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04.11.16 Work Session Packet
City of Farmington Mission Statement 430 Third Street Through teamwork and Farmington,MN 55024 cooperation,the City of Farmington provides quality services that preserve our proud past and foster a promising future. AGENDA CITY COUNCIL WORKSHOP April 11, 2016 6:30 PM Farmington City Hall 1. CALL TO ORDER 2. APPROVE AGENDA 3. DISCUSSION ITEMS (a) Debt Overview and Potential Refinancing Opportunities (b) 2016 Street Light Fund Expenditures (c) Private Street Sighs (d) Youth on Boards Initiative 4. CITY ADMINISTRATOR UPDATE 5. ADJOURN 4FARif City of Farmington f 1•111113-% 430 Third Street Farmington,Minnesota 651.280.6800 -Fax 651.280.6899 °*+r.:p o-, www.cifarmington.mn.us TO: Mayor, Councilmembers and City Administrator FROM: Robin Hanson,Finance Director SUBJECT: Debt Overview and Potential Refinancing Opportunities DATE: April 11, 2016 INTRODUCTION Municipal governments borrow funds,primarily through the issuance of tax-exempt bonds,to help pay for a variety of projects,including roads, municipal utilities and the construction of municipal buildings. Generally these bonds are not eligible for refinancing for many years, often seven to ten years from their date of issuance.Annually, city staff meets with our financial advisor, Ehlers,to review the city's debt issuance plans and analyze existing debt looking for refinancing opportunities. DISCUSSION Today the city has $28.2 million in outstanding debt with interest rates ranging from 2.0%-4.2%and final maturities ranging from 2017(fire truck loan)to 2030(195th street reconstruction bonds).A picture of the city's debt from 2010 through 2030, including new debt as anticipated in the city's draft comprehensive financial plan, is included in your packets as Exhibit A. The dark blue columns on the chart represent existing debt. Over the last six years the city's debt has been reduced$13.3 million or 32% from the$41.5 million which was outstanding as of December 31, 2010. The light blue columns reflect future CIP debt issuance. The dark green line depicts the city's goal, as set forth in the Debt Management policy, to have no more than$1,000/resident of outstanding debt by 2020. The remaining scheduled principal and interest payments for the city's existing debt are illustrated in Exhibit B. The green columns represent the annual principal payments,while the red amounts represent the interest scheduled to be paid each year. The total interest remaining on the existing debt is approximately$5.5 million. As you look at the total principal and interest due in 2016-2019,you can see the total amount continues to increase. This is to be expected with the increasing principal payments structured in the 2013B street reconstruction bonds. As previously mentioned, one of staffs goals during its annual review with Ehlers is to answer the question, which issue(s), if any, does it make economic sense to refund to lower the city's future interest costs?One of the tools used to assist the city with this review is a schedule which Ehlers updates each year, included as Exhibit C. The five issues highlighted in aqua are optionally redeemable February 1,2017. The three issues highlighted in gold are redeemable the following year and will be part of next year's review and discussion. In the current interest rate environment it makes economic sense to refund three of the five bond issues which are optionally redeemable next February. These three issues--2007A, 2008B and 2010C each have a "Save%" (ie.net present value savings as a%of refunded principal)in excess of 5%. On their face,the other two issues-2008A(3.33%)and 2010D(-5.94%)do not make economic sense to refund.However, staff has some suggestions for you to consider which would result in interest savings for these two issues, also. The potential gross interest savings are shown in green in Exhibit D. Based on today's interest rate estimates the total gross savings, if all five bond issues are refinanced(some with bonds,some with internal loans), is estimated to be$1.8 million. The net present value savings is complicated,given the blended financing recommendation and sizable issuer contribution. This number will continued to be worked on and shared with the city council as the refinancing(s)is/are refined. Different refmancing approaches are being recommended for different series of bonds. The recommendations are discussed below and also summarized for you in Exhibit E. Non Road and Bridge Fund Bonds 2007A The proceeds of the 2007A bonds were used to finance city hall and the First Street garage. In this interest rate environment, it makes sense to refund these bonds. Based on the direction received from the city council last fall and the fact that interest