HomeMy WebLinkAboutFND-012-08
Cl~illgron
REPORT
FINANCE DEPARTMENT
Date:
GENERAL PURPOSE AND ADMINISTRATION COMMITTEE
MONDAY, JUNE 2, 2008 Resolution #: QfA~C3l);;2- 0 ~
Meeting:
Report #: FND-012-08
File#:
By-law #:
Subject:
DEVELOPMENT CHARGES AMENDMENT STUDY AND BY-LAW 2008
Recommendations:
It is respectfully recommended the General Purpose and Administration Committee
recommend to Council the following:
1. THAT the Development Charges Amendment Study, May 2008, prepared by
Hemson Consulting Ltd. be approved;
2. THAT the Development Charges quantum for Residential charges be approved
as follows, effective July 1, 2008, subject to annual indexing:
Residential
Single and Semi
Townhouse and Row
Large Apartment
Small Apartment
$15,102
$13,153
$10,377
$ 6,577
3. THAT the Development Charge quantum for both Non-Residential-Industrial
and Non-Residential - Excluding Industrial charges be phased-in for all units, as
follows:
Non-Residential - Excluding
Industrial (per sq. m.)
July 1, 2008
July 1, 2009
July 1, 2010
July 1, 2008
July 1, 2009
$26.98
$31.14
$35.29
$52.36
$63.18
Non-Residential - Industrial
(per sq. m.)
REPORT FND-012-08
PAGE 2
4. THAT Council in approving the Amendment Study expresses its intent to ensure
that the increase in the need for services attributable to the anticipated
development will be met and that any future excess capacity identified in the
Study will be paid for by development charges or other suitable charges to
protect the public interest;
5. THAT Council has reviewed the changes made to the draft By-Law and after
having considered the changes, Council determined that there is not a need for
an additional public meeting;
6. THAT for completed applications as determined by the Chief Building Official
received on or before June 30, 2008, where the development charges will be
paid by June 30, 2008, that the applicable development charges be calculated
based on By-Law 2005-108, prior to the amendment proposed as attached to this
report;
7. THAT the attached By-Law (Attachment "A"), inclusive of any amendments made
by Council at the meeting of June 9, 2008, be recommended to Council for
approval to amend By-Law 2005-108; and
8. THAT the Region of Durham and recorded interested parties be provided a copy
of this report and be notified of Council's decision.
./\ ,
Reviewed bL/ ~- ~
Franklin Wu,
Chief Administrative Officer.
NT/hjl
REPORT FND-012-08
PAGE 3
BACKGROUND AND INFORMATION:
1.0 The 2005 Development Charges
1.1 On June 2th, 2005, Council adopted the existing development charges with the
approval of report FND-007-05 and the accompanying By-Law 2005-108. This
By-Law, by statute expires after five years or June 30, 2010.
1.2 On March 31st, 2008, Report FND-007-08 pertaining to Fiscal Impact Analysis of
New Development was approved. During the course of this study, it was
determined that the Municipality's current development charges rates do not
adequately fund the growth related costs eligible for recovery through
development charges. Report FND-024-07 was approved December 10, 2007 to
authorize an interim review and amendment to the 2005 Development Charges
By-Law.
1.3 The legislation only allows calculation of a charge based on the historical
average service level of the past 10 years. The legislation does not permit the
use of development charges to increase the service levels in any category. If
the allowable permitted calculated charge under the legislation is not used, the
shortfall is transferred to the tax base and the historic average is eroded, such
that in future less development charges can be recoverable.
2,0 The 2008 Development Charges Amendment Study
2.1 Staff from all Departments and the Library worked diligently, as a Steering
Committee with Craig Binning of Hemson Consulting Ltd., to bring forward the
amendment study May 2008. The result of the analysis was to produce a revised
development charge that reflects the costs of services required to support the
projected new development to 2014. The executive summary is attached
(Attachment "B"), with the full study circulated under separate cover on May 15,
2008.
2.2 The amendment study introduction provides an overview of the areas of focus
in this report. The focus of the study was limited to adjusting the development
charge rates to reflect the increased cost of servicing growth in Clarington.
3.0 Non-Residential Charge
3.1 In reviewing the non-residential development charges within the lakeshore area
municipalities of Durham Region, all lower tier municipalities have a commercial
and industrial development charge. The Region of Durham is currently in
process to update their rates and is proposing a two-year phasing to the full rate
by July 1, 2010.
