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M-6/30/1983 . . . THE REDEVELO~ENT AGE~CY OF THE CITY OF S~~TA MONICA, CALIFO~~IA ~otes :0 Combined Financ~al Statereen:s June 30, 1983 (1) Summary of Si~nificant Accounting Policies General The Redevelopment Agency of the City of Santa Xonica (Agency) was established by the Santa Monica City Council in 1957 pursuant to the Community Redevelopment Law of California as cod~fied in the State of California Health and Safety Code. The purpose of the Agency is to eliminate blight and to promote economic revitalization w~thln designated project areas of the City of Santa Monica. The Agency is funded by Federal and local sources. The only source of Federal funding has been provided under programs sponsored by the V.S. Department of Housing and Vrban Development (HUD). Through HUD, the Agency has received funds for its Co~ventional Urban Renewal Program (Title I) and the Community Development Block Grant Program (CDBG). All Federal programs are still operational; however, add~tional fund~ng for the Title I Program, other than that which is necessary to complete existing redevelopment activit~es, has ceased. Local funds are prov~ded principally from incremental property taxes and rentals for che park~ng f acllit ies . Basis of Accounting The accompany~ng combi~ed financial statements of the Agency have been prepared on the modified accrual basis of accounting. The ~od~fied accrual basis of accounting is defined as the basis of a~counting under which revenues are recognized when they become both measurable and available to finance operations of the currene period. Expenditures are recognized when the related liability is incurred, except for principal and interest on general long-term debt which is recognized when due. Investments Investments are stated at cost and generally consist of Federal Government-backed securities. Lon~-Ter~ Liab~lities Long-ter~ l~abilities are accounted for in the General Long-Ter~ De,t Account Group. . . . . THE REDEVELO~ENT AGE~CY OF THE CITY OF SANTA ~O~ICA, CALIFO~~IA ~otes to Combined Financial State~ents, Continued (1) Summary of Significant Accounting Policies, Continued Tax Increment Revenues Incremental property taxes are considered as project revenues by the Agency when they become both measurable and available for financing the Agency's redevelopment activities during the year. Property taxes are considered available if received Within 60 days following year-end, ~n accordance with the Sational Council on Governmental Accounting's Interpretation Number 3. Increme~tal property tax revenues represent property taxes collected from the excess of taxes levied and collected each year on any redevelopment proJect over that amount which would have been levied and collected on the base year property tax assessment. (A property tax base year 1s deter- mined to be the year prior to the establishment of a redevelopment project area. ) Total (Memorandum Only) The column in the accomoanying combined financial st~tements capt~oned "Total (Memorandum only)" is not necessary for a fair presentation in accordance with generally accepted accounting principles but is presented as additional analytic data. (2) Project Notes and ~onds On November 2, 1978, the Agency authorized the offering of $14,470,000 ~n Downtown Redevelopment Project Parking Lease Revenue Bonds. Proceeds from the bonds have been used by the Agency to finance the acquisition and construction of two garages (the Parking Facility), which provide parking facilities for a major shopping center in the City or Santa Monica. A summary of project bonds payable held in the Agency's general long-ter~ debt account group at June 30, 1983 follows (see note 3). 2 THE REDEVELOPMENT AGENCY OF THE CITY OF SANTA MONICA, CALIFOR~IA ~ Notes to Combined Financial Statements, Continued (2) Project Notes and Bonds, Continued !