Regarding the Proposed Rules for the All Ohio Future Fund (ORC 126.62)
On behalf of the Greater Ohio Policy Center (GOPC), I respectfully submit the below comments in response to the proposed rules for the All Ohio Future Fund. We respect the work that the Office of Budget and Management has put into developing the proposed rules, and offer the following as a means of improving upon the rules drafted by the department.
We submit our comments with the knowledge that the Ohio Department of Development expects the state of Ohio to experience a 5.73% population loss by 2050.
We believe the All Ohio Future Fund can help bend our projected demographic curve and minimize net population loss. However, we also believe policymakers must be clear-eyed that infrastructure investments made today will continue to have maintenance and replacement costs over the coming decades. We do not want to saddle our smaller and older population with unsustainable infrastructure costs.
We respectfully request that the proposed rules make the following clarifications to ensure the highest and best use of these funds. The best use of these funds includes supporting catalytic sites within existing communities and minimizing the loss of productive farmland.
Maximum Award Amounts
GOPC recommends the following addition to Section (B)
(B) Awards from the all Ohio future fund may be made either through loans or grants, as determined in the sole discretion of the agency, in consultation with the Office of Budget Management. Awards may support up to 50% of anticipated project cost.
Make Catalytic Employers on Less than 30 Acres Eligible
GOPC recommends the following addition to Section (C)
(4) A clear definition of the scope of the project that includes:
(a) An accounting of eligible costs and total project costs;
(b) Project site capacity targets;
(c) A project site size greater than thirty acres;
(d) A project site size less than thirty acres that has a large number of jobs of large economic impact in the region
(e) Either how the site will attract an end-user and the type of end-user the site will attract, or an end-user that has been identified and who is likely to use the site; and
(f) Any other information required by the agency.
Application Evaluation
GOPC recommends the following additions to Section (D)
(D) The agency will evaluate applications and award loans or grants from the fund. The agency is to consider:
(1) The strength of expected economic impact of a project site;
(2) The local community’s ability to support the project site;
(3) The quality of expected jobs created at the project site;
(4) The importance of the project site to the region’s economic development;
(5) Public ownership and local control of land to be improved
(6) The existence of other utility and accessible transportation infrastructure already in place within one (1) mile of the site
(7) The existence of a prior non-agricultural use on eligible project sites with less than 100 acres
(8) Any other factors deemed appropriate.
Project Completion and Tenant Longevity Requirements
GOPC recommends the following additions to Section (E)
(E) The agency may:
1. recapture funds disbursed from the all Ohio future fund if an end-user is not under agreement to utilize the project site within five years of disbursement of the award.
2. recapture funds if end-user leaves the site within fifteen (15) years of the award date and cannot find a replacement end-user with similar or greater economic impact and expected job creation
3. disburse funds to projects that have received other state funds for site preparation, including funds through the Brownfields Remediation Program, Building Demolition and Site Revitalization Program, and Historic Preservation Tax Credits
Thank you for your consideration of these comments and suggestions. Should you have any questions, please feel free to contact me either by phone at 614-224-0187 (office) or 614-245-5406 (mobile) or via email at jwarner@greaterohio.org.
With regards,
Jason Warner Director of Strategic Engagement Greater Ohio Policy Center