REPORT FND-012-08
PAGE 4
3.2 The cities of Pickering and Oshawa both have a standard charge for all non-
residential. Ajax and Whitby have separated industrial at a different rate than
the other non-residential components. This is the approach previously
undertaken in Clarington also.
3.3 Clarington's non-residential rate for Industrial is currently at $22.82 per square
metre and the maximum permissible under the Amendment Study is $35.29 per
square metre or a 55% increase. The value for all other non-residential is
currently $44.54 per square metre moving to $63.18 per square metre or a 52%
increase.
3.4 Council has expressed through the Corporate Strategic Business Plan, 2007-
2010, a clear initiative to promote and attract non-residential activities to
Clarington. The Amendment Study, May 2008, is determined based on the
substantially increased costs for providing the capital program required to
accommodate growth. However, due to the significant effect this may have on
Council's priority to attract the non-residential sector, it is proposed that a
phasing mechanism be employed.
3.5 Due to the greater price/cost sensitivity surrounding attracting industrial growth
as compared to other non-residential (I.e. commercial and institutional), a
different phasing mechanism is recommended. It is recommended that the
industrial component be phased into the full rates over three increments
whereby the full charge would be effective July 1, 2010. For other non-
residential development, the full charge would be effective by July 1, 2009.
This is reflected in Schedule 2 to the proposed By-Law.
4.0 Residential Charge
4.1 The residential charge being recommended is an increase of 52% over the
current charge.
5.0 Tax Impact
5.1 The existing taxpayer picks up any shortfall for the cost of growth related
services which is not collected through the development charge. The
Amendment Study has fully documented the shares of the capital program that
will not be funded from development charges. This will be addressed through
the annual budget process as projects come forward.
6.0 Meeting with Developers
6.1 Staff and the Municipality's consultant met with the development community on
May 22nd to provide an overview of the amendment study, the methodology
applied in the development charge calculation and to provide an opportunity for
questions to be answered. The meeting was set up over and above the
requirements of the Development Charges Act and in addition to the scheduled
public meeting for June 2, 2008.
REPORT FND-012-08
PAGE 5
7.0 Exemption Where Permits Applied For
7.1 The effective date of change in the quantum is recommended as July 1,2008.
It is recommended that building permit applications that have been submitted to
the Chief Building Official on or before June 30 and are complete will not be
subject to the new amendment to the By-Law. The increase in the charge is
imposed at the time of issue of the building permit and so a specific resolution
has been added to this report.
Attachments:
Attachment "A" - Proposed By-Law
Attachment "B" - Development Charges Amendment Study - Executive Summary
I nterested Parties:
Region of Durham
Finance Department
60 Bond Street
Oshawa, Ontario L 1 H 8B6
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L 1C 3A6 T (905)623-3379 F (905)623-4169
Attachment "A"
THE CORPORATION OF THE MUNICIPALITY OF CLARINGTON
BY-LAW NO. 2008-XXX
Being a by-law to amend Municipality of Clarington
Development Charge By-law No. 2005-108, as amended by By-
law No. 2007-195 and By-law 2006-160.
WHEREAS Subsection 2(1) ofthe Development Charges Act, S.O. 1997, c.27 (the
"Act") provides that the council of a municipality may by by-law impose development charges
against land,to pay for increased capital costs required because of increased needs for services
arising from the development of the area to which the by-law applies;
AND WHEREAS the Cnuncil of The Corporation of the Municipality of Clarington
enacted By-law No. 2005-108 - Being a By-law to impose development charges against land in
The Municipality ofClarington pursuant to the Development Charges Act, 1997 for The
Corporation ofthe Municipality ofClarington. By-law No 2005-108 was amended by By-law
No. 2006-160 and by By-law No. 2007-195;
AND WHEREAS Council has before it a Background Study entitled "Development
Charges Amendment Study, Municipality of Clarington" dated May, 2008 (the "Study");
AND WHEREAS Sectinn 19 of the Act provides for the process for an amendment to a
development charge by-law, including the requirement that a public meeting ("Public Meeting')
be held before an amendment is passed;
AND WHEREAS Council gave notice to the public ofthe Public Meeting and held the
Public Meeting pursuant to sections 12 and 19 of the Act on June 2, 2008, prior to which the
Study and the proposed amending by-law were made available to the public, and Council heard
comments and representation from all persons who applied to be heard and considered Report
FND-012-08 dated June 2, 2008 (the "Staff Report');
AND WHEREAS staff of the Municipality considered the public comments and
representations made at the Public Meeting at the meeting of Council held on June 9, 2008 and
submitted to Council Addendum Report to Report FND-OI2-08 dated June 2, 2008;
AND WHEREAS at its meeting on June 9, 2008, by Resolution No. C-XXX-08 Council
approved the recommendations contained in Report FND-012-08 and the Addendum thereto;
NOW THEREFORE THE COUNCIL OF THE CORPORATION OF THE
MUNICIPALITY OF CLARINGTON ENACTS AS FOLLOWS:
1. THAT By-law No.200S-108, as amended, is further amended by deleting Schedule
"1" attached thereto and replacing it with a new Schedule "'1" in the form and with
the content of Schedule "I" attached to and forming part of this by-law.
