Loading...
HomeMy WebLinkAbout2025-12-23 EDA Packet Meeting Location: Municipal Center 7100 147th Street West Apple Valley, Minnesota 55124 December 23, 2025 Economic Development Authority Meeting Tentative Agenda 6:30 PM 1. Call To Order 2. Approve Agenda 3. Consent Agenda Consent Agenda Items are considered routine and will be enacted with a single motion, without discussion, unless a councilmember or citizen requests to have any item separately considered. It will then be moved to the regular agenda for consideration. A. Approve 2026 EDA Meeting Calendar B. Approve Minutes of November 13, 2025, Special Meeting 4. Regular Agenda A. EDA Resolution of Support for Allocation of Pooled TIF Funds to Real Estate Equities for the Proposed Valley Station Apartments Project 5. EDA Items And Communications 6. Staff Updates 7. Adjourn Next Regularly Scheduled Meeting Date: January 23, 2026 ITEM: 3.A. MEETING DATE: December 23, 2025 SECTION: Consent Agenda Description: Approve 2026 EDA Meeting Calendar Staff Contact: Breanna Vincent, Department Assistant Department / Division: Community Development Action Requested: Motion to approve the 2026 meeting calendar. Summary: Meetings are held on the fourth Thursday of every other month at 6:00 p.m. at the Apple Valley Municipal Center, 7100 - 147th Street West. Thursday, January 22, 2026 Thursday, March 26, 2026 Thursday, May 28, 2026 Thursday, July 23, 2026 Thursday, September 24, 2026 Tuesday, December 22, 2026 Background: N/A Budget Impact: N/A Attachments: None ITEM: 3.B. MEETING DATE: December 23, 2025 SECTION: Consent Agenda Description: Approve Minutes of November 13, 2025, Special Meeting Staff Contact: Christina Scipioni, City Clerk Department / Division: Community Development Action Requested: Approve minutes of special meeting on November 13, 2025. Summary: The minutes of the special Economic Development Authority meeting are attached for your review and approval. Background: State statute requires the creation and preservation of meeting minutes which document the official actions and proceedings of public governing bodies. Budget Impact: N/A Attachments: 1. 2025-11-13 EDA Minutes ECONOMIC DEVELOPMENT AUTHORITY City of Apple Valley Dakota County, Minnesota November 13, 2025 Minutes of the Meeting of the Economic Development Authority of Apple Valley, Dakota County, Minnesota, held November 13, 2025, at 6:30 p.m., at Apple Valley Municipal Center. PRESENT: President Tom Melander, Commissioners John Bergman, Ruth Grendahl, Lisa Hiebert, Clint Hooppaw, Jodi Kurtz, and Ken Johnson ABSENT: None City staff members present: City Administrator Lawell, Community Development Director Benetti, City Attorney Hills, and City Clerk Scipioni Approval of the Agenda President Melander asked staff if there were any changes to the agenda. Mr. Lawell stated there were no changes to the agenda. MOTION: of Kurtz, seconded by Grendahl, approving the agenda as presented. Ayes - 7 - Nays - 0. Consent Agenda MOTION: of Hooppaw, seconded by Bergman, approving the consent agenda. Ayes - 7 - Nays - 0. Consent Agenda Items A. Approve the minutes of the September 25, 2025, regular meeting Regular Business A. Resolution of Support for Allocation of Pooled TIF Funds to Real Estate Equities for the Proposed Valley Station Apartments Project Mr. Bennetti stated Real Estate Equities, LLC is purchasing a 3.1-acre EDA-owned site located at 15584 Gaslight Drive. On September 25, 2025, the Developer received approval to construct a new 144-unit multifamily development, with approximately 90% of units affordable to households earning at or below 60% of Area Median Income. There is a funding gap for the project the developer is working on closing. Economic Development Authority City of Apple Valley Dakota County, Minnesota November 13, 2025 Page 2 Mr. Benetti further stated the Developer has secured an $808,000 Metropolitan Council Livable Communities Demonstration Account Grant, and the City has tentatively committed approximately $1.2 million in Local Affordable Housing Aid from its 2025 and 2026 allocations. An estimated $4 million gap remains. To address the remaining shortfall, the Developer has requested additional financial assistance from the Dakota County Community Development Agency through the allocation of available pooled TIF funds to complete the project’s funding. Mr. Benetti stated TIF No. 11 was created on April 17, 2002, and is set to decertify by December 31, 2029. The district was originally established to support affordable housing development