DATA AND ANALYSIS OF CONDITIONS REPRESENTING A BLIGHTED AREA

FOR THE

HADLEY TOWNSHIP SOUTH REDEVELOPMENT AREA

FEBRUARY 26, 2013

DATA AND ANALYSIS OF CONDITIONS REPRESENTING A BLIGHTED AREA

FOR THE

HADLEY TOWNSHIP SOUTH REDEVELOPMENT AREA

February 26, 2013

February 26, 2013 To Whom It May Concern: Reference is made to the accompanying Data and Analysis of Conditions Representing a Blighted Area for the Hadley Township South Redevelopment Area in Richmond Heights, Missouri prepared by the undersigned. Please be advised that, based upon the results of the above referenced study, the undersigned has determined that the area described in the study (the Redevelopment Area) is a blighted area as such term is defined in Section 353.020(2) of the Missouri Revised Statutes, as amended, and a preponderance of the Redevelopment Area is blighted under Section 523.274.1 of the Missouri Revised Statutes, as amended. The Redevelopment Area suffers from a multitude of physical, social, and economic deficiencies including age, obsolescence, inadequate or outmoded design or physical deterioration, creating economic and social liabilities, and these conditions are conducive to ill health, transmission of disease, crime or the inability to pay reasonable taxes. This report describes and documents those conditions that, without the incentives available under Chapter 353, will further erode the Redevelopment Areas viability and continue its economic and social liability for the City of Richmond Heights, its residents, and the other taxing districts that depend upon it as a revenue source.

DEVELOPMENT STRATEGIES, INC. Real Estate, Community and Economic Development Consultants by:

Larry Marks, AIA, AICP Principal

TABLE OF CONTENTS 1.0

INTRODUCTION ........................................................................................................ 1 Study Area .............................................................................................................. 1 Overview of Previous Redevelopment Efforts ...................................................... 2 Historical Development ......................................................................................... 4 Existing Development ............................................................................................ 5 Existing Zoning ....................................................................................................... 7 Neighboring Development ..................................................................................... 8 Data Gathering Methodology ................................................................................ 9

2.0

SUMMARY AND CONCLUSIONS ............................................................................. 10 Summary ............................................................................................................. 10 Finding of Blight .................................................................................................. 13

3.0

BLIGHTING FACTORS ............................................................................................. 14 Age of Buildings ................................................................................................... Obsolescence ...................................................................................................... Inadequate or Outmoded Design ....................................................................... Physical Deterioration ......................................................................................... Economic Liability ............................................................................................... Social Liability ...................................................................................................... Crime .................................................................................................................... Inability to Pay Reasonable Taxes ..................................................................... 15 17 17 21 26 27 28 29

APPENDICES A. Legal Description of Hadley Township South Redevelopment Area B. Parcel Numbers Map and Parcel Information C. Photographs of Blighting Conditions EXHIBITS 1. Redevelopment Area Aerial ................................................................................... 1 2. Existing Land Use ................................................................................................... 6 3. Existing Zoning ....................................................................................................... 7 4. Neighborhood Development Aerial ....................................................................... 8 5. Blighting Conditions ............................................................................................ 14 6. Date of Construction of Buildings ...................................................................... 16 7. Obsolescence and Outmoded Design Factors .................................................. 18 8. Condition of Structures ....................................................................................... 23 9. Rights-of-Way Conditions .................................................................................... 26 10. Parcel Identification Map .....................................................................APPENDIX B

1.0

INTRODUCTION

STUDY AREA Development Strategies was tasked with a study of the Hadley Township South Redevelopment Area (the Redevelopment Area or Area), which encompasses approximately 17.2 acres, excluding rights-of-way, in the City of Richmond Heights (the City). The Area extends generally from Elinor Avenue on the north, to Berkley Avenue and Hampton Creek on the east, to West Bruno Avenue on the south, to Hanley Road on the west (see Aerial of Redevelopment Area). The Redevelopment Area contains a total of 103 parcels of property.