rates have not changed much since then, staff is recommending the bonds be current refunded later this year. Staff would work with Ehlers to ensure the new cash flows align with the new debt payments. For these bonds,the final maturity would remain the same. Meanwhile,the annual debt service requirement would be reduced. Recent estimates indicate the gross levy savings (partially funded with special assessments)would be reduced approximately$830,000. Please note, the projected savings would have been higher,but part of the savings are being used to cover the negative cash position in this fund. 2010 D The proceeds of the 2010D bonds were used for improvements at the ice arena. Based on the cash flow projections prepared by Ehlers, it does not make economic sense to refund these bonds with tax-exempt bonds. Given the relatively small dollar amount remaining($405,000)and the relatively short term remaining (3 years), staff recommends these bonds be refinanced with an internal loan from from one of the following three funds: General Fund, Sewer Fund or Water Fund. The internal loan would be repaid, along with interest, from the future debt levy that would have otherwise been applied to the 2010D bonds. Internally financing the redemption of these bonds would enable staff to create a repayment schedule that better matches projected cash flows and realize gross interest savings of approximately$9,500. Similar to the issue above,the projected savings would have been higher,but a portion of the savings are needed to cover the negative cash position in this fund. Road and Bridge Fund Related Bonds 2008A,2008B,and 2010C The individual cash flow projections prepared by Ehlers indicate it makes economic sense to refund the 2008B and 2010C bonds at this time,but not the 2008A bonds. So, staff was going to recommend the city current refund the 2008B and 2010C bonds and internally fund the redemption of the 2008A bonds. However, after more thought and upon further analysis it makes more financial sense and increases the savings to the city to step back and look at the Road and Bridge Fund differently. Rather,than continuing to transfer money into and out of various bond issues from the Road and Bridge Fund as detailed on the large 'wallpaper'hanging in the conference room,what if we set aside the minimum amount needed to refund the two Road and Bridge Fund bonds which are not optionally redeemable at this time,2011A and the 2013A bonds, and utilized available cash to pay down(ie. reduce)the combined principal of the 2008A/2008B/2010C bonds and only reissue/refund bonds to the extent needed? By reducing the current refunding bond size by approximately$2.6 million(combination of remaining large special assessment prepayment and available funds in the Road and Bridge Fund), the final maturity for these combined bonds would now be 2/1/2023 (four years earlier than the current longest maturity of 2/1/2027) and would enable the city to collapse(ie. close)the Road and Bridge Fund in 2024, after fully redeeming all of the related bonds the previous year. The cash flow projections show this approach would further increase the city's savings by approximately $500,000. Rather, than future special assessment receipts and debt levy being used for debt service for the refunding bonds,additional savings could be generated for future CIP funds (ie cash,reducing the amount of debt needed for future CIP improvements). Another way of saying this is the current comprehensive financial plan anticipates $1.4 million being transferred from the Road and Bridge Fund into the CIP. The total funds available to the CIP,utilizing the accelerated principal repayment refinancing,would be closer to $1.9 million. Equally as important,the CIP's reliance on the VRC assessments,as well as some other assessments for which the exact repayment timing is unknown,would be eliminated. Rather,the VRC and the other assessments for which the timing is uncertain could be redirected to address other budget needs when they are received. One final item to consider regarding this particular refunding is staffs recommendation to provide an internal loan of$300,000. If doable(have not had an opportunity to discuss with bond counsel),this would be part of the final maturity. The reason for wanting to explore this option is related to the special assessments in this bond issue. To be conservative, these types of bonds are structured assuming 0% special assessment prepayment. In the city's case, if the underlying development in the present day 2008B bonds were to begin development the city would begin to receive accelerated prepayments. It would not be able to call the bonds and would have to continue to reinvest those funds at an interest rate less than it would be paying on