86-1661 WHITE - CITY CLERK
PINK - FINANCE G TY OF SA I NT PAU L Council
CANARV - DEPARTMENT � Flle NO•
BLUE - MAVOR
� - uncil Resolution ,-�
Presente y ' � �`�'
Referred To L- Committee: Date � '- �
Out of Committee By Date
Wf�REA.S:
1. On December 3, 1986, he Port Authority of the City of Saint Paul ad pted
Resolution No. 2753 gi ing pr iminary approval to the issuance of taxable re enue bonds
in the initial princi amoun of $25,000,000 to finance the purehase of tvao office
buildings with a total f 506, 35 square feet and 19.94 acres of land fran S ce Center
Inc. The buildings ar locat at 444 and 520 Lafayette. Miller & Schroeder Financial
has agreed to undenari the venue bond issue for a term of 30 years.
2. Laws of Minne ta 197 , Chapter 234, provides that any issue of reve ue bonds
authorized by the Port uthori y of the City of Saint Paul, shall be issued o y with the
oonsent of the City C cil of the City of Saint Paul, by resolution adopted n accordance
with law;
3. The Port Aut ity of the City of Saint Paul has requested that the ity Council
give its requisite oon nt pur uant to said law to facilitate the issuance of said revenue
bonds by the Port Aut ity of the City of Saint Paul, subject to final appro al of the
details of said issue the rt Authority of the City of Saint Paul.
RESOLVED, by the 'ty Co cil of the City of Saint Paul, that in accorda ce with Laws
of Minnesota 1976, Cha er 234 the City Council hereby oonsents to the iss ce of the
aforesaid revenue bonds for th purposes described in the aforesaid Port Aut rity
R�esolution No. 2753 th exact etails of which, including, but not limited to provisions
relating to maturities, intere t rates, discount, recie�iption, and for the iss nce of
additional bonds are t be det rmined by the Port Authority, pursuant to reso ution
adopted by the Port Au rity, and the City Council hereby authorizes the iss nce of any
additional bonds (incl ing re unding bonds) by the Port Authority, found by e Port
Autharity to be necess for arrying out the purposes for which the aforesa d bonds are
issuea.
COUNCILMEN Requested by Department of:
Yeas Drew Nays ��
Nicosia [n Favor
Rettman
Scheibel
Sonnen � __ Ag81IlSt BY
Tedesco
Wilson
DE � 8 19�� Form Approved by City Attorney
Adopted by Council: Date � r-�
Certified Ya s d uncil Se t BY `-"
By
Appr by , avor: ��� Appro d y Mayor for Submiss' to o` cil
By — By
PU IISHED �� 1 01987
st. Paul port Author ty • DEPARTMENT ' � � ����� � _ OsOSS
.
J.A. Campobas'so, E.A Krau CONTACT
PHONE
December 3 1986 DAT� ��� ,Qi
ASSIGN NUhBER FOR R0 ING 0 R C1 All Locations for Si nature :
i Department Direct r � Director of Management yor
Finance and Manag ment S rvices Director � 4 City Clerk
Budget Director �, �TA��B�E ISSLIE
2 Clt,�/ At'�Ot"118„�/ SPACE CENTER INC. .
HAT WILL BE ACHIEYED BY TA NG ACT ON ON THE ATTACHED MATERIaLS? {Purpose/
Rationale) :
The purpose of the t xable evenue ond issue is to finance the purchase of two o ice
buildings containing a tota of 50 ,635 square feet on 19.94 acres of land from S ce Center,
Inc. The buiid�ngs re loc ted at 44 and 520 Lafayette.
RECEIVE
DEC 4 �
OST BENEFIT BUDGETA Y AND ERSONN L IMPACTS ANTICIP TED: ` MAYOR'S OFFI
The amount of the ta able b nd iss is $25,000,000 and,will be for a term of 30 ars.
Primary tenants in t e buil ing ar the Department of Human Services and the Minne ota Poilu-
tion Control Aqency. .
