Agenda 07/26/2011 Item # 9H7/26/2011 Item 9.H.
EXECUTIVE SUMMARY
OBJECTIVE: The "Impact Fee Program for Existing Commercial Redevelopment" results in a
waiver of impact fees for the benefit of the permitee to the extent that redevelopment has an impact
upon the county's infrastructure, and the permitee is not required to pay the otherwise resulting
impact fees. If a permitee is granted such a waiver, for economic development incentive purposes,
the development's impact on the infrastructure will need to he funded by an alternative source of
county revenues (like property taxes) to ensure the cost is not absorbed by other fee payers. About
60 companies have benefited from waivers granted pursuant to the "Impact Fee Program for
Existing Commercial Redevelopment." However, the county has not funded the Impact Fee funds
as legally required, from alternative revenue sources where the redevelopment has resulted in an
impact on infrastructure. The most likely source of repayment would be the General Fund. At
this time the obligation owed is potentially as high as 52,369,293 plus the known future obligation
attributable to Arthrex's commercial redevelopment of its' Creekside facility which was not
included in the calculation included in its' Fee Payment Assistance application. This could add (up
to) an additional $500,000 that the General fund owes the Impact Fee funds in the future. As such,
the General Fund faces an unfunded liability which has not been budgeted amounting to what
could be as much as $3 million dollars. There are other programs /transactions which will likely
have the same adverse impact on the General Fund and should be accounted for accordingly, for
example: impact fee waivers granted developments by non - profits.
CONSIDERATIONS: The "Impact Fee Program for Existing Commercial Redevelopment" results
in a waiver of impact fees for the benefit of the permitee to the extent that redevelopment has an
impact upon the county's infrastructure, and the permitee is not required to pay the otherwise
resulting impact fees. if a permitee is granted such a waiver, for economic development incentive
purposes, the development's impact on the infrastructure will need to be funded by an alternative
source of county revenues (like property taxes) to ensure the cost is not absorbed by other fee
payers. About 60 companies have benefited from waivers granted pursuant to the "Impact Fee
Program for Existing Commercial Redevelopment." However, the county has not funded the
Impact Fee funds as legally required, from alternative revenue sources. The most likely source of
repayment would be the General Fund. At this time the obligation owed is potentially as high as
$2,369,293 plus the known future obligation attributable to Arthrex's commercial redevelopment of
its' Creekside facility which was not included in the calculation included in its' Fee Payment
Assistance application. This could add (up to) an additional $500,000 that the General fund owes
the Impact Fee funds in the future. As such, the General Fund faces an unfunded liability which
has not been budgeted amounting to what could be as much as S3 million dollars. There are other
programs /transactions which will likely have the same adverse impact on the General Fund and
should be accounted for accordingly, for example: impact fee waivers granted developments by
non - profits.
FISCAL IMPACT: General Fund (or alternative county revenue source) obligation potentially
owed to the Impact Fee funds in the range of 52.37- $3 million. Exact amount to be calculated by
County Finance and Staff.
LEGAL CONSIDERATIONS: See Nabors Giblin & Nickerson PA legal opinion dated March 24,
2011 regarding "Waivers of Impact Fees" providing that waivers of impact fees where a particular
T development has an impact on infrastructure and where the impact fee is due but not paid as a
result of a policy set by the county, requires the county make the impact fee funds whole from
Packet Page -563-
7/26/2011 Item 9.1-1.
alternative sources of revenues. Growth under no circumstances can be charged more than its fair
share. If it does, then the impact fee is deemed an unlawful tax and is not authorized by Florida
law. The impact fees not paid by the permitee, must be paid by the county, not by the other fee
pavers.
See also Chapter 74- 201(c)(5) Imposition of Impact Fees — Impact Fee Program for Existing
Commercial Redevelopment
GROWTH MANAGEMENT IMPACT: None
RECOMMENDATION: Direct County Staff and County Finance to calculate the extent to which
the General Fund owes the Impact Fee Funds for the Impact Fees waived pursuant to the Existing
Commercial Redevelopment, other similar programs and transactions for the reasons stated above
under legal considerations.
Prepared By: Commissioner Georgia Hiller
Attachments: Staff Email, Nabors Giblin Legal Opinion, Ordinance 74 -201 in part.
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7/26/2011 Item 9.H.
