications. Member comments Rentenbach asked that if we have a project come forward, will we have assessment dollars available. Galla said yes. She will work on a chart so you can review what dollars are being requested, what is left, and then you will have to make decisions on which projects should get funded. This is where your ‘criteria’ is so important. Bunek commented on an article in the newspaper on Sugar Loaf. Zemaitis stated that she is excited to be on the board at this time and all the projects coming forward, which she is looking forward to. Walter said that the pendulum swings and it is coming back with development. It was moved by Rentenbach, seconded by Bunek to adjourn. Meeting adjourned at 11:00 am.


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MEMORANDUM

From: T. Galla, Director To: LCBRA Date: April 21, 2015 LCBRA Meeting Attached please find the Review Criteria for Brownfield Applications, and Brownfield Redevelopment Transaction Costs. Please reference the Criteria for any applications for assistance. NEW BUSINESS ITEMS 1. Traverse City Housing Commission, Elmwood Twn. Site At the March 17, 2015 meeting the LCBRA:

accepted the application from Traverse City Housing Commission, approved Envirologic Technologies as consultant on this project.

ACTION TO CONSIDER:

a. Approval of Work Order #17, Revolving Loan Fund, for $8,500. NOTE: Work Order #17 is part of the ‘Community Health Monitoring’ Task of the Revolving Loan Fund, and is NOT considered a Loan on this project. Depending on the results of this Work Order and responses from MDEQ and MSHDA/HUD regarding contaminants on the site, additional work under the assessment funds may be needed. If so, a Work Order would need to come back to the LCBRA for consideration of use of assessment funds.

2. Smith application – Vacant car wash/oil change, Suttons Bay Twn. site This is a new application and the Director has been told that if assessment funding is not approved by the LCBRA, the purchase agreement may need to be modified. Also, the timeframe of the purchase agreement is 21 days, which is not enough time to get this application through the LCBRA, approve a consultant and a Reimbursement Agreement, and conduct the environmental assessments. A modification to the purchase agreement and timeframe may still be needed if the LCBRA approves any funding for this project. The applicant has requested up to $15,000 for assessment work. The non-refundable application fee of $150.00 has been received and deposited. As part of the Cooperative Agreement with U.S. EPA for the assessment grants (petroleum and hazardous substances), EPA approved a Work Plan which states:

LeelanauCountyBrownfield

RedevelopmentAuthority(LCBRA)

LeelanauCountyBrownfieldRedevelopmentAuthority(LCBRA)Countywebsite:www.leelanau.cc/BRAintro.asp

8527E.GovernmentCenterDr.Suite108SuttonsBayMI49682Phone:(231)256‐9812orTollFree(866)256‐9711,Ext.6Fax:(231)256‐0174

MarkWalterChairman

KathyEganVice‐Chairman

KarenZemaitisTreasurer

TrudyGalla,AICPDirector

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“The Authority will seek other leveraged funds for each project, and seek opportunities to recapture funds used for assessments into a revolving fund for future projects and program continuation. This may involve matching funds from the applicant, an agreement for recapture of grant funds used on a site once the site is sold, capture of TIF funds through brownfield plans, and/or donations of funds and resources. Leelanau County, and its Partners, are dedicated to continuation of our program after the grant is expended.”

If the LCBRA agrees to accept this application and consider funding, the Director recommends a Reimbursement Agreement for Repayment be put in place for the approved funding under the assessment funds. (The Director is working on a draft Reimbursement Agreement). Due to the fact that petroleum products were used at this site, the Petroleum assessment funds could be allocated. Petroleum sites must be submitted to MDEQ for eligibility, and to EPA for concurrence. ACTION TO CONSIDER:

a. Acceptance of the application b. Approval of a Reimbursement Agreement with the Recipient for the funds c. Approval of a consultant for this project (AKT Peerless, or Envirologic Technologies)

Note: The selected consultant would need to provide a Work Order for consideration by the LCBRA – either at the next regular scheduled meeting, or at a Special Meeting which requires a payment of $250.00 by the applicant for calling a Special Meeting. (The LCBRA has the right to waive or modify the Fee Schedule). All documents developed through the use of assessment or RLF funds are public information.

