Memorandum December 2, 2019 L20002 TO: Chris Cummings, Assistant Director, Economic Development THRU: Melisa Drugge, Regional Development Manager FROM: Shanna Bailey, Regional Project Manager Rich Rodriguez, Finance Officer SUBJ: Funding Opportunity of $2,444,650 – Special Public Works Fund Program for Malheur County, Treasure Valley Reload Center Land Purchase, No. 944-13751 Please accept this memorandum for the Oregon Infrastructure Finance Authority (IFA) for funding assistance. Business Oregon’s (statutorily and by rule referred to as Oregon Business Development Department) staff administers the IFA. This memorandum will provide an application review, findings and analysis, and staff’s recommendation for requested action. There may also be post approval follow-up instructions for staff. BACKGROUND Applicant: Malheur County is southeast Oregon. The certified population for 2018 is 31,925. The County is considered both rural and distressed. Funding Request: Loan Project Type: ☐ Planning (technical) ☐ Design ☒ Construction SPWF Other Source: SPWF Project Background: House Bill (HB) 2017 which included $26 million in Connect Oregon Funding to be used to purchase land and construct a truck-to-rail reload facility in Malheur County passed in the 2017 legislative session. Malheur County as the lead agency, completed the site selection process and placed an option on a 290.35 acre parcel known as the Farmer Property, of which a 65 acre portion of the Farmer Property will be used to construct the reload facility and 148.413 acres of the Farmer Property will be used for industrial development opportunities associated with the reload facility. The L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 1 remaining 76.937 acres are zoned exclusive farm use (EFU). Funding for the EFU acres will be provided by Malheur County using county reserve funds. The purchase option includes two irrigated water rights; 51.1 acres of water rights from a supplemental ground well on the Farmer Property and legal title to 52 acres of water rights from the Snake River. The county also placed a purchase option on the 78.93 acre Nyssa Industries site south of the Farmer Property. The Nyssa Industries site will be used for additional industrial site development opportunities associated with the reload facility. The purchase options for both properties expire on December 31, 2019. Connect Oregon Funding for the reload site land purchase will not be available until early 2020. Malheur County is requesting funding to purchase the reload site and associated industrial land before purchase options expire on December 31, 2019. Upon receiving Connect Oregon Funding, Malheur County will pay down the Business Oregon loan by the full amount received from ODOT for the land purchase. ODOT has budgeted $700,000. Project Description: Purchase 213.413 industrially zoned acres of the Farmer Property (65 acre reload site and an additional 148.413 acres for associated development) and associated water rights. Purchase 78.93 acres of land zoned as light industrial (Nyssa Industries site) pending receiving an appraisal and additional collateral if necessary. Work Plan: The project is scheduled to be completed by February 2020; a description of each primary activity and anticipated dates are projected in the attached table. Public Involvement Statement: This project was discussed by the Malheur County Board of Commissioners at a public meeting held on October 1, 2019. FINDINGS AND ANALYSIS This project helps implement the following goals and objectives of providing funding to municipalities for publicly-owned facilities that support economic and community development in Oregon: - Special Public Works Fund: to provide financial or other assistance to enable municipalities to construct, improve and repair those facilities that are essential for supporting continuing and expanded economic activity (ORS 285.B.413 (2)) by increasing traded sector jobs Statewide planning goals #3 Agricultural lands; #9 economic development; #11 public facilities and services; and #12 transportation. - Department’s strategic plan priority: Cultivate Rural Economic Stability Program Findings & Compliance 1. Malheur County is an eligible applicant as defined in the ORS as a Municipality. 