the related debt. This is exactly what happened with the large special assessment payment received in the 2008B bond issue. This is very expensive. If these prepayments were directed at the internal loan,the city's internal loan could be repaid early reducing the amount of interest cost the city would incur. Proposed Timeline Unless market expectations change and interest rate hikes appear more likely, staff recommends waiting until the fall to issue current refunding bonds. This timing means the city council would receive a pre sale report in September,the bonds would be sold in October and the bond sale closing would take place in November. Please refer to Exhibit F for a more detailed proposed refunding timeline. Parameters Resolution According to a recent Ehlers publication, "one strategy to keep in mind for upcoming bond sales is to consider a parameters resolution. By adopting a parameters resolution,the governing body establishes certain financial parameters and then delegates authority to execute and approve the bond sale to a specific official or officials as long as the parameters are satisfied. For example, ...for a refunding,minimum net present value savings as a percentage of refunded principal..." Having such a resolution in place would enable staff to be more nimble,responding to market changes more quickly, such as a slower bond issuance day in the market(a good time to sell,because there would be less competing issues)or increases in interest rates. Staff would like to discuss this strategy during the workshop and receive direction from the city council as to how you would like to proceed with respect to a parameters resolution. In summary, staff is recommending the following to strengthen the cash flows and reduce future interest costs to the city: Non Road and Bridge Fund Bonds • Refund the 2007A bonds (city hall),resulting in reduced annual debt levy amounts needed for the new bonds ranging from a minimum of$30,000/year to $408,000 in 2027,the final year debt levy would be collected. • Refinance the 2010D(ice arena)bonds with an internal loan. Road and Bridge Fund Related Bonds • Refund the 2008A(Elm Street), 2008B(195th Street extension)and 2010C bonds (Walnut Street). Utilize available prepaid special assessments and funds available in the Road and Bridge Fund to reduce the size of the refunding bond sale. Explore providing an internal loan to minimize the city's exposure to negative re-investment rates related to prepaid special assessments. BUDGET IMPACT Possible future interest and debt levy savings. ACTION REQUESTED Provide direction to staff on how to proceed regarding the potential refinancing opportunities discussed in this memo, including the parameters resolution. ATTACHMENTS: Type Description ® Exhibit Exhibit A-Debt Overview © Exhbit Exhbit B-Scheduled Debt Repayment ▪ Exhbit Exhibit C-Schedule of Tax Levy Supported Debt Issues © Exhibit Exhbit D-Potential Gross Interest Savings ® Exhibit Exhibit E-Staff Refinancing Recommendations • Exhibit Exhbit F -Proposed Refunding Timeline Q I I mai• o L Ca X o W O£ g C y N > C 16 O 8 L � ' ° - a O0 g li rn CIS > c 0 c. Ch r0. o■ o go 3 e- no { C M n , d ^ m E tea _ " ; _ RI a. O r-0 a. Odo 0 N y o CU c E N m o ^ N rn d • > L C M N > tri u K Ta N r-I CU u3. r4 O y V y ^ M L N a y 3 N 3 ' CU 3 ( Z'C C .n w O c6� da. N E -a 2 C rn a ro C L N cu CI RS y;O 2 C OJ 10 IC ..0 N gl N t0 p C d 5 i in ri ++V O N a •n v Q N 3 C C y d 3 p a Ol _ i ;a O. .+�.'O o off ` L C O o. ..?2. 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N 0- U Ln 0 O • N Ia 0 N GI I GI O O 0 0 0 0 0 O O O O o 0 0 0 O O 0 O O O O d O O O O O O O O O 0 O O 0 0 0 O O 0 o ai oo N is Iri v m Ni .+ - IA tn IA ul- Staff Refinancing Recommendations Exhibit E Non Road and Bridge Fund Bonds Road and Bridge Fund Related 2007A 2010D 2008A 2008B 2010C City Hall & 1st Street 195th St Purpose Garage Arena Improvements Elm Street Extension Walnut Street Current cash balance ($49,100) ($110,257) $2,153,104 $203,439 Meets 105%requirement No No Yes Yes Amount Optionally Redeemable Feb. 1,2017 $6,480,000 $405,000 $6,390,000 Est. New Issuance Amount $6,670,000 N/A $3,785,000 Note *In addition to the cash balances above,the city would utilize"'$1,050,000 of Road and Bridge Fund $'s to reduce the size of the bond issue (i.e. pay down principal, reduce future interest costs) Current Interest Rates 4.00-4.10% 2.70-3.10% 4.00-4.10% 3.65-3.90% 3.00-3.75% Estimated Interest Rates 3 year CD+25bp, After Refinancing .80%-2.05%* currently—1.50% 1.00-1.70% Current Final Maturity 2/1/2028 2/1/2020 2/1/2024 2/1/2023 2/1/2027 Proposed Final Maturity 2/1/2028 6/30/2020 2/1/2023 Est. Underwriter's Discount $66,700 $0 $37,850 Est.Cost of Issuance $64,500 $0 $55,000 Staff Recommendations Refunding provides Internal