by offsetting land acquisition costs, providing eligible on-site improvements, and promoting the development and preservation of affordable housing both within Apple Valley and in neighboring communities. Because TIF District No. 11 is managed by Dakota County, no direct City funds or budget allocations are involved in this request. Adoption of the resolution would formally convey the City’s support and encouragement for the Dakota County CDA Board of Commissioners to authorize the allocation of pooled TIF funds to assist in financing the Valley Station Apartments project. Discussion followed regarding the developer’s request, project funding, and project requirements. Director of Community and Economic Development Alfson and Assistant Director of Community and Economic Development Dykes, both from the Dakota County Community Development Agency, participated in the discussion. The commissioners directed staff to place this item on a future meeting agenda for further discussion and consideration. Staff Updates There were no staff updates. Adjourn MOTION: by Hooppaw, seconded by Grendahl, to adjourn at 6:54 p.m. Ayes - 7 - Nays – 0. Respectfully Submitted, Christina M. Scipioni, City Clerk Approved by the Apple Valley Economic Development Authority on __________. Thomas O. Melander, President ITEM: 4.A. MEETING DATE: December 23, 2025 SECTION: Regular Agenda Description: EDA Resolution of Support for Allocation of Pooled TIF Funds to Real Estate Equities for the Proposed Valley Station Apartments Project Staff Contact: Tim Benetti, Community Development Director Department / Division: Community Development Action Requested: Adopt the EDA Resolution of Support for the allocation of Pooled Tax Increment Funds by the Dakota County Community Development Agency to assist in the financing and development of the proposed Valley Station Apartments in the City of Apple Valley by Real Estate Equities, LLC. Summary: Real Estate Equities, LLC (also referenced as Apple Valley AH I, LLLP and collectively herein as "Developer") is purchasing a 3.1-acre EDA-owned site located at 15584 Gaslight Drive and legally described as Lot 1, Block 2, Carroll Center 4th Addition (the "Gaslight Site"). On September 25, 2025, the Developer received approval to construct a new 144-unit multifamily development, with approximately 90% of units affordable to households earning at or below 60% of Area Median Income (AMI). The total estimated development cost of this project is approximately $55 million. To help finance the project, the Developer applied to the Dakota County Community Development Agency (CDA) for an allocation of tax-exempt bonds, which triggered eligibility for the “automatic” 4% Low-Income Housing Tax Credits (LIHTC) available for qualified developments. However, the Developer represents to the City and the CDA that prevailing wage requirements, the unique design of the Project, increased building and labor costs, and higher than expected interest rates have resulted in unforeseen increased costs to the Project, resulting in an estimated $6 million financing gap. The Developer provided a detailed explanation of the funding gap and associated cost increases in a letter to the EDA dated December 4, 2025 (attached). To help address this gap, the City has secured an $808,000 Metropolitan Council Livable Communities Demonstration Account (LCDA) grant and has tentatively committed approximately $1.25 million in Local Affordable Housing Aid (LAHA) from its 2025 and 2026 allocations. These uses are permitted under the LAHA program and are consistent with the agreement between the City and the Dakota County CDA. Despite these commitments, an estimated $4 million funding gap remains. To address the remaining shortfall, the Developer has requested additional assistance from the Dakota County CDA through the allocation of available pooled TIF funds. The CDA is seeking separate consideration and approval from the Dakota County CDA Board of Commissioners to allocate a portion of pooled TIF revenues from Tax Increment Financing District No. 11 – Pennock, also known as the CDA Scattered Site TIF District. These funds would be used to help close the remaining financing gap and allow the project to proceed. TIF District No. 11 was created (certified) on April 17, 2002, and is set to decertify by December 31, 2029. This district encompasses several affordable multiple-family developments in Apple Valley, including Remington Cove, Haralson Apartments, Legacy Square Condominiums, Hearthstone, and The Timbers. Revenues