2. THAT By-law No.2ooS-1 08, as amended, is further amended by deleting Schedule
"2" attached thereto and replacing it with a new Schedule "'2" in the form and with
the content of Schedule "2" attached to and forming part of this by-law.
3. THAT By-law No.200S-108, as amended, is further amended by deleting Schedule
"3" attached thereto and replacing it with a new Schedule "3" in the form and with
the content of Schedule "3" attached to and forming part of this by-law.
2
4. TRA T By-law No.200S -I 08, as amended, is further amended by deleting Schedule
"4" attached thereto and replacing it with a new Schedule "4" in the form and with
the content of Schedule "4" attached to and forming part of this by-law.
5. This by-law comes into force and is effective on July I, 2008.
By-law read a first and second time this 9th of June 2008.
By-Law read a third time and finally passed this 9th of June 2008.
Jim Abernethy, Mayor
Patti L. Barrie, Municipal Clerk
Page 2
SCHEDULE "1"
RESIDENTIAL DEVELOPMENT CHARGES
SCHEDULE "1" TO BY-LAW NO. 2005-108, AS AMENDED
AND AS FURTHER AMENDED BY BY-LAW 20G8-XXX
RESIDENTIAL DEVELOPMENT CHARGES PER UNIT
Single and Semi-Detached
Townhouse, Multiple and Row Units
Apartments
$15,102
$13,153
Large
Small
$10,377
$6,577
SCHEDULE "2"
NON-RESIDENTIAL DEVELOPMENT CHARGES
SCHEDULE "2" TO BY-LAW NO. 2005-108, AS AMENDED
AND AS FURTHER AMENDED BY BY-LAW 2008-XXX
PHASING SCHEDULE BY EFFECTIVE DATE
NON-RESIDENTIAL DEVELOPMENT CHARGES PER
SQUARE METRE OF GROSS FLOOR AREA
July 1, 2008 July 1, 2009 July 1, 2010
Non-Residential (excluding Industrial) $52.36 $63.18 $63.18
Industrial
$26.98
$31.14
$35.29
SCHEDULE "3"
ALLOCATION OF RESIDENTIAL DEVELOPMENT CHARGES
SCHEDULE "3" TO BY-LAW NO. 2005-108, AS AMENDED
AND AS FURTHER AMENDED BY BY-LAW 2008-XXX
ALLOCATION OF RESIDENTIAL DEVELOPMENT CHARGES
% Allocation
General Government 2.57%
Library Service 5.89%
Fire Protection Services 5.44%
Indoor Recreation 32.70%
Park Development and Related Facilities 9.50%
Operations (Buildings, Equipment and Fleet) 4.43%
Parking 0.35%
Transit n/a
Roads and Related 39.12%
Total Development Charge 100%
SCHEDULE "4"
ALLOCATION OF NON-RESIDENTIAL DEVELOPMENT CHARGES
SCHEDULE "4" TO BY-LAW NO. 2005-108, AS AMENDED
AND AS FURTHER AMENDED BY BY-LAW 2008-XXX
ALLOCATION OF NON-RESIDENTIAL DEVELOPMENT CHARGES
% Allocation
Non-Residential
(excluding Industrial
industrial)
General Government 2.96% 5.30%
Library Service n/a n/a
Fire Protection Services 6.28% 11.25%
Indoor Recreation n/a n/a
Park Development and Related Facilities n/a n/a
Operations (Buildings, Equipment and Fleet) 5.11% 9.15%
Parking 0.40% 0.71%
Transit n/a n/a
Roads and Related 85.25% 73.59%
Total Development Charge 100% 100%
Attachment "B"
DEVELOPMENT CHARGES
AMENDMENT STUDY
Municipality of Clarington
REMSON Con sui tin g L t d
May 2008
:-1
EXECUTIVE SUMMARY
Hemson Consulting Ltd. was retained by the Municipality of Clarington to complete a
Development Charges Amendment Study. This Amendment Study provides the basis
and background to update the Municipality's development charges to accurately
reflect the servicing needs and fully recover the increasing costs related to servicing
growth in Clarington.