financing *Staff recommends combination of a opportunity to improve eliminates 105%rule refunding and an internal loan of$300,000 cash flow matching, requirement, eliminates (would reduce bond issue). Last to be paid, achieve 105% arbitrage and trustee except to the extent that there are special compliance and fees, provides for assessment prepayments. generate debt levy improved cashflow savings. matching *Road and Bridge Fund would be collapsed (i.e. closed) in 2024. *Eliminates reliance on VRC assessments for future debt service or CIP payments ^'$500,000 in future special assessment receipts and plann debt levy for these bonds would become CIP levy(i.e. pay cash for Estimated Total Levy Savings $830,000 $9,500 future CIP improvements) *does not include 25bp buffer Exhibit F 11-4 PRELIMINARY SCHEDULE OF EVENTS THE CITY OF FARMINGTON GENERAL OBLIGATION CAPITAL IMPROVEMENT PLAN REFUNDING BONDS, SERIES 2016A (current refunding of Series 2007A Bonds) And GENERAL OBLIGATION REFUNDING BONDS,SERIES 2016B (current refunding of Series 2008A,2008B and 2010C Bonds) September 19,2016 City Council reviews Presale Report and considers resolution calling for the sale of Bonds. [Presale Report and resolution for Council packet due on or before September 15, 2016.] September 26,2016 Ehlers provides rating materials to Standard and Poors. Week of October 3,2016 Rating Conference call with Standard and Poors. October 6,2016 Ehlers distributes Preliminary Official Statement to market. October 17,2016 Ehlers receives bids City Council considers bids, awards sale of Bonds and adopts resolution. [Resolution provided by Dorsey and Whitney for council packets on or before October 12, 2016.] November 10,2016 Estimated closing date. [within 90 days of the date of the February 1, 2017, the call date of the Series 2007A, 2008A, 2008B and 2010C Bonds] February 1,2017 Series 2007A,2008A,2008B and 2010C Bond redeemed. pp vvt rw.ehlers-inc.com E H L E R S Minnesota phone 651.697-8503 3068 Goitre Po°mie Me 6FAPERS ea KWIC CntinS E,$Q in Win and Minas fax 851438T-8355 Rosevi3e,MN 55113-1122 IQfl tree 600.652-1171 of ii , City of Farmington iii430 Third Street Farmington,Minnesota 651.280.6800 -Fax 651.280.6899 °'-n•„ S www.cifarmington.mn.us TO: Mayor,Councilmembers and City Administrator FROM: Kevin Schorzman, City Engineer SUBJECT: 2016 Street Light Fund Expenditures DATE: April 11, 2016 INTRODUCTION In 2010, the city began collecting a street light utility fee which is used to pay for the electricity and maintenance of street lights and traffic signals within the city. DISCUSSION As reported at the March 21,2016 city council meeting,the street light utility fund has matured to the point where there is a positive fund balance which can be used to pay for modifications and upgrades to the city's street light and traffic signal system. Staff would hie to discuss two proposals with the city council related to street light fund expenditures in 2016. First, as the city council is aware,MnDOT is doing a project on TH-3 this summer that includes replacement of the traffic signals at TH-3/Elm Street and TH-3/Ash Street. On January 4, 2016,the city council approved an agreement with MnDOT related to the city's share of the traffic signal costs. Those costs are estimated to be approximately$55,000. Staff is proposing that this cost be paid out of the street light fund. Second, for several years, the city has been interested in conversion of street lights from older technology (high pressure sodium (HPS))to newer technology(LED). The majority of street lights in the city are either owned by Dakota Electric or Xcel Energy. We have been waiting for these companies to establish rates for LED lighting so that we could explore converting some/all of our street lights to LED's. While Xcel has yet to establish an LED rate, Dakota Electric has established several rates for the different types of lighting (decorative, cobra, etc.) Dakota Electric's rate for decorative LED lighting does not make financial sense for the city at this point(monthly cost is higher than existing lights,therefore the city would never recover the investment required to convert the lights and would pay a higher monthly cost than we currently do). However,Dakota Electric's rate for LED fixtures to replace cobra-style overhead lighting is less per month than the current HPS lights. Therefore it does make sense to consider paying the upfront conversion costs for these types of fixtures within Dakota Electric's territory as the conversion cost will be paid over time with lower monthly costs. There are currently 87 of these lights that staff is proposing we convert to LED. The cost of converting the lights is approximately$500 per light for a 150 watt HPS equivalent LED,and$800 per light for a 250 watt HPS equivalent LED. The current HPS monthly rate, and the new LED monthly rate are listed below: • 150W HPS-$14.16 per month 150W LED Eq.