F3NANCING SOURCE AND UDGET CTIVIT NUhBER CHARGED OR CREDITED: (Mayor's signa-
ture not re-
Total Amaunt of"Tr nsacti n; N quired if und�r ,
� �10,000)
Funding Source: ;
Activity Number: •
ATTACHMENTS List and Numbe Al1 At achments : �
1. Staff Memorandum �
2. Draft City Council Reso tion ,
3. Port Authority Re oluti No. 53
cc. J. Shoholm
pEPARTMENT REVIEW CITY ATTORNEY REY�EW
,�Yes No Council Resolu ion Re uired? � Resolution Required? x es No
Yes x No Insuran e Requ red? Insurance Sufficient? X es No
Yes X No Insuran e Att hed:
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(S •REVER E SIDE� FOR INSTRUCTIONS)
Revised 12/84
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541I
�, Resolution No. �7�
RESOLUTION OF
THE RT AU HORITY OF THE CITY OF SAINT PAUL
WHE S, t e purpose of Chapter 474, Minnesota
Statutes, kn as t e Minnesota Municipal Industrial Develop
ment Act (here'nafte called "Act") as found and determined b
the legislatu is t promote the welfare of the state by the ,
active attract'on an encouragement and development of econom -
cally sound i ustry and commerce to prevent so far as possib e
the emergence f bli hted and marginal lands and areas of
chronic unempl yment and to aid in the developznent of existin
areas of bligh , mar inal land and persistent unemployment; a d
� , f ctors necessitating the active promotion
and deve opmen of e onomically sound industry and commerce a e
the incr asing conce tration o£ population in the metropolita
areas an the apidl rising increase in the amount and cost f
governme tal s rvice required to meet the needs of the
increase popu ation and the need for development of land use
which wi�l pro ide a adequate tax base to finance these
increased cost and ccess to employment opportunities for su h
population; an
WHE AS, T e Port Authority of the City of Saint Pa 1
(the "Authorit ") ha received from Space Center, Inc.
(hereinafter r ferre to as "Company") a request that the
Authority issu its axable revenue bonds to finance the
acquisition by the P rt Authority of two buildings currently
owned by the C mpany and located at 540 Lafayette and 444
Lafayett� in t e Cit of Saint Paul and the improvement of
other fa�iliti s own d by the Company and identified as
444 Buil ing edney Building and Great i�Torthern Freight Hous
(hereina ter c llect vely called the "Project") , all as is mo e
fully de cribe in t e staff report on file; and
� WHE AS, t e Authority desires to facilitate the
selectiv deve opmen of the community, to retain and improve
its tax ase a d to elp it provide the range of services and
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employment op ortun' ties required by its population, and sai
Project ,will ssist the City in achieving that objective. S id
Project 'Iwill elp t increase the assessed valuation of the
City an help maint in a positive relationship between asses ed
valuati n and debt nd enhance the image and reputation of t e
City; a d
WHE EAS, he Project to be financed by revenue bon s
will re ult i subs antial employment opportunities in the
Project;
WHE EAS, he Authority has been advised by repre-
sentatives of the C mpany that conventional , commercial
financing to ay th capital cost of the Project is availabl
only on a lim ted b sis and at such high costs oF borrowing
that the econ mic f asibility of operatinq the Project would be
significantly reduc d, but the Company has also advised this
Authority tha but or revenue bond financing, and its
resulting low borro ing cost, the Project would not be •
undertaken;
, WHE EAS, e Authority, pursuant to Minnesota
Statute , Sec ion 47 .01, Subdivision 7b did publish a notic ,
a copy of whi h with proof of publication is on file in the
office of the Autho ity, of a public hearing on the proposal of
the Comp ny t at the Authority finance the Project hereinbef re
described by he is uance of its industrial revenue bonds; a d
WHE EAS, e Authority did conduct a public hearin
pursuant to s id no ice, at which hearing the recommendation
containe in he Aut ority's staff inemorandum to the
Commissiloners were eviewed, and all persons who appeared at
the hear,ing w re giv n an opportunity to express their views
with respect o the roposal.