A. BACKGROUND AND INTRODUCTION
. In February 2008, a Study of the Fiscal Impact Analysis of New Development
in Clarington was completed. The Study examined the effects of allowing
several large scale residential proposals to proceed earlier than was anticipated
under the Municipality's 2005 Development Charges Background Study.
. The results of the Fiscal Impact Analysis show that the Municipality's current
development charge rates do not adequately fund the growth-related costs
eligible for recovery through development charges. The most significant
funding shortages are with respect to the provision of roads and related
infrastructure.
. A key recommendation of the Fiscal Impact Analysis was that current
development charge rates be reviewed immediately and that new rates be
established to more fully recover the cost of servicing growth in the
Municipality. Following this recommendation, this 2008 Development
Charges Amendment Study was initiated in February 2008.
. The Amendment Study provides the basis for amending Clarington's current
development charges by-law, By-law No. 2005-108, as permitted under section
19 of the Development Charges Act (DCA).
. The focus of the Amendment Study is limited to adjusting the development
charge rates to reflect the increased cost of servicing growth in Clarington.
REMSON
ii
. The growth forecast for the Amendment Study is consistent with the growth
forecast of the 2005 Development Charges Background Study and has been
adjusted to account for growth that has occurred since the completion of that
Study and data released from the 2006 Census.
. The end date of the planning periods in the Amendment Study remains
consistent with the 2005 Development Charges Background Study. The
proposed planning periods for this Amendment Study are a seven-year period
from 2008 to 2014 for the general services and 2008 to 2031 for the engineered
services. Historic service levels are based on the ten-year historical period from
1998 to 2007.
. This study calculates new development charges for the Municipality of
Clarington in compliance with the provisions of the DCA.
. The Municipality needs to continue implementing development charges to
fund capital projects related to growth throughout Clarington so that
development continues to be serviced in a fiscally responsible manner. The
calculated changes to the development charges rates are required in order to
reflect the revised costs associated with the infrastructure requirements.
. This report identifies the growth-related net capital costs which are
attributable to development that is forecast to occur in the Municipality.
These costs are apportioned to types of development (residential, non-
residential) in a manner that reflects the increase in the need for each service
attributable to each type of development. This report therefore presents
development charges for each type of development.
B. ELIGIBLE SERVICES ARE INCLUDED IN THE ANALYSIS
. The following Municipal services have been included in the development
charges analysis:
. Public Library
. Emergency Services
. Indoor Recreation
REMSON
iii
. Engineering - Park Development and Facilities
. Operations
. Parking
. General Government
. Roads and Related (including storm drainage, sidewalks, street lights,
streetscapes, intersection and level crossings, etc.)
C. THE MUNICIPALITY HAS AN EXTENSIVE GROWTH-RELATED CAPITAL
PROGRAM FOR THE PROVISION OF ELIGIBLE SERVICES
General Services 2008 - 2014
. Municipal staff, in collaboration with Hernson Consulting, has developed a
growth-related capital program setting out projects that are required to service
the anticipated growth. The growth-related capital programs are based on a
seven-year planning period of 2008 ro 2014.
. The gross cost of the Municipality's growth-related capital program for general
services amounts to $93.3 million and provides for a wide range of
infrastructure expansions. A government grant of $2.2 million for the public
library has been identified, and thus the net cost of the growth-related capital
program is $91.1 million. Of the $91.1 million, approximately $62.2 million
has been identified as eligible for recovery through development charges over
the 2008 - 2014 planning period.