2. Project is not to achieve compliance. 3. Project priority is high. 4. Program suggestions: desktop or standard on-site monitoring procedure for the project. L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 2 5. This project is found to be compliant with applicable Department policies, Rules and Statutes. The application has been determined per current ORS to be eligible for funding. Funding Recommendation Budget Line Items IFA Source Land - Farmer Property $2,050,000 Land - Nyssa Industry Property (industrial zoned) Total Malheur County $969,900 Totals $3,019,900 $394,650 $2,444,650 $394,650 $969,900 $3,414,550 Proposed Work Plan Activity Date Land Appraisal Nov 2019 Preliminary Title Report Nov 2019 Purchase land and Water Rights Dec 2019 Project Close-out Feb 2020 Reload Facility Start-up July 2023 Source of Business Oregon Funds (Indicate Loan/Grant/Principal Forgiveness, Bond, Private or Public, and Taxable or Tax Exempt) Amount SPWF Loan, Public, Tax Exempt $2,444,650 Total $2,444,650 Source of Other Funds (For other State funds, indicate loan / grant, et cetera) Amount Malheur County $969,900 Total $969,900 Financial Findings & Compliance Repayment source The County is slated to establish a new budgetary Fund preliminarily identified as the “Reload Land Repayment Fund”. As such there is no historic data for this Fund for presentation. General Fund summary The following table shows a performance review of the Applicant’s General Fund for the last three audited fiscal years ending June 30, 2018 and fiscal year 2019 budget. L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 3 General Fund Malheur County audited 2016 3,951,034 audited 2017 4,503,780 audited 2018 5,333,566 budgeted 2019 6,439,064 4,583,721 2,834,958 7,418,679 11,717 4,564,596 4,576,313 11,994,992 4,991,125 2,887,338 7,878,463 23,767 4,955,731 4,979,498 12,857,961 5,481,221 2,762,904 8,244,125 55,906 4,999,533 5,055,439 13,299,564 4,912,614 2,018,927 6,931,541 25,000 5,566,260 5,591,260 12,522,802 9,543,189 9,704,343 9,839,885 2,622,633 2,772,550 2,852,684 12,165,822 12,476,893 12,692,569 (4,747,143) (4,598,430) (4,448,444) 61,044 280,225 294,495 0 28,460 19,262 12,226,866 12,785,578 13,006,326 (231,874) 72,383 293,238 784,620 757,403 812,260 4,503,780 5,333,566 6,439,064 9,473,066 3,397,756 12,870,822 (5,939,281) 324,325 11,234 13,206,381 (683,579) 305,000 6,060,485 Performance Review FY Ending June 30th Beginning Fund Balance Revenues Property Taxes Other Operating Revenues Operating Revenues Interest and Miscellaneous Other Non-Operating Revenues Total Non-Operating Revenues Total Revenues Expenditures Personal Services Materials & Services Total Operating Expenses Net Operating Income Capital Outlay Debt Service Total Expenses Net Revenues Net Transfers/Adjustments Ending Fund Balance current FY The General Fund ending balance has remained strong over the reviewed period. The 2018 ratio of ending fund balance to total expenditures was 50%. This well exceeds the greater than 3% underwriting criteria for this metric. This level of General Fund unrestricted fund balance is suggestive of prudent fiscal management by the County. Debt service analysis Net Revenues for Debt Coverage: The following table reflects the Projected Net Revenues available to the Applicant’s Reload Land Repayment Fund as provided with the Applicant’s application and related supplemental information. L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 4 Summary of Revenues, Expenditures, and Debt Service Coverage Reload Land Repayment Fund PRO FORMA Year (ending June 30th) Beginning Fund Balance Operating Revenues Reload operating revenue Lease reload lands revenue Leased adjacent lands revenue Operating transfers in - General Fund Total Operating Revenues Operating Expenses Personal Services Materials & Services Other Operating Expenses Total Operating Expenses Debt Service Funds Avail for Debt Coverage Existing Loan 1 Existing Loan 2 Other Proposed Loan IFA Proposed Loan Total Debt Service Debt Service Coverage Ratio Other Activities Cash Avail After Debt Service Loan Proceeds / Drawdowns Capital Outlay (OUT) Other Non-Operating Activity Net Other Activity Net Transfers IN (OUT) Adjustments Net Transfers & Adjustments Ending Fund Balance Current FY 2020 0 0 0 0 0 2025 