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Mr. David Loch <br /> August 11, 1998 <br /> Page 5 <br /> • <br /> Issue V The County does not accept the "but/for" test in the Plan <br /> Information regarding the "but/for" analysis can be found in <br /> Section J (2), Page 5, Findings and Need for Tax Increment <br /> Financing, in the Tax Increment Financing Plan for TIF No. 19 <br /> which states: "The reasons and facts supporting this finding are <br /> that the developer has represented to the city that it would not <br /> undertake the proposed development without the assistance of <br /> tax increment financing. Private investment will not finance <br /> these development activities because of prohibitive costs. It is <br /> necessary to finance these development activities through the <br /> use of tax increment financing so that other development by <br /> private enterprise will occur within the Project Area." <br /> The City Council of the City of Elk River has made a finding <br /> that the facts presented to it by the developer support, in the <br /> opinion of the city, that the development would not reasonably <br /> be expected to occur solely through private investment within <br /> the reasonably foreseeable future. <br /> • All supporting information provided by the developer with <br /> regard to the but/for analysis is public information and <br /> available to the Commissioners at your request. Some of the <br /> information can be found in the developers tax increment <br /> application package which is attached to this letter. <br /> Issue VI The County has concern about the total captured value that the <br /> city has in TIF Districts. <br /> As indicated in the County Commissioner's response to the City <br /> Council's request for public input on TIF No. 19, you indicate <br /> that "Assuming the same rate of growth that has occurred in the <br /> last five years, the Sherburne County Board is concerned that 9 <br /> percent of the city's tax base will be involved in TIF Districts." <br /> This is an invalid assumption. <br /> • Does this assumption anticipate any growth in the city's total <br /> tax capacity, or does it simply anticipate growth in the city's <br /> TIF tax capacity? <br /> • Does this assumption consider that TIF No. 19 is somewhat of <br /> an anomaly in that its estimated market value is more than <br /> 410 <br />