REMSON
iv
. The following is a summary of the growth-related capital program for the
general services:
Capital Forecast DC
Gross Subsldlesl Net Recoverable
Service Cost Recoveries Cost 2008 - 2014
1$0001 1$0001 ($000) ($000)
1.00 TOTAL - PUBLIC LIBRARY $10,465.0 $2,244.4 $8,220.8 $5,331.3
1.1 Buildings, Land & Furnishings $9,865.0 $2,244.4 $7,620.6
1.2 Material Acquisitions $600.0 $0.0 $600.0
2.00 TOTAL. EMERGENCY SERVICES $11,872.0 $0.0 $11,872.0 $7,076.9
2.1 Buildings, land & Furnishings $10,260.0 $0.0 $10.260.0
2.2 Vehicles $1,500.0 $0.0 $1,500.0
2.3 Firefighter Equipment $112.0 $0.0 $112.0
3.00 TOTAL -INDOOR RECREATION $41,069.0 $0.0 $41,069.0 $30,388.9
3.1 Buildings, Land, Furnishings & Equipment $41,069.0 $00 $41,069.0
4.00 TOTAL - ENGINEERING - PARK DEVELOPMENT AND FACILITIES $17,090.0 $0.0 $17,090.0 $9,927.1
4.1 Park Development, Facilities & Equipment $17,090.0 $0.0 $17,090.0
5.00 TOTAL. OPERATIONS $8,619.4 $0.0 $8,619.4 $5,774.0
5.1 Buildings, Land & Equipment $5,179.5 $0.0 $5,179.5
5.2 Municipal Fleet $3,439.9 $0.0 $3,439.9
6.00 TOTAL. PARKING $518.1 $0.0 $518.1 $432.9
6.1 New Parking Spaces $518.1 $0.0 $518.1
7.00 TOTAL.GENERALGOVERNMENT $3,680.0 $0.0 $3,680.0 $3,312.0
7.1 Growth Studies $3,680.0 $0.0 $3,680.0
TOTAL. 7 YEAR GENERAL SERVICES $93,313.5 $2,244.4 $91,069.1 $62,243.2
. Details regarding the capital programs for each of the general services are
provided in Appendix B of this report.
REMSON
v
Engineered Services 2008 - 2031
. The growth-related capital program for roads and related services is based on a
build-out planning period of 2008 to 2031.
. The Municipality's growth-related capital program for roads and related
services amounts to a gross cost of $153.1 million and provides for roads
construction, storm drainage, sidewalk, street lights, streetscapes and other
related works. No government grants have been identified, and thus the net
cost of the growth-related capital program remains at $153.1 million. Of the
$153.1 million, approximately $133.6 million has been identified as eligible for
recovery through development charges.
. The following is a summary of the growth-related capital program for the roads
and related services:
Caoital Forecast DC
Gross Subsidies! Net Recoverable
Service Cost Recoveries Cost 2008 - 2014
1$000\ 1$000\ 1$000\ 1$000\
1.00 TOTAL - ROADS AND RELATED $153,OS8.4 $0.0 $153,058.4 $133,593.0
1.1 Roads & Related Projects $150.961.8 $0.0 $150,961.8
1.2 Other Road Related Projects $2.096.6 $0.0 $2,096.6
TOTAL. ENGINEERED SERVICES $153.0S8.4 $0.0 $1S3,058.4 $133,593.0
. Details regarding the capital programs for the roads and related services are
provided in Appendix C of this report.
REMSON
vi
D. DEVELOPMENT CHARGES RATES CALCULATED WITH FULL REFERENCE TO
THE DCA
. Development charges rates have been established under the parameters and
limitations of the DCA This study provides the rationale and basis for the
calculated rates.
. A Municipality-wide uniform cost approach is used to calculate development
charges for the eligible services. This results in uniform residential and non-
residential charges throughout the Municipality.
. The calculated charges are the maximum charges the Municipality may adopt.
Lower charges can be approved; however this will require a reduction in the
capital plan and reduced service levels or financing from other sources, most
likely through property tax increases.
. It should be noted that the capital programs put forward for Operations and
Parking have not fully utilized the maximum allowable funding envelope.
