City Policies Tax Incentive Policy and Guidelines - 5/12/20

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                     Agenda Item Review Form
                      Muskegon City Commission

Commission Meeting Date: 4/14/2020                    Title: Tax Incentive Policy and Guidelines

Submitted By: LeighAnn Mikesell                       Department: Economic Development

Brief Summary: The Tax Incentive Committee has created a policy document for Commission
approval that reflects the findings and recommendations in the previously reviewed committee
report.

Detailed Summary:
In an effort to standardize and control the rate and term of tax abatements granted in the City of
Muskegon, the Tax Incentive Committee (comprised of staff from Economic Development,
Planning, and Finance) has created the attached policy to guide our recommendations to the City
Commission when tax abatements are requested. This system incentivizes companies that reflect
community goals and values, while keeping Muskegon competitive in the region for attraction and
expansion of business base.

Amount Requested: N/A                                Amount Budgeted: N/A

Fund(s) or Account(s):                               Fund(s) or Account(s): N/A

Recommended Motion: Motion to approve the Tax Incentive Policy and Guidelines as presented.

Check if the following Departments need to approve the item first:
Police Dept.
Fire Dept.
IT Dept.


For City Clerk Use Only:
Commission Action:
TAX INCENTIVES POLICY
 INFORMATION PACKET AND GUIDELINES
OVERVIEW:
A company that is in the planning phase of a major business attraction or expansion project that
will include a capital investment in real and/or personal property may be eligible for a number of
statutorily provided and locally approved tax incentives or abatements. The City of Muskegon
strives to apply these incentives with maximum return on investment for the developer and
community. The process for requesting and receiving an eligible tax incentive for a development
or expansion project has been simplified in the following policy guidelines and forms.

The City of Muskegon maintains this policy with the objectives of:
   • increasing employment opportunities for our residents,
   • diversifying and stabilizing the tax base of the community,
   • reducing functional obsolescence of existing buildings and lots,
   • encouraging expansion of our existing business base,
   • providing for improved housing and commercial amenities for the community,
   • encouraging attractive, viable building sites and
   • enhancing our economic development tools to attract and retain businesses

POLICY ELIGIBILITY CRITERIA:
1. A tax abatement shall not be granted until there is compliance with the associated state
statute; and
2. Leasehold property shall not qualify for a real property tax abatement unless applicant is
responsible for payment of the property taxes, and can demonstrate timely payment of property
taxes upon the City’s request; and
3. A tax abatement shall be issued for a term reflective of the points earned in the City’s scoring
matrix; and
4. A tax abatement shall not be issued unless an Applicant completes the attached application
form and provides all necessary documents to ensure accurate scoring by the Tax Incentive
Review Committee.

APPLICATION PROCESS:
Once a company has determined that it meets the minimum criteria for consideration of a tax
abatement, then a company may begin the process of formally applying for the relevant
incentive. The process is as follows:
1. Letter of Intent submitted on applicant’s letterhead to the Planning Director (No
improvements shall be considered for abatement if made or permitted prior to the approval of
the abatement application).
2. Complete any relevant Michigan Department of Treasury Forms. Include with the form:
        a. Cost Sheet for anticipated improvements in real property.
        b. Lease Agreement showing building terms and applicants’ tax liability (if applicable).
3. Submit application form and attachments to the City of Muskegon Planning Department.
4. Tax Incentive Review Committee verifies completion and eligibility of Applicant’s documents
for submission and makes recommendation to the City Commission regarding approval and
length of the requested abatement.
5. City Commission Public Hearings are scheduled.
6. City Commission votes on establishment of the District and approval of the associated
abatement (City Commission may also vote to reject any application for abatement).
7. Resolution submitted to State Tax Commission for final approval and issuance of certificates
where necessary.
8. Projected investment must be complete within two years or risk liability for any abated values.