NOW� THERE ORE� BE IT RESOLVED by the Commissioner
of the Port A thori of the City of Saint Paul, Minnesota a
follows:
1. On th basis of information available to the
Authority it ppear , and the Authority hereby finds, that s id
Project ,const' tutes roperties, used or useful in connection
with one',, or m re re nue producing enterprises engaged in an
business within the eaning of Subdivision 1(a) of Section
474.02 of the Act; hat the Project furthers the purposes
stated i Sec ion 47 .O1 of the Act and, but for the
willingness o the uthority to furnish such financing, the
Company ould not un ertake the Project , and that the effect of
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the Project, if unde taken, will be to encourage the develop-
ment of econo ically sound industry and commerce and assist i
the prevention of th emergence of blighted and marginal land,
and will help to pre ent chronic unemployment, and will help
the City to retain a d improve its tax base and provide the
range of services an employment opportunities required by it
population, an will help to prevent the movement of talented
and educated rsons out of the state and to areas within the
state where th ir se vices may not be as effectively used and
will result in more ntensive development and use of land
within the Cit and ill eventually result in an increase in
the City's tax base; and that it is in the best interests of
the port distr' ct an the people of the City of Saint Paul an
in furtherance of th general plan of development to assist t e
Company in fin ncing the Project.
2. Subje t to the mutual agreement of the
Authority, the Compa y and the purchaser of the revenue bonds
as to the deta' ls of the lease or other revenue agreement as .
defined in the Act, nd other documents necessary to evidence
and effect the finan ing of the Project and the issuance of t e
revenue bonds, the P oject is hereby approved and authorized
and the issuan e of axable revenue bonds of the Authority in
an amount not o exc ed approximately $25,000,000 (other than
such additiona reve ue bonds as are needed to complete the
Project) is au horiz d to finance the costs of the Project an
the recommenda ions f the Authority' s staff, as set forth in
the staff inemo andum to the Commissioners which was presented
to the Commiss 'oners are incorporated herein by reference an
approved.
3. There has heretofore been filed with the
Authority a fo of reliminary Agreement between the Authori y
and Company, r latin to the proposed construction and
financing of t e Pro ect. The form of this aqreement has bee
examined by th Comm ssioners. It is the purpose of the
agreement to e idenc the commitment of the parties and their
intentions wit resp ct to the proposed Project. Said
Agreement is h reby pproved, and the President and Secretary
of the Authori y are hereby authorized and directed to execut
said Agreement
4. Upon xecution of the Preliminary Agreement by
the Company, t e sta £ of the Authority is authorized and
directed to co tinue negotiations with the Company so as to
resolve the re ainin issues necessary to the preparation of
the documents ecess ry to the adoption by the Authority of i s
� final bond res lutio and the issuance and delivery of the
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revenue bonds; provi ed that the President (or Vice-Presiden
if the Presid nt is absent) and the Secretary (or Assistant
Secretary if he Secretary is absent) of the Authority, or i
either f suc offi ers (and his alternative) are absent, th
Treasur r of he Authority in lieu of such absent officers, re
hereby uthor zed i accordance with the provisions of
Minneso a Sta utes, ection 475 .06, Subdivision 1, to accept a
final offer o the nderwriter made by the Underwriter to
purchase said bonds nd to execute an Underwriting Agreement
setting ,forth such ffer on behalf of the Authority. Such
accepta ce sh 11 bin the Underwriter to said offer but shal
be subj ct to appro al and ratification by the Port Authorit
in a fo mal s ppleme tal bond resolution to be adopted prior to
the delivery f said revenue bonds.
5. The r venue bonds (including any interim note or
notes) a,nd in erest thereon shall not constitute an
indebtedness f the uthority or the City of Saint Paul with' n
the mea ing o any constitutional or statutory limitation an
shall not con titute or give rise to a pecuniary liability o �
the Auth!ority or the City or a charge against their general
credit or tax' ng pow rs and neither the full faith and credi
nor the taxin powe s of the Authority or the City is pledge
for the i,payme t of t e bonds (and interim note or notes) or
interest ther on.
6. In or er to facilitate completion of the reve ue
bond financin herein contemplated� the City Council is here y
requested to onsent, pursuant to Laws of Minnesota, 1976,
Chapter 234, o the issuance of the revenue bonds ( including
any interim n te or otes) herein contemplated and any
additio al bo ds which the Authority may prior to issuance o
from time to ime th reafter deem necessary to complete the
Project or to refund such revenue bonds; and for such purpos
the Executive ice P esident of the Authority is hereby
authorized an directed to forward to the City Council copie
of this resol tion a d said PreliminarX Agreement and any
additional av ilable information the City Council may reques .
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7. The ctions of the Executive Vice-President o
the Authority in ca sing public notice of the public hearing
and in escri ing t e general nature of the Project and
estimat 'ng th prin ipal amount of bonds to be issued to
finance the P oject re in all respects ratified and confirm d.
