HomeMy WebLinkAboutCouncil Provided Information - 4/14/2026Redevelopment Agency of Salt Lake City
RESOLUTION NO. _16_
Housing and Transit Reinvestment Zone
Tax Increment Reimbursement Program Policy
RESOLUTION OF THE BOARD OF DIRECTORS OF THE REDEVELOPMENT AGENCY OF
SALT LAKE CITY ADOPTING THE RDA HOUSING AND TRANSIT REINVESTMENT ZONE
TAX INCREMENT REIMBURSEMENT PROGRAM POLICY
WHEREAS, the Utah Housing and Transit Reinvestment Zone Act (HTRZ Act) was
enacted to further a number of objectives including promoting a higher utilization of public transit
and increasing the availability of housing including affordable housing.
WHEREAS, pursuant to the Act, the Redevelopment Agency of Salt Lake City (RDA)
administers the tax increment, including entering into reimbursement agreements (also known as tax
increment reimbursement agreements) with project developers or property owners associated with an
HTRZ Committee approved Housing and Transit Reinvestment Zone (HTRZ) for the purpose of
utilizing the funds as allowed by the HTRZ Act.
WHEREAS, the Board of Directors of the Redevelopment Agency of Salt Lake City
Board) supports the distribution of tax increment associated with an HTRZ pursuant to the process
outlined below.
NOW, THEREFORE, BE IT RESOLVED BY THE BOARD OF DIRECTORS OF THE
REDEVELOPMENT AGENCY OF SALT LAKE CITY, that we do hereby establish policy
guidelines for the RDA HTRZ Tax Increment Reimbursement Program to include the following:
1. GENERAL
a. Purpose
The RDA HTRZ Tax Increment Reimbursement Program (Program) may provide
project developers or property owners a tax increment reimbursement
Reimbursement) for the development of improvements in or associated with an
HTRZ that meet the goals and objectives of the HTRZ Act, the executed interlocal
agreement between the RDA and Salt Lake City, and the RDA’s Mission and Values,
and provides significant public benefit. The Program is designed to provide
reimbursements that are calculated using Salt Lake County’s assessed property value.
The developer or property owner will receive a percentage of the tax increment
generated from its project for a specified timeframe, and the RDA will receive the
residual tax increment generated by the project.
b. Authorization
The RDA shall determine whether a project meets the goals and objectives of the
HTRZ Act, the executed interlocal agreement between the RDA and Salt Lake City,
the approved HTRZ, and the RDA’s Mission and Values. As provided in the HTRZ
Act, a Reimbursement can only be authorized pursuant to a Reimbursement
Agreement (Agreement), the terms of which are approved by the Board. The Board
reserves the right to modify or deny a tax increment reimbursement application at any
time for any reason. The Board’s approval of an Agreement shall be made by
resolution and include a description of the development the applicant will undertake,
the amount of funds the applicant may receive, and the terms and conditions under
which the applicant may receive the funds.
c. Tax Increment Calculation
The formula to calculate the Reimbursement generated from the proposed
improvements shall be as follows:
i. Step 1: Estimate the Total Annual Tax Increment.
o Determine the property's taxable value as shown upon the assessment
roll last equalized prior to the construction of improvements on the
property. This value is referred to as the property’s Base Taxable
Value.
o Calculate the difference between the Base Taxable Value of the
property prior to improvements and the property’s estimated taxable
value after the improvements have been made. This difference is
referred to as New Growth.
o Multiply New Growth by the current effective tax rate.
New Growth) x (Effective Tax Rate) = Total Annual Tax Increment
TI)
ii. Step 2: Estimate the Annual TI Received by the RDA.
o Total Annual TI multiplied by the percentage of TI received by the
RDA. (Total Annual TI) x (% of TI received by the RDA) = Total
Annual TI Received by the RDA.
iii. Step 3: Estimate the Annual Reimbursement Payment.
o Using the developer/property owner reimbursement rate
Reimbursement Rate) established in the Agreement, calculate the
estimated annual reimbursement payment.
o (Total Annual TI Received by the RDA) x (Reimbursement Rate) =
Estimated Annual TI Reimbursement Payment. Refer to Section 2 for
more information on calculating the participation rate between the
RDA and the developer.
iv. Step 4: Calculate the Maximum Amount of Tax Increment Available to
the Developer or Property Owner Over the Term of the Agreement.
o (Estimated Annual TI Reimbursement Payment) x (the Term of the
Reimbursement Agreement) = Total TI Available to Developer or
Property Owner Over the Term. An annual growth multiplier based
on current economic conditions may be applied to this calculation, at
the RDA’s sole discretion.