COLLIER COUNTY
Board of County Commissioners
Item Number: 9.H.
Item Summary: Commercial Redevelopment Impact Fee Executive Summary.
(Commissioner Hiller)
Meeting Date: 7/26/2011
Prepared By
Name: RainevJennifer
Title: Executive Aide. BCC
7/20/2011 11:30:00 AM
Submitted b}
Title: Executive Aide. BCC
Name: Rainevlennifer
7/20/2011 11:30:01 AM
Approved By
Name: IsacksonMark
Title: Director -Corp Financial and Mgmt Svs.CMO
Date: 7/20/2011 1:37:13 PM
Packet Page -565-
RE: Change of Use Program
7/26/2011 Item 9.1-1.
RE: Change of Use Program
PattersonAmy
Sent: Monday, June 27, 2011 5:17 PM
To: NillerGeorgia
cc: ochsLeo; casalanguldaNick
Yes.
Year 1- $1,266,277.54
Year 2 - $1,103,015.99
Total- $2,369,293.53
Thank you,
Amy
From: HillerGeorgia
Sent: Monday, June 27, 20115:12 PM
To: PattersonAmy
Cc: Ochsbeo; CasalanguidaNick
Subject: Re: Change of Use Program
Would you have the total awarded to the 60 companies?
Georgia Hiller
Commissioner, District 2
On Jun 27, 2011, at 4:58 PM, "PattersonAmy" <AmvPatterson(a�colliereov neV wrote:
Commissioner Hiller,
Per your request, attached please find the Code provisions related to the Change of Use Program (below)
and the 2010 and 2011 Annual Reports, along with the Resolution extending the Program to March of 2012.
The adopted program provisions are as follows:
Collier County Code of Laws and Ordinances - Chapter 74
74 -201. Imposition of Fees
i) Impact Fee Program for Existing Commercial Redevelopment. Proposed developments
which meet the criteria set forth below shall not be assessed additional impact fees related
to changes of use within the existing buildings, except for water and wastewater impact fee
assessments which are exempt from this program. This program will officially sunset two
years from the date of adoption unless continued by a resolution of the Board of County
Commissioners prior to this date.
https: // mail. colliergov .net /owa/ ?ae= ltem &t= IPM.Nc °'' -- 7hYJwxlSLoTg %2fl %2fUsGxBwA... 7/18/2011
Packet Page -566-
RE: Change of Use Program
7/26/2011 Item 9.H.
Development is proposed within a lawfully existing building which has had a Certificate of
Occupancy issued for at least 3 years. Impact fees for the existing building must have been
paid the then applicable impact fees at time of construction; and
Proposed development is solely within the existing building and does not include the addition
of any new square footage.
C. Demolition and reconstruction projects are not eligible for this program.
s +r
Please let me know if you have any questions.
Thank you,
Amy
252 -5721
285 -6831
Under Florida Law. e-mail addresses are public records. If you do not want your e-mail address released in response to a public
records request do not send electronic mail to this entity. instead. contact this office by telephone or in writing.
<Change of Use 2010 I.pdf>
<Change of Use 2010 Ii.pdf>
<Change of Use 2011.pdf>
<Resolution 2011- 054.pdf>
https : / /mail.colliergov.net/owa' ?ae= Item &t= IPM.Nr ' ' ' " 7hYJwxlSLoTg %2fIa /o2fUsGxBwA... 7718/2011
Packet Page -567-
TALLAHASSEE
Sum 200
1500 Mahan Orr e
Tallahas , Florida 32308
(850) 224 -4070 Tel
(850)22A-4073 Fax
Reply to Tallahassee
Nabors
Gib in
Nic ersonPA
d FoRFJEYS A-, LA'N
March 24, 2011
Via Electronic and U.S. Mail
Amy Patterson.
Collier County Impact Fee Manager
2800 N. Horseshoe Drive
Naples, Florida 34104
Re:
Dear Ms. Patterson:
Waivers of Impact Fees
7/26/2011 Item 9.H.
FORT LAUDERDALE
208 S.E. Sixth Street
Fort Lauderdale, Florida 33301
(954) 525 -8000 Tel
(954) 525-8331 Fax
TAMPA
Sum 1060
2502 Rocky Point Drive
Tampa, Florida 33607
(813) 281 -2222 Tel
(813) 281 -0129 Fax
Our firm has been requested to provide an opinion as to whether the County
may grant an exemption or waiver of impact fees for certain economic
development purposes.