<>-nd 1 !Bue Date of issue lntetest Outstanding rate June 30, 1983 Annual re~uire"ents to'.aturity dates Downtown Froject Bonds lle~.I,1978 6.25%-7.75% $ 14,1001000 Various amounts from $180,000 to $1,115,000 De~.1,1983 to Det.I.2008 In addition. the Agency was indebted for the following amounts: General loans due to the City of Santa Monica General Fund with interest accruing at 12% per annum (on the principal only). These notes are all payable an December 31, 1983 $ 7.903,744 Ocean Park Federal Allocation Fund note from Community Development Block Grant at 4.26%, principal due at maturity on September 16, 1983 1,500~OOO $ 91403,744 ~ (3) Restricted Assets As part af the covenants for the Agency's Downtown Redevelopment Project Parking Lease Revenue Bonds, the fiscal agent is required to maintain three separate cash funds, as follows. Bond Service Account Monies are transferred into this account each May 15 in amounts equal to interest due on the next two ensuing interest payment dates. In addition, on each November 15 an a~ount equal to the principal amount of bonds maturing on the next ensuing December 1 is transferred into this account. Working Capital Account The sum provided in this account is to be used to pay any taxes and assessments levied on the Agency's interest in the leased premises, insurance premiums, annual fiscal costs of mai~renance and operation, if the City defaults on the lease. The fund is to be maintained at $5,000. ~ 3 . . . THE REDEVELOPME~T AGENCY OF THE CITY OF S&~TA MONICA, CALIFO~~IA ~otes to Combined F~nancial Statements, Continued (3) Restricted Assetsl ~ontinued Reserve Fund Account A sum to be equal to at least the maximum annual debt service amount over che life of che bonds is Co be maintained in this account. Monies in the Reserve Fund may be used by the Agency, first, far the paTment of losses sustained by reason of accident or destruction of the Parking Facil~ty financed by issuance of the bonds and not covered by the required insur- ance so long as the balance remaining in the Fund is equal to 50% of maximum annual debt service; second, to help redeem the bonds outstanding under circumstances where the Parking Facility is not to be repaired or rebuilt; and third, for the payment of interest on and principal of the bonds in the event no other funds are available therefor, or for the final retirement of all bonds then outstanding. On June 30, 1983, the aforementioned accounts reflected the following balances: Bond Service Fund Working Capital Fund Reserve Fund S 476.770 5,000 11189,705 Total $ 116711475 The balances of each of such assets are held ~n trust by an independent fiscal agent. (4) Capitalized Lease On May 1, 1978, the City entered into a lease agreement with the Agency to provide parking for the shopping center in the Downtown Project. The lease requires the City to pay the Agency a base rental at an estimated rate of approximately $1,190,000 per year, and, in addition, the lease requires the City to make add~tional payments each year sufficient to operate and maintain the Parking Facility. The lease extends for a per~od of 3S years or repayment of the bonds issued to finance construction of the Parking Facility, whichever occurs earlier (note 2). Upon termination of the lease, ownership of the Parking Facility will rest with the City. Such lease meets the criteria of a cap~talizable financing lease. At June 30. 1983, the present value of the lease payments receivable froID the City was S12,773,558. 4 ~ . . . THE REDEVELO~E~T AGE~CY OF T~E CITY OF S.~~TA ~ONICA, CALIFO~~IA Notes to Combi~ed FinanClal Statements, Continued (5) Deficit Fund Balances At June 30, 1983, the Downtown and Ocean Park Redevelopment Projects had deficit fund balances of $2,890,668 and $2,833,594, respectively. It is anticipated that these fund deficits will ultimately be alleviated through future tax increment revenue and ather project revenues. 