Adopted Decem er 3, 1986
Attest ' /s/ George W. Winter
President
The Port Authority of the City
of Saint Paul
s Arthur . Good an
Secretary
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PORT � � � . - ������
� AUTH RI Y
OF THE CITY OF . PAUL
Memorandum
TO: BOARD F COMM SSIONE S DATE: DEC. 1, 1986
(MEETI G DECE BER 3, 1986)
FROM: John A. Campo asso "
, �
SUBJECT:
PUBLIC HEARIN - PRE IMINARY AND UNDERWRITING AGREEMENTS
$25,000,000 T BLE VENUE BOND ISSUE
SPACE CENTER, INC. - OFF-SITE
RESOLU�ION NO 2753
PUBLIC SALE H ARING SALE OF LAND
SPACE ENTER, INC. - UFF-SITE
RESOLU ION NO 2754
1. Th Com a
Sp ce Cen er, In . was established in 1916 at its present headqu rters
in Lafaye te Par . For the past seventy years the Minnesota
Corporati n has een primarily involved in real estate managemen with
other act vities including warehousing, transportation, financia
services nd co unications. The Company has invested over $20, 00,000
in the La ayette Park area with ownership of over 45 acres. The have
developed three ffice buildings containing over b30,000 Sq. Ft. which
are home o many State offices including the Department of Natur 1
Resources Pollu ion Control Agency and Department of Human Servi ces.
They own large general warehouse facility totaling 240,000 Sq. Ft.
and sever 1 othe buildings in the area that have potential for
rehabilit tion.
2. The Pro e t
St ff pro oses t e purchase of two office buildings from Space C nter,
In . for 25,000 000 including 19.94 acres. Two appraisals have been
co ducted one b Muske, Inc. indicating a value of $27,600,000 nd
an ther b Ameri an Appraisal Associates, Inc. indicating a valu of
$27,385,0 U. Mu e, Inc.'s appraisal is broken down as follows:
I� Bui ding - 444 Lafayette Road $15,U90,000
' Bui ding - 520 Lafayette Road $ 9,630,000
Lan $ 2,880,000
The appra sals w re based on existing leases in place, Space Cen er's
guarantee to cov r any shortfalls and Port Authority financing.
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BOARD OF COMMI SIONER
SPECIAL MEETI DECEM ER 3, 1986
SPACE CENTER, INC.
PAGE 2
One of the buildi gs to be purchased is located at 444 Lafayette with
gross Sq. t. of 23,635 and a total net leaseable space of 233, 00 Sq.
Ft. The pr mary t nant is the Department of Human Services with 53,000
Sq. Ft. dition 1 tenants include the Department of Labor and
Industry, inneso a Tax Court and Computer Service Company.
The other uildin located at 520 Lafayette, has gross Sq. Ft. o
183,000 an tota net leaseable Sq. Ft. of 154,919 with the pri ary
tenant bei g the ollution Control Agency with 75,000 Sq. Ft. ,
Additional tenant include the Department of Employee Relations, Office
of Attorne Gener 1, and Office of Lawyers Professional Responsi ility.
The two ma or ten nts in both of these buildings have recently s gned
five year scalat ng leases which terminate in late 1991.
The sale s prop sed in an effort to free Space Center, Inc.'s quity
in the two buildi gs so they would be able to do additional proj cts in
Lafayette ark. pace Center, Inc. has explored alternative fin ncing
for the pr ject; owever, based on the five year term of the lea es
they have ot bee able to secure adequate financing to proceed ith
additional invest ent in the area. In addition the low fixed in erest
rate and t e long term financing was necessary for the feasibili y of
the projec and w s not available through other sources.
Space Cent r, Inc is proposing to take $8,205,000 from the proc eds of
the sale d inve t them in rehabilitation of buildings in Lafay tte
Park. The propos l includes $5,000,000 for the renovation of th 444
Lafayette uildin , $1�,500,000 for the Great Northern Freight Ho se and
$1,705,000 for th Kedney Building. The rehabilitation of the G eat
Northern F eight ouse will allow Space Center, Inc. to move its
headquarte s from the 444 building, allowing the Department of Hu an
Services t expan its square footage in that building.