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Review Criteria for Brownfield Applications (Adopted May 2007, and adopted as part of Policies & Procedures January 19, 2011)

The LCBRA may consider evaluation of projects based upon the following discretionary criteria: The nature and extent of contamination (such as threat to water quality and public

health), and the extent to which the contamination will be remedied. The existence of abandoned, vacant buildings, or blight, and the extent to which the

project will remove the buildings and blight. The extent to which the project will encourage growth in appropriate areas so as to

minimize or discourage sprawl and loss of “Greenfields”. The type and size of the new use. The extent to which the project creates new – temporary, and long term jobs. Benefits to transportation needs (parking, traffic congestion, pedestrian traffic, etc.) Promotion of tourism and/or recreation. Promotion of cultural and/or historical preservation. Improvements to public infrastructure consistent with land use or master plans. Overall enhancement to the community. Consistency of the project with the community land use or master plan. Consistency of the project with the Leelanau General Plan. Other factors benefiting the community. The viability of the project without Brownfield assistance.

Activities • Approve funding criteria and project selection • Solicit Applications & meet with potential applicants • Assess Projects, viability and eligibility • Conduct full review of the Proposed project • Approve or reject Loan Application • Conduct Community Involvement Activities

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(Adopted as part of Policies & Procedcures)

L. BROWNFIELD REDEVELOPMENT TRANSACTION COSTS

Costs and expenses related to the authorization, execution, administration, oversight, or fulfillment of the LCBRA’s obligations as allowed by Act 381 and incurred as a result of assistance to a brownfield redevelopment project shall be borne by the developer. These costs and expenses shall be defined in an executed development agreement between the LCBRA and the developer or reimbursed through Tax Increment Financing under an approved Brownfield Plan. These transaction costs include, but are not limited to:

1) direct or indirect fees and expenses incurred as the result of an application;

2) amendment to a brownfield plan;

3) review of a proposed brownfield development project and/or plan;

4) approval of a proposed brownfield development project and/or plan;

5) printing costs;

6) costs of reproducing documents;

7) filing and recording fees;

8) attorney fees;

9) financial expenses;

10) insurance fees and expenses;

11) administration and accounting for loan proceeds and tax increment revenues,

12) oversight and review;

13) all other costs, liabilities, or expenses related to preparation and execution of or enforcing

of brownfield plans, Act 381 MDNRE/MEGA work plans, any and all agreements with a

developer;

14) and any other costs, charges, expenses, and professional and attorney fees in connection

with the foregoing.

4 of 63

TO: TRUDY J. GALLA, AICP, DIRECTOR, LEELANAU COUNTY BROWNFIELD REDEVELOPMENT AUTHORITY

FROM: JEFF HAWKINS

SUBJECT: GENERAL CONSULTING MONTHLY UPDATES AND INVOICES

DATE: APRIL 21, 2015 This memorandum serves to provide information regarding invoices and updates that are being presented to the LCBRA for services rendered on various projects related to General Environmental Consulting activities. Please find attached several items for your consideration: 1. Former Leelanau County Government Complex – RLF Eligibility (W.O. #13)

Update: We have received confirmation from both EPA and MDEQ that we can use RLF and Assessment Grant funds on the former Government Complex site. Project Invoices for Consideration: There are no invoices for consideration.

2. RLF Loan Selection for Potential Projects (W.O. #14) Update: Envirologic has explored the concept of renegotiating the RLF Cooperative Agreement to set aside up to 10% of the RLF funds to aid in several high priority projects. After multiple conference calls with EPA which received a favorable response, a revised Work Plan was submitted to EPA on December 10, 2015. On January 26, 2015, the LCBRA received an amendment to the Cooperative Agreement allowing for an additional Work Plan Task #6 which addresses the 10% use of RLF funds to allow for health monitoring of populations and monitoring and enforcement of institutional controls and approves related re-budgeting. Project Invoices for Consideration: There are no invoices for consideration.

3. General Services (W.O. #15) Update: There were no activities this month. Project Invoices for Consideration: There are no invoices for consideration this month.