5 . . . r=1 PEAT I ~ ~IARWICK Peal. \brwlck. \!llchell & Co Ce'{,iid P'Jbhc -\c,,;}unt.cnb 55~ South Flol'er Street La, ..nge:e, C t1'lOmln 900~1 The Board of Directors The Redevelopment Agency of the City of Santa Manica, California: We have examined the financial statements of the various funds of the Redevelopment Agency of the City of Santa Monica (Agency) for the year ended June 30, 1983 and have issued our report thereon dated October 14, 1983. Our examination was made in accordance w1th generally accepted audit1ng standards and, accordingly, included such tests of the accounting records and such other auditing procedures as we considered necessary in the clrcumstances. We performed the procedures contained in the publication entitled Guidellnes for Compliance Audits of California Redevelopment Asencies as promulgated by the Controller of the State of Californ1a in connect10n w1th a review or the Agency's compliance with laws, regulations and administrative requirements governing activities of the Agency, as required by Section 33080.1(a) of the Health and Safety Code of the State of California. The procedures we performed would not necessarily disclose instances of noncompliance because they were based on select1ve tests of accounting records and related data. During the performance of the aforementioned procedures, nothing came to our attention that would lead us to believe that the Agency did not comply with applicable laws, regulations and administrative requirements governing its activities. This report is to be used solely for filings with appropriate regulatory agencies and is not intended for any other purpose. -?~tJ 1Jf~/ -n-tA-ttJJ2 f &. October 14, 1983 . . . APPENDIX B Katz Hollis August 28, 1984 santa Monica Redevelopment Agency 1685 Main Street, Room 104 Santa Mon~ca, Californla 90401 Attn: Mr. Ernesto R. Flores Economlc Development Manager Dear Mr. Flores: Enclosed is a tabulation of proJected taxable value and resulting tax revenue (Table 1) for Ocean Park Redevelopment proJects l( a) and lIb) (hereinafter sometimes referred to cOllectively as the Ocean Park Redevelopment ProJect or as the ProJect). The pro- Jected revenues are based on information supplied by Agency staff; assumptions determ~ned by our rev~ew of the ProJect taxable value history: the property tax assessment and tax apportionment proce- dures of Los Angeles County; and prellminary County reports of 1984-85 taxable value for the ProJect Area. ~eneral A~sumptions Tax revenues for 1984-85 have been proJected by applying an esti- mated 1984-85 tax rate ($1. 045375 per $100) to total lncremental taxable value for the proJect Area, as reported by the Los Angeles County Auditor-controller. The 1984-85 tax rate and the rates utilized ln subsequent fiscal years have been estimated based on the actual annual decline experienced in the overnde tax rate from 1978-79 to 1983-84. The hlstorical declining trend lS as- sumed to continue in future years unt~l 1988-89 when the tax rate is assumed to stabilize at one percent ($1.00 per $100) of taxable value established by Article XIIIA of the Cal~fornia Constitution. The overn.de tax rate decllne ~s the result of several factors: an effectIve llm~t, established by Article XIIIA, on the amount that can be levied (l.e., annual debt serv~ce on indebtedness ap- proved by the voters puor to 1978): nsing taxable values w~thln the Jurisdictions of taxing entities levying the approved override rate (thereby redUCIng the amount needed to be lev led by the tax- ~ng entity to meet annual debt service requ~rements): and the ac- tual retirement, over time, of the voter-approved debt. WhIle the tax rate ~s assumed to declIne to one percent of taxable value and remain constant in subsequent years, current law permlts taXIng ent~ties derivlng revenues from the one percent rate to re- duce theIr leVIes under certaIn circumstances. It is the apparent Katz...;olllS Corer & i\ssocla:eS.ln c F'ra~c'al Consultants 550 S H:il Stres' Sute 980 LQS Ar,ge'es,CA 9C018-2410 ~:2;3) 629 -3eeS Sari =rar"lCISCO, CA :415) 786- OS6e . . . KatzHollis Mr. Ernesto R. Flores Santa Monica Redevelopment Agency August 28, 1984 Page 2 Intent of the law to insulate the other taxing entitles and redevelop- ment agencies from the effects of such reduct10ns on their property tax revenues. For purposes of this analysis, It 1S assumed that any use of a tax rate reductIon from the one percent rate by any taxing entIty allocated revenues from property taxes collected withIn the proJect Area would not have a detrimental fiscal impact upon the Agency's receipt of Incremental tax revenues. Impacts of Lesislat10n InitIative PetItion - An InItiatIve petItIon (the -lnItIative-) has