1,477,567 0 0 0 0 0 0 0 0 62,200 62,200 0 0 0 55,800 55,800 0 0 0 55,800 55,800 1,064,657 750,000 390,000 0 2,204,657 1,703,451 750,000 390,000 0 2,843,451 0 0 0 0 0 0 0 0 294,390 267,500 382,707 180,750 0 0 0 0 0 0 0 0 28,800 590,690 28,800 592,257 0 0 0 0 0 0 62,200 0 0 0 62,200 62,200 1.00 55,800 0 0 0 55,800 55,800 1.00 55,800 0 0 0 55,800 55,800 1.00 1,613,967 0 0 0 136,400 136,400 11.83 2,251,194 0 0 0 136,400 136,400 16.50 0 0 0 0 0 0 0 0 0 0 2,444,650 (2,444,650) 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1,477,567 0 0 0 0 0 0 0 1,477,567 2,114,794 0 0 0 0 0 0 0 3,592,361 12.33 2021 Projected 2023 2022 2024  The Reload Land Repayment Fund will, initially, be supported with operational transfers in from the County’s General Fund.  In FY 2020 the County anticipates receiving Connect Oregon funding from the Oregon Department of Transportation (ODOT) covering the portion of land the Reload Facility will be situated upon (this is totally within the Farmer property). ODOT has budgeted $700,000. Full payment will be directed to the outstanding loan principal, and accounts for reduced interest payments in FY 2022  Finally, note the operating activities shown starting in 2024 are actually derived by the Malheur County Development Corporation (MCDC) but are shown here for presentation purposes to demonstrate how funds available for debt service are derived. MCDC will be contractually required to provide funds for debt service to the County. L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 5 Estimated Beginning Date 12/31/2019 12/31/2020 12/31/2021 Construction Phase Interest Estimate Malheur County- Treasure Valley Reload Center Land Estimated Estimated Loan Principal Annual Accrual Ending Date Amount Interest Rate Period* 12/31/2020 $2,215,200 2.81% 12 12/31/2021 $1,985,750 2.81% 12 12/31/2022 $1,985,750 2.81% 12 Estimate Accrued Interest** $62,200 $55,800 $55,800 * Number of Months. Based on a 30 day month, 360 day year. Actual accrual period depends on the dates funds are disbursed. ** The actual amount of accrued interest due will be based on the dates and amounts of Once the reload facility is functional, operating, and generating cash flow as a business enterprise, net operating revenue from reload operations and related revenue are forecasted to provide sufficient funds to provide the required 1.20x service debt service. Repayment is additionally bolstered by two land lease revenue streams; (a) from the leasing of property on the 65 acres of Reload property and (b) from the leasing of associated industrial lands. Stress testing analysis Revenues are generated by three different identified sources as noted prior; reload operations directly, leasing activities that occur directly on reload property, and leased industrial lands adjacent to the reload property. In the event the leasing opportunities fail to occur, then reload operations alone are anticipated to generate debt service coverage ratio of no less than 3.22x. Existing obligations and risks The following table reflects the applicant’s debt service requirements as of their last audit. Loan Source Net Direct Debt Gravel Pit Loan Goodfellows Bldg Lease Net Direct Debt Self-Supporting Debt Self-Supporting Debt Gross Bonded Debt Summary of Outstanding Debt Obligations Malheur County June 30, 2018 Annual Debt Payment Source Balance Service $52,406 $140,326 $192,732 $11,233 $19,262 $30,495 $0 $192,732 $0 $30,495 Road Fund General Fund FF&C Pledged Debt Priority Maturity Yes Yes Parity Parity 2031 2025 The County has a de minimis amount of debt, the longest maturity is 2031, or about ten years. L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 6 Underwriting standards The applicant meets 12 of the 15 applicable indicators in the attached Financial Summary. The following indicators are not met:    Top 10 Taxpayers as % of Total Tax Collections [21% is not <15% standard] Unemployment Rate as Percentage of State Avg. (mry) [113% is not <110% standard] Per Capita Income as Percentage of State Avg.