LENGTH OF THE TAX ABATEMENT:
The City Commission has approved the use of the following matrices to calculate the length of
the associated tax abatement. The points in this scoring system are tied to community goals
endorsed by elected officials and staff, thereby rewarding and incentivizing specific development
types and values with additional potential years of abatement:

                          Cognate            Value Cognate                Value
                          PA 198                   PA 210, 255, 146
                 Taxable Value                0-5    Taxable Value         0-5
                 Job Creation                 0-3    Location              0-2
                 Resident Hiring              0-2    New Business          0-1
                                                     Resident
                                                     Owned/Managed         0-2
                 TOTAL                        0-10   TOTAL                 0-10



                                    PA 198 IFEC Scoring Guide
                               1-7 Points: 9-Year 50% Abatement

                              7-10 Points: 12 Year 50% Abatement

                             PA 210 Tax Abatement Scoring Guide

                            1-5 Points: 3 Years frozen taxable values

                            6-8 Points: 6 Years frozen taxable values

                           9-10 Points: 10 Years frozen taxable values
                             PA 255 Tax Abatement Scoring Guide

                                 1-5 Points: 4 Year Abatement

                                 6-8 Points: 8 Year Abatement

                                9-10 Points: 12 Year Abatement

                             PA 146 Tax Abatement Scoring Guide

                            1-5 Points: 4 Years frozen taxable values

                            6-8 Points: 8 Years frozen taxable values

                          9-10 Points: 12 Years frozen taxable values


TAX ABATEMENT APPLICATION FEE:
The City Commission has authorized the implementation of a non-refundable application fee of
$1,000.00 for Public Act 146, Public Act 255, and Public Act 210 abatement applications. Public
Act 198 tax abatement applications carry a non-refundable application fee equal to 2% of the
abated taxes, not to exceed $1,722.

REQUIREMENTS AFTER TAX ABATEMENT IS APPROVED:
By the December 31 that is two years after the December 31 of the year that the abatement is
approved, the applicant will supply the Planning Director with a letter confirming that the
purchases, employment numbers, renovations, and/or other applicable cognates are complete.
If these figures have not been reached, a letter of explanation must be submitted to the Planning
Director, for review by City Commission, which may then cancel the abatement, or offer a new
abatement with reduced values and years.

For assistance with your business attraction and retention needs, please contact the City
Economic Development Office at 231-724-6870. For assistance with the associated process and
application, please contact the City Planner’s Office at 231-724-6702.
                         Tax Incentive Policy Scoring Guide

INDUSTRIAL FACILITIES EXEMPTION (PUBLIC ACT 198)

TAXABLE VALUE: The City will consider the estimated additional tax base that the development
will generate based on plan review, assessor's analysis and permit fees. 1 point awarded for
$250,000 - $499,999 in taxable value, 2 points awarded for $500,000 to $749,999, 3 points
awarded for $750,000 to $999,999, and 4 points awarded for taxable value creation over
$1,000,000. Any improvement resulting in $5,000,000 or more in new taxable value will be
recommended for the full 12 year abatement. Additionally, any construction of a new industrial
facility will be recommended for the full 12 year abatement.
JOB CREATION: Up to 3 additional points can be earned by creating new full time jobs in the
City Limits. 1 point will be earned for 10 newly created jobs, 2 points for 11-24 jobs, and the full
3 points for 25+ jobs. Any development creating 100 or more jobs in the first three years will
recommended for the full 12 year abatement.
RESIDENT HIRING: An additional point will be awarded if the proposed development will
commit to employing 10% of its full time staff from within the city limits, and an additional 2
points will be awarded if the proposed development will commit to employing 20% of its full
time staff from within the city limits.



COMMERCIAL REHABILITATION TAX ABATEMENT (PUBLIC ACT 210)
COMMERCIAL REDEVELOPMENT DISTRICT ABATEMENT (PUBLIC ACT 255)
OBSOLETE PROPERTY REHABILITATION ACT (PUBLIC ACT 146)

TAXABLE VALUE: The City will consider the estimated additional tax base that the development
will generate based on plan review, assessor's analysis and permit fees. 1 point awarded for
$150,000 to $249,999 in taxable value, 2 points awarded for $250,000 to $499,999, 3 points
awarded for $500,000 to $749,999, and 4 points awarded for $750,000 to $999,999, and 5
points for taxable value creation over $1,000,000. Any development creating a taxable value
over $5,000,000 will recommended to receive the full abatement.
LOCATION: An additional two points will be awarded to a development if it is proposed in one
of the City's identified Commercial or Residential Redevelopment Areas (map attached).
NEW BUSINESS: An additional point will be awarded if the development is being proposed by a
commercial entity or housing developer that has not previously developed in the City of
Muskegon.
RESIDENT OWNER: An additional two points will be awarded if the proposed business or
development is owned or managed by a City of Muskegon resident.
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                                                                                                                                                                                                                                                                                                                                                                                                                                                             WESTERN                                                                                                                                                                                                                                                                                                     ON                                                                                                                                STRONG                                                                                                                                                                                            HL
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        M                                                                                                                                                                                                                                                                           NE                                                  UG
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             TH