qua- lified for the general election of November 6, 1984. The initiatIve would amend the state ConstitutIon to further restrict State and local government's ability to levy new taxes or increase existIng taxes. If enacted, among the provis1ons of the resulting constitutIonal amendment would be the requirement that taxable values on the 1978-79 tax rolls be reconc1led to eliminate any annual inflationary adJustments (lImIted to a maximum of 2% annually) to real property values used 1n creating that year's roll. Per the provisions of Art1cle XIIIA of the California Con- stitution, 1975-76 values, and SUbsequent years' values for property which changed ownersh1p or was newly constructed, were used as a basis for creating the 1978-79 tax rolls. The initiative would result 1n a reduction of 1978-79 values and would affect the values of each parcel in the ProJect Area for each subsequent year, unless and/or untIl such parcel was reassessed under the provisions of ArtiCle XIIIA. The ini- tiative also would require the refunding of all property taxes paid, plus lnterest, in eXCess of the amount WhICh would have been requ1red with the lower values. The inItiative does not include any proviSions for the method of refunding moneys should such action become necessary, state legislation would be required to establlsh such a method. Redevelopment agencies with proJects which have generated tax increment in the years since passage of Article XIIIA would ostenslbly be liable for some, If not all, of the refund due to proJect area taxpayers as a result of passage of this new Initlative. Addltlonally, proJect area values would be adJusted downward reflecting the removal of the pre- 1978-79 Inflat10nary adJustments from values for 1978-79 and subsequent tax years. This may result 1n a reduction of tax 1ncrement revenue to be rece1ved by an agency 1n future fiscal years. Katz Hollis has analyzed the potentlal 1mpact of the lnitlative on ProJ- ect resources and has submitted that analys1s to the Agency under separ- ate cover. Under the assumpt10ns utllized 1n that analys1s, approval of .. . . . Katz Hollis Mr. Ernesto R. Flores santa Monica Redevelopment Agency August 28, 1984 Page 3 the initiative would require an est1mated total refund, including inter- est, through 1984-85 of $79,512. Further, annual revenues from the Project have been estimated to decline by $8,315 1n 1984-85 and subse- quent years. Projected tax increment revenues, shown on Table l, have not been reduced to reflect the potential effect of the in1tiat1ve on Project revenue. Supplemental Lien Dates A bill enacted last year, SB 813 (statutes of 1983, Chapter 498), pro- v1des for the supplemental assessment and taxation of property as of the occurrence of a change of ownership or completion of new construction. Previously, statutes enabled the assessment of such changes only as of the Harch 1 tax lien date next following the change and thus delayed the rea11zat10n of increased property taxes from the new assessments for up to 14 months. As enacted, Chapter 498 prov1des 1ncreased revenue to redevelopment agencles to the extent that new construction or changes of ownershlp occur within the boundaJ::1es of redevelopment proJects subse- quent to the March 1 lien date. For the purpose of this analys1s, no attempt has been made to estlmate the impact on revenues to the Agency as a result of supplemental assessments. The proJection on Table 1 con- tains no adJustments to value or revenue as a reflection of such adJust- ments. Bus1ness Inventory Revenue In 1979, the Legislature enacted Assembly Bill 66 (statutes of 1979, Chapter 1150), e1iminat1ng the assessment and taxation of business in- ventory property and providing for replacement revenue for local agen- cies, except redevelopment agencies. In 1980, the LegiSlature enacted AB 1994 (Statutes of 1980, Chapter 610) providing replacement revenue, 1n part, for the loss of business inventory revenues for redevelopment agenc1es. Because of the residential nature of the Ocean Park Redevel- opment ProJect, the amount of the replacement revenue rece1ved by the Agency has been minimal in each fiscal year (approximately $150). The