generated from these developments have contributed to the district since 2002. The district was originally established to support affordable housing development by offsetting land acquisition costs, providing eligible on-site improvements, and promoting the development and preservation of affordable housing both within Apple Valley and in neighboring communities. At the direction of the CDA, Northland Public Finance conducted a cursory review of the amount of public subsidy requested by the Developer. Northland’s memorandum dated November 13, 2025, concludes that the proposed level of financial assistance is reasonable (attached). TIF District No. 11 is administered by the Dakota County CDA. Adoption of this resolution would formally convey the EDA’s support for the Dakota County CDA Board of Commissioners’ consideration and potential approval of the pooled TIF allocation to assist in financing the Valley Station Apartments project. Background: The site is the former Apple Valley Park and Ride facility, which was decommissioned by the Minnesota Valley Transit Authority (MVTA) and is no longer in service. In 2024, the City issued a Request for Proposals (RFP) to redevelop the Site and subsequently selected the Developer’s proposal for a four-story, workforce (affordable) apartment community. A purchase agreement between the City and the Developer was executed shortly thereafter. The City Council approved the proposed development on September 25, 2025. Budget Impact: N/A Attachments: 1. EDA Resolution of Support - Pooled TIF Funds - Valley Station Apts (12-23-2025) 2. Valley Station Apartments - Gap Financing Explanation (12-04-2025) 3. Northland Memo to CDA - Valley Station Apts. (11-13-2025) 4. Valley Station Apts Elevations & Site Plan EDA CITY OF APPLE VALLEY ECONOMIC DEVELOPMENT AUTHORITY RESOLUTION NO. EDA 2025 - ____ A RESOLUTION OF SUPPORT FOR THE ALLOCATION OF DAKOTA COUNTY COMMUNITY DEVELOPMENT AGENCY POOLED TAX INCREMENT FUNDS TO ASSIST IN THE FINANCING OF THE PROPOSED VALLEY STATION APARTMENTS IN THE CITY OF APPLE VALLEY BY REAL ESTATE EQUITIES, LLC WHEREAS, on October 24, 2024, the City of Apple Valley’s Economic Development Authority (the “EDA”) approved a Purchase and Sale Agreement between the EDA and Real Estate Equities, LLC (also referenced as Apple Valley AH I, LLLP and collectively as the “Developer”) for the sale of a 3.1 acre site owned by the EDA and legally described as Lot 1, Block 2, Carroll Center 4th Addition, Dakota County, Minnesota, and addressed as 15584 Gaslight Drive, Apple Valley, Minnesota (the “Subject Property”); and WHEREAS, on September 25, 2025, the City Council for the City of Apple Valley (the “City”) adopted Resolution No. 2025-143, approving issuance of a building permit to the Developer to construct a new 144-unit affordable workforce apartment building (the “Project”) on the Subject Property, with an estimated total development cost of $55,000,000 (fifty-five million dollars) for the project; and WHEREAS, to finance the Development, the Developer has applied to the Dakota County Community Development Agency (the “CDA”) for an allocation of tax-exempt bonds which activates the allocation of automatic 4% low-income housing tax credits to be applied towards the Development; and WHEREAS, the Developer represented to the City that prevailing wage requirements, the unique design of the Project, increased building and labor costs, and higher than expected interests rates have resulted in unforeseen increased costs to the Project, thus creating a financing gap of over $6 million; and WHEREAS, as part of an effort to close this gap, the City received a Metropolitan Council Livable Community Demonstration Account (LCDA) grant of $808,000 through the City, and the City has tentatively agreed to commit approximately $1,250,000 of its 2025 and 2026 Local Affordable Housing Aid (LAHA) funds to the Project; leaving approximately $4 million needed to complete the financing package; and WHEREAS, the CDA is considering allocating a yet to be determined amount of pooled tax increment financing (TIF) funds that have been generated and collected from properties within Apple Valley under its existing TIF District No. 11 - Pennock, also referred to as the “CDA’s Scattered Site TIF district.” The TIF District No. 11-Pennock includes several affordable multiple family developments within Apple Valley, such as Remington Cove, Haralson Apartments, Legacy Square Condominiums, Hearthstone and The Timbers; and 2 of 2 WHEREAS, the purpose of these