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    HE                                                     MC
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             9T




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                H




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         L
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               AS




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           NN




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    AR
                                                                                                                                                                                                                                                                                                                                                                                                                                                                          MICHIGAN                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      BA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 FRANCIS




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       TH
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    ST                                                                                                                                                                                                                                                     CA                                                                                       BENTON




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          U
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               R
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       JEFFERSON
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         RA




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   WASHINGTON                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             MANGIN                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         WINSLOW
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              O
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             WASHINGTON




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 M
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                BEIDLER




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    VINE




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              RN
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      JIROCH
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     GRAND




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         AW




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               GLADE




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                GRAND                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     BUSH                                                                                                                     BUSH

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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             KINGSLEY
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          DIVISION




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           5TH
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              FRANKLIN




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     SOUTHERN                                                                                                                                                                                                                                                                                                                                                                                                                                                                           GRAND




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            TERRACE
                                                                                                                                                                                                                                                                                                                                                M                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          S                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           OAK PARK                                                                OAK PARK
                                                                                                                                                                                                                                                                                                                                                 CG
                                                                                                                                                                                                                                                                                                                                                      RA                                                                                                                                                 FOREST
                                                                                                                                                                                                                                                                                                                                                                                          FOREST
                                                                                                                                                                                                                                                                                                                                                        FT                                                                                                                                                                                                                      FOREST                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  EMERSON
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      7TH




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  KREGEL
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        MESSLER
                                                                                                                                                                                                                                                                                                                                                                       Y




                                                                                                                                                                                                                                                                                                                            VE                                                                                                                                                                                                                                                                                                                                                                                                                                                               FOREST                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     KREGEL                                                                                                                                                                                                                                                           KREGEL
                                                                                                                                                                                                                                                                                                                                                                     ER




                                                                                                                                                                                                                                                                                                                              R                                                                                                                                         IRELAND                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           FOREST                                                                                                                                                                                        FOREST
                                                                                                                                                                                                                                                                                                                                  NO
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                                                                                                                                                                                                                                                                                                                                                                    M




                                                                                                                                                                                                                                                                                                                                              IV
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             GLADE




                                                                                                                                                                                                                                                                                                                                    N                                                   DALE                                                                                                                                       IRELAND
                                                                                                                                                                                                                                                                                                                                                               G




                                                                                                                                                                                                                                                                                                                                                Y
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                                                                                                                                                                                                                                                                                                                                                        NT




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                                                                                                                                                                                                                                                                                                                                                     O




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        DALE




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    SAUTER
                                                                                                                                                                                                                                                                                                                                                    M




                                                                                                                                                                                                                                                                                                                                        EL                                                                                                                                DALE                                                                                                                                                                                                                                                                                                                                                                                                  JEFFERSON
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            G
                                                                                                                                                                                                                                                                                                                                                                    MCGRAFT




                                                                                                                                                                                                                                                                                                                                          M                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    DALE




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                                                                                                                                                                                                                                                                                                                 SC                                                                                                                                                                                                          DALE                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            RA                                       DALE                                                                                                            DALE                                                                        DALE




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  DALE                                                                                                                    CE




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           CRESTON
                                                                                                                                                                                                                                                                                                                    H       UY                                                          LARCH




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           BROADMOOR
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            EDWIN




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      BURTON
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          VULCAN



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                                                                                                                                                                                                                                                                                                                                 LE                                                                                                                                     LARCH                                                                                                    LARCH
                                                                                                                                                                                                                                                                                                                                    R
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         LARCH                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         AURORA                                                                                     AURORA                                                                                                                                                                                                                                                                                                            EV                                                                                                                            AURORA
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      AN




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     CLINTON
                                                                                                                                                                                                                                                                                                                 M                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          LARCH                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                ST
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    ON




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        SMITH
                                                                                                                                                                                                                                                                                                                  O
                                                                                                                                                                                                                                                                                                                        O




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           WIERENGO
                                                                                                                                                                                                                                                                                                   G                     RE                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     LARCH                                                                    LARCH
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  FAIRVIEW