Space Cent r, Inc proposes to enter into a Management Agreement with
the Port thorit to manage the two properties. The management fee
would be b sed on 4Y. of net revenues plus SO% of excess net oper ting
income (N I) once the Port Authority has retained lOX of the ini ial
excess NOI. The nagement fee will be subordinated to the debt
service wi h any hortfall being carried forward and being recap ured
when exces NOI i available.
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BOARD F COMM SSIONE S
SPECI MEETI G NOVE BER 3, 1986
SPACE ENTER, INC.
PAGE 3
3. Ba Ik r
� oun
The Port uthori y Commission at its October 14, 1983, Board Mee ing
approved he cre tion of an industrial development district
encompass ng the entire Enterprise Zone of which Lafayette Park as
included. The P rt Authority in August of 1985 assumed the
responsib lity o administering the Enterprise Zone program and n
encoura�i capi al investment within the Zone. This project wi 1 meet
the inten of th creation of the district and will have a signi icant
impact on capita investment within the Enterprise Zone. .
Bo 'h Dist icts 4 and 5 are supportive of the pro�ect. District , in
pa ticula , woul like to see a continued development effort mov
no thward toward illiams Hill while District 4 is interested in
de elopme t alon Seventh Street.
The City' Plann g and Economic Development Department is in th
process o study ng the land use for the entire Lafayette Park/W lliams
Hil�l area and is in support of the type of development Space Cen er,
Incl. is p oposin . Space Center, Inc., the City and the Port Au hority
have work d close y to insure that this project is within the sc pe of
the City' Compr ensive Plan for the area and all parties agree that
the proje t will nhance future development in the area. Space enter,
Inc. has lso wo ed closely with the State of Minnesota and has
reviewed he prop sed State Office Campus concept with the Depar ment
of Admini tration and the Governor.
Future de elopmen , beyond the scope of this project, includes o fice
space for the Dep rtment of Public Safety and the Department of evenue
for which equest for Proposals are anticipated to be out in the Spring
or �ummer of 1987. The Department of Revenue's requirements for 70,000
Sq.� Ft. o one fl or (building foot print) makes Lafayette Park ne of
the r mos viable locations.
4. Fin ncin
The propo d fina cing would be done as a taxable revenue bond i sue
bas d on thirty year amortization with a five year "put" provi ion.
The "put" rovisi n allows the bonds to be refinanced at the end of
fiv year as wel as provides Space Center, Inc. with an option to
pur�hase that ime. The option price would be for the outsta ding
principal on the onds, less debt service reserve including inte est
earnings d the alance of the excess accumulated net operating
income. e Port Authority would have the ability to sell the
buildings to the tate with Space Center, Inc. maintaining its o tion
to purchas .
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BOAItD OF COMM SSIONE S
SPECIAL MEETI G DECE BER 3, 1986
SPACE CENTER, INC.
PAGE 4
The Port uthori would receive its customary 1'G fiscal and
administr tive f es as well as lOX of any excess net operating i come
from the roject. The Port Authority will also control the
construct on fun and debt service reserve and will approve all
dispersem nts fr these funds including interest earned. The p oceeds
from the ale wi 1 be dispersed as follows:
Pay ent of utstanding Debt $ 9,600,000
Deb Servi Reserve 2,620,000 •
Con tructi Fund 8,205,000
Spa e Cent , Inc. 4,000,000
Bon Issua e 75,000
Bon Disco t 500,000
$25,000,000
Space Cen er, Inc. has agreed to guarantee any shortfall on the ebt
service t t cann t be covered from interest earnings on the res rve
and const uction unds.
5. Underwriti
Miller & hroede Financial, Inc. has agreed to underwrite the hirty
year bond issue a an interest rate to be set at the time the bo ds are
sold. We nticip te the bonds will be sold at our regular Decem er,
1986, Boa Meeti g.
6. Recommenda ion
Staff has ntervi wed officers of the corporation, reviewed thei
financial tateme ts as well as existing leases on the two facil ties
and recom nds ap roval of the above resolutions.
sjs
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PORT AUTHO�IN OF T E CIN O SAINT PAUL TOLL FREE(800 328-8417
1900 AMHOI T TOWER • 34 ST. PEfER STREET • ST. PAUL, MN, 55102 • PHONE(612 224-5686
December 3, 1986
Mr. J�ne$ Bellu , Dire tor
Planningland E nomic veloFment Department � �
City of �t. Pau ��
14th Floor, Cit Hall ex
St. Paul� Minne ota 5 102 �'�
SUBJECT: � SPACE CEI�TrER INC.