4. Leland River Club Preliminary BCRLF Planning (W.O.#16)

Update: Envirologic has begun working to evaluate eligible activities that may be addressed utilizing the RLF. Project Invoices for Consideration: Invoice #01012 ($515.00)

MEMORANDUM

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Leelanau County Brownfield Redevelopment AuthorityGeneral Environmental Consulting Services

Monthly Project Update

Budget and Cost Summary

4/21/15Page 1 of 1

LCBRAFile # W/O Project

13 140292 Former Government Center RLF Eligibility 1,500.00 00200 8/5/2014 543.75$ 543.75$ 956.25$ 00452 10/15/2014 140.00$ 683.75$ 816.25$ 00733 1/13/2015 190.00$ 873.75$ 626.25$ 00800 2/9/2015 237.50$ 1,111.25$ 388.75$

14 140290 RLF Loan Selection - 10% Fund Allocation 6,000.00 00222 8/6/2014 140.00$ 140.00$ 5,860.00$ 00454 10/15/2014 175.00$ 315.00$ 5,685.00$ 00480 11/4/2014 1,223.75$ 1,538.75$ 4,146.25$ 00734 1/13/2015 345.00$ 1,883.75$ 4,116.25$ 00801 2/9/2015 520.00$ 2,403.75$ 3,596.25$ 01012 4/15/2015 515.00$ 2,918.75$ 3,081.25$

15 140291 General Services 4,500.00 00201 8/5/2014 210.00$ 210.00$ 00355 9/18/2014 770.00 980.00$ 3,520.00 00453 10/15/2014 350.00 1,330.00$ 3,170.00 00481 11/4/2014 840.00 2,170.00$ 2,330.00

Totals 12,000.00$ 6,200.00$ 6,200.00$ 5,800.00

General Updates:

Envirologic

1. Budget Expended includes "Invoices for Consideration" amount.

Invoice # Invoices for

Consideration Budget1

Expended

Budget Remaining

Task Completed

Invoice Date

Budget Estimate Site/Phase

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TO: TRUDY J. GALLA, AICP, DIRECTOR, LEELANAU COUNTY BROWNFIELD REDEVELOPMENT AUTHORITY

FROM: JEFF HAWKINS

SUBJECT: EPA BROWFIELD ASSESSMENT GRANT MONTHLY UPDATES AND INVOICES

DATE: APRIL 21, 2015 This memorandum serves to provide information regarding invoices and updates that are being presented to the LCBRA for services rendered on various projects related to General Environmental Consulting activities. Please find attached several items for your consideration: 1. Quality Assurance Project Plan (QAPP) (W.O. #1H/P-14)

Update: Envirologic has submitted the QAPP to EPA for their review and consideration. Project Invoices for Consideration: Invoice #01018 ($1,997.50)

2. Community Outreach (W.O. #2H/P-14)

Update: Envirologic developed and completed a new tri-fold brochure. Envirologic developed an invitation for the Brownfield Informational Session which was held on March 17, 2015 and attracted approximately 40 attendees. Envirologic developed the Powerpoint presentation for the session and co-presented with AKT Peerless. Envirologic will be presenting to the April meeting of the Leelanau Clean Water group. Project Invoices for Consideration: Invoice #01010 ($1,190.00)

3. Leland River Club (W.O. #3H/P-14)

Update: Envirologic has begun initiation of the Phase I ESA for the new developer, Peterson Homes. Project Invoices for Consideration: Invoice #01011 ($835.50)

MEMORANDUM

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Leelanau County Brownfield Redevelopment Authority2014 EPA Petroleum Assessment Grant and Hazardous Substances Grant Monthly Budget Update

Budget and Cost Summary

4/21/15Page 1 of 1

Project ProjectBudget Budget Invoices for Task

Estimates Estimates Consideration Hazardous Petroleum Hazardous Petroleum CompletedLCBRA Grant Work

File # Plan Task W/O Project Site/Phase Hazardous Petroleum Initial EPA Grant Award 200,000.00$ 200,000.00$ Envirologic Contract Amount 71,200.00$ 71,200.00$