(mry) [63% is not >85% standard] The Top Ten taxpayers in the County are presented below. The majority of these taxpayers are long-term stable entities. Top Ten Taxpayers Top Ten Taxpayers Idaho Power Co Kraft Heinz Food USG Oregon, LLC Fry Foods, Inc Century Link Union Pacific Railroad Wal-Mart Real Estate Americold Realty, Inc EP Minerals, LLC Pacificorp Total Amount 2018 $ 330,606 $ 252,119 $ 291,359 $ 62,173 $ 45,924 $ 38,607 $ 33,403 $ 30,387 $ 41,307 $ 35,857 $ 1,161,742 Applicant’s bond rating The County does not have debt rated by a public ratings agency (e.g. Moody’s, Standard and Poor’s, etc.) Financial statement of program SPWF as of October 13, 2019: 1. Available funds $49,333,592 2. Remaining balance, if the project is approved, is $46,888,942 3. All existing Business Oregon loans paid as agreed COLLATERAL AND VALUE Although liquidation (sale) of the property is not the primary source of repayment as proposed by the Recipient, it is prudent to look at the coverage the collateral provides as that could be viewed as the primary source of repayment before the development project is completed and financially viable. L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 7 An appraisal dated October 31, 2019 was received by Business Oregon that valued the Farmer Property 290.35 acres of land and water rights at $2,050,000 which is the same amount of funding being provided by Business Oregon for this land purchase. Because Business Oregon will maintain collateral rights on the entire 290.35 acres and its associated water rights, the Farmer Property loan will be fully collateralized with a LTV of 100%. An appraisal for the Nyssa Industrial property has not, yet, been received. A condition of the award is an appraisal that that provides 100% loan to value which may include additional collateral, if required. FINANCIAL RECOMMENDATION The proposed loan will be structured in two phases. The first phase (Construction Phase), will consist of interest only payments and will accrue interest on actual funds disbursed, estimated first disbursement will be on December 16, 2019. All accrued interest during the construction phase (estimated to be $173,800) will be due in annual payments prior to the first principal and interest payment. The interest rate will be set at 2.81% for this phase. Construction is scheduled for completion by June 2023. The second phase (Repayment Phase) will begin with constant annual payments of principal and interest sufficient to repay the outstanding principal balance, together with interest, within a 22 year period. The estimated first principal and interest payment due date is December 1, 2023. The loan can be prepaid in part or in full without penalty. The interest rate will be set at 2.81% for the repayment phase. The “Repayment Phase Loan Summary” table summarizes the repayment phase of the proposed financing. Type SPWF Repayment Phase Loan Summary Malheur County ODOT Loan Award Interest Monies in Principal Amount Rate 1st Year Amount $2,444,650 $458,900 $1,985,750 2.81% Amortized (in years) 22 Est. Annual Payment* $136,400 * Actual payment will likely be different. Payment rounded to nearest $100. Construction Period Interest is expected to be paid prior to or with the 1st scheduled P&I payment date. The proposed loan is for a 25 year period, the first three years being interest only as noted prior. Funding Recommendation and Conditions of Award Conditions: Based upon the prior analysis, the award recommended above should be subject to the following conditions: L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 8 A. Full Faith and Credit Pledge. The Recipient will be required to pledge its full faith and credit and taxing power within the limitations of Article XI, Sections 11 and 11 b, of the Oregon Constitution to pay the amounts due under the Financing Contract. The Financing Contract shall be payable from all legally available funds of the Recipient. B. Operating Agreement. The Recipient will be required to establish a legal operating agreement with the Malheur County Development Corporation with a 25-year duration. The operating agreement shall bind the Corporation to yearly deliver to the Recipient cash monies from the Corporation in sufficient amounts to fully fund the annual debt service of this proposed loan. Recipient shall provide a copy of operating agreement satisfactory to Business Oregon before any loan funds are disbursed. C. Additional Award. The recipient shall receive ODOT funding for real property acquisition. Recipient shall