Actual Reimbursement is dependent on the increment being generated by the project.
d. Eligible Costs
The tax increment reimbursement will be limited by state law as indicated by Section
63N-3-607(4) of the HTRZ Act and Section 11-41-103 of the Prohibition on Retail
Facility Incentive Payments Act. The RDA may determine, in its sole discretion, if
the entire project or only specific project elements are eligible.
e. Design Review
Projects approved for Reimbursement must follow the RDA’s administrative design
review process. Projects will be required to be in conformance with all Salt Lake City
policies, ordinances, and codes.
2. REQUIREMENTS AND STRUCTURE
a. Threshold Requirements of Projects that Incorporate Housing
i. Projects must meet all applicable standards and objectives of the HTRZ Act
and the approved HTRZ; and,
ii. At least 10% of housing units within a project must be affordable to those
earning 60% the Area Median Income (AMI) and below, or, 20% of units
must be affordable to those earning 80% AMI and below. Income averaging
of units within a single project may be utilized to achieve AMI thresholds;
and,
iii. Projects must include activated, ground floor space if not a private residence.
Activated, ground floor space means a minimum of 50% of all ground floor,
street-facing building facades must contain an active (commercial, retail, or
office) use that is not exclusive to the tenants of the building; and,
iv. Projects must comply with the RDA’s Sustainable Development Policy; and,
v. The applicant must provide sufficient evidence (including, but not limited to
the project pro forma, senior lender agreement(s), equity investor agreements,
etc.) that tax increment funding is necessary for the project to succeed and to
verify that the request is reasonable.
b. Threshold Requirements of Projects that Do Not Incorporate Housing
i. Projects must meet all applicable standards and objectives of the HTRZ Act
and the approved HTRZ; and,
ii. Projects must meet at least two (2) of the RDA’s qualifying livability
benchmarks: permanent job creation; affordable commercial spaces;
ownership; transportation opportunities; neighborhood safety; community
engagement and support; public art; public space; walkability; and building
preservation, rehabilitation, or adaptive reuse (collectively, Qualifying
Livability Benchmarks).
iii. Projects must include activated, ground floor space; and,
iv. Projects must comply with the RDA’s Sustainable Development Policy; and,
v. The applicant must provide sufficient evidence (including, but not limited to
the project pro forma, senior lender agreements, equity investor agreements,
etc.) that the Reimbursement is necessary for the project to succeed and to
verify that the request is reasonable.
c. Affordable Housing Requirements.
i. Deed Restriction – If the project qualifies for a Reimbursement based on the
incorporation of housing, prior to executing an Agreement, a restriction shall
be recorded against the property that requires continued use of the specified
units as affordable housing for at least 30 years. Both rent and income
restrictions shall be included to limit the maximum rent that can be charged
for a unit and to require that the unit be made available only to households
with qualifying incomes.
ii. Bedroom Count Mix – The affordable units shall be located on different
floors of the building and spread among bedroom counts (1-bedroom, 2-
bedroom, 3-bedroom, etc.) in the same proportion as the units available
within the rest of the project.
d. Eligible Project Locations
Eligible projects shall be located in or associated with an active HTRZ that allows tax
increment reimbursements pursuant to the HTRZ Act.
e. Maximum Reimbursement Term
The Reimbursement term will be negotiated based upon a project’s level of public
benefits and demonstrated financial need and shall be consistent with the HTRZ Act.
f. Maximum Reimbursement Rate
i. Base Level Reimbursement – The maximum reimbursement rate for Projects
that only meet the Threshold Requirements is 60%.
ii. Increased Reimbursement Incentives – Projects may be eligible to receive an
additional 10% increase in the reimbursement rate for meeting elements listed
below, with each element being worth an additional 10%. The possible total
maximum reimbursement rate is 90%. The elements are:
1. Incorporating Qualifying Livability Benchmarks in the project
beyond the Threshold Requirements.
2. Providing an additional 10% of total affordable units at 60% AMI and
below beyond the Threshold Requirements.