Task #2 1H/P-14 140554 QAPP 1,000.00 1,000.00 01018* 4/15/2015 1,997.50$ 998.75$ 998.75$ 1.25$ 1.25$

Task #4 2H/P-14 140555 Community Outreach 3,000.00 3,000.00 01010* 4/15/2015 1,190.00$ 595.00$ 595.00$ 2,405.00$ 2,405.00$

Task #1 and 2 3H/P-14 150070 Leland River Club Phase I ESA and BEA 2,250.00 2,250.00 01011* 4/15/2015 835.50$ 417.75$ 417.75$ 1,832.25$ 1,832.25$

Subtotal 2,250.00 2,250.00

Totals 6,250.00$ 6,250.00$ 4,023.00$ 2,011.50$ 2,011.50$ 4,238.50$ 4,238.50$

Budgeted Grant Funds for Envirologic Activities 6,250.00$ 6,250.00$ Envirologic Contract Budget Remaining Subtotal 64,950.00$ 64,950.00$

Budgets Returned from Under Budget Projects

Subtotal Under Budget Projects -$ -$ Total Envirologic Contract Budget Remaining 64,950.00$ 64,950.00$

* Pending approval by LCBRA

Number

Envirologic

Project Budget Expended Project Budget Remaining

Invoice Date Invoice Total

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Scope of Services

Agreement for Services – RLF Grant Leelanau County and Its Brownfield Redevelopment Authority

Applicable to Agreement Dated May 9, 2011, as amended Work Order No. 17 Dated April 6, 2015

Between

LEELANAU COUNTY AND ITS BROWNFIELD REDEVELOPMENT AUTHORITY (CLIENT) 8527 E. GOVERNMENT CENTER DR. SUITE 108 SUTTONS BAY, MI 49682-9718

And

ENVIROLOGIC TECHNOLOGIES, INC. (ENVIROLOGIC) 2960 INTERSTATE PARKWAY KALAMAZOO, MICHIGAN 49048 Subject Matter: Traverse City Housing Commission Site, 10200 E. Carter Center, Traverse City Funding Sources: Brownfield Cleanup Revolving Loan Fund, Task 6 (Recent Amendment) CLIENT requests that ENVIROLOGIC perform the work described below in accordance with the terms of the above-referenced Agreement, as amended and as described in this “Scope of Services.” ENVIROLOGIC will begin work on this Work Order and complete the services as described in the attached "Scope of Services." ENVIROLOGIC and CLIENT have designated the following representatives for this “Scope of Services:” Jeffrey C. Hawkins (269) 342-1100 Name (ENVIROLOGIC) Phone Trudy J. Galla, AICP, Director (231) 256-9812 Name (CLIENT) Phone If CLIENT accepts this Scope of Services, please sign this Work Order on behalf of CLIENT and return to the ENVIROLOGIC Representative above: ACCEPTED AND AGREED TO: LEELANAU COUNTY AND ITS LAND BANK AUTHORITY and BRA (CLIENT) ENVIROLOGIC TECHNOLOGIES, INC. By Trudy J. Galla By Jeffrey C. Hawkins Title Director Planning and Community Development Title President

Signature________________________ Signature________________________ Date ______________ Date _