Leg1s1ature has now enacted SB 794 (Statutes of 1980, Chapter 447), repealing the provision for state replacement revenue provided 1n Chap- ter 1150 and Chapter 610 for local agencies. This measure holds rede- velopment agencies harmless from the loss of bus1ness lnventory replace- ment revenues through state payments (spec~al subventions). The special subventions would be 1n amounts equal to the difference between the pre- . . . KatzHollis Mr. Ernesto R. Flores Santa Monlca Redevelopment Agency August 28, 1984 Page 4 vl.ously received business inventory replacement revenue and revenue de- ci ved by vlrtue of supplemental assessments (discussed above). If in any year, however, the previous year's revenues from the supplemental tax roll exceeds the former amount of bUsl.ness l.nventory subvention revenue, that prior year I s excess will be crealted agalnst the state subvention due. This legislation, effectlve for the 1984-85 fiscal year, will have an lnslgnlficant impact on proJect resources, and has not been lncluded In proJected tax revenues shown on Table 1. Verification of 1984-85 Taxable Value A review of the current year value for Ocean Park Redevelopment ProJect was conducted in order to venfy the accuracy of the 1984-85 ProJect Area values reported by Los Angeles County. Incorrectly reported values for a proJect area affect the amount by which the total proJect value exceeds the base year value, resulting in tax increment receipts which could be elther higher or lower than amounts actually due an agency. The review consisted of a parcel-by-parcel reVlew of the local secured and unsecured property tax values, and a review of taxable values for state assessed property. There appear to be two relatively IDlnor errors made by Los Angeles County in the computatlon of 1984-85 taxable value for the project Area. First, unsecured assessments outside the Project Area, havlng a comblned taxable value of $351,572, have been lncorrectly encoded for inClusion in total proJect value. The taxable value attributable to these assessments has been excluded from the prOJected Tax Allocatlons shown on Table 1. Secondly, an assessment apparently located wlthin the proJect Area boundanes has been excluded In the county's determination of total ~roject value. As of this writing, staff within the county AS- sessor's offlce are currently investigating their records concernlng the ProJect boundaries to determine the approprlateness of encodlng thls as- sessment for lncluslon in total ProJect value. (The 1984-85 taxable value of thls assessment lS $3,066,555.) The potential increase in Agency tax revenues which rnlght result from the verlflcatlon and reas- signment by the County of the $3 mlllion assessment has not, however, been included 1n the proJectlon. Tax Disbursement since 1979-80, the Agency has actually recelved from approx1mately 96 to 108 percent of estlmated tax lncrement revenues computed based upon proJ- ... .. . . . . Katz Hollis Mr. Ernesto R. Flores santa Mon1ca Redevelopment Agency August 28, 1984 Page 5 ect Area values as reported by the County Auditor-Controller in August of each fiscal year. The Agency's receipt of revenues Wh1Ch vary from originally computed revenues 1S the result of several factorsj delln- quent tax payments, redemptlon paymen ts from pr 1 or years, and ad Just- ments to the tax roll made throughout the fiscal year. In subsequent fiscal years, lt is also antlcipated that actual receipts may vary from original estimates. Because histor1cally, receipts in the Ocean Park Redevelopment ProJect have not van.ed signif1cantly from origlnal esti- mates, and have exceeded original estimates 1n certain fiscal years, Table 1 does not reflect potentlal adJustments of th1S nature. In accordance w1th the Agency's tax recelpt experience, combined secured and unsecured tax allocat10ns attr ibutable to the August estimate of revenues are received 1n periodic payments through January, representlng approxlmately 45% of the total revenue, wlth an additional 45% recelved through the end of May. The balance of the revenues are received through August of the fo1lowlng fiscal year. Historlcal Taxable values A review