3. The inclusion of 3- and 4-bedroom units in projects that incorporate
housing.
4. Meeting a priority identified in the RDA’s Annual Housing Funding
Strategy established pursuant to the Housing Allocation Funds Policy.
g. Maximum Reimbursement Amount
The maximum Reimbursement amount will be negotiated based upon a project’s
eligible costs, level of public benefits, and demonstrated financial need, and shall be
consistent with the HTRZ and HTRZ Act.
3. EVALUATION AND APPROVAL PROCESS
a. Applications that meet the requirements detailed in Section 2 will be evaluated and
processed as detailed below.
i. Step 1: Application Processing and RDA Staff Review.
All applications shall be made to RDA staff, on standard RDA forms. All
applications must be complete to be evaluated, and if either the applicant or
proposed project fails to demonstrate the ability to meet application
requirements, RDA staff may deny the application.
ii. Step 2: RDA Finance Committee Review.
RDA staff shall forward complete applications that meet the threshold
requirements to the RDA Finance Committee. The RDA Finance Committee
shall evaluate applications, supplemental materials, and other documentation
necessary to thoroughly review the application and formulate a
recommendation to the Board.
iii. Step 3: Board Consideration of the Tax Increment Reimbursement
Agreement Terms.
Upon review of the application and supporting material, the Board may
consider for approval a resolution detailing the Agreement terms.
iv. Step 4: Agreement Finalization.
Once the terms of an agreement have been authorized by the Board through
an approved resolution, the RDA and developer will execute an Agreement
consistent with the terms approved by the Board, and any other legal
agreements (including an affordable housing restriction) deemed necessary by
the City Attorney’s Office.
4. AGREEMENT TERMS
a. Participation and Reimbursement Agreement Terms
In addition to any other terms as recommended by legal counsel, the following terms
shall be included in the Agreement:
i. Reimbursement to Benefit Owner: RDA Discretion
The RDA intends that the beneficiary of the Reimbursement will be the
owner of the project for the life of the Agreement. In the event of a transfer or
sale of the project or property, the Agreement and all benefits conferred under
the Agreement shall benefit the project and be recorded against the property
to run with the land, with the intent that all Reimbursements will remain with
the owner of the real property and project. In the event that the ownership of
the real property and improvements are severed, the RDA will have sole
discretion to determine the beneficiary of the tax increment.
If the Agreement is executed and the real property and project are conveyed
to a third party while the improvements are still being constructed, the RDA
will retain the right to consent to the transfer the Agreement to the new
owner, in order to ensure that the benefits the RDA anticipated receiving
under the original Agreement with the original developer are consistent with
the new developer. If RDA does not consent to the transfer of the Agreement,
the Reimbursement will cease and the Agreement will terminate.
ii. Tax Appeals
All reimbursement recipients shall be required to notify the RDA if they have
applied for a property tax appeal with Salt Lake County. In the event that any
such appeal results in a reduction in property taxes, the percentage share of
the Reimbursement payable by the RDA to the recipient will decrease, and
the percentage share of the tax increment received by RDA shall be increased,
so that the dollar amount received by the RDA is the same as if no appeal of
the assessed value had been made.
iii. Recapture Provisions in the Event of Default
Agreements shall require the recapture of Reimbursement funds allocated to a
project that fails to meet the requirements as provided in the Agreement.
iv. Participant Reporting Requirements
Agreements shall require the following reporting from Reimbursement
recipients as per the following:
1. Project Completion: Upon project completion, Reimbursement
recipients shall provide a report that includes, but is not limited to,
the total cost of improvements, a summary of completed
improvements, and outcome metrics relating to project-specific
requirements.
2. Annual Pre-Reimbursement: Contingent upon receiving an annual
Reimbursement, Reimbursement recipients shall provide a report that
includes a notification of any tax appeals and outcome metrics
relating to project-specific requirements. As applicable, the report
shall include relevant data that is certified by a financial officer or
public accountant.
b. Interest
Interest will not accrue against the RDA on the anticipated or projected tax increment
to be reimbursed to the developer.
5. REPORTING REQUIREMENTS
a. Reporting
The RDA shall provide a written briefing to the Board once per fiscal year, which
contains an update on the RDA’s Reimbursement portfolio. Such briefing shall
include a summary of new Agreements, anticipated budget impacts, and project
metrics.