1 4/14/2015 of 63

1. Scope of Services The site is a two-phased residential development. The second phase of development has been complicated by the presence of hazardous substances (notably arsenic) in soil at the property. The arsenic is presumed to be a residual contaminant from the past use of the property as an orchard. The owner of the property, the Traverse City Housing Commission, is considering securing a loan from the Leelanau County Brownfield Redevelopment Authority’s U.S. EPA Brownfield Cleanup Revolving Loan Fund (RLF) grant. Cleanup Planning Prior to any activities in this Work Order, Envirologic will secure eligibility for the use of grant funds. Further we will seek eligibility for the potential borrower (Traverse City Housing Commission) to support a future RLF loan. Redevelopment of a contaminated site requires several considerations to ensure that future residents and the environment are adequately protected from existing environmental contamination. At the present, it appears that the Traverse City Housing Commission believes that removal of surface and shallow soil may be an effective remedy. Envirologic proposes to review the existing data to determine the effectiveness of various cleanup alternatives such as removal or capping. If sufficient data exists, we will develop preliminary budget estimates for the cleanup alternatives. Such information will be useful at a later date in the preparation of an Analysis of Brownfield Cleanup Alternatives (ABCA). If data is insufficient to demonstrate the effectiveness of a cleanup option, Envirologic will prepare recommendations for further assessment of the property to aid in the success of the proposed cleanup. Cleanup Planning can also involve evaluation of the financial tools that can be used to help developers overcome the cost of cleanup and even the playing field with non-contaminated sites. Envirologic will evaluate what, if any, future value the property may be able to contribute as a source of revenue for payback of the loan. We will convene a meeting with the Traverse City Housing Commission to determine the length of time the property will remain exempt from ad valorum taxes, the potential taxable value of the real estate should/when the property’s status as tax exempt status terminates, and other financial data. Such information will be useful in constructing loan documents for review by borrower, County and U.S. EPA. To support the future RLF Loan, it will be necessary to secure some form of approval from the Michigan Department of Environmental Quality for the proposed cleanup action. Envirologic will reach out to local district MDEQ staff and determine the best and quickest means of documenting the proposed cleanup activity and securing MDEQ approval. Envirologic proposes to meet with the Traverse City Housing Commission staff to discuss timing requirements, development plans, costs, the overall process and schedule, and other pertinent information. We will help the prospective borrower understand key requirements for the use of RLF funds including eligibility, prevailing wage requirements, quality assurance, public participation, signage, and reporting.

2 4/14/2015 of 63

Following the completion of the cleanup planning, Envirologic proposes to deliver the following:

1. Approved eligibility of the property and prospective borrower. 2. Recommendations, if any, for any assessment needed prior to finalizing cleanup plans. 3. Matrix of alternative cleanup technologies, benefits, estimated costs, and concerns. This

will include a preliminary Wage Determination of prevailing wages for worker categories likely to be engaged in the cleanup.

4. Recommendations for engaging MDEQ in approval of the cleanup and estimated costs associated with that effort.

5. An overall schedule for the engagement of a BCRLF loan including key approvals (BRA, USEPA, MDEQ), products (ABCA, Community Involvement Plan, Cleanup Plan), and other pertinent dates.

6. An overall cost estimate of the cleanup activities and ancillary requirements. 7. A concept for structuring the BCRLF loan including terms and overall costs, roles of various

parties to the cleanup including oversight, community involvement, technical oversight, etc. Upon completion of these activities, Envirologic envisions that a second Work Order to implement an RLF Loan will be developed and presented to the BRA. Components of this second Work Order may include development of loan documents, development of the cleanup plans for MDEQ review, a draft Analysis of Brownfield Cleanup Alternatives, development of a Community Involvement Plan, implementation of community involvement activities, engagement with MDEQ, submittals to USEPA for review and approval, and other activities necessary to implement the cleanup project. 1.1 Compensation For this initial work we propose the following budget:

• Preliminary Cleanup Planning/Development of Considerations $ 8,500 (RLF Grant, Task 6)

Total $ 8,500 111. Schedule Work performed under this Work Order will be completed as expeditiously as possible as directed by the County. H:\Projects\Projects_L\Leelanau County\Work Orders\General Consulting Projects\Work Order No#17 - TC Housing Commission.docx

3 4/14/2015 of 63

West Bay

Date: Pet. HazMat Pet. HazMatGrant/Loan

Eligible TIF EligibleTask # (1-6) Notes

4/6/2015 Consumers Energy X $0.00 $ -0.56 - Total

3/29/2015 Envirologic $ 4,023.00 - TotalInovice # 01018 EPA Assessment Grants - QAPP X X $1,997.50Inovice # 01010 Community Outreach Assessment Grant X X $1,190.00Invoice # 01011 Assessment Grant X X $835.50Invoice # 01012 RLF Grant X X $515.00

12/15/2014 MAC Service Corporation $ 712.50 - TotalInvoice # m211 EPA RLF Grant X X $300.00Invoice # m212 EPA RLF Grant X X $412.50