$25,0 0,000 AXABLE REVENUE BOND ISSUE
Dear Jim�
We sutmit herew th for your review and referral to the office of the yor,
City Co cil an City ttorney's office details pertaining to the iss nce
of $25,0�0,000 n taxa le revenue bonds to finance the purchase of t
office building conta ning 506,635 square feet on 19.94 acres of lan fran
Space Cer�ter, I c. T buildings are located at 444 and 520 Lafayett .
In addit�on to e sta f inesr�orandi,an, w�e are attaching a draft copy of the
proposed'City uncil esolution and a copy of Port Authority Resolut' n
No. 2753 which uthori ed ttie sale of taxable revenue bonds in the unt
of $25,OQ0,000.
Your expeditiou handi ng of this matter will be appreciated.
�ours truly,
.
gene A. Kraut
EAK:ca Executive Vice President
oc. Mayor Latun r
EUGENE A KRAUT,C.I.D. D�NALD G.D NSHEE,C.I.D. CHARLES M.TpWLE CLIFFORD E.RAMSTED,P.E. PERRY K.FEDERS C.P.A.
EXECUTIVE VICE PRESIDENT ASSL EXEC.VI E PRESIDENT DIRECTOR OF INDUSTRIAL DEVELOPMENT CHIEF ENGINEER DIRECTOR OF FiNANCE
ASST.TREASURER
RICHARD GIERDAL WILLIAM E.McGNERN
�,I PROPERTY ANAGER DIRECTOR OF PUBLIC RELATIONS
COMMISSIONERS GEORGE W.WINTER WIL AM WILSON ARTHUR N.GOODMAN VICTOR P.REIM RAYMOND E.LANGEVIN CHRIS N OSIA JEAN M.WEST
PRESIDENT I VI E PRESIDENT SECREfARV TREASURER COMMISSIONER COMMI IONER COMMISSIONER
C.I.D.Certified Industrial Developer
. � �., � ���-�
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. �� CI Y OF SAINT PAUL
:�ii�iii:`iu . O G'E OF TS� CITY COUDTCIL
Cammittee Report
F�i� ce l�ana eme�t � Persannel �ommittee.
DEC�ER 11, 1986 '
1. Approval or minu es fro meeting held November 26, 1986. a roved.
2 _ .<w• �; a� _ . . .
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3. Resolution appro ing th issuance of Port Authority Revenue Bonds in t
amount of $628,0 0 to f nance the construction of an office, manufactu ing
and warehouse fa ility or S & S Partnership in Riverview Industrial P rk.
approved ,
4. Resolution amend ng the 1986 budget by adding $46,623 to the Financing Plan
. � and to 'the Spend ng Pl� fo•r General Government Accounts = Housing Inf rmation •
Office. a r ved � � '
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� "5. Resolution amend ng the 1986 budget by adding $28,(s30- to �the Financing Plan -- -
� and Co the Spend'ng Pla �or General Fund - Finance and Management Ser ices -
Housing Informat'on Off ce. approved
6. Resolution amend'ng the 1986 budget by adding $4,000 to the Financing lan
and to the Spend'ng Pla for City Attorney - Outside Services. a r ved
7. Resolution amend'ng the 1986 budget by adding $20,000 to the Financing Plan
� and to the Spen "ng Pla for Parks and Recreation - Private Donations. �
approved
8. Resolution amen ing the 1986 budget by adding $42,938 to the Financing Plan
and to the Spen ing P1 - Police Accreditation. approved
9. Resolution amen ing th 1986 budget by adding $42,938 to the Financing Pl.an
and to the Spen ing P1 for Special Projects - Police Accreditation. approved
10. Resolution amen ing th 1986 budget by adding $118,910 to the Financin Plan
and to the Spen ing P1 n for Public Works - Engineering. a roved
11. Resolution appr ving t e 1986-1989 Maintenance Labor Agreement between
'Independent Sch ol Dis ri.ct 625 and Plasterers Local No. 20. a rov d
12. Resolution amen ing th 1986 budget by transferring $28,000 from Conti gent
Reserve to Comm nity S rvices - Public Health for the Lead Study Progr m.
approved
C;I7' HAI-I- FLOOR SAL�i"C PAUL, OTA 55IO2
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