6. EXCEPTIONS
The Board, by a majority vote of those present, may waive requirements or make exceptions
to the foregoing criteria and procedures with a finding that the RDA’s mission and values
will be furthered by such waiver or exception. RDA staff will prepare a written
recommendation and statement regarding the waiver or exception. The statement will be
placed in the project file.
Passed by the Board of Directors of the Redevelopment Agency of Salt Lake City, this day of
December 12th, 2023.
Chair
Approved as to form: __________________________________
Salt Lake City Attorney’s Office
Allison Parks
Date:____________________________
The Executive Director:
does not request reconsideration
requests reconsideration at the next regular Agency meeting.
Erin Mendenhall, Executive Director
Attest:
City Recorder
Allison Parks (Dec 15, 2023 10: 51 MST)
Dec 15, 2023
Daniel Dugan (Dec 20, 2023 13:09 MST)
Erin Mendenhall (Dec 20, 2023 14:01 MST)
4
Granary District Alliance (GDA)
Granary District, Salt Lake City
Granarydistrictslc@gmail.com
March 31, 2026
To: Salt Lake City Council and Mayor’s Office and CRA Director Danny Walz
Re: Pickle Building Demolition and Revised Development Plans
Dear Mayor Mendenhall, City Council Members and Mr. Walz,
We at the Granary District Alliance (GDA) as well as many community members, are deeply
saddened by the loss of the historic Pickle Co Building which has been an iconic and important
historic structure in our community.
As mentioned in our previous letter, The GDA endorsed the original plan in 2023 as it was an
adaptive reuse for the building, preserving a portion of the front facade and retrofitting the rest of
the building preserving its original character.
We understand that Blaser Ventures was within their rights to demolish the building as a revised
demolition permit was issued by Salt Lake City building services. The developer has expressed
regret and apologized for the lack of transparency with the GDA board with the change in plans
and the demolition carried out last week.
After discussions with the Blaser team and witnessing their development of the site, we applaud
the new building that is currently being built with similar architectural elements (namely the arched
windows and parapet), constructed reusing the bricks from the original Pickle building, and believe
it is the best path forward for the site. This revised development also includes publicly accessible
open space in the form of a pocket square behind the rebuilt building.This revised plan dovetails
with the developer’s plans for the Kilby development parcels east of the site. This will create a
walkable, connected space with existing buildings that maintain the original character of the
Granary district, something the GDA highly values.
www.thegranarydistrict.com @thegranarydistrict
Our formal recommendation, as voted on and approved unanimously by our board on May 28th,
2025, and again on March 23, 2026 is to support the new concept of the Blaser Pickle Building
rebuild including the proposed open space. We encourage the City Council and CRA to follow
through with their agreement with the developer to issue the $6M in tax increment reimbursement
funding previously allocated to the project. We also support including a stipulation in this
agreement to ensure that the public open space or pocket square in the current plan gets
constructed as a condition of the agreement for public benefit. We understand that these funds
are required for the project's financing and future feasibility. As a board, we would like to see the
site thrive. We believe it is the best solution moving forward to avoid blight to the neighborhood that
such a stalled or abandoned project would cause.
We encourage the CRA and City Council to support this new vision of the Pickle Co building and
issue the CRA funding agreement. This funding will facilitate the reconstruction of the building and
the proposed public space as the best case scenario for this site. Please reach out if you have any
questions or would like to engage in additional discussions on this matter. Thank you for your time
and consideration.
Sincerely,
The Granary District Alliance Board
Annastasia Kaessner, Granary District Alliance, Chair 2026
www.thegranarydistrict.com @thegranarydistrict
Pickle & hide
Tax increment reimbursement
APRIL 2026
Original project scope
Phase I
Renovation of “Hide” building
•5,500 sf commercial
•141 units of residential (38% at 60-80% AMI)
Phase II
Renovation of “Pickle” building
•14,500 sf of commercial
Renovation of “Ed’s Restaurant”
•2,500 sf of commercial
Activated ground floor use: 50% of the ground floor, street- facing building facades contain an active use not
exclusive to building tenants.