3/31/2015 AKT Peerless $ 490.00 - TotalInvoice # 38447 EPA RLF Primary Administration $490.00

3/27/2015 Leelanau Enterprise $ 283.10 - TotalPostcards and Web Advertising $188.10

$70.00$25.00

4/30/2015 Leland Township $ 211.44 - TotalSewer System $31.68

$89.88$89.88

$6,235.04

Amount Denied: $ Initials: _______ _______

Amount Approved: $

$6,235.04

Date:

Amount

EPA Assessment Grants

Description

Leland Residential

(Loan)

EPA RLF Grant

Completed by: T. Galla Date Completed: 4/17/15

Leelanau County Brownfield Redevelopment Authority (LCBRA)

Claims & Accounts April 21, 2015

TOTAL CLAIMS & ACCOUNTS:

X X

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Leelanau County Brownfield Redevelopment Authority

Invoice number 01018 Invoice date 04/15/2015

Professional Services 16.50 85.00 1,402.50

Dean G. Hazle

Project Scientist

Professional Services 4.25 140.00 595.00

David B. Warwick

Principal

Hours RateBilled

Amount

Professional Fees

Phase subtotal 1,997.50

QAPP

Invoice total 1,997.50

We accept Check, ETF, Visa, MC Discover & Amex as payment options

INVOICE: Through Mar 29, 2015

Leelanau County Brownfield Redevelopment AuthorityTrudy Galla8527 E. Government Center DriveSuite 108Suttons Bay, MI 49682-9718

Invoice number 01018Date 04/15/2015

Project 140554 2014 EPA Assessment Grants - QAPP W.O. 1HP-14

of 63



Professional Services 8.50 140.00 1,190.00

Jeffrey C. Hawkins

Principal

Hours RateBilled

Amount

Professional Fees

2014 EPA GRANTS - COMMUNITY OUTREACH

Invoice total 1,190.00





Project 140555 2014 EPA Grants - Community Outreach W.O. 2HP-14

of 63



Environmental Data Resources, Inc. 1.00 195.50 195.50

Subcontractor

Units RateBilled

Amount

Subcontractor


Caitlin M. Andler

Project Scientist


David A. Stegink

Senior Project Manager


Jeffrey C. Hawkins

Principal

Hours RateBilled

Amount

Professional Fees

Phase subtotal 835.50

LELAND RIVER CLUB WORK ORDER #3HP

Invoice total 835.50





Project 150070 Leland River Club - Assessment Grant

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Caitlin M. Andler

Project Scientist


David A. Stegink

Senior Project Manager

Hours RateBilled

Amount

Professional Fees

Phase subtotal 515.00

LELAND RIVER CLUB PRELIMINARY BCRLF PLANNING, WO #16

Invoice total 515.00





Project 150131 Leland River Club - RLF Grant

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Invoice Number: m211Invoice Date: 12/15/14

Bill To:

Leelanau County RLF Grant8527 East Government CenterSuite 108Suttons Bay, MI 49682

12/15/2014, Grant Tracker budget table update and EPA balance 300.00reconciliation, 4 hours @ $75.00 an hour

300.00TOTAL AMOUNT DUE

Revolving Loan Fund Grant Amount

INVOICE

The MAC Service Corporation: Committed to providing valuable services while saving you money.

www.micounties.org

Trudy GallaGrant: Leelanau County EPA RLF GrantGrant ID: Grant Assistance No. BF-00E00388-1

935 North Washington AvenueLansing, Michigan 48906

Voice: 1-800-336-2018Fax: 1-517-482-8244

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Invoice Number: m212Invoice Date: 1/21/15

Bill To:

Leelanau County RLF Grant8527 East Government CenterSuite 108Suttons Bay, MI 49682

Grant Budget and consultant proposal invoice review, 5.5 hours at 412.50$75.00 an hour

412.50TOTAL AMOUNT DUE

Revolving Loan Fund Grant Amount

INVOICE

The MAC Service Corporation: Committed to providing valuable services while saving you money.

www.micounties.org

Trudy GallaGrant: Leelanau County EPA RLF GrantGrant ID: Grant Assistance No. BF-00E00388-1

935 North Washington AvenueLansing, Michigan 48906

Voice: 1-800-336-2018Fax: 1-517-482-8244

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LEELANAU COUNTY APPENDIX H POLICIES AND PROCEDURES FEE SCHEDULE

APPLICATION REVIEW FEES

A. Brownfield Project Application Form – Part 1

A Brownfield Project Application Form - Part 1 will be required to introduce a proposed development project to the LCBRA board and request initial consideration of Brownfield Incentives.