Based upon our discussions, the County is contemplating a proposal
involving the establishment of a program whereby an annual amount will be
established which will be available for an exemption or waiver of impact fees upon
certain non - residential development within the County. The specific non-
residential development which would be eligible for such exemption or waiver
would be identified targeted industries that meet specific guidelines. We have not
been asked to review the guidelines themselves, so therefore our analysis will
address the validity of the concept itself.
Packet Page -568-
7/26/2011 Item 9.H.
Amy Patterson
Collier County Impact Fee Manager
March 24, 2011
Page 2
Summary Answer
Collier County may grant exemptions or waivers to certain targeted
industries based upon established guidelines. As a result of the exemption or
waiver, sufficient protections must be incorporated in the administration of the
impact fee to assure that the cost of infrastructure needed to support such industries
is not absorbed by other impact fee payers.
General Discussion
Impact fees are charges imposed against new development to provide for the
cost of capital facilities made necessary by that new growth. The purpose of the
charge is to impose upon the newcomers, rather than the general public, the cost of
new facilities necessitated by their arrival. See City of Dunedin v. Contractors &
Builders Ass'n of Pinellas Count v, 312 So. 2d 763 (Fla. 2d DCA 1975).
Impact fees are a product of a local governments' home rule powers and are
imposed in conjunction with their power to regulate land use and their statutory
responsibility to adopt and enforce comprehensive planning. See Art. VIII, § 2,
Fla. Const.; City of Miami Beach v Fleetwood Hotel. Inc., 261 So. 2d 801, 805
(Fla. 1972); Wald Corp. v. Metro. Dade Countv, 338 Sc. 2d 863, 868 (Fla. 3d DCA
1976). As the development of the requirements for a valid impact fee has been
through the exercise of local governments' home rule powers, their characteristics
and limitations are derived predominantly from Florida case law and not by
statute.'
' In 2006, the Legislature adopted section 163.31801, Florida Statutes, which
set forth certain requirements for a valid impact fee. The primary purpose of the
enactment was to memorialize certain standards which had been developed over
the years in the administration of impact fees.
Packet Page -S69-
7/26/2011 Item 9.H.
Amy Patterson
Collier County Impact Fee Manager
March 24, 2011
Page 3
As developed under Florida case law, a valid impact fee must meet the "dual
rational nexus two -prong test. First, there must be a reasonable connection or
rational nexus between the anticipated need for the additional capital facilities and
the rgrowth in population. Second, there must be a reasonable connection or
rational nexus between the expenditure of the impact fee proceeds and the benefits
accruing to the rg owth that paid those proceeds. See Hollywood, Inc. v. Broward
County, 431 So. 2d 606, 611 -12 (Fla. 4th DCA 1983). See also St. Johns County
v. N.E. Fla. Builders Ass'n, 583 So. 2d 635, 637 (Fla. 1991).
Under the first prong of the dual rational nexus test, the needs are
sufficiently attributable to new development when the need for additional capital
facilities is rationally related to the rg owth generated by that development. See
Hollywood, Inc., 431 So. 2d at 611. The second prong of the dual rational nexus
test requires that for a valid impact fee there must be a reasonable connection or
rational nexus between the expenditure of the fees collected and the benefits
accruing to the new development. See id. a*. 611.
Waivers or Exemptions
In the administration of impact fees, local governments frequently
incorporate provisions which authorize either the exemption or waiver of impact
fees from certain development. Though frequently the terms "exemption" and
"waiver" are used interchangeably, they do have a difference in meaning.
Generally, exemptions are granted where a particular development does not have
an impact on infrastructure and, therefore, no fee is due. For example, the
renovation of an existing residential unit which does not create any additional
dwelling units is generally determined to be exempt from the payment of the fee,
primarily because no new impact is created. Normally, waivers are provisions
which are applied to a particular development that has an impact upon the
infrastructure, yet, based upon some policy determination, the governmental entity
has determined that they should not be required to pay the impact fee. The
economic development incentive program being considered in Collier County is in
the nature of a waiver. For the purpose of these discussions, exemptions and
waivers shall be collectively referred to as "exemptions."
Packet Page -570-
7/26/2011 Item 9.1-1.
