CRC Memorandum

No. 1095 A publication of the Citizens Research Council of October 2009

DETROIT BALLOT ISSUES PROPOSAL S: PUBLIC SCHOOLS BOND PROPOSAL

On November 3, 2009, electors in Detroit will vote on nancial manager of DPS. The federal American Recov- Proposal S, which would allow Detroit Public Schools ery and Reinvestment Tax Act of 2009 would reduce (DPS) to borrow $500.5 million. Proposal S is a bond the borrowing costs of these bonds to taxpayers by referendum placed on the ballot by the emergency fi- lowering the interest costs.

Bond Proposal

Shall the School District of the City of Detroit, County of Wayne, Michigan, borrow the principal sum of not to exceed Five Hundred Million Five Hundred Forty Thousand Dollars ($500,540,000) and issue its unlimited tax general obligation bonds for the purpose of defraying the costs of:

• Constructing new replacement buildings and/or additions to existing buildings; • Remodeling existing buildings, including energy conservation, safety and security improvements; • Acquiring, improving and developing sites, including playgrounds, playfields and outdoor athletic facilities in the School District; • Furnishing, refurnishing, equipping and reequipping School District buildings; and • Acquiring and installing instructional technology equipment in and connecting School District buildings?

Yes __ No __

The estimated millage to be levied in 2010 to service this issue of bonds is 3.82 mills ($3.82 per $1,000 of taxable value) and the estimated simple annual average millage rate required to retire the bonds of this issue is 2.56 mills ($2.56 per $1,000 of taxable value). The debt millage levy required to retire all bonds of the School District currently outstanding and proposed by this ballot proposal is currently estimated to remain at or below 13.0 mills. The bonds may be issued in multiple series, payable in the case of each series in not to exceed thirty (30) years from the date of issue of each series. If the School District borrows from the State to pay debt service on the bonds of this issue, the School District may be required to continue to levy mills beyond the term of the bonds to repay the State.

(Under State law, bond proceeds may not be used to pay teacher or administrator salaries, routine maintenance or repair costs or other School District operating expenses.)

Programs and Definitions

A general obligation bond is a municipal bond in CRC Board of Directors which the issuing government pledges to use all avail- EUGENE A. GARGARO, Jr., Chair DANIEL T. LIS JEFFREY D. BERGERON, Vice Chair ALEKSANDRA A. MIZIOLEK able revenues at its disposal to repay bondholders, NICK A. KHOURI, Treasurer CATHY H. NASH JOSEPH R. ANGILERI including raising property taxes. If property tax rev- PAUL OBERMEYER JOHN T. BOZZELLA BRYAN ROOSA BETH CHAPPELL enues fall short of the required bond payments, the LYNDA ROSSI RICK DIBARTOLOMEO terms of a general obligation bond require the local TERENCE M. DONNELLY JERRY E. RUSH RANDALL W. EBERTS MICHAEL A. SEMANCO government to raise property taxes to make up the DAVID O. EGNER TERENCE A. THOMAS, Sr. INGRID A. GREGG AMANDA VAN DUSEN shortfall. A limited tax general obligation bond al- MARYBETH S. HOWE KENT J. VANA JEFFREY P. GUILFOYLE, President