Hadley Township South Redevelopment Area Blight Analysis

OVERVIEW OF PREVIOUS REDEVELOPMENT EFFORTS Over the last 24 years, the Hadley Township South Redevelopment Area has attracted various speculators, fostered in large part by the increasing traffic on Hanley Road, the proximity to I-64, the success of neighboring redevelopment efforts, and the obsolescence of the existing uses in the Area. Today, approximately 28 percent of the properties are owned by speculators and investment owners. Summarized below are the events that have led up to the current interest in redevelopment of the Area: 1999-2002 Multiple land speculators and developers made contact with property owners wanting to purchase their property. May thru July 2002 Several residents living in the neighborhood expressed concern about developer activity. November 2002 City hired Woolpert LLC, a professional planning firm to assess the neighborhood. August 2003 A petition was submitted by the Hadley Township Homeowners Association asking the City Council to issue a Request for Proposals (RFP) for in-fill housing as outlined in the Woolpert Study. September 2003 At a special City Council workshop meeting, the City Council requested staff to develop a Request for Proposal that substantially followed the request made by the Hadley Township Homeowners Association. THF submitted a plan to redevelop the entire area, proposing a detailed mixed-use development. The City Council refused THFs proposal. City Council directed staff to develop a second RFP to entice developers to do residential in-fill housing with no commercial development.

March 2004 An RFP was published seeking proposals for in-fill single-family housing. March 2004 Kinder Construction Inc. submited a proposal in response to the RFP. June 2004 Kinder Construction Inc. rescinded its proposal. August 2004 The City Council held a special workshop to hear from the residents of the Hadley Township neighborhood. September 2004 The City Council voted to prepare a comprehensive RFP on the Hadley Township neighborhood. February thru May 2005 The City Council held visioning sessions to work on the preparation of the new RFP.
Hadley Township South Redevelopment Area Blight Analysis 2

June 2005 The Citys Hadley Township Redevelopment Area RFP was released. To further encourage developers to pick up the RFP, a letter outlining the proposal was sent to over 80 developers and home builders along with a copy of the advertisement. September 2005 The City received five (5) proposals: Conrad Properties Corporation, Wolfe Properties, L.L.C. and Forest City Ratner Enterprises; Michelson Commercial Realty & Development, LLC and Heine & Croghan Architects, Inc. (collectively, Michelson); Mills Properties, Inc.; THF Realty, Inc., The Jones Company, Fischer & Frichtel and Mayer Homes, affiliated as the Bricktown Development Company; and QuikTrip.

December 2005 Public presentation of the proposals and City Council interviews were held. January 2006 A Public Open House allowed residents the opportunity to review each proposal and ask questions of each development team. Residents were asked to complete a questionnaire, giving the City feedback based on resident review of the three plans. February 2006 The City Council selected the Michelson proposal. March thru May 2006 - TIF Commission meeting was held. June 7 and June 14, 2006 - TIF Commission Public Hearing was held. July 12, 2006 - (Bill No. 5126 approved) - Designated a portion of the City as a Redevelopment Area and finding that such area was a blighted area under the Real Property Tax Increment Allocation Redevelopment Act; approved the Redevelopment Plan for the Hadley Township Redevelopment Area; and approved a Redevelopment Project for Redevelopment Project Area 1. October 16, 2006 - (Bill No. 5143 approved) - Authorized the execution of a Redevelopment Agreement with Michelson. October 15, 2008 The City met with affected residents and property owners to request their feedback regarding Michelsons failure to acquire property as required in the Redevelopment Agreement. January 2009 Michelson advised the City that it is unable to move forward with project. February 27, 2009 The City sent out a new Hadley Township Redevelopment Area Request For Proposals (RFP). May 29, 2009 The City received one proposal from Gateway Real Estate Partners titled United Plaza at the Heights. The developer and City agreed that the developer must secure project financing before formal discussions could begin. February 16, 2010 The City signed a preliminary funding agreement with United Plaza, LLC.
Hadley Township South Redevelopment Area Blight Analysis 3

March 15, 2010 The City terminated the Michelson Redevelopment Agreement and selected United Plaza, LLC as the preferred developer. The City Council authorized City Staff to begin negotiating a new Redevelopment Agreement. November 30, 2010 The City terminated its relationship with United Plaza, LLC. February 8, 2011 The City met with multiple developers, planners, and economic development agencies. There was no interest by developers in the Area as it was defined. City Staff recommended amending the Redevelopment Plan and reducing the Redevelopment Area. September 6, 2011 The City Council amended the Redevelopment Plan and Area. January 9, 2012 The City issued a new Request For Proposals (RFP) for the amended Redevelopment Area. February 23, 2012 Three proposals