Amy Patterson
Collier County Impact Fee Manager
March 24, 2011
Page 4
Collier County currently authorizes several exemptions under its existing
ordinances. (See Article I1, section 74- 201(d), Code of Collier County). Several
of these are in the nature of an exemption, as they are necessary to meet the
requirements of a valid impact fee. (See Article II, section 74- 201(d)(I), (2), (4),
(5) and (6), Code of Collier County). However, some of the exemptions under the
ordinance are more in the nature of waivers similar to the concept that would apply
for an economic development waiver. (See Article II, section 74- 201(d)(3), Code
of Collier County - publicly owned residential housing). As such, true waivers
already exist under the County Code.
In the analysis of exemptions of impact fees, there are two aspects which
need to be reviewed. The first is whether the exemptions serve a public purpose
and, second, whether the manner in which the exemptions is applied affects the
validity of the impact fee. Each which will be discussed separately.
Public Purpose
In the crafting of waivers or exemptions from the payment of fees, sufficient
guidelines must be provided to assure that the application of the exemptions is
evenly applied and serves a public purpose. The determination of the existence of
a public purpose is generally a matter for the legislative body, subject only that
such determination is not deemed arbitrary. Miccosukee Tribe v. S. Fla, Water
MPmt. Dist., 48 So. 2d 811 (2010); Jackson -Shaw Co. v. Jacksonville Aviation
Auth., 8 So. 3d 1076 (Fla. 2008).
Many local governments implement programs which provide incentives for
economic development within their community. Florida law contains a variety of
provisions which authorize the granting of incentives for economic development
purposes. The provisions of Article VII, section 3 of the Florida Constitution and
section 196.1995, Florida Statutes, deal with the granting of exemptions from ad
valorem taxation for economic development purposes. An additional provision for
economic development is contained in section 125.045, Florida Statutes. Both the
constitutional provision and the statutory sections provide clear legislative
Packet Page -S71-
7/26/2011 Item 9.H.
Amy Patterson
Collier County Impact Fee Manager
March 24, 2011
Page 5
authority that programs which aid in economic development serve a public
purpose. For example, section 125.045, Florida Statutes, clearly provides that the
expenditure of public funds for economic development activities, including
developing local infrastructure, issuing bonds to finance or refinance the cost of
capital projects, leasing or conveying real property and making grants to private
enterprises for the expansion of businesses existing in the community, or the
attraction of new business to the community, all serve a public purpose and are a
valid use of public funds. Consistent with this constitutional and statutory
recognition, several local governments have utilized the exemption of impact fees
as an incentive to encourage economic development. This may be through a
variety of means, including full or partial exemptions of impact fees and /or the
deferral of payment, all of which, if appropriately targeted, serve a public purpose.
Therefore, the provision of economic incentives through the exemption of impact
fees serves a public purpose.2
Validity As To Impact Fees
The fundamental premise of impact fees is that new development should be
required to pay its fair share of the cost of its impacts upon infrastructure required
to serve that development. Though growth may be charged less than its fair share,
it can under no circumstances pay more. If it does, then the impact fee is deemed
an unlawful tax and not authorized by Florida law. See Volusia County v.
Aberdeen at Ormond Beach, L.P., 760 So. 2d 126 (Fla. 2000).
In Collier County, impact fees are calculated on the basis of one hundred
percent of the cost of growth's impact on infrastructure. Even if a new
development is granted an exemption for economic development purposes, that
new development still has an impact upon infrastructure which will need to be
2 However, in the implementation of that program, it is essential that there be
clear guidelines within which to evaluate businesses that are eligible for economic
incentives, such as the exemption of impact fees. Failure to do so could lead to
legal challenges as to the arbitrary application of the exemption program.
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7/26/2011 Item 9.H.
Amy Patterson
Collier County Impact Fee Manager
March 24, 2011
Page 6
funded. Therefore, sufficient protections must be incorporated into the
administration of the impact fee to assure that the cost of the infrastructure to
support such businesses is not absorbed by other fee payers. Generally, that impact
is addressed by the use of alternative revenue sources. Therefore, if an exemption
is granted, the impact upon the infrastructure resulting from that new development
should be addressed by other revenues appropriated to offset that impact. Failure
to do so or provide some other mechanism to address that cost would be contrary
to established impact fee law and potentially could result in the fee's invalidity.