-$8.69 per month • 250W HPS-$17.95 per month 250W LED Eq.-$13.16 per month As you can see, there is a monthly savings of$5.47 per month for the 150W LED's and a savings of$4.79 per month for the 250W LED's. If you factor in these savings the conversion cost payoff is approximately 7.6 years for the 150W and approximately 14 years for the 250W. It should be noted that once the conversion is complete,Dakota Electric is responsible for operation and maintenance of the lights with no future maintenance contribution by the city other than the monthly charge. Dakota Electric has indicated that the conversion of all 87 lights would take some time as they need time to order the materials and then to schedule the conversions amongst their other daily tasks. Therefore, staff recommends authorizing the conversion of half of the lights this year, and half next year. With 11 150W fixtures and 76 250W fixtures, the total cost of the conversion is approximately$66,300. The location of the lights is shown on the attached map. BUDGET IMPACT This year, there are approximately$90,000 in funds available for the two items mentioned above. The cost for the traffic signals on TH-3 is approximately$55,000, leaving approximately$35,000 for LED conversion. Based on past fund performance, it is anticipated that there will be enough money in the street light fund to pay for the remaining half of the lights in 2017. ACTION REQUESTED Discuss this item and provide direction to staff related to the two proposals. ATTACHMENTS: Type Description i Exhibit Dakota Electric Overhead Street Light Locations I \7 ) N w J ' Lakeville-1 e— 1 ilium ii■41" �' .. 14 ilkSlibvP11=1,4 41% ii v I Li III was i H gip l r - Empire TWP 4r---i sa ', ;r. (64 ,41; ; go 11111:11r41-10 _ .... ___(64. rit •.... I : ar 1 1 t ` �z ss Farmingto I i 111 it >m 1 — = !1— f - - - - - - - - - - J �, l 31, I �� e nom 50 — 31 r NNE ; r A�Y. J 1 Farm ington • J� I. I!W! 1 III 1111I 1 — . 1 + I — 7a Nu IF 1 — b, �, 1 I 1 I AKE CAR i � � I I le 1 -Eureka--T, ' ----i. I NM I `■ I I— .. N 3 tfu 1 i� 1 0 vernliiti°lt_ Cas�ROCk TWP � t ^/ S°td`t at.pltch 1"07,„Urn r River I I f�{ r l c, N FIJ C Map No.: C2-25-AB N 0 1,3002,600 5,200 ASSOCIATION Twp.:T114N R20W S25 Dakota Electric A Feet a Y Tadmaoefiugy'Paruc 47)( CO 0 This drawing is neither a legally recorded map nor a survey and is not intended to be used as one.Check with DEA Land Use Manager to verify specific site locations are within DEA Service Territory. This drawing is to be used for reference purooses only.Dakota Electric Association is not responsible for any inaccuracies herein contained.For location of buried cable call Gopher State One Call 0 1-800-252-1166 or 651-454-0002. M City of Farmington 430 Third Street Farmington,Minnesota 49 651.280.6800 -Fax 651.280.6899 4.4444 a WWW.ci.farmington.mn.us TO: Mayor,Councilmembers and City Administrator FROM: Kevin Schorzman, City Engineer SUBJECT: Private Street Signs DATE: April 11,2016 INTRODUCTION As the city council may be aware, there are a number of private streets within the city. Historically, all street name signs have been white lettering on a green background. DISCUSSION Two years ago,the city began a program by which all signs within the city are replaced on a seven year cycle. This was done based on requirements in the Manual on Uniform Traffic Control Devices (MUTCD) which required all road authorities to develop a plan that would ensure sign retroreflectivity. This year we are in an area that has private streets that intersect our public streets. Staff has been discussing the benefits of changing to a different color sign background on private streets. These benefits include: • Public safety benefits-Most of the private streets in town do not follow the normal Dakota County street naming convention. Most emergency services personnel know the general location of these private streets based on their theme(birds, last names, etc.),but may not be completely familiar with exactly where they are going. Different colored signs for private streets can provide a visual cue to our emergency services personnel responding to incidents on these streets. • General awareness-Based on calls from residents, it is clear that many of them do not realize that they live on a private road, and therefore the city is not responsible for maintenance, snow removal, etc. Having different colored signs on private streets will provide a visual cue to current and future residents that they live/will be living on a private street. The Police Chief and Fire Chief support changing the background color of private street signs. The MUTCD allows three different