HomeMy WebLinkAboutStaff Report 3.E 01/09/2012 Age Iteivw#3 .E
z ■LU
185e,
DATE: January 9, 2012
TO: Honorable Mayor and Council Membe s'ihrough City Manager
FROM: John Brown, City Mana
Gaebler, Housing Administrator
SUBJECT: Resolution Electing To Serve As the Successor Agency to the Petaluma
Community Development Commission (PCDC) Pursuant to Health and Safety
Code Section 34177
RECOMMENDATION
It is recommended that the City Council adopt the attached Resolution Electing To Serve As the
Successor Agency to the Petaluma Community Development Commission (PCDC) Pursuant to
Health and Safety Code Section 34177.
BACKGROUND
Responding to a declared state fiscal emergency, in the summer of 2011 the State Legislature
enacted two measures intended to stabilize school funding by reducing or eliminating the
allocation of property tax revenues to the State's redevelopment agencies ("RDA's").
Assembly Bill IX 26 (the "Dissolution Act") bars RDA's from engaging in new business and
provides for their windup and dissolution. AB IX 27 offered an alternative: redevelopment
agencies could continue to operate if the cities and or counties that created them agreed to make
payments into funds benefitting the school and special districts. In October 2011, the California
Redevelopment Association (the"CRA") and League of California Cities (and others) sought
relief from both bills from the California Supreme Court.
On December 29, 2011, the California Supreme Court delivered a bifurcated decision, effective
immediately, determining that all RDAs will be dissolved under the Dissolution Act and that
none will have the opportunity to "opt into" continued existence under AB 1X 27. Although the
CRA and various housing development advocacy groups (including many of Petaluma's
nonprofit agencies) have indicated their intent to seek legislative relief to continue economic
development and affordable housing activities in California, it is premature to speculate on the
nature or likely outcome of such proposals.
Therefore, there are certain decisions and actions that each city or county (the "Sponsoring
Community") that established an existing redevelopment agency must make in January 2012.
The first requires a Council decision as to whether or not it will designate the City as the
"Successor Agency" to the Petaluma Community Development Commission. _ _
Agenda Review:
City Attorney Finance Director City Manager
DISCUSSION
The Dissolution Act, which was found to be constitutional by the Supreme Court, does the
following:
• Continues to suspend and prohibit of most redevelopment activities in effect since late
June 2011
• Dissolves RDAs as of February 1, 2012
• Creates "Successor Agencies" and local "Oversight Board" to continue to satisfy
enforceable obligations of each former RDA, and administer the dissolution and
wind-down of each dissolved RDA; and
• Establishes roles for,the County-Auditor Controller, the Department of Finance and the
' State Controller's Office in the dissolution process and satisfaction of enforceable
obligations of former RDAs.
As noted above, as of February 1, 2012 every RDA will be dissolved and a Successor Agency
will be created for each RDA. The Successor Agency will be the Sponsoring Community of the
RDA (the City) unless it elects not to serve in that capacity. Technically, a Sponsoring
Community needs to adopt a resolution and deliver it to the County Auditor-Controller no later
than January 13, 2012 only if it elects not to act as the Successor Agency for its former RDA.
(An alternative resolution declining to serve as Successor Agency is also attached). However,
staff has been advised by the City Attorney that a resolution electing to serve as Successor
Agency will indicate a clear statement of intent. Among other duties, the Successor Agency
will be responsible for staffing the Oversight Board which will make decisions about the
liquidation of RDA assets. The Oversight Board of the Successor Agency will consist of 7
members appointed by the following agencies: County Board of Supervisors (two members);
Mayor (one member); County Superintendent of Education (one member); Chancellor of
California Community Colleges (one member); Largest special district taxing entity (one
member); and a former RDA employee appointed by the Mayor (one member). Any decisions
made by the Oversight Board are subject to review by the State Department of Finance and the
State Controller's Office. The advantages of serving in this capacity are clearly defined in the
Fiscal Impact section below.
If Council chooses not to assume that role, the Successor Agency will be "the first taxing entity
submitting to the County Auditor-Controller a duly adopted resolution electing to become the
"Successor Agency." If no taxing entity steps forward, the Governor will appoint three County
residents to serve in that capacity.