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              MCILWRAITH
                                                                                                                                                                                                                                                                                                    RE
                                                                                                                                                                                                                                                                                                         EL




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      SUPERIOR
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           ELWOOD
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 MANZ
                                                                                                                                                                                                                                                                                                            EY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            TUR NER




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    DYSON
                                                                                                                                                                                                                                                                           ER
                                                                                                                                                                                                                                                                         LM




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                LAKETON




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                                                                                                                                                                                                                                                                       PA




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             FRANKLIN




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                LAKETON
                                                                                                                                                                                                                                        FRI




                                                                                                                                                                                                                                                                                                                                                                                                                                                                          NEVADA




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               5TH
                                                                                                                                                                                                                                                                                                       N




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                RAY
                                                                                                                                                                                                                                            SB




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                NI
                                                                                                                                                                                                                                                                                                     LA




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    ALPHA




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   AUSTIN
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      TEMPLE




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  M




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                                                                                                                                                                                                                                                                                                   NO




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  COMMERCE
                                                                                                                                                                                                                                               IE




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  WINDSOR                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          S
                                                                                                                                                                                                                ADDIS




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             JIROCH

                                                                                                                                                                                                                                                                 RO




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    CONTINENTAL
                                                                                                                                                                                                                                                                   IL
                                                                                                                                                                                                                                                                      SO




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      BAR BARA
                                                                                                                                                                                                                  ON




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               VALLEY
                                                                                                                                                                                                                                                                           N                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               HOLBROOK
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                CLINTON




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       ROUSE
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                REYNOL DS
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    HOLBROOK




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       HOWDEN
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 SHELBY




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            INTERWOOD
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              CROWLEY




                                                                                                                                                                         ON
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         KINSEY




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      BRUNSWICK
                                                                                                                                                                 IS
                                                                                                                                                              RR




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 RIAL
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            HUIZENGA




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                                                                                                                                                            HA                                                                                                                                                                                                                                                                                                                                YOUNG
                                                                                                                                                                                                                                                                                                                                                                        YOUNG
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          GLADE




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         US 31 SB
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  YOUNG




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           INDUST
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         EV




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                                                                                          O           RE                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   AN
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      ST
                                                                                      ESH                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  KEATING                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       ON
                                                                                  LAK
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      HUDSON




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            LYMAN                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              KEATING




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         WOOD
                                                                                                                               MA




                                                                                                                                                                                  FAIR                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          KEATING                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            KEATING
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      KEATING
                                                                                                      ON                                                                                                                                                                                                                                                            WOODCREEK
                                                                                                                                                                                                                                                                                                                                                                                                                 PARSLOW
                                                                                                                                 NN




                                                                                                                                                                                               BOURDON
                                                                                                                                                                                   ESTES




                                                                                        RIS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     KEATING




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   BURTON
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        KEATING




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             DYSON
                                                                                    HAR




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               WOODWARD
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              THERESA
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            WILSON
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               7TH
                                                                                                                                                                                                                                                                                                                                                                                                 VAN DINTHER




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           WILSON                                                                                                                                                                                              DELANO
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          GLADE
                                                                                                                                                  TORRENT




                                                                                                                                                                                                                                                                                                                                                                                                                                                             ROYALE GLEN
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        SAN FORD




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      REMEMBRANC E
                                                                                                                                                              BLODGETT




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             DELANO




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     ELWOOD
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           DOWD




                                                                                         ER
                                                                                     MIN                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             HANCOCK
                                                                                                                                                                                                                                                                 M




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         CENTER
                                                                                                                                                                                                                                                                  CG
                                                                                                                     MO




                                                                                                                                                                                                                                                                                                                             RO




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     MCILWRAITH
                                                                                                                                                                                                                                                                    RA




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 HARVEY
                                                                                                                                                                                                                                                                                                                               SE                                                                                                                                                                                                                                                                                                                                                                                                                                                 MANN
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           HOWDEN
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     HOYT
                                                                                                                        ON




                                                                                                                                                                                                                                                                      FT




                                                                                                                                                                                                                                                                                                                                 W                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    LATIMER
                                                     DEN




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                LEAHY
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        HENRY




                                                                                                                                                                                                                                                                                                                                          OO
                                                                                                                                                                                                                                                                                                                                                                                                                                                       BAR CLAY
                                                                                                                                                                                                                                                                               PK