Salt Lake City Community Reinvestment Agency
Policy WAIVERs & Conditions
HTRZ Tax Increment Policy
1.Affordability minimum term reduced from 30 years to 15 years
2. Emission Free Building
•Waived for designated restaurant spaces
3. “On site net zero”
a.RMP Blue Sky Participation at $350/mo for Phase I energy needs
b.SEDI for Pickle and Ed’s Restaurant
c.Water-wise landscaping, smart irrigation, zero emissions landscaping equipment
d.Easement for midblock walkway
Salt Lake City Community Reinvestment Agency
Approved reimbursement terms
Reimbursement Rate: 90%
Base Rate (60%) + Public Benefits (10% each)
1.Building Preservation, Rehabilitation, and Adaptive Reuse
2.Walkability
3.Neighborhood and Commercial Services (FY25 Housing Funding
Priority)
15 years
$6,909,585
$6,094,254
Salt Lake City Community Reinvestment Agency
Modified project scope
•Risk and uncertainty
•$1 million in project costs
•Shotcrete and steel stabilization
Building demolished on May 21, 2025
Salt Lake City Community Reinvestment Agency
Modified project scope
40% of materials salvaged for reuse
•50,000 bricks + 70,000 bricks
from Granary District
•Star anchors
•Sandstone for fireplace
•Timber for site furnishings
•Roof trusses
+28 parking spaces for 192 total
parking stalls
Salt Lake City Community Reinvestment Agency
Policy WAIVERs & Conditions
HTRZ Tax Increment Policy
1.Affordability minimum term reduced from 30 years to 15 years
2. Emission Free Building
•Waived for designated restaurant spaces
•Requested waiver for common area amenities (3 community fireplaces and 2 grills)
3. “On site net zero”
a.RMP Blue Sky Participation at $350/mo for Phase I energy needs
b.SEDI for Pickle and Ed’s Restaurant
c.Water-wise landscaping, smart irrigation, zero emissions landscaping equipment
d.Easement for midblock walkway
Salt Lake City Community Reinvestment Agency
Approved reimbursement terms
Reimbursement Rate: 90%
Base Rate (60%) + Public Benefits (10% each)
1.
2.Walkability
3.Neighborhood and Commercial Services (FY25 Housing Funding Priority)
Term: 15 years
$6,909,585
$6,094,254
Salt Lake City Community Reinvestment Agency
Building preservation, rehabilitation, adaptive reuse
“To acknowledge a neighborhood’s history and maintain its unique
character through preservation, rehabilitation, or repurposing of historic
or underutilized structures. The project will preserve, rehabilitate, or
repurpose an existing structure for a land use that contributes positively to
the surrounding neighborhood.”
Pickle Building was one of three buildings considered in this public benefit,
along with the preservation of the Hide Building’s facades and the full
adaptive reuse of Ed’s Restaurant.
Salt Lake City Community Reinvestment Agency
Modified Scope & Term revisions
Salt Lake City Community Reinvestment Agency
•Requested policy waiver for Sustainable Development Policy
•Possible reduction of Tax Increment Reimbursement Rate
o Pro rata share of Pickle building (3.3% = $223,456)
o Full reduction of Public Benefit (10% = $677,139)
o No reduction
Next steps
Salt Lake City Community Reinvestment Agency
Amended Term Sheet and Resolution
Tax Increment Reimbursement Agreement
CITY COUNCIL OF SALT LAKE CITY
451 SOUTH STATE STREET, ROOM 304
P.O. BOX 145476, SALT LAKE CITY, UTAH 84114-5476
SLC.GOV/COUNCIL
TEL 801-535-7600 FAX 801-535-7651
BOARD STAFF REPORT
COMMUNITY REINVESTMENT AGENCY of SALT LAKE CITY
TO:CRA Board Members
FROM:Kate Werrett
Budget and Policy Analyst
DATE:April 14, 2026
RE:PICKLE AND HIDE MIXED-USE DEVELOPMENT TAX INCREMENT REIMBURSEMENT
REQUEST TERM REVIEW
________________________________________________________________________________
ISSUE AT-A-GLANCE
The Board will receive a briefing and consider adopting a resolution that would approve modifications to the terms
of a Tax Increment Reimbursement Agreement with Mountain West Development, LLC (Developer), also known as
Blaser Ventures, for the Pickle & Hide development in the 900 South Housing and Transit Reinvestment Zone
(HTRZ) located at approximately 739 South 400 West (see background section for information on the HTRZ, which
was the first approved in SLC). On March 18, 2025, the Board adopted Resolution No. 5 of 2025 approving the
original tax increment reimbursement agreement term sheet. After obtaining the necessary permits, the developer
demolished the Utah Pickle Co. building which the application and term sheet identified for adaptive reuse. This
prompted reconsideration of the previously approved tax increment reimbursement term sheet.