FISCAL IMPACTS
The City's financial liability for serving as the Successor Agency is expressly limited in Health
& Safety Code Section 34173(e) to the property tax increment the Successor Agency receives to
pay enforceable obligations and the value of any PCDC assets transferred to it, so the City's
2
General Funds and other funds are not expected to be at risk if the City elects to be the Successor
Agency to the dissolved PCDC.
The Enforceable Obligation Payment Schedule (Attachment #2) that was approved by the City
Council lists all PCDC enforceable obligations through 2011. It will be amended to cover the
period January 1 through June 30, 2012 and will cover the obligations that will be paid by the
Successor Agency, using bond proceeds as well as any balance in the redevelopment funds, until
the Successor Agency can adopt, and the Oversight Board approves, a Recognized Obligation
Payment Schedule
There are significant financial impacts resulting from the dissolution of PCDC. PCDC's
Administrative Fund (Fund 5400) with a balance of approximately $14,000,000 and the Housing
Fund balance of$2,100,000 are in jeopardy of being transferred to the County for distribution
among the taxing entities after payment of the enforceable obligations.
The new property tax revenue to the City's General Fund generated from PCDC's dissolution
will be approximately $498,000 annually. This amount could increase or decrease depending on
changes in assessed valuation.
An "administrative payment" to the Successor Agency is provided in Fiscal Year 2011-12 at 5%
of the former RDA's tax increment, which should be approximately $700,000 and 3% each year
after that but not less than $250,000 annually. This payment is given to the Successor Agency to
meet the administrative expenses of serving as the Successor Agency, winding down the
redevelopment agency, and continuing with its obligations (including administering debt
repayment, staff support to the Oversight Board, filing State Controller's reports and associated
mandated activities.) If Petaluma does not elect to become the Successor Agency, the
administrative funds will be paid to the agency that does accept that role.
Additionally, for the Council's information, the loss of redevelopment funding to administrative
and personnel costs for the current fiscal Year 2011-2012 will be $891,550. The majority of
these expenses will be covered by the administrative payment that is made to the Successor
Agency. The funding for current redevelopment programs and all Housing programs could be
lost even though the City took steps last year to protect the funding for programs and other assets
of the agency. The positions currently allocated, in full or in part to the Redevelopment budget
are:
• City Manager 50%
• Finance Director 30%
• Economic Dev. Manager 100%
• Housing Administrator 100%
• Housing Coordinator 100%
• Senior Planner 20%
• Proj. Mgr—Green Building 20%
• Engineering Manager 5%
3
ATTACHMENTS
I. Exhibit#1: Resolution Electing.to Serve as Successor Agency
Exhibit#2: Resolution Declining to Serve as Successor Agency
2. Current Enforceable Obligation Payment Schedule(EOPS)
s/housing/s"cc essoragencysta((report
4
ATTACHMENT#1
EXHIBIT 1
RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PETALUMA
ELECTING TO SERVE AS SUCCESSOR AGENCY TO THE PETALUMA
COMMUNITY DEVELOPMENT COMMISSION PURSUANT TO HEALTH AND
SAFETY CODE SECTION 34177
WHEREAS, the City Council of the City of Petaluma ("City") approved and adopted
the Redevelopment Plan for the Central Business District Redevelopment Project and the
Petaluma Community Development Project ("Redevelopment Plans") covering certain properties
with the City ('Project Area"), pursuant to the California Community Redevelopment Law
(Health and Safety Code Section 33000 et seq.) (the"CRL"); and
WHEREAS, the Petaluma Community Development Commission ("Commission") is a
redevelopment agency engaged in activities to execute and implement the Redevelopment Plans
pursuant to the CRL; and
WHEREAS, the California Legislature adopted, the Governor signed, and the California
Supreme Court, in California Redevelopment Association, et al. v. Ana Matosantos, et al., has
upheld ABX 1 26, legislation that amends the CRL; provides that the Commission will be
dissolved effective as of February 1, 2012; and empowers a designated "successor agency"to
wind down the affairs of the Commission, subject to review and approval by a local Oversight
Board and the State of California; and
WHEREAS, ABXI 26 designates the city that created a redevelopment agency as the
successor agency; and
WHEREAS, ABXI 26 further provides that the City may elect not to serve as the
successor agency, provided that it files a duly authorized resolution of its governing body to that
effect with the county auditor-controller; and
WHEREAS, the California Supreme Court has determined that such resolution must be
adopted and filed with the county auditor-controller no later than January 13, 2012; and
WHEREAS, under ABXI 26, if a city that authorized the creation of a redevelopment
agency elects not to serve as a successor agency, the county auditor-controller shall determine
the first local agency in the county that elects to become the successor agency, or, if no local
agency elects to serve as the successor agency, the Governor shall appoint three county residents
to serve as the governing board of a designated local authority serving as a successor agency,
until a local agency elects to become the successor agency; and
WHEREAS, the City Council of the City of Petaluma believes that it is in the best
interest of the community for the City to serve as the successor agency to the Commission
pursuant to ABXI 26.