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            SUPERIOR
                                                                                                                                                                                                                                                                                                                                            D                                                                                                                                                                                             HACKLEY
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             9TH
                             LEON

                                                      MA




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              POLISKI
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 BEIDLER




                                                                                                                         G




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            CONTINENTAL
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         5TH
                                                        RK




                                                                                                                   DIN
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   STEIN




  MORTON                                                                                                  HAR




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          AUSTIN
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    JEFFERSON




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         VALLEY
                                                                                                                                                                  GLEN
                                                                                                                                                                                                                                                                                                                                                                                                                                   VINCENT




                                                                                                                                                                                                                                                                     GLEN                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         HACKLEY
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         HACKLEY
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          MAFFETT
                                                                                                                                                                                                                                                                                                                                                                                         CREEKVIEW




  HARDIN G
                                                       IN G
                                                                                                                                                                                                                                                                                                                                                                                                               PARK




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        LEMUEL



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                                                D                                                                                                                                                                                                                                                                                                                                                                                                                                                                              BAR NEY
                                            HAR                                                   N
                                                                                      SO
                                                                                  SIS
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          WAALKES




                                                                                                                                                                                                                                                                    RIDGE                                                                                                                                                                                                                                                                                                                                                                                                                                                                             BAR NEY
               CROZIER                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       BAR NEY




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               ELWOOD
                                                                                                                                G




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          ALBERTA
                                                                                                                                                                                                                                                                                    CUMBERLAND




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           BEIDLER
                                                                                                                                 R




                                                                                                                                                                                                                                                              LEXINGTON
                                                                                                                                  EE




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          MANZ
                                                                                                                                                                                                                               HADDEN




                                                                                                                                                                                                                                                                                                                                                GLE
                                                                                                                                    N




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    REYNOL DS




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             BLACK CRK
                                                                                                                                           W




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          BR 31 SB
                                                                                                      MCCRACKEN




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     GLADE
                                                                                                                                                  O




                                                                                 CUTLER
                                                                                                                                                                                                                                                                                                                                                    N




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       RAMP
                                                                                                                                                  O




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              PULASKI                     PULASKI
                                                                                                                                                                                                            WESTWOOD
                                                                                                                                                   D




                                                                                                                                                                                                                                                                                                 BEARDSLEY                                                                                                                                     WILD WOOD                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              IVORY
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         HOVEY
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    BAKER




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   US 31 SB TO SHERMAN
                                                                                                                         PHILO                                                                                                                                                                   RANDOLPH                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       HOVEY
                                                                                                                                                                                                                                                WICKHAM




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              HOVEY
                                                                                                                                                                                                                                                                                                                                                        PINE GRV




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             RIOR DAN




                                                                                     LETART                                                                                                                                                                                                      WINCHESTER                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               HOWELL
                      LEON




                                                                                                                                        TORRENT




                                                                                                                                                                                                                                                                    MONTAGUE                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  HUME                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     MERCY
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     SUPERIOR




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             SUN DOLPHIN
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 OLTHOFF
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             JEFFERSON




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            ELWOOD
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   5TH




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    DYSON




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       8TH




  WARREN
                                                                                      BEL LEVUE




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       RAY




                                                                                                                               LINDBERG
  CHARLES
                                                                                                                                                                                                                                                                               PUBLIC ALLEY
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    BR 31 NB
                             FOREST HILLS




                                                                       LIBERTY




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       EMERSON
                                                       PINEHURST




                                                                                                                  BUNDT                                      BUNDT
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       PARK
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  FAIRFIELD




   HUGHES                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                SHERMAN
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       9TH




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          6TH




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            JARMAN




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          SEAWAY




                                                                                                                               MANOR




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  UTAH




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           OAK
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    TEMPLE




 NORMAN                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          BEU LAH
                                                                                                                                                                         ESTES




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  THIRD
                                                                   NORMAN                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              IDAHO
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         MANAHAN                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         PEN


                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     BLUE JAY

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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  MAPLE                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      N
                                                                                                                                                                                                                                                                                                                 GLENSIDE




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            ROBERTS
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     MANAHAN




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  VULCAN
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             PLAZA DRIVE W




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   MAIN MAIN




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   VAL K
                                                                                                                                                    HARBOR                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     MANAHAN