provide copy of award letter as evidence of award. ODOT is requiring monthly project status reports. Recipient shall submit a copy of the reports to Business Oregon. Further, the Recipient agrees to apply funds from the ODOT award by October 31st 2020 to pay down the outstanding principal of this proposed loan. ODOT has budgeted $700,000. (Note that the property to be paid by ODOT is a subset of and totally within the Farmer Property, further identified below.) D. Future Land Sales. The Recipient may wish to sell parcels of the industrial lands from time to time. Prior to doing so, the Recipient is required to (a) receive written concurrence from Business Oregon for such sale, and (b) proceeds from any land sale must solely be used to pay down the principal of this loan. E. Mortgage, Assignment of Rents, and Security Agreement. (Farmer Reload Property) The Recipient shall provide a security interest in the entire Farmer Property approximately 290.35 acres of real property located at (Identified in yellow, on page 1 of the attached property site description). The lien must be a First lien position. The lien must be secured by a mortgage, assignment of rents, and security agreement document recorded in Malheur County and shall be with a Standard Title Policy, with Oregon Infrastructure Finance Authority (IFA) as the insured. The lien shall include proportional water rights from a supplemental ground well (permit no. G-16990 with Oregon Water Resources Department) on the Farmer Property and legal title to 52 acres of water rights from the Snake River (being a portion of water rights evidenced by State Record of Water Right Certificate 45954) Note: Prior to funds disbursement, IFA must receive and accept a Preliminary Title Policy which will include a map, legal description of property to be used as collateral and existing encumbrances to insure proper lien position. F. Mortgage, Assignment of Rents, and Security Agreement. (Nyssa Industries Property) The Recipient shall provide a security interest in approximately 78.93 acres of real property (Identified on pages 3 and 4 of the attached property site description). The lien must be a First lien position. The lien must be secured by a mortgage, assignment of rents, L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 9 and security agreement document recorded in Malheur County and shall be with a Standard Title Policy, with Oregon Infrastructure Finance Authority (IFA) as the insured. Note: Prior to funds disbursement, IFA must receive and accept a Preliminary Title Policy which will include a map, legal description of property to be used as collateral and existing encumbrances to insure proper lien position. An appraisal suitable to Business Oregon must also be provided prior to funding and based on the appraised amount of property, Business Oregon may ask for additional collateral or reduce award amount. Instructions: The two subject land transactions must close through escrow. These loan funds will be disbursed into escrow. List of Attachments 1. Financial Summary 2. Property Site description L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 10 Budget recommends that this award come from: Program Funds Date: 2019.12.02 14:44:19 -08'00' David Barnett Senior Finance Accountant (Budget) APPROVAL: We respectfully request your approval on the subject application (for projects not going to board). ✔ Approve project and recommendation as submitted Approve project and recommendation with the following modifications: signed by Chris Cummings Chris Cummings Digitally Date: 2019.12.02 18:27:07 -08'00' Chris Cummings, Assistant Director Economic Development L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 11 ATTACHMENT Malheur County FINANCIAL SUMMARY Municipal Financial Position 2017 2018 2019 Property Tax Collections Borrower's Property Tax Rate per $1,000 Consolidated Rate per $1,000 A.V. Non-school Rate per $1,000 A.V. Municipal Levy Current Collection Rate Total Collection Rate $2.58 $14.95 $8.40 $4,608,666 84.38% 98.43% $2.58 $14.88 $8.40 $5,077,695 94.35% 97.94% $2.58 $17.66 $11.15 $5,578,096 94.42% 99.61% $ $ $ $ 2.58 15.83 9.32 5,088,152 91.05% 98.66% 6,439,064 13,006,326 49.51% 13,299,564 1,001,806 7.53% $ $ 5,425,470 12,672,923 42.69% 12,717,506 854,033 6.68% General