5
NOW THEREFORE, BE IT RESOLVED by the City Council of the City of Petaluma
as follows:
Section 1. All of the recitals above are true and correct and incorporated herein.
Section 2. Based on the foregoing recitals and the information provided to the City
Council by City staff, the City Council hereby declares that the City of Petaluma elects to serve
as successor agency to the Petaluma Community Development Commission and to assume the
responsibilities, rights and powers of a successor agency pursuant to Health and Safety Code
Section 34177 and other applicable law.
Section 3. The City Manager is hereby authorized to take all action necessary to
effectuate this Resolution.
Section 4. This Resolution is effective on the day of its adoption.
Section 5. If any provision, clause, section or part of this Resolution is found to be
unconstitutional, illegal or invalid, such finding shall affect only such provision, sentence,
clause, section or part, and shall not affect or impair any of the remaining parts.
•
6
EXHIBIT 2
RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PETALUMA
DECLINING TO SERVE AS SUCCESSOR AGENCY TO THE PETALUMA
COMMUNITY DEVELOPMENT COMMISSION PURSUANT TO HEALTH AND
SAFETY CODE SECTION 34173(d)(I)
WHEREAS, the City Council of the City of Petaluma ("City") approved and adopted
the Redevelopment Plan for the Central Business District Redevelopment Project and the
Petaluma Community Development Project ("Redevelopment Plans") covering certain properties
with the City ("Project Area"), pursuant to the California Community Redevelopment Law
(Health and Safety Code Section 33000 et.seq.) (the "CRL"); and
WHEREAS, the Petaluma Community Development Commission ("Commission") is a
redevelopment agency engaged in activities to execute and implement the Redevelopment Plans
pursuant to the CRL; and
WHEREAS, the California Legislature adopted, the Governor signed, and the California
Supreme Court, in California Redevelopment Association. et al. v. Ana Matosantos, el al., has
upheld ABX 1 26, legislation that amends the CRC; provides that the Commission will be
dissolved effective as of February 1, 2012; and empowers a designated "successor agency" to
wind down the affairs of the Commission, subject to review and approval by a local Oversight
Board and the State of California; and
WHEREAS, ABXI 26 designates the city that created a redevelopment agency as the
successor agency; and
WHEREAS. ABXI 26 further provides that the City may elect not to serve as the
successor agency, provided that it tiles a duly authorized resolution of its governing body to that
effect with the county auditor-controller; and
WHEREAS, the California Supreme Court has determined that such resolution must be
adopted and filed with the county auditor-controller no later than January 13, 2012; and
WHEREAS, under ABXI 26, if city that authorized the creation of a redevelopment
agency elects not to serve as a successor agency, the county auditor-controller shall determine
the first local agency in the county that elects to become the successor agency, or, if no local
agency elects to serve as the successor agency, the Governor shall appoint three county residents
to serve as the governing board of a designated local authority serving as a successor agency,
until a local agency elects to become the successor agency; and
WHEREAS, the City Council of the City of Petaluma does not believe that it is in the
best interest of the community for the City to expend the time and resources required to serve as
the successor agency pursuant to ABXI 26.
NOW THEREFORE, BE IT RESOLVED by the City Council of the City of Petaluma
as follows:
7
Section 1. All of the recitals above are true and correct and incorporated herein.
Section 2. Based on the foregoing recitals and the information provided to the City
Council by City staff, the City Council hereby declares that pursuant to Health and Safety Code
Section 34173(d)(1), the City of Petaluma elects not to serve as successor agency to the Petaluma
Community Development Commission. The City Council so resolves with full recognition that
another entity, yet to be determined, will serve as the successor agency to the Commission, and
that Commission assets and enforceable obligations will be administered by an entity other than
the City of Petaluma.