Dakota County CDA controlled pooled TIF funds is to help offset land acquisition costs, provide eligible on-site improvements, support certain affordable housing projects within and outside the City of Apple Valley, and to develop and preserve affordable housing for the City’s and neighboring communities’ residents with quality, safe and healthy housing; and WHEREAS, it is in the best interest of the City of Apple Valley that the TIF District No. 11 - Pennock funds received by the CDA from the foregoing properties/projects be used to support projects within the City of Apple Valley. NOW THEREFORE BE IT RESOLVED, that the Economic Development Authority for the City of Apple Valley hereby expresses its support and encouragement to the Dakota County Community Development Agency to allocate a portion of its pooled TIF funds generated specifically by TIF District No. 11 - Pennock (CDA’s Scattered Site TIF District) to Real Estate Equities, LLC / Apple Valley AH I, LLLP, to be used exclusively towards the Valley Station Apartments project and development in the City of Apple Valley, Minnesota. ADOPTED this 23rd day of December 2025. ____________________________________ Thomas O. Melander, President Apple Valley Economic Development Authority ATTEST: ___________________________________ Christina M. Scipioni, City Clerk/Secretary December 4, 2025 Apple Valley Economic Development Authority 7100 147th Street W Apple Valley, MN 55124 RE: Valley Station Apartments – Explanation of Funding Gap To members of the EDA and staff, This memo serves to explain the current funding gap for Valley Station Apartments, resulting from changes to the project since Real Estate Equities was selected as the developer for the Gaslight Site in 2024. When REE submitted its RFP, it did so with the expectation that it would request $750,000 from DCCDA through its HOPE program, which REE was utilized on several other projects within Dakota County. Due to changes in the project, REE submitted a request for funding to DCCDA for $4,000,000, in addition to previous LCDA and LAHA requests. These changes include: • Reduction to Affordability Levels • Changes to Parking Requirements • Unforeseen Costs Reduction to Affordability Levels The RFP submission included affordability levels ranging from 50-70% AMI, averaging to 60%, which is the maximum allowed under the federal low-income housing tax credit (LIHTC) program, and which is the most efficient affordability mix for purposes of maximizing private first mortgage proceeds. In discussions with staff from the Dakota County CDA, they indicated they may have an interest in providing lower cost financing for the development in the form of a Pooled TIF loan, if in return we agreed to have deeper affordability for the project. The currently proposed unit mix averages to ~58%, which decreases the amount of mortgage proceeds the project supports by $1,250,000, compared to the originally proposed 60% AMI average. Below is a comparison of the affordability proposed with the RFP application, compared to the current proposal. RFP Submission Current Proposal 30%AMI - 3 50%AMI 25 37 60%AMI 98 89 70%AMI 25 15 148 144 Average AMI 60.00%57.85% Affordability Comparison Total Units Changes to Parking Requirements The RFP submission included a proposed parking ratio of 1.60 parking spaces per unit. In working through the site plan review with City staff and Planning Commission, concerns regarding the parking count were raised. To alleviate these concerns, Real Estate Equities increased its parking ratio to 1.74 spaces per unit. Due to limited space onsite, this required an additional 22 stalls to be constructed within the footprint of the building, which was accomplished by using the south half of the first level as an additional parking garage. This added approximately $300,000 of additional costs that were not contemplated at time of the RFP submission. Below is a comparison of the initial parking proposed to the current parking proposed: In addition to the increased parking count, REE was also advised that it should not charge for the use of the covered parking stalls. REE’s standard practice, which was assumed to be permissible at time of RFP submission, is to charge $75/month for the use of a dedicated parking space. The elimination of this parking revenue is expected to decrease the amount of first mortgage that can be leveraged by approximately $1,400,000. When factoring in partially offsetting LIHTC benefits to not charging for the parking, the overall reduction in project