Fund Unreserved Ending Fund Balance Expenditures Fund Balance/Expenditures Total Revenues Intergovernmental Revenues Percentage Intergovernmental $ $ (Grants) Municipal Debt Position Gross Bonded Debt* Net Direct Debt Overlapping Debt Net Direct Debt/Assessed Value (mry) Net Direct & Overlapping Debt/A.V. (mry) Net Direct Debt Per Capita Net Direct Debt Service (mry) Percent of Debt Retired in 10 yrs. Net Direct Debt Service/Expenditures Net Direct Debt Service/Revenues Reload Land RepaymFinancial Position Number of Connections (mry) Self-Supporting Debt Outstanding * Self-Supporting Debt Per Capita Operating Revenues Gross Revenues (operating + non-oper.) Total Operating Expenses Annual Debt Service Debt Service Coverage Ratio Operating Ratio Ending Fund Balance Top 10 Ratepayers as % of Revenues Accounts Receiveable $ $ $ $ $ $ $ $ $ 302,213 $ 302,213 $ - $ 5,333,566 12,785,578 41.72% 12,857,961 912,230 7.09% $ $ $ $ 279,324 $ 279,324 $ - $ $ $ 2017 N/a $ $ $ $ $ $ 2018 N/a - $ $ - $ - $ - $ - $ N/a N/a - $ N/a N/a 2010 Population 2020 Malheur County Assessed Value FY 2020 Assessed Value Per Capita Top 10 Tax Payers as % of Total Tax Collections Top 10 Tax Payers as a % of Assessed Value 2020 2019 N/a Average - - N/a N/a N/a N/a N/a N/a N/a N/a Most Recent Annual Year* Growth Rate 31,313 31,925 $1,562,201,938 $2,162,052,713 $ 49,890 $ 67,723 0.00% 20.91% 0.00% 0.05% Most Recent Year* $ 30,231 L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase $ $ 248,599 192,732 0.01% 0.01% 6.04 30,495 87.45% 0.23% 0.23% - $ $ - $ - $ - $ - $ N/a N/a - $ - $ General Economic and Demographic Data County Per Capita Income 4,503,780 12,226,866 36.84% 11,994,992 648,063 5.40% Average 0.19% 3.30% Page 12 State Per Capita Income County PCI as Percentage of State PCI County Unemployment rate State Unemployment rate County Rate as Percentage of State Rate 2020 $ 2020 2020 48,137 62.80% 4.50% 4.00% 112.50% *MRY - Most Recent Year for which data is available ITEM MUNICIPAL FINANCIAL POSITION Malheur County FINANCIAL INDICATORS SUBJECT Total Tax Collection Rate (3 yr. Avg.) Current Tax Collection Rate (3 yr. Avg.) General Fund Balance as % of Expenses (mry) External Revenues as % of Total Revenues (3 yr. Avg.) STANDARD SCORE* >95% >87% >3% <20% 1 1 1 1 0.23% 0.23% 87.45% 0.01% <1,000 <20% <5% >60% <2% 1 1 1 1 1 N/a N/a N/a N/a N/a >1,500 <$650 >1.20 <15% <15% N/a N/a N/a N/a N/a >$20,000 >3% >0% <15% <110% >85% 1 1 1 0 0 0 98.66% 91.05% 42.69% 6.68% MUNICIPAL DEBT POSITION Net Direct Debt Per Capita (mry) Net Direct Debt Service to General Fund Expenses (mry) Net Direct Debt Service to General Fund Revenues (mry) Percentage of Debt Retired in 10 Yrs. Net Direct Debt to Assessed Value (mry) 6 RELOAD LAND REPAYMENT FUND FINANCIAL POSITION Number of Connections (mry) Revenue Debt Per Capita (mry) Debt Service Coverage Ratio (mry) Accounts Receivable (3 yr. avg.) Top 10 Ratepayers as % of Revenues (3 yr. avg.) MUNICIPAL ECONOMIC/DEMOGRAPHIC POSITION Assessed Value Per Capita (mry) Assessed Value Annual Growth Rate since 2010 Population Growth Rate - since 2010 Top 10 Taxpayers as % of Total Tax Collections Unemployment Rate as Percentage of State Avg. (mry) Per Capita Income as Percentage of State Avg.(mry) * Score: 1 = meets, 0 = fails, N/a = not applicable 67,723 3.30% 0.19% 20.91% 112.50% 62.80% EVALUATION OF INDICATORS: The Department will make an Ore. Bond Bank loan to a local government that fails to meet five or fewer of the applicable minimum thresholds and a direct loan (including SDWRLF) to a government that fails to meet more than five but fewer than ten. The Department will not finance a local government that fails to meet the majority of the applicable minimum thresholds. A possible exception to this rule is where the project in large part will cure weak performanceas evidenced by the thresholds. NUMBER OF APPLICABLE THRESHOLDS FAILED BY THIS LOCAL GOVERNMENT = TOTAL NUMBER OF APPLICABLE THRESHOLDS = L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase 3 15 Page 13 L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 14 L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 15 L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 16 L20002 / 944-13751 Malheur County Treasure Valley Reload Center Land Purchase Page 17