Section 3. The City Manager is hereby authorized to take all action necessary to
effectuate this Resolution.
Section 4. The City Clerk is hereby directed to transmit a copy of this Resolution to
the Sonoma County Auditor-Controller by or before January 13, 2012.
Section 5. This Resolution is effective on the day of its adoption.
Section 6. If any provision, clause, section or part of this Resolution is found to be
unconstitutional, illegal or invalid, such finding shall affect only such provision, sentence,
clause, section or part, and shall not affect or impair any of the remaining parts.
8
ATTACHMENT #2
Name of Redevelopment Agency: Petaluma Community Development Can.Msslon Pagel of t Pages
Project Area(s) Central Business District and Petaluma Cornniucly District
ENFORCEABLE OBLIGATION PAYMENT SCHEDULE
Per AB 26-Section 34167 and 34169(1
Total Outstanding Total Due During Payments by Mona,
Project Name/Debt Obligation Payee Description Debi or Oblige/Ion Fiscal Year Aug'- Sept Oct Nov Dec total
II 2001A Tax Allocations Bonds U.S.Bank Bonds Issued to tune non-housing projects 3.430,000.00 404,314.00 24657,00 $ '24,657.00
412003A Tax Allocations Bonds U.S.Bank Bonds issued to fund non-housing projects 17,710.475.02 1.505,07200 50500600 $ 505,00600
a 2005A Tar Allocations Bonds U.S.Bank Bonds Issued to fund non-housing projects 25509,20002 104481400 394.907.00 $ 394907.00
II 2007 Tax Allocations Bonds U.S:Bank Bonds issued to fund non-housing projects 51,440,120.18 1.597.012.00 683,506.00 $ 603,506.00
32011-Tax Allocations Bonds U.S.Bank Bonds Issued to fund non-housing projects 14396,633.60 1.194.576.00 27228800 $ 272,268.00
it Logan Place Burbank Housing 2 Loan for affordable housing project 1.700000.00 1,700,00000 1.700.000.00 $ 1.700.000.00
0 Employee Costs Employees of City Payroll and benefits for employees 713,150.00 713,15000 59.42900 59.42900 59,42900 59.429.00 $ 237,716.00
31 Lease payments Discovery Systems Payment for office equipment 1,828.00 1.02800 152.00 15200 15200 15200 $ 60800
31 Lease payments SMART Payment for railroad Meg 12,000.00 12,000.00 1,000.00 1.00000 100000 100000 $ 4,000.00
3)Lease payments Ice House LLC Payment for otfcespace 240000 2,400.00 200.00 200.00 200.00 200.00 $ 800.00
O Contract for services Petaluma Downtown Assn Payment for services 50,000.00 50,000.00 4,166.67. 4,16667 4,16667 4.16667 $ 16.666.68
Old Redwood Hw/Conlracl for
8 design consulting services URS Corp. Design 4.128.260.00 724.288.00 144,857.60 144,85760 144.857.60 144857.60 144857.60 S 724,288.00
p Auto Center Drive Ext./Design URS Corp. Design 29399000 1501080 3,75270 " 3,752.70 .3.752,70 3.752.70 $ 1501080
Auto Center Drive ExilConstrucfon
I)Contract FEDCO Construction Construct roadway 952,97000 243899.32 60.974.83 60,974.63 60,97483 60,97483 $ 243.899.32
Ante Center Drive Ext./Employee Employees of Cry of
i)Costs Pelalume Payroll for employees' 238.04000 238.04000 5951000 59510.00 .59,51000 59,51000 S 238,04000
Rainier Ave.Cross-Town
31 Connector/Contract for consulting Metropolitan Planning Group Planning 23100.00 23,100.00 462000 4620.00 4,620.00 4,62000 4,62000 $ 23,10000
Rainier Ave.Cross-Town
Ii Connector/Canned for consulting URS Corp. Envlronmenlal 056.14900 856,149.00 171.229.80 .171,229.60 171,229.80 17122980 17122980 $ 856,149.00
Petaluma River.Traln Contract for
1) consulting services CSWRluber-Stroeh Design 176,18000 4065162 '8.13152 8,131.52 8,131.52 8,131.52 8131,54 3 40657.62