options for street name signs other than the standard white lettering on a green background: white on blue,black on white, and white on brown. Examples of each color scheme are attached to this memo. Staff does not support changing to a blue background as there would not be a high level of contrast between the blue signs and green signs. BUDGET IMPACT N/A ACTION REQUESTED Discuss the attached examples of private street name signs and provide staff feedback on which color council prefers. ATTACHMENTS: Type Description D Exhibit Private Street Name Sign Options I i ■ Escalade Way ou it Private Escalade Way Pvt ■ Escalade Way Private J iiii c§ FARy/,�,6, STAN DAR D DETAILS Last Revision: _ PRIVATE STREET SIGN MAR 2016 >7')A----4.- ,--,,!%.:7k, City Plate No .147 0,e A4s,,AFR011,„si, FARM \ GTON VI \ \ ESOTA GEN- , �� 2012 K:\STANDARDS\STANDARD PLATES\2012 STANDARD DETAILS\ ��4EFa►Rii City of Farmington 4 430 Third Street Farmington,Minnesota 651.280.6800 -Fax 651.280.6899 .+ �, www ci.farmington.mn.us mmo TO: Mayor, Councilmembers and City Administrator FROM: David McKnight, City Administrator SUBJECT: Youth on Boards Initiative DATE: April 11,2016 INTRODUCTION A proposal has been made to the city to have students sit on our boards and commissions. DISCUSSION Mayor Larson and I met with Wyatt Cieluch who is leading the Youth on Boards Initiative. Wyatt is a sophomore at Farmington High School who participated in a similar program when he lived in Northfield. Wyatt shared that the goals of the initiative include: 1. Create youth involvement in politics 2. Connect students with boards and commissions that match their interests 3. Create a wave of youth input into the political landscape of the Farmington area and beyond 4. Encourage leadership and student representation of the school Mayor Larson proposed to bring this issue to the city council work session for discussion with the entire city council. BUDGET IMPACT NA ACTION REQUESTED Discuss the proposed Youth on Boards Initative and provide staff with direction on this issue. ATTACHMENTS: Type Description © Backup Material Proposal Youth on Boards Initiative in ISD 192 Created by Wyatt Cieluch Mission Statement: The goal of the Youth on Boards Initiative in ISD 192 is to create a connection between youth and politics to give students an opportunity to share their opinions and learn about the political process. Also connecting young community members with boards and commissions that match their interests as well as provide resources and support to ensure their experience serving on a board or commission is one that is both enjoyable and educational. Goals of the Initiative: • Create youth involvement in politics. • Connect students with boards and commissions that match their interests. • Create a wave of youth input into the political landscape of the Farmington area and beyond. • Encourage leadership and student representation of the school. Tentative Timeline March-April 2016: • Gain the support of the school administration as well as the support of the boards and commissions of Farmington and Dakota County. • Find.a staff advisor willing to host meetings of students involved in the initiative and give the students the resources they need to be successful. • Create an application and form a group of teachers, staff members and members of administration to screen applicants and select students to serve on the boards and commissions. • Search for and apply for any grants applicable to the Youth on Boards initiative. May 2016: • Distribute applications to students and create excitement for the process. • Select students to represent FHS on the boards and commissions. • Connect students with their respective boards that want to start in the summer. June-Mid August 2016: • Provide support for students involved with boards over the summer. Late August 2016: • Follow up with students that were accepted to a board position and connect them to their board and commission and give them any resources they need. (Ex. Economic Plan for Farmington) • Provide support to students with questions about their role on the board or regarding the initiative. School Year 2016-2017 • Set up meetings for youth members from all boards to come together and discuss the current issues or projects that their board is involved in. • Continue to support and answer questions from students or community members. • Distribute applications in late April, early May to students interested in joining the program. (Students previously accepted need not to apply again unless wanting to serve on a different board or commission.) VJ2. lh 4`z''..r,0; ,;;,...:40,,,, v A !` a r a �' : , ; 41 Are 4 S . t f 14;44 i3 ��' f hG �tm � i .pia ll; 1 � k a+ u F k 7� rC'r E % ti fit R 4 ws ', . A (' A s+ r.�l6 5 4t fr1