sources available to the project is approximately $660,000. RFP Submission Current Proposal Surface Stalls 88 80 Covered Stalls 149 171 Total Stalls 237 251 Units 148 144 Parking Ratio 1.60 1.74 Parking Comparison Changes to Building Design and Costs Reduction to Unit Count The RFP submission included a proposal to construct 148 units. To address concerns raised by the Planning Commission related to density, building height, and parking, the plan was revised to 144 units. This makes certain fixed costs relatively more expensive, because the building is generating less revenue to support those costs. The estimated impact to the project when comparing reduced revenues to reduced costs is approximately $100,000 Non-Continuous Building Footprint Another material change was that the RFP submission included a proposal to build over the existing sanitary sewer than runs west to east underneath the property, with the intent to sleeve it in the event it ever needed repaired. That was ultimately deemed unsupportable by staff post-RFP selection, and floors -1, 1, and 2 needed to be separated into a north and south component. This required several additional building elements that increased costs by approximately $350,000. These costs include: • Additional parking ramp (concrete, snow melt system, garage door) • Additional footing and foundation walls • Additional shafts, ducting, furnaces, fire/smoke dampers in building corridors • Additional stormwater pumps • Additional ventilation systems Green Energy Requirements In order to be competitive for MetCouncil LCDA funding, the project committed to additional sustainable elements such as the below, which adds approximately $650,000 to project costs: • Rooftop solar • Continuous exterior insulation (required per Energy Star) • Garage ceiling insulation (required per Energy Star) • EV Car Chargers (34 total) • Energy Star verification and certification Prevailing Wage Requirements At time of the RFP submittal, the state legislation requiring payment of prevailing wages for LIHTC projects was just passed, and the requirements and timeline for implementation were ambiguous. Also, depending on the type of financing that may require prevailing wage, different programs often use different wage rates (e.g. federal vs. local / commercial vs. residential) and the initial statutory language approved by the state did not provide clear guidance on which wage rates would be required under the new law either. While REE has built several prevailing wage projects, it is not something that is typically required until the state recently implemented it for all LIHTC projects. Given the timing and lack of clarity on the new requirements for LIHTC projects, REE did underestimate the overall impact it would have on this specific project. Now that the new prevailing wage requirements have been clarified and REE is in the process of closing another project under the new program, we have been able to determine the cost premium for prevailing wage at Valley Station is estimated at approximately $2,300,000, when adjusting for the partially offsetting LIHTC benefits. Summary Below is a comparative summary of the soft fund request REE contemplated to the CDA at time of RFP submission to its current proposal: RFP Submission Current Proposal Base assistance for afforability (60% AMI)750,000$ 750,000$ Additional assistance for deeper affordability - 1,250,000 Additional assistance due to increased parking - 300,000 Additional assistance due to lost parking revenue - 660,000 Additional assistance due to reduced unit count - 100,000 Additional assistance due to non-continous footprint - 350,000 Additional assistance due to Green Energy requirements 650,000 Additional assistance due to Prevailing Wage Requirements - 2,300,000 Total Assistance Requested 750,000$ 6,360,000$ RFP Submission Current Proposal Dakota County CDA HOPE Loan 750,000$ -$ Dakota County CDA Pooled TIF Loan - 4,000,000 MetCouncil LCDA Loan - 808,000 City of Apple Valley LAHA Loan - 1,250,000 Additional Private Funding Sources 302,000 Total Proposed Sources of Assistance 750,000$ 6,360,000$ Items being subsized Source of Subsidy Funding Request Comparison 150 South Fifth Street, Suite 3300, Minneapolis, MN 55402 Main: (612) 851-5900 / Direct: (612) 851-4964 / Email: tomdal@northlandsecurities.com Member FINRA and SIPC |Registered with SEC and MSRB MEMORANDUM To: Dakota County Community Development Agency City of Apple Valley From: Tammy Omdal, Northland Public Finance Date: November 13, 2025 Re: Public