Petaluma River Trail/Contract for
?I consulting-services.. Geoff Hornsby Right-of-way services 44.50000 9.50500 3,16833 3,16833 3,16833 $ 950499
US 101:East Washington
1l Inlerchange/Consulling Services URS Corp. Design 1,76404400 411,68900 82,337.80 8233180 82,337.80 6233180 82.337,80 $ 411,689.00
US 101 8 East Washington
is Interchange/Consulling Services Associated Right of Way Ser Right-of-way services 17690000 19.817 00 396300 3,96300 3,96340 3,963 40 396340 $ 19817.00
US 101&East Washington Sonoma Co.Transportation
91 inlerchange/Crcy matching funds Agency Local Agency matching funds 1,797,144.00 $ -
Old Redwood Miry/City matching Sonoma Co.Transportation
3l funds Agency Local Agency matching funds 14,829.000 00 $ -
Rainier Ave.Crass-Town Sonoma Co.Transportation
Ii Connector/Ctty matching funds Agency Local Agency matching funds 7,498,000.00 498,000.00 29000000 290,00000
• TOlele•:Thle Page 5 147,746,091 82 $ 11,30532134 4 539.377 65 4 604,125 32 6073493 65 2.487.857 55 2.473.256 14 6.71231041
Thiele-Paha2 i 5 - 4 - 5
forals•Page 3 8 - $ - it - $ - - - -
Totals.Pa9e4 $ - 9 4 4' - - . •Totals-0ther Obtgadons S 1144.512234 00 5' 5.190052.00 4 5' _ - - 2,59502600 2,595026 00
go:els-All Pagas i4 26225832582 $' 1649537374 4 539.377 65 5 60432032 607.491 55 2.467.957 55 5.009 282 14 9,307.33641
This Enforceable Obligation Payment S hed 1 (BOPS)is to be adopteBbylhe redevelopment agency no later than late August R is valid through 1291111.It Is the ba Is for the Preliminary Draft
Recognized Oblig tl P yrieMSchedule IROP51 wlrl h must beprepared by Me dl s I I g Ag y by 990/11 The draft ROES Oust be prepared hythe Successor Agency by 1190911.)
If an agency adOpti a continuation dl per ABX1 27 this EOP6 will not be valid and there la no need to prepare a BOPS.
Include any/payments to he made after the adoption of the EOP6.
9
•
• r •
Name.ot Redevelopmanl Agency: PelLUm(COmnunilyoevalopmarrl Commission Page 1 of Pages
Project Areais) Central Business Distinct and Petaluma Community Dialed
OTHER OBLIGATION.PAYMENT.SCHEDULE
Pen AG 26-Section 34167 and 34169(')
Total Outstanding Total Due During Payments by m onlh
Project Name/Deal Obligation Payee Description Debt or Obligation Elicit Year Aug" Sept Od Nov Dec Total
Il Section 33676 Payments General County Payments per former CRL 33676 :8,16362400 29155800 145.77900 $ 145.77900
2)Sedlon 33676 Payments• Cinnabar School Dish Payments per CRL 33676 350.39200 1251400 625700 $ .6257.00
-31 Section 33676 Payments Old Adobe Union School Payments per former CRL 33676 34650400 12.378.00 0,18900 S 6,189.00
4)Section 33676 Payments Pet.Coy Elem.Oat Payments per former CRL 33676 3.025.23200 100,04400 5402200 $ 54.022.00
5)Sevllon 33676 Payments- Waugh School Dist Payments per fernier CRL 33676. 304,892.00 1080900 5.44450 $ 5.444.50 '
6)Seclion 33676 Payments Pet.Coy Jl.High Dist Payments per former CRL 33676 5,109.07200 105324.00 92,662.00 S 92662.00
71 Section 33676 Payments SoCo.JI.Jr.College Payments per forme CRL'33676 1.543.472.00 55.12400 2756200 $ 27.56200
81 section 33676 Payments Pet.HIQNElem AWJF Payments per former CRC33676 3,256.596.00 116.307.00 58.15350 $ 58.15350
9)Pass Through Agreement County Payments per former CRC 33401 93.357.672.00 3.334,203.00 1667.10150 51667,101.50
107,Pass Through Agreement County-Library Payments per former CRL 33401 6,899.10500 246.399.00 123,19950 $ 123.19950