This staff report includes a request from the Community Reinvestment Agency (CRA) staff for guidance regarding
potential modifications to Resolution No. 5 of 2025. Under this resolution, the CRA agreed to support the developer
via a tax increment reimbursement agreement by contributing up to 90% of the tax increment collected from the
development within the HTRZ. Due to the demolition, CRA staff is seeking guidance from the CRA Board on how to
proceed with the tax increment reimbursement agreement (Agreement).
Goal of the briefing: Receive details regarding changes to the existing resolution, discuss the proposed
modifications, and provide direction to CRA staff. The CRA Board may take action at its discretion.
POLICY QUESTIONS
1. Should the CRA Board require modifications to the waivers previously granted under the Sustainable
Development Policy, given the original basis was granted due to the preservation and adaptive reuse of the
demolished Pickle Building? Waivers include:
o Sustainable Development Policy Section 3.a.b: The emission-free building operation requirement
was waived to accommodate restaurant gas stovetops. As proposed and originally approved, the
rest of the project must comply with this requirement and have no on-site fossil fuel combustion.
Schedule:
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o Sustainable Development Policy Section 4.a.ii: The on-site net zero building requirement was
waived and adjusted to require “off-site next zero” standards as part of the original approval.
2. Should the CRA Board allow partial reimbursement, considering some construction materials were
incorporated into the project?
3. How should the city balance partial compliance (e.g., material reuse, other redevelopment benefits) against
the loss of the community valued building?
4. What safeguards can the CRA impose to guarantee that future term sheets for HTRZ tax increment
reimbursements won't also change after board approval?
5. Should the CRA establish financial or legal consequences for developers who fail to meet project
commitments or for changing project plans when applying for incentives after board approval?
6. Should there be a formal mechanism to prevent similarfailures in future tax increment reimbursement
projects?
7. Should the CRA require CRA Board approval for any significant demolition in future projects receiving tax
incentives or establish a requirement for formal board discussion/straw poll as was the case in the USA
Climbing development?
ADDITIONAL & BACKGROUND INFORMATION
Housing and Transit Reinvestment Zone Tax Increment Reimbursement Program
In December 2023, the CRA Board adopted Resolution 16 of 2023 - Housing and Transit Reinvestment Zone Tax
Increment Reimbursement Policy (HTRZ Policy). The HTRZ policy outlines the purpose of the program, threshold
requirements, general terms for base level reimbursement, and options to receive increased reimbursement
incentives. The purpose of the program is to provide developers tax increment for the development of qualifying
improvements.
The base level program participation provides a 60% property tax reimbursement from the application parcels. The
program allows for an increased reimbursement rate by incorporating the following:
- Additional Qualifying Livability Benchmarks
- Increased affordable housing percentage
- Inclusion of family-sized units
- Incorporating CRA Annual Housing Funding Strategy priorities
By incorporation of the above items, applicants may be eligible to receive up to a 90% property tax reimbursement,
the program’s maximum participation rate.
Mountain West Development, LLC Program Participation
In January 2025, the developer, Mountain West Development, LLC, submitted a tax increment reimbursement
application for its Pickle & Hide development.
In the original application, the Developer requested and was granted by the CRA Board three program and policy
waivers:
1. HTRZ Policy Section 2.c.i: A reduction in the affordable housing deed restriction from 30 years to 15 years.
2.Sustainable Development Policy Section 3.a.b: The emission-free building operation requirement was
waived to accommodate restaurant gas stovetops. As proposed and originally approved, the rest of the
project must comply with this requirement and have no on-site fossil fuel combustion.
3.Sustainable Development Policy Section 4.a.ii: The on-site net zero building requirement was waived and
adjusted to require “off-site next zero” standards as part of the original approval.
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The Developer requested the maximum property tax reimbursement and was approved to receive a 90%
reimbursement by the CRA Board due to the inclusion of Increased Reimbursement Incentive elements in the
application. The application materials included the following Increased Reimbursement Incentive elements:
Revised Application/Reconsideration of Program Participation
ATTACHMENTS