of taxable values Wl thln the project Area since 1978-79 was conducted in order to determine the historical stabillty anil/or growth of revenue generation w1th1n the ProJect Area. The review revealed that, in recent fiscal years (i.e., 1983-84 and 1984-851, taxable values for certain categories of property Were demonstrat1ng aberrant trends. Further analysis undertaken to establish the cause of the aberrat10ns ind~cated that changes in ownership within the completed Sea Colony I and II resident1al condomlnlum development were, in some instances, re- sult1ng in a net decrease 1n the taxable value for an indiv1dua1 unit. Discussions with county appralsal staff and a parcel-by-parcel analysis of all valuation changes which have occurred within the development since 1982-83 1ndicate that the assessed values be~ng ass1gned to resold un~ts ln recent Elscal years are less than values assigned in earl1er years of the development's eX1stence. It 1S unclear whether the decline is due to overstatement of the ear11er assessments or a net real decline in the market value of the unlts. W1th regard to the latter, County ap- praisal staff respons1ble for assigning taxable values to Sea Colony I and II 1nd1.cate that market condlt1ons have now improved such that the value of units selling presently and 1.n the near future should approxi- mate the 1980 sales values. . ~ . . . Katz Hollis Mr. Ernesto R. Flores Santa Monica Redevelopment Agency August 28, 1984 Page 6 If the improvement in market condltions does reVerse the trend of deva- 1uatlon for the unlts, total growth in value for the ProJect Area (which has, in all years analyzed, off-set the decline ln value of the condomi- niums} should accelerate. We have, however, excluded from the projec- tions of Table 1 any trended growth for the proJect Area ln fiscal years 1985-86 through 1987-88 as a ref1ectlon of the possibi11ty of contlnued decline in the value of the condomlnlums. Bew Construction Activity The estimates of taxable value added as a result of new construction and change in ownership activlty in the proJect Area include valuation esti- mates for an anticipated residentla1 development, .Colony III,. for which the exact scope and timJ.ng have yet to be finalized. An Amended Sales Agreement (August 17, 1983} between the Agency and Pacific Doml- nion Property Company (the Developer) provldes, under certain speclfied conditions, for the transfer of the proposed development site from the Agency to the Developer. Assumptions concerning the planned scope and timJ.ng of the proposed development are based prlmarily on information provlded by representatives of Paciflc Dominlon Property Company. Table 2 J.ndicates the estimated year to year additlon of taxable value to the ProJect. Resultant increases in tax allocations for 1985-86 through 1994-95 are reflected in Table 1. Sea Colony III is planned as a reSldentla1 development of PaClfic Domi- nion Property Company which completed a similar residential development wlthln the Project Area (Sea Colony I and II) in 1980. Plans for Sea Colony III include 26 townhouses and a four-story, 127 unit resldentla1 condominium overlooking the ocean. Construction is anticipated to start in the first quarter of 1985 and be completed in the fourth quarter of 1986. Additional taxable value as a result of the constructlon of the unlts is assumed to be added to the 1986-87 and 1987-88 tax rolls. Based on absorption rates experienced ln the sale of Sea Colony I and II unlts, lt lS assumed that approximately 65% of the units will close escrow through March, 1988 with the rema1ning units to close escrow by March, 1989. In addltion to the development of Seal colony III, lt lS our understand- lng that ln1tlal steps are underway to convert approxlmately 500 reS1- dential rental units (the Santa Monica Shores) into condom1niuws with1n the Project boundaries. AS the tlm1ng and realJ.zatlon of the converSlon are not known at the present time, this development actlvlty is not in- . .. , . . . KatzHollis Mr. Ernesto R. Flores Santa Monlca Redevelopment Agency August 28, 1984 Page 7 eluded 1n the ProJection of Tax Allocatlons. Should the Santa Monica Shores