Finance Assistance for Valley Station Project The Dakota County Community Development Agency (the “CDA”) and the City of Apple Valley (the “City) asked Northland to provide an opinion on the amount of public subsidy requested by Real Estate Equities (the “Developer”) for the Valley Station project (the “Project”). Northland has completed a cursory review of information provided to Northland by the CDA. Information reviewed by Northland included the estimated development cost for the Project, the public funding request, and estimated project cash flow, among other information. Based on Northland’s review of the information, we find the proposed public financial assistance for the Project to be reasonable. Northland’s review and opinion is based on the following:  The Developer’s estimates for the Project, including development costs, and annual cash flow from the Project, are reasonable and within industry standards.  The Developer Fee of the approximate amount of $5.2 million, of which approximately $3.1 million will be deferred and payable from revenues from the Project, is reasonable. The Developer Fee as a percentage of the estimated total development cost for the Project is within the CDA’s limitations and is consistent with other similarly situated projects in the metro area.  The Developer estimates a financing gap of $6,058,000 for the Project and is requesting public subsidy to close this gap. The gap is the difference between the estimated total development cost of approximately $55.3 million (TDC) less loan proceeds, investor (syndication) proceeds for tax credits, deferred developer fee, and other sources of funding the Developer has secured for the Project. Valley Station November 13, 2025 Page 2  The sources of the $6,058,000 of public funds proposed by the CDA and the City to close the financing gap are as follows: o $4.0 million from a TIF Note to be issued to the Developer by the CDA and secured by available tax increment from other established tax increment financing (TIF) districts within the City administered by the CDA. The Project is not and will not be within a TIF District. o $1.25 million from Local Affordable Housing Aid (LAHA) funds to be provided by the City. LAHA funds come from the State of Minnesota to the City. LAHA is a new state funding stream for cities and counties, established in 2023, to support local affordable housing initiatives. The Project qualifies as an eligible affordable housing project and use of LAHA funds. o $808,000 from Met Council Livable Communities Demonstration Account (LCDA) grant funds awarded to the City. The LCDA provides funding for projects that increase access to housing, jobs, services and transit in an effort to support more equitable, livable communities in the region.  The public funds are equal to 11.0% of TDC. In Northland’s experience and opinion, when public funds for a project exceed 10% of the total development cost of a project, there should be certain extraordinary public benefits of the project to warrant a higher level of subsidy. The CDA and the City may consider the following to be extraordinary public benefits. o The Valley Station proposes to meet the goals identified by the City in its request for proposals for “The Gaslight Site”, currently owned by the City. o The CDA is not proposing to establish a new TIF district for the Project (it would qualify to be included in a housing TIF district). Instead, the CDA will leverage available tax increment funds from other established TIF districts in the City administered by the CDA. This will provide benefit to the City and other taxing jurisdictions from increased tax revenue from the Project upon completion. o The Project will redevelop a currently vacant and underutilized site in the City and be subject to property taxes. o The Project will provide affordable housing choices for residents providing 129 units (89.6% of the total 144 units) with rents at or below 60% average median income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ð IWð  8QLW 7\SH$  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð   IWð  %5 8QLW  IWð IWð  8QLW 7\SH$  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  *5266$5($727$/ /HYHO $UHD /HYHO IWð /HYHO IWð /HYHO IWð /HYHO IWð /HYHO IWð /HYHO IWð *UDQGWRWDO IWð 1 81,70,;*5266$5($ 1DPH &RXQW 8QLW*URVV $UHD 7RWDO$UHD 0DLQ)ORRU 8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð   IWð  %5 8QLW  IWð IWð  8QLW 7\SH$  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð  8QLW  IWð IWð   IWð  *UDQGWRWDO  IWð