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     SHERIDAN
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               U S31 NB
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      OREGON
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            PARK




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  MCARTHUR
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        MCILWRAITH




                                                                                                                                                                                                                                                                           GARRISON




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                                                                                                                                                                                                                                                                                                                                                                   BROADWAY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        CENTER




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         GRIFFIN



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                                                     PLAINFIELD




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            KRUGER
                                                                                                                                                                                                                                                                                                                                                                                                                                                   D                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              MANAHAN
                                                                                                                                                                                                                                                                                                           CORNELL                                                                                                                       AN
                                                                                                                                                                                                                                                                                                                                                                            DAWES




                                                                                                                                                                                                                                                                                                                                                                                                                                       TL
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       MAPLE GRV
               LEON




                                                                                                                                                                                                                                                                                                                                                                                                                                      S
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              CONTINENTAL




                                                                                                                                                                                                                                                                                                                                                                                                                                    E
                                                                                                                                                                                                                                                                                                                                                                                                                                                       LT
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     JEFFERSON
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                BR 31 SB




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               WAALKES




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   OAKRIDGE




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      MCDERMOTT
                      LINCOLN PARK
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 BRUNSWICK

                                                                                                                                                                                                                                                                                                                                                                                                                                   W
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               LEMUEL




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              MAFFETT




                                                                                                                                                                                                                                                                                                                                                                                                                                                     VE
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   MADI SON




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           FAIRFIELD
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                SHEFFIELD




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          AUSTI N



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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     PARK




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         WORDEN
                                                                                                                                                                                                                                                                                                           SUMMIT                                                                                                                                                            D



                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           BAILEY
                                                                                                                                                                                                                                                                                                                                                                                                                                                   SE
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      LEAHY
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               GLADE




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             5TH




                                                                                                                                                                                                                                                                                                                                                                                                                                                                          AN
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 M




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              VALK
                                                                                                                                                                                                                                                                                                                                                                                                                                               O                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             KOOI




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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  AS




                                                                                                                                                                                                                                                                                                                                                                                                                                                                        TL
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        RO




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   PANZL
                                                                                                                                                                                                                                                                                                                                                                                                                                             RO




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           OAK
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     O




                                                                                                                                                                                                                                                                                                                                                                                                                                                                    S                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            K
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          Y




                                                                                                                                                                                                                                                                                                                                                                                                                                                                  EA
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              N




                         MAYFAIR
                                                                                                                                                                                                                                                                                                   PRINCETON
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      POST                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    OA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      COLUMBIA
                                                                                                                                                                         BONNEVILL E                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  COLUMBIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           YARMOUTH
Environmental Building Standards Committee Recommendation
April 4, 2020


REVIEW

Current energy code standards equate to LEED baseline certification. If we want to incentivize
construction that meets a higher standard, we can only include stricter or higher level
certification.

Costs to reach higher levels of LEED certification far outweigh any tax abatement we could
offer, and therefore would not result in the incentive we were hoping to provide.
LEED construction is 3.3 – 8.5% more than standard construction plus certification fees from
$20,000 to $60,000. If we average the value of all the IFT abatements currently within the city,
a company can count on about $4,000 per year in reduced taxes paid to the city. If the points
awarded to the developer provide another 3 years of abatement, they can expect to save
$12,000. That amount does not cover the certification fees, let alone the additional
construction costs.

Only 6 states have municipalities that offer tax refunds/abatements/credit. The Cincinnati
program has been under scrutiny and is being redesigned. Chatham County, Georgia offers full
property tax abatement for 5 years, then reduces the abatement by 20% for the next 5 years
for any commercial building that reaches gold certification. Current incentives given by a
municipality within Michigan only apply to municipal buildings. In other local agencies
throughout the country, policies are more related to providing faster permit reviews, a density
bonus, or cash toward construction costs. A density bonus would not be applicable in
Muskegon at this time since we have so much vacant land ready for construction. Any program
that offers cash toward construction would be developed outside the tax incentive policy.
Ideas related to faster permit reviews and the possibility of adding certain green practices to
our building code such as material conservation, use of recycled material, or a requirement to
use LED lights were presented to Public Safety.
Environmental Building Standards Review and Recommendation                               Page 2


We can make a larger impact on the environment (reducing carbon emissions) by using proper
planning principles and developing a walkable, bikable, transit friendly city. Reducing the need
for and use of cars will provide a significant and lasting impact on the environment. An EPA
study entitled “Location Efficiency and Building Type – Boiling It Down to BTUs” compared four
factors: drivable versus walkable location; conventional construction versus green building;
single-family versus multifamily housing; and conventional versus hybrid automobiles. The
study made it clear that none of the factors contributed as much as walkability. It showed
specifically how, in drivable locations, transportation energy use consistently tops household
energy use, in some cases by more than 2.4 to 1. The most green home in sprawl still loses out
to the least green home in a walkable neighborhood.