BROWNFIELD PROJECT APPLICATION APPLICATION FEE

Part 1 Application $150.00

All Brownfield applicants will be assessed an Application Fee of $150.00 for consideration of the Brownfield Project Application Form - Part 1 Application. The Part 1 Application Fee is payable upon submittal. The fee will be non-refundable regardless if the application/request is approved or denied by the LCBRA. The fee is also non-refundable through tax increment financing (TIF) under an approved Brownfield Plan or Act 381 Work Plan.

B. Brownfield Project Application Form – Part 2 (Brownfield Plan, Act 381 Work Plans and amendments), Revolving Loan Fund, or Local Site Remediation Revolving Fund (LSRRF), etc.

A Brownfield Project Application Form - Part 2 is required if a Brownfield Plan, MDEQ Gran/Loan, EPA Revolving Loan, or Local Site Remediation Revolving Fund (LSRRF) is requested as a project incentive.

BROWNFIELD PROJECT APPLICATION APPLICATION FEE

Part 2 Application – Brownfield Plans, Act 381 Work Plans, Amendments to Brownfield Plans and Act 381 Work Plans, EPA Revolving Loans, MDEQ Grants/Loans and LSRRF Loans

$500.00

The Part 2 Application fee is payable upon submittal. The fee will be non-refundable regardless if the application/request is approved or denied by the LCBRA. The fee is also non-refundable through tax increment financing (TIF).

March, 2015 Policies & Procedures of 63

LEELANAU COUNTY APPENDIX H POLICIES AND PROCEDURES FEE SCHEDULE

The Application Fee will be applied to, but not limited to, the following available Brownfield Programs:

• Leelanau County Brownfield Redevelopment Authorityo Brownfield Plans and Act 381 Work Plans (including amendments)o Brownfield Loan – Local Site Remediation Revolving Fund -- Administered by

the Brownfield Redevelopment Authority

• Michigan Department of Environmental Qualityo Brownfield Redevelopment Grants (BRGs) - up to $1,000,000 in funding

available to each projecto Brownfield Redevelopment Loans (BRLs) - up to $1,000,000 in funding available

to each projecto Revitalization Revolving Loans (RRLs)

• Environmental Protection Agencyo Brownfield Cleanup Revolving Loan Fund (RLF) Loan - Administered by the

Brownfield Redevelopment Authority

Note: Application fees may apply to other grants or loans obtained to address and support Brownfield assessment and/or cleanup activities

C. Reimbursement Agreement – For all projects requiring a Reimbursement Agreement with the LCBRA, 1% of the total amount offered by the LCBRA will be due and payable to the LCBRA upon signing of the Reimbursement Agreement. The minimum fee is $1,000 and maximum (regardless of total amount) is $15,000. The fee is also non-refundable through tax increment financing (TIF).

D. Brownfield Redevelopment Authority (LCBRA) - Special Meeting $250.00/meeting

E. Agency and Other Review Fees - Any fees required by other agencies, are in addition to the fees cited above and must be paid directly to the agency by the Applicant. Any direct costs associated with the review of a Brownfield application, plan, work plan etc. as identified herein by other than staff for the LCBRA, shall be reimbursed by the Applicant prior to the proposal moving to the next stage of the application process. This includes processing fees associated with attorney reviews and any agency reviews.

F. Additional Review Fees – for requests of documents not covered by the above fee schedules, the Director may require any fee deemed appropriate to cover the activities necessary for response to the review request

G. Waiver – The LCBRA reserves the right to waive this Fee Schedule if deemed necessary, or appropriate.

March, 2015 Policies & Procedures of 63

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