ultimately be sold as 1ndividual resl.dences, tax increment reve- nues generated by the ProJect w.ould increase slgnificantly over the amounts proJected in Table 1. Trended Taxable Value Growth Amounts added as the result of trended growth are based on the followlng assumptlons: Real Property Values: Real property is comprised of locally assessed secured and unsecured land and improvements. Slnce the enactment of Article XIIIA (effective as of the 1978-79 Fiscal Year), these values have been lim1 ted to growth reflecting 1nflation of up to two percent annually. MaJor exceptions to this .stabill.zation" of value are new assessments whl.ch may occur in lnstances of new construction or changes of ownership. The attached proJections are based on the assumption that l.nflation wlll remaln at a minimum of two percent annually in future Years. The PrO)ectlons on Table 1, however, exclude any trended growth through Flscal Year 1987-88 as a reflection of the possl.bl.l1ty of a de- chne in value of Sea Colony I and II. (See Historical Taxable Value sectlOn above.) In 1986-89 and thereafter, the maXl.mum lnflationary in- crease allowable (2 percent) has been included 1n the proJection. State Board of Equal1zation Values: Taxable values for propert1es as- sessed by the State Board of Equalization (SSE), shown under Other Prop- erty ln Table 1, have been held constant at 1984-85 levels for the pur- poses of the attached projections. A recent decislon by the state Court of Appeals, discussed below, may have an impact on the manner in WhlCh utility property is assessed by the SSE. However, such impact cannot be determlned at thl.S time, and has not been consldered in preparation of the attached prOJection. Following the passage of PrOposltlon 13, addlng Artlcle XIIIA to the state Constltution, the state Board of Equalization determlned that the provlsions of that Article requlrlng a roll back of real property values to theu 1975-76 values did not apply to state assessed property. The State Court of Appeals has recently overturned thlS deternunat10n and ruled that public utility property assessed by SBE should have been treated in the same manner as all other property. (ITT World Cornmunica- tlons, Inc. v. city and County of San Francisco, 151 Cal. App. 3d 1. Cal. Rptr.-Jan. 1984). ;, or- . . . Katz Hollis Mr. Ernesto R. Flores Santa Monica Redevelopment Agency August 28, 1984 Page 8 The State Court of Appeal's declsion has been appealed to the californla Supreme Court. However, a hearlng date has yet to be set. SBE staff have lndicated that if the Appeal Court's deciSlon is upheld by the SUpreme Court, the resulting assessments are not antlcipated to have s ignlficant impact state....ide, or on maJor utility assessees. However, there could be an lmpact on an area speclfic basis. Total 1983-84 SBE property tax value for the Project Area is $16,868,930 with $16,656,340 (98.8 percent) derived from valuations for a major utility assessee, General Telephone. Personal property Values - Taxable Value shown for 1984-85 under the Other Property category includes the value for secured and unsecured personal property. Personal Property 1S reassessed each year. Value for personal property has been held at the 1984-85 reported level throughout the project1on. We hope this information is useful and are avallable to respond to any questlons you may have. Sincerely, KATZ, HOLLIS, COREN & ASSOCIATES, INC. .... . . ... . . . ..... ..... ..0 '" E-< > ""' 0'0 >or>:; o c: -'" ~ ... 01'" ...:a. .u c:: c:: III Q) Q) E 0 0..0 o ..... > QJ '0' Q) r>:; CI:J .- - - - - .-c - S ~ ~ ~ <J,J ::l .. C III ~ E-< > Q) >>:: ... Q) ~I ii~ ...... QJ III ::l .u ...., o '" E-<> H~ ..... <II..., ..., '" o Q) E-< r>:; ~~~ i~ ...... III ... U '" tIl (lJ "" >< r.. M ..... 'J:I 0) i;t In .... M N 0) ~ ...... 0\ .... .... 0\ i;t ...... \Q Q t"- ...... ~ Q ,..., ..... CD t"- .... ..; "- Z .... ..; "- Z i;t .... Lt"1 '" I ..... CO 0\ ..... N 1'"- o:l .... "" .... .... '" <::> M '" - r- 0\ ..... '" <::> r- ...... '" '" .... o CO 0\ M ..... N <::> ,.., ..... CO r- '" CO I .... CO '" ...... ll\ r- '" <::> o CO ""' 0\ '" .... 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