11)Statutory Payments County-General Payments per CRC336075. 2.97949300 115.259.00 57.62950 $ 57,62950
12)Statutory Payments County-Library Payments per CRL'33607.5 199,49800 7.71700 3,850,80 $ 3,05850
131 Statutory Payments Son.Co.Water Agency Payments per 02E33607.5 80,321 00 3,107.00 1.553.50 $ 1.553,50
14)Statutory Payments Spring Lake Pk-SCWA Payments per CRL 336075 25.91500 100300 501.50 $ .501.50
151 Statutory Payments Zone 2A-Pet.Basin Payments per CRL 33607.5 168,755.00 7,00000 3,500.00 $ 3,500.00
-16)Statutory Payments Marin Sonoma Mosquito Payments per CRL 336075 25,926.00 100300 50150 $ 501.50
171 Statutory Payments Bay Area Air Quality Dist Payments per CRL 33607.5 19,902 00 77000 30500 $ 38500
18)Statutory Payments South So.Res.Cn.Land Payments per CRL 336075 2,406.00 9300 46.50 $ 4650
191 Statutory Payments' Pet.City Elem.Dist' Payments per CRL 336075 1.555.477.00 60,172.00 30,086.00 4 30.08600
20)Statutory Payments Pet City it High School Payments per CRC'336075 1.093,289.00 73,24000 3662000 $ 36,620.00
21)Statutory Payments Soo .Jt.Jr.College Payments per CRC336075 563,107.00 2178100 10.891.50 $ 10,891.50
22)statutory Payments School SorvIce Admin Payments per CRC 33607,5 206,405.00 7,98500 3,99250 $ 3,99250
23)Statutory Payments PelHlgh/EIem AWUF Payments per CRC 336075 1.108.16200 45.963.00 2298150 $ 22981.50
241 Statutory Payments Schools Equalization Aid Payments per CRC 33607.5 33,576.00 1,299.00 64950 $ 64950
25)Statutory Payments Coy of Petaluma j Paym ants per CRL'33607.5 1.758.380.00 68,021.00 34.01050 $ 3401050
26)Statutory Payments Warm Springs Dam Payments per CRL 33607.5 74,90100 2,897.00 1448.50 $ 114050
27)Housing Fund Loan Repayment City lnLleu Housing Fund Repayment for houslnq fund 1.300,000.00 400.000.00 200.00000 $ 20000000
28)Properly Tax Collection Fee Sonoma County Collection Fee fortax Increment 244,429.00 '244,42900 122,21450 $ 122,21450
29)Browns-geld Program City at Petaluma Cooperative Agreement 400,000.00 50000.00 2500000 $ 25,000.00
301 Rental Assistance/Fair Housing Petaluma People Service Cooperative Agreement 204,000.00 204,000,00 102,000.00 $ 102000.00
31)Transitional Housing salvation Army Cooperative Agreement 75,000.00 75.000.00 37.500.00,$ 37,50000
32)Transitional Housing COTS Cooperative Agreement 332,40000 332600.00 166.200.00 $ 16620000
33)Mobile Home Rent Control Sonoma County Cooperative Agreement 15,000.00 15,000.00 7,500.00 $ 7,50000
34)Rehab single family homes Rebuilding Together Cooperative Agreement 250,000.00 . 250000.00 125.00000 $ 125,000.00
35)Ecos.DevJSlte Development City or Petaluma Cooperative Agreement 6.000,000.00 1.000.00000 500,000.00 $ 500,000.00
[Totals-Other Obligations I f.34,512,234.001$ 5,190,052.001$ - I$ • I$ - Is - Is 1,595,026.00 I$2,595,026.00
•This Enforceable Obligation Payment Schedule(COPS)Is to be adopted byte redevelopment agency no later than late August.k la valid through 12/31111.11 Is @e baste for the Prellninary Draft
Recognized Obligation Payment Schedule(BOPS),which most be prepared by tha dissolving Agency by 0130111./The draft ROPS must be prepared births Successor Agency by 11130/114
if an agency adopts a continuation ordinance per AO%117,this COPS will not be valid and there Is no need to prepare a ROPS.
"include only payments to be made after the adoption or the FOPS.
***All payment amounts are estimates
•
1774353.1
10