CITIZENS RESEARCH COUNCIL OF MICHIGAN

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CRCMICH.ORG CRC Memorandum lows a local government to raise expected to be spent within three state credit enhancement and loan property taxes within constitu- years with a binding commitment mechanism through the School tional, statutory, or charter limits. from a third party that 10 percent Loan Revolving Fund (SLFR) for An unlimited tax general obliga- of the proceeds will be spent within school district bond issues. State tion bond allows a local govern- the first six months. This program qualified bonds must be approved ment to levy taxes of up to 100 reduces school borrowing costs by by the state treasurer and bond percent of a property’s value if providing tax credits to bondhold- proceeds must be used for capital necessary. Both types of general ers in lieu of interest giving school expenditures. Districts that re- obligation bonds are generally districts interest-free loans. On ceive qualification from the State rated highly by credit ratings agen- large projects, savings can be 50 get 1) a rating on the bonds equal cies with unlimited tax bonds al- percent. The federal government to the State’s credit rating, which most always rated higher because has allocated up to $246.5 million will often result in a lower interest they require voter approval and in total QSCBs to DPS for years rate and cost, and 2) the ability to have a stronger tax pledge backing 2009 and 2010. State law requires borrow from the State an amount them.1 voter approval before the bonds sufficient to enable the district to can be issued. pay principal and interest require- As part of the American Recovery ments on its outstanding qualified and Reinvestment Tax Act of 2009, BABs are “taxable tax credit bonds” bonds in the short-run if its prop- the federal government allocated and are designed for subsidizing erty tax levy is insufficient to pay authority for Qualified School state and local government obliga- the full debt service (a minimum Construction Bonds (QSCBs) and tions, including school construc- debt millage of seven mills must Build America Bonds (BABs).2 tion. BABs provide an issuer with a be levied before a district can bor- QSCBs, a new type of tax credit direct subsidy of 35 percent of the row from the State). Once the dis- bond, allow state and local govern- interest cost. These bonds can also trict retires earlier debt and tax- ments to issue up to $22 billion ($11 be used for school construction.3 If able value growth becomes billion in 2009 and $11 billion in Proposal S passes, DPS plans to is- sufficient to meet the district’s to- 2010) for the construction, rehabili- sue $246.5 million in QSCBs and tal annual debt service, the district tation, and repair of public school $254 million in BABs. will stop borrowing from the State facilities. This includes the acquisi- and begin to use its surplus rev- tion of land, work on existing The Michigan Department of Trea- enue to repay the loan principal schools, and new construction. No sury houses the School Bond and accrued interest. Bonds must more than two percent of the avail- Qualification and Loan Program be qualified before districts put able proceeds may be used for is- (SBQLP). The SBQLP provides a them in front of electors for a suance costs, and 100 percent of vote.4 The bonds that would be the proceeds must be reasonably

3 “Recovery Act Funding for School Construction.” National 4 State of Michigan: School Loan 1 The Free Dictionary: Financial Clearinghouse for Educational Revolving Fund Process. Michigan Dictionary, “General Obligation Facilities website: www.edfacilities. Department of Treasury, School Bond.” http://financial- org/school-modernization/ Bond Qualification and Loan dictionary.thefreedictionary.com/ (accessed 20.Sep.09); and Mark Program. www.michigan.gov/ General+Obligation+Bond+-+GO Prussing, Roan Blacker, and Duncan documents/3272_2816_7.pdf (accessed 28.Sep.09). Brown. Recovery Act Bond Finance: (accessed 30.Sep.09); and State of 2 See Internal Revenue Bulletin Qualified School Construction Bonds. Michigan: Bond Qualification Process 2009-17 for more information on July 31, 2009. www.commerce. Overview. Michigan Department of QSCBs (http://www.irs.gov/irb/ wa.gov/DesktopModules/CTED Treasury, Bureau of Bond Finance, 2009-17_IRB/ar08.html) and Internal Publications/CTED Publications School Bond Qualification and Loan Revenue Bulletin 2009-16 for more View.aspx?tabID=0&ItemID= Program. www.michigan.gov/ information on BABs (www.irs.gov/ 7675&MId=484&wversion=Staging documents/3160_2815_7.pdf irb/2009-16_irb/ar08.html). (accessed 29.Sep.09). (accessed 30.Sep.09).

2 CRC Memorandum authorized by the passage of Pro- loan fund revenues combined with bond proceeds would allow it to posal S have received preliminary direct federal stimulus funding.6 build new state of the art facilities qualification and should receive with 21st century technology, over- final qualification if the bond pro- If the proposal passes, DPS plans haul safety and security infrastruc- posal passes.5 This means that the to use the bond proceeds to build ture, move DPS to a standardized loans would be backed by the eight new schools and modernize pre-kindergarten through eighth State and DPS would be approved or renovate 10 schools. The evalu- grade model, develop flexible to borrow money from the State ation criteria used to determine learning environments, and ex- if its property tax levy does not which schools to build and reno- plore opportunities to use decom- cover its total debt service re- vate include academic perfor- missioned spaces for community quirements. The 2010 operating mance, utilization (student per services and activities.7 Table 1 budget suggests that the current square feet), demographic fore- details the project list and budget. capital budget anticipates State casts, facility condition, building age, past investment, and building needs. The District states that the

5 State Qualified Bond Election 7 Detroit Public Schools. I’m in. Results, Wayne County: Detroit City Creating Centers of Excellence: 2009 School District. treas- 6 DPS FY2010 Operating Budget: pg. Bond Referendum. secure.state.mi.us/apps/findschool 33. www.detroitk12.org/admin/ www.detroitk12.org/admin/ bondelectinfo.asp?county finance/manager/docs/ communications/docs/ name=82&schooldistrictname= 2009.07.31_DPS_Budget_Book.pdf 2009.09.18_ProposalS_description.pdf 82010 (accessed 30.Sep.09). (accessed 30.Sep.09). (accessed 29.Sep.09).