Further, to the extent that other revenues are utilized to offset the impact of new
development on infrastructure and other growth which has contributed to this
revenue stream, then a credit may be due.
Therefore, it is our opinion that exemptions can be given for economic
development purposes, provided clear guidelines are established. Further, that the
amount exempted should be funded from other revenue sources and, to the extent
that those revenues are derived from other development that is subject to the
payment of impact fees, then a credit may be required.
Should you have any guegtions, please feel free to contact me.
Sincerely,
Greeory T. Stewart
GTS:pad
cc: Jeffrey A. Klatzkow, County Attorney
Leo E. Ochs, Jr., County Manager
Packet Page -573-
ARTICLE I1. - IMPACT FEES# PTICO_ CH741MFERE _ARTIIIMFE_S74- 201IMI1 7/26/2011 Item 9.H.
Collier County, Florida, Code of Ordinances >> PART 1- CODE >> Chapter 74 - IMPACT FEE
REGULATIONS >> ARTICLE II. - IMPACT FEES >>
ARTICLE H. - IMPACT FEES
Sec. 74 -201. - Imposition of impact fees.
(a) General requirements. All development within the unincorporated areas and within the boundaries of
all municipalities in the county shall pay all assessed impact fees unless such impact fees, in whole
or in part, have been exempted, waived, or deferred pursuant to this chapter. The impact fee shall be
assessed based on a calculation of the impact of the proposed development on the respective public
facilities. The amount of the impact fee to be assessed for each type of public facility shall be as
specified in sections 74-302 through-Z4:211 (section 74-302 -- Speciat requirements for road impact
fee; section 74-303 — Special requirements for water impact fee and/or sewer impact fee; section 74-
.04— Special requirements for parks and recreational facilities impact fee; section 704 -3055- Special
requirements for library facilities impact fee;.section 74-306 — Special requirements for emergency
medical services impact fee;$eCtien 74- 307 — Special requirements for educational facilities impact
fee; section 74- 306 — Special requirements for correctional facilities impact fee; section 74-309 —
Special requirements for fire facilities impact fee; section 74- 310 — Special requirements for general
government impact fee; and section 74- 311 — Special requirements for law enforcement impact fee).
(b) Impact tee rates. The board hereby adopts the impact fee rates incorporated by reference in sections
74.302 through 74-311, inclusive, and as set forth in Schedules 1 through 10, inclusive, appended
hereto as Appendix A, which shall be imposed upon all development occurring within the county.
These impact fee rates may be changed from time -to -time by board resolutions or by Collier County
Ordinances provided, in every instance, the board advertises notice of a scheduled public hearing in
a newspaper of general circulation in Collier County with regard to the then proposed impact tee
schedule amendments.
(c) Change of size or use. Impact fees shall be imposed and calculated for net increase, alteration,
expansion, or replacement of a use or a building, or part of a building (including dwelling unit), and
each accessory or non - accessory building, provided such net increase, alteration, expansion, or
replacement of the use, building, or part thereof or therein, by applying this chapter results in: (1) a
net increase in the number of dwelling units; (2) a net increase in the size or square footage of a
building; (3) a net increase in the size of the use; or (4) intensification of the use so as to constitute
an expansion of the same use category or result in a change to a higher impact fee land use
category; or (5) otherwise create additional demand or additional impacts on any of the public
facilities. The impact fee imposed under the applicable impact fee rate shall be calculated as follows:
(1) It the impact fee is calculated based on land use and not square footage, such as a golf
course, the impact fee imposed shall be the impact fee due under the applicable impact fee
rate for the impact fee land use category resulting from the alteration, expansion or
replacement minus the impact fee that would be imposed under the applicable impact fee rate
for the impact fee land use category immediately prior to the new alteration, expansion or
replacement.
(2) In the event only the square footage of a use or building is increased, the impact fee shall be
calculated only for the net increased square footage.
(3) The impact fee imposed for any accessory buildings shall be that applicable under the impact
fee rate for the land use for the primary building unless the accessory building has its own
impact fee rate.