RECOMMENDATION

   •   Approve the tax incentive policy without inclusion of points for green building
       practices.
   •   Continue to incorporate good planning principles when guiding potential developers
       and approving site plans.
   •   Work with Safebuilt to develop building code modifications to require material
       conservation, the use of recycled materials when available, and the inclusion of LED
       lighting.
   •   Work with Safebuilt to accelerate permit review processes for buildings that are LEED
       certified.
Environmental Building Standards Supporting Data
April 4, 2020


Michigan Energy Code

•            Incorporates the International Energy Conservation Code (IECC) – this is a model code that
             regulates minimum energy conservation requirements for new buildings.

•            The Michigan Energy Code is intended to provide flexibility to permit the use of innovative
             approaches and techniques.

LEED (Leadership in Energy Environmental Design program) is a green design mission which
promotes design and construction practices with the idea that an increase in energy efficiency
will lead to a decrease in expenditure.

             •           Companies pay LEED to critique a building’s green design based off criteria developed by
                         the U.S. Green Building Council (USGBC) and labeling it Certified, Silver, Gold, or
                         Platinum. If the building does not meet the USGBC’s criteria, LEED will deny certification.

             •           USGBC - launched an online data visualization resource that highlights real-time green
                         building data for each state in the U.S. It highlights LEED projects, LEED-credentialed
                         professionals, and USGBC membership in each state.
                         https://www.usgbc.org/resources/state-market-brief

             •           LEED project data below only includes commercial rating systems. USGBC green building
                         data from each state – LEED-credentialed professionals, member organizations and
                         LEED projects.


                                LEED ACHIEVEMENT PROJECTS, 1/7/20
                                                        Certified       Silver        Gold     Platinum
                                                                                                       638
                                                      622
                                                            605
    NUMBER OF PROJECTS




                                                368




                                                                                                             352
                                                                                                 287
                         280
                               230
                                     174




                                                                                                                              159
                                                                                                                                    151
                                                                                                                        132
                                                                               118
                                                                         110
                                                                  109




                                                                                     109




                                                                                                                   30




                                                                                                                                          27
                                           26




                                                                                           7




                                MI                      IL                       IN                     OH                     WI
                                                                               STATE



EPA’s Energy STAR program
   • This program helps to calculate the returns on energy efficiency investments by way of
       various calculators based on cash flow opportunity, financial value and building upgrade
       values.
Environmental Building Standards Supporting Data                                          Page 2

Energy Vanguard
   • A diminishing return can take place whereby adding additional energy efficient
       materials to a structure results in smaller increments of efficiency.




•   Examples of incentives offered across the U.S. - Financial incentives / Expedited permitting /
    Property tax reductions or abatements for significant periods of time / Density bonuses /
    Accelerated building permit processing / Free publicity

•   The cost to obtain LEED certification can depend upon a variety of factors and expectations.
    The U.S. Green Building Council (USGBC) indicates the cost to obtain LEED certification can
    depend on factors/expectations:

       o Type and size of project / timing of introduction of LEED as a design goal or
         requirement / level of LEED certification desired / composition and structure of the
         design and construction teams / the process used to select LEED credits / clarity of
         the project implementation documents / base case budgeting assumptions

•   Fees charged by the U.S. Green Building Council to earn LEED are expensive - $20,000 to
    $60,000.

•   One of the first LEED cost studies was published in October 2003 by KEMA, an energy
    consulting company. The total project cost LEED certification premiums identified in the
    KEMA study continue to be among the most commonly cited:

       o   LEED Certified – 0-2.5 percent
       o   LEED Silver – 0-3.3 percent
       o   LEED Gold – 0.3-5.0 percent
       o   LEED Platinum – 4.5-8.5 percent

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