Table 1 Proposal S Project List

School Name Project Budget Recommendation Bethune Academy $8,605,811 Renovated Facility Brightmoor PK-8 $32,180,556 New Facility $41,488,148 New Facility Cooley High $8,306,132 Renovated Facility $24,819,339 Renovated and/or New Facility Duffield PK-8 $8,578,108 Renovated Facility $53,467,428 New Facility Ford High School $20,594,893 Renovated and/or New Facility JR King PK-8 $15,896,250 Renovated Facility Marcus Garvey PK-8 $11,271,996 Renovated Facility Mark Twain PK-8 $8,597,281 Renovated Facility Martin Luther King Jr., High School $54,469,031 New Facility Maybury PK-8 $37,406,135 New Facility McNair PK-8 $21,979,291 New Facility $54,746,160 New Facility Munger PK-8 $18,374,295 New Facility Northwestern High School $26,870,380 Renovated and/or New Facility Western International High School $28,610,966 Renovated and/or New Facility

Source: Detroit Public Schools. I’m in. Creating Centers of Excellence: 2009 Bond Referendum.

3 CRC Memorandum

Issues Related to the Bond Proposal

Detroit Public Schools FY2010. At the end of FY2008, DPS approximately 83,777 students in Finances had a budget deficit of $142.4 mil- FY2010.9 lion. Further spending in excess of School district operating revenues revenues in FY2009 is projected to The DPS operating budget ac- and expenditures are budgeted increase the deficit to $279.5 mil- counts for some debt service ex- separately from capital revenues lion (these numbers come from penditures out of the General Pur- and expenditures. Operating ex- the FY2010 Operating Budget and pose (GP) Fund. In April 2005, DPS penses are those incurred through may vary somewhat from audited refinanced $210 million in short- the normal daily business of the CAFR results, which put the term State Aid Anticipation Notes school district; operating revenues FY2008 deficit at $139.7 million). into long-term debt payable over fund those expenditures. Debt The FY2010 current operating bud- 15 years as part of an overall defi- service on bonds to finance capi- get projects a $17.4 million positive cit elimination plan approved by tal expenditures is funded by a ending operating balance. How- the State in February 2005. This dedicated property tax levy; vot- ever, this positive ending balance created an annual obligation ers approve the sale of bonds and is based on the district having through FY2020 for debt service authorize the local unit to levy 83,777 students and receiving a cut payments out of the GP Fund. property taxes without limit to pay of only $110 per pupil in state aid. Debt service payments are pro- the principal and interest on those The State Legislature recently jected at $37.3 million in the bonds. passed a FY2010 School Aid bud- FY2010 budget. One of the terms of this long-term debt issuance Operating Budget. Data from DPS get that cuts state aid $165 per pu- was that DPS had to maintain a financial reports show that in a 13- pil, so DPS will be forced reduce positive GP Fund balance. As of year period from Fiscal Year (FY) its expenditures to make up for the the end of FY2008, DPS had a fund 1995 to FY2007, actual DPS rev- additional cut of $55 per pupil. deficit in the GP Fund and was enues exceeded expenditures in Enrollment numbers for FY2010 therefore not in compliance with only four fiscal years, the most re- are not yet known, but student the agreement. cent being FY2002.8 Table 2 shows enrollment has declined from budgeted operating revenues and over 173,000 students in FY1999 to expenditures for FY2008 to 94,000 students in FY2009. This represents a 46 percent decline in the student body in 11 years. The 9 Robert Bobb. Detroit Public District estimated that if current 8 Gary S. Olson and Kathryn Schools: FY2010 Budget presentation. Summers-Coty. A Review of the trends continue, it should have June 29, 2009. www.detroitk12.org/ Financial Status of the Detroit Public admin/finance/manager/docs/ Schools. Senate Fiscal Agency: State 2009.06.29_DPS_FY2010_Budget.pdf Notes. September/October 2008. (accessed 1.Oct.09).