. The fully calculated residential charges are recommended to vary by unit type,
reflecting the difference in occupancy patterns expected in various unit types
and the associated differences in demand that would be placed on Municipal
services.
. The fully calculated non-residential charges are recommended to be applied on
a Municipal-wide basis. This study has differentiated a non-residential charge
for the roads and related component, remaining consistent with the currently
imposed non-residential charges. The charge is differentiated between
industrial and all other non-residential land uses (commercial, institutional).
REMSON
vii
. Based on the Municipality of Clarington's gtowth forecast and growth-related
capital programs, new residential development charges rates have been
calculated. The following is a summary of the calculated residential
development charges by unit type:
Calculated Charge By Unit Type (1)
Charge
SERVICE After Rows &
Cashflow Singles & Other Large Small
Per Capita Semis Multioles Apartments Apartments
PUBLIC LIBRARY $287 $890 $775 $611 $387
EMERGENCY SERVICES $265 $822 $716 $564 $358
INDOOR RECREATION $1.593 $4.938 $4,301 $3,393 $2,151
ENGINEERING. PARK $463 $1,435 $1,250 $986 $625
DEVELOPMENT AND
FACILITIES
OPERATIONS $216 $670 $583 $460 $292
PARKING $17 $53 $46 $36 $23
GENERAL GOVERNMENT $125 $388 $338 $266 $169
SUB.TOTAL GENERAL $2,966 $9,195 $8,008 $6,318 $4,004
SERVICES
.
MUNICIPALlTY.WIDE $1,906 $5,908 $5,145 $4,059 $2,573
ENGINEERING SERVICES
SUB-TOTAL ENGINEERING $1.906 $5,908 $5.145 $4,059 $2,573
SERVICES
TOTAL RESIDENTIAL $4,872 $15,102 $13,153 $10,377 $6,577
CHARGE PER UNIT
(1) Based on Persons Per Unit Of:
3.10
2.70
2.13
1.35
HEMSON
. ..~ ' .
viii
. Based on the Municipality of Clarington's growth forecast and growth-related
capital programs, new non-residential development charges rates have been
calculated. The following is a summary of the calculated non-residential
development charges:
Commercial & Industrial
Institutional
SERVICE After Cashflow After Cashflow
Per Square Metre Per Square Metre
PUBLIC LIBRARY $0.00 $0.00
EMERGENCY SERVICES $3.97 $3.97
INDOOR RECREATION $0.00 $0.00
ENGINEERING - PARK DEVELOPMENT AND FACILITIES $0.00 $0.00
OPERATIONS $3.23 $3.23
PARKING $0.25 $0.25
GENERAL GOVERNMENT $1.87 $1.87
SUB-TOTAL GENERAL SERVICES $9.32 $9.32
MUNICIPALITY-WIDE ENGINEERING SERVICES $53.86 $25.97
SUB-TOTAL ENGINEERING SERVICES $53.86 $25.97
TOTAL NON-RESIDENTIAL CHARGE PER SQ.M $63.18 $35.29
REMSON
" ' .
ix
E. NEWLY CALCULATED RATES ARE 50% HIGHER THAN CURRENT RATES
. The fully calculated Municipality-wide residential charge for a single/semi-
detached unit, $15,102, represents an increase of 52% over the Municipality's
current charge, $9,961.
. The $63.18 per square metre of gross floor area represents a 52% increase over
the Municipality's current non-residential commercial and institutional charge
of $41.54 per square metre. The newly calculated non-residential industrial
charge is $35.29 per square metre, which is a 55% increase over the current
charge of $22.82 per square metre of gross floor area.
. The scale of these increases is consistent with the experience of many
municipalities in Southern Ontario as the development charge inflation index
has outpaced inflation and resulted in rapid increases in construction costs.
. The calculated development charges rates are increasing in rhe Municipality of
Clarington largely as a result of significant increases in the costs of
constructing municipal infrastructure.
F. THIS AMENDMENT IS NOT PROPOSING ANY CHANGES TO DEVELOPMENT
CHARGE POLICIES AND PRACTICES
. The scope of this amendment is limited to a review of the cost of servicing
growth in Clarington.
. The proposed amending by-law does not alter any of the terms of the by-law
and all existing rules, exemptions and other provisions will remain unchanged.
. The expiry date of the by-law, June 30, 2010, is not altered by the proposed
amendment.
REMSON