(4) If proposed changes to a lawfully existing building or then permitted use are deemed to create
any additional impact on one or more public facilities, then the impact fee that will be due and
payable to the county for such proposed changes will be determined by the net increase in
demand on those public facilities any lawfully existing building or land use that is expanded,
replaced, or changed shall be required to pay impact fees based on the new or net additional
demand placed upon one or more public facilities by applying the then applicable impact fee
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ARTICLE II. -IMPACT FEES# PTICO_ CH74IMFERE _ARTIIIMFE_S74- 201IMIM -- " " `
7/26/2011 Item 9.H.
rate schedule. Therefore, impact fees will be assessed only for the net increase in square
footage, number of unit(s), intensification of land use, or any other change resulting in
increased available capacity. The burden of verifying the previous lawful land use, units and �.
square footage, as applicable, shall be on the applicant. Any proposed changes under this
section which would result in lower net impacts upon one or more public facilities are not
entitled to a downward adjustment, off -set, or credit against any previously paid impact fees.
(5) Impact Fee Program for Existing Commercial Redevelo evelopments which
�� meet the criteria set forth below shall not be assessed(additional impact fees lated to
'f p.!- changes of use within the existing buildings, except for Jrateraod impact fee
assessments which are exempt from this program. This program will officially sunset two
years from the date of adoption unless continued by a resolution of the Board of County
Commissioners prior to this date.
( e. Development is proposed within a lawfully existing building which has had a Certificate
JOr of Occupancy issued for at least 3 years. Impact fees for the existing building must
have been paid the then applicable impact fees at time of construction; and
b. Proposed development is solely within the existing building and does not include the
addition of any new square footage.
C. Demolition and reconstruction projects are not eligible for this program.
(d) Exemptions. The following development or change in use shall be exempted from paying additional
impact fees:
(1) Alteration, expansion or replacement of a building, structure, dwelling unit, or use provided the
respective alteration, expansion or replacement: (1) will not create any additional net increase
in the size or square footage of the respective development, including number of dwelling
J ' units, (2) will not result in a net increase of the intensity of use(s); or (3) will not otherwise
create any additional net demand of the respective public facility. Lawful buildings, structures
and/or uses that are not in actual use at the time of the submittal of an application to the
county for development approval and issuance of that building permit (or other development
approval) and that would otherwise result in an obligation to pay the new (additional) impact
fees shall not be eligible for this exemption unless the applicant can prove that the building
had been lawfully used during any time within the immediately preceding seven years and the
building or structure has not been condemned.
(2) New building(s) or addition to a building(s) or an accessory building or structure that will not
create additional net demand upon the public facility for which the exemption is sought over
and above the then existing development impacts deemed to be created by the then lawful
existing building(s), structures or uses.
(3) Construction or expansion of publicly owned residential housing; however this exemption shall
not apply to the applicable impact fees for water and/or sewer public facilities, or for the
applicable impact fees for educational public facilities.
(4) Lots, pads, sites, foundations or spaces for a single mobile home, recreational vehicle, travel
trailer, or park model, when the applicable impact fee has been previously paid, or if the then
existing development was not subject to the impact fee because the county's original
applicable impact fee ordinance had not then become effective.
(5) An 'adults only community' shall be exempt from the educational facilities impact fee only If:
(i) evidence of permanent age restrictions, which require all residents of the adults only
community to be older than 18 years of age, are recorded in the land records of Collier County
and run with the specified geographic area, or (it) an effective planned unit development
document restricts the occupationiresidency of the subject property to persons older than 18
years of age.
(6) Development for which the respective impact fee is then expressly prohibited by Florida law,
rule or regulation, or by federal law, rule or regulation.
(7) Exemptions from road impact fees for specified airport leases.
a. Placement of buildings upon the leasehold by or through the leasing subtenant or
tenant within the then existing boundaries of a county owned airport are eligible for
exemptions from road impact fees provided the airport leasing agreement was
executed prior to March 13, 2001, and the lease, when executed, expressly provided
that the county or the airport authority, not later than 29 years subsequent to the initial
effective date of the leasing agreement, at no expense to the county or airport
authority, will automatically acquire title to the respective buildings, or if the board or
airport authority decides not to acquire title to such buildings, the subtenant (or tenant),
at no expense to the county or the airport authority, shall promptly remove such
buildings and restore the leased (or subleased) premises to the physical conditions that
existed as of the commencement date of the respective leasing agreement. Eligibility •
for these exemptions shall be vested retroactively to the date of the original execution
of the lease.
b.
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