Table 2 Detroit Public Schools Operating Revenues and Expenditures ($ in Millions) FY2008 Actual* FY2009 Revised FY2010 Budget Revenues $1,274.5 $1,288.2 $1,195.0 Expenditures $1,416.9 $1,425.3 $1,177.6 Difference $(142.4) $(137.1) $17.4 * Numbers are from unaudited General Ledger reports and may vary somewhat from audited CAFR reports. Source: Detroit Public Schools FY2010 Operating Budget.

4 CRC Memorandum

Table 3 Detroit Public Schools Total Revenues and Expenditures ($ in Millions) Expenditures Total Revenues and Operating Debt Service Financing Sources Expenditures and Capital Outlay Other Total FY1999 $1,809.1 $1,133.5 $167.4 $261.9 $1,562.8 FY2004 $1,724.2 $1,664.4 $400.3 $7.0 $2,071.6 FY2008 $1,350.5 $1,329.8 $168.9 $0.4 $1,499.1

Source: Detroit Public Schools, Comprehensive Annual Financial Report, June 30, 2008. Ten-Year Summary of Governmental Funds Revenues and Expenditures: pgs. 91-92.

Analyzing revenues and expendi- wide11) and greater security needs.12 duce overhead costs; taking a new tures per pupil highlights the ef- approach to technology; develop- fect of an increasing spending gap Even if the FY2010 budget remains ing new operational strategies, in- coupled with a declining enroll- balanced, the district must address cluding reviewing transportation ment. From FY1995 to FY2007, the the legacy deficit created by years and physical plant needs; focusing DPS foundation allowance in- of expenditures exceeding rev- on increasing safety and security in creased from $5,584 per pupil to enues. The deficit elimination plan schools; focusing on core district $7,565 per pupil, a 25.1 percent in- submitted to the State in April 2009 responsibilities; competitively bid- crease. At the same time, expen- proposes eliminating this deficit ding non-academic services (e.g., ditures per pupil in DPS increased over multiple years and adopting a transportation); and containing 80.2 percent from $7,229 to multi-year perspective when bud- workforce costs by eliminating $13,382.10 Like other school dis- geting. Actions taken by the Dis- non-essential positions and re- tricts in Michigan, DPS has faced trict to reduce the deficit in FY2009 structuring costs. Options to ad- rapidly increasing costs for em- included strengthening vendor dress the budget deficit identified ployee and retiree health care and controls and negotiating 25 per- in the FY2010 budget presentation benefits. However, DPS faces cent contract reductions with include bankruptcy and asset liqui- some spending pressures that are some vendors, instituting limits on dation, expanding the number of distinct from many other Michigan hiring and personnel costs, and im- DPS charter schools, and develop- districts, including having a high proving grant compliance. Actions ing a multi-year deficit reduction percentage of low-income stu- planned for the FY2010 budget and plan.13 dents (in fall 2008, 74 percent of beyond include transforming cen- DPS students were eligible for free tral administration to sharply re- Debt Service. The DPS Compre- or reduced price lunch compared hensive Annual Financial Report to 41 percent of students state- (CAFR) compares total revenues (operating and debt service) with 11 Center for Educational Performance and Information (CEPI) expenditures broken down by cur- Data and Reports. Free and Reduced rent operating expenditures, debt Lunch Counts, District Level Data, service and capital outlay expendi- Fall 2008-09. michigan.gov/ tures, and other expenditures. As documents/cepi/ Table 3 shows, in FY2008 expendi- FRLDistFall08_270278_7.xls (accessed 6.Oct.09). 12 Robert Bobb. Detroit Public 13 Robert Bobb. Detroit Public 10 Olson and Summers-Coty, SFA, Schools: FY2010 Budget presentation: Schools: FY2010 Budget presentation: October 2008. pg. 39. pgs. 13, 48-57, 61.

5 CRC Memorandum tures continued to outpace rev- age limit of 13 mills and it can bor- and the ratio of bonded debt to enues. Debt service expenditure row money from the SLRF to help state equalized valuation/taxable levels in FY2008 were comparable pay its debt service. However, if value of property went from 7.7 to what they were in FY1999 and less the District does not borrow any percent to 15.64 percent. The than half of FY2004 debt service more money (i.e., the bond pro- amount of bonded debt per capita spending. Detroit residents face posal does not pass), DPS will pay increased from $528 to $1,637.16 higher capital costs than residents of less in debt service and debt mill- many other school districts across age rates will begin to go down Detroit Public Schools the state because DPS has one of sooner than if the proposal passes Governance the lowest taxable value per pupil and the district borrows more In December 2008, the Michigan rates in the state. In 29 of Michigan’s money. The estimated annual av- Superintendent of Public Instruc- wealthiest districts, the value of tax- erage millage rate required to re- tion declared DPS to be in a state able property in 2005 was more than tire the bonds of this issue is 2.56 of financial emergency and the $500,000 per pupil; in Detroit, the mills; this means that it is pro- Governor appointed Robert Bobb value of taxable property was less jected to cost $2.56 per $1,000 of as the emergency financial man- 14 than $50,000 per pupil. This results taxable value to pay off the debt ager in March 2009. His initial ap- in higher taxes and lower quality fa- that would be incurred as a result pointment lasts until March 2010; cilities in Detroit. of passage of this proposal. This the law allows his contract to be projected millage rate would ex- renewed on an annual basis for not School debt property tax millage tend until the debt is retired (30+ more than one year.17 rates have increased from 5.9 mills years depending on when the debt in FY2000 to 13 mills in FY2008 is issued and if debt service pay- Until recently, DPS has been the (they have been at that level since ments are extended through the state’s only first class school dis- FY2004). Debt retirement millage SBLQP). This rate is only a projec- trict, which gave it all the powers rates for other districts throughout tion because the required millage enjoyed by other school districts the state ranged from 0 mills to rate will fluctuate with taxable in the state (general powers dis- 12.65 mills with the majority of dis- value levels and the cost of bor- tricts) along with some additional tricts levying under 10 mills for rowing at the time the debt is is- requirements and powers. One of 15 debt retirement. sued. The fact that passage of Pro- the biggest distinctions is the posal S would extend the length school board and governing struc- The District claims that passage of of time residents are required to ture is set up differently for a first Proposal S will not increase taxes pay debt service taxes is not an ar- class district. The school code for district residents. This is tech- gument against the proposal; it is defines a first class district as one nically true. DPS is at its debt mill- simply an acknowledgement that with at least 100,000 pupils en- residents will be required to repay rolled on the most recent pupil 14 The Citizens Research Council of the debt. membership count day and DPS Michigan and the Education Policy now has fewer than 100,000 pu- Center at Michigan State University. As of FY2008, DPS had $1,309.9 Adequacy, Equity and Capital million in outstanding debt for Spending in Michigan Schools: The school building and site improve- Unfinished Business of Proposal A. ments. This proposal would add 16 May 2005: pg. 4. $500.5 million to that amount. Detroit Public Schools, Comprehensive Annual Financial 15 From FY1999 to FY2008, total LEA Millage Rates. michigan.gov/ Report, June 30, 2008. Ten-Year bonded debt increased from documents/ Summary of Governmental Funds lea_millage_39045_7.pdf (accessed $510.7 million to $1,500.9 million Revenues and Expenditures: pgs. 29.Sep.09); some districts levy 96-106. additional mills for sinking funds to 17 help pay debt service expenditures Local Government Fiscal (DPS does not levy sinking fund Responsibility Act. Michigan Public mills). Act 72 of 1990, MCL 141.1238.

6 CRC Memorandum pils.18 The Michigan Attorney Gen- ing school aid and first class sta- Fiscal Mismanagement eral issued an opinion stating that tus does not impact the level of Audits done since Robert Bobb “the Detroit Public Schools does state aid received by a district.21 took over as financial manager not qualify as a first class district have found widespread waste, in- under the [Revised School] Code Right now, it is unclear what form cluding paying ghost employees, and is, therefore, a general powers of governance the district will be providing health coverage for in- district.”19 This opinion has the operating under after March of eligible dependents, and unused power of law until a court rules on next year. This is important be- supplies and equipment.23 A $1.5 the issue. The Attorney General’s cause if the bond proposal passes, billion bond passed in 1994; recent ruling determined that the limita- whoever is governing the district investigations by the District’s in- tion preventing community col- will have control over how the spector general found overspend- leges from opening charter funds are spent. The possibilities ing for land and building purchases schools in first class districts no include an emergency financial and “a gross lack of due diligence longer applies to DPS. However, manager, a first class school board, in looking after taxpayers’ dol- the school code does not address a general powers school board, or lars.”24 Questionable transactions how a district should transition the mayor, among other options. included: from a first class district to a gen- Putting control of DPS under the mayor or another governmental eral powers district. The ruling • Paying $24.1 million in 2002 for actor would require action by the says that board and district re- five floors of a building from a legislature and may require a vote structuring needs to be addressed company that paid $21.7 mil- of the people of Detroit. by the State Legislature, but the lion for the whole building in current DPS board is advised to Declining Enrollment 2001; exercise only the powers of a gen- • Paying $5.6 million for proper- eral powers district. As discussed above, DPS has lost ties in 2001 and 2002 that were almost half its students in the last appraised by the City of De- The School Aid Act, which governs decade. This raises questions about troit at $812,800; the appropriation, allocation, and the viability of the district and the • distribution of state funds to local Paying $11.9 million in 2003 for necessity of funding for new build- a property that sold for $1.3 districts, defines a first class district ings and renovations. On the other as one that “had at least 60,000 million two years earlier; hand, it does cost money to close • Paying $114.9 million ($286 per pupils in membership for the im- and/or demolish buildings and to mediately preceding fiscal year.”20 square feet) for the construc- right-size a district with declining tion of the new Cass Tech High This definition does not affect the enrollment. A 2005 report found revised school code, which gov- in 2004 (the cost per square that more than half of all DPS feet allowable as of June 30, erns the organization, regulation, schools were built before 1930 and and maintenance of local and in- the average school is 60 years old.22 termediate school districts. The Improved facilities may make DPS School Aid Act definition applies a more attractive choice for Detroit only for the purpose of determin- parents and improve the quality of 23 the educational experience for DPS “DPS Audits Find Millions in Waste.“ ClickOnDetroit.com, students. 5.Aug.09. www.clickondetroit.com/ print/20287494/detail.html 18 The Revised School Code. Michigan (accessed 28.Sep.09); and Jennifer Public Act 451 of 1976, MCL 380.402. Mrozowski. “Two resign as DPS sends 19 Michigan Attorney General Op. 21 Mich. At. Gen. Op. No. 7234 (July sick-time fraud cases to prosecutor.” No. 7234 (July 20, 2009). 20, 2009). The Detroit News, 28.Apr.09. 24 20 The State School Aid Act of 1979. 22 The Citizens Research Council of Marisa Schultz. “Inquiry shows DPS Michigan Public Act 94 of 1979, MCL Michigan and the Education Policy overpaid millions on real estate 388.1606(11). Center at MSU: pg. 4. deals.“ The Detroit News, 24.Sep.09.

7 CRC Memorandum

2009, under the state’s SBQLP City and District Revitalization for districts in the Detroit- DPS states that the proposal Warren-Flint Combined Sta- would result in the creation of tistical Area is $190 per square 11,000 jobs using the state’s job feet; projects exceeding this creation formula. This includes amount require additional 3,725 direct jobs and over 7,000 documentation25); • indirect jobs. It would not include Paying $13 million for a 99- a direct tax increase (though it year lease of property from would increase the amount of the City of Detroit and time debt service taxes are paid) spending nearly $100 million and would lead to a $500.5 million to build schools on the prop- investment in Detroit. This in- erty (the City will own the creased debt would come with schools and property when federal stimulus benefits allowing the lease expires); • the district to repay half the bonds Paying $121.8 million ($399 with 0 percent interest. DPS has per sq ft) for the construction recently closed 21 schools and this of the bond funding would allow it to in 2004; and, • modernize and renovate 10 Paying $3.8 million for 200 ad- schools and build eight new ditional parking spaces that schools. were never used.

If Proposal S passes, the District plans to appoint a DPS Bond Advi- sory and Fiscal Committee to ad- dress concerns with how the money will be spent and provide transparency. The committee would be composed of parents and political, industry, labor, and com- munity leaders. It would be tasked with conducting regular reviews of ongoing construction and funding and ensuring project goals, bud- gets, and schedules are met.

25 2009 Cost per Square Foot Parameters. Michigan Department of Treasury. www.michigan.gov/ documents/treasury/ Cost_per_SqFt_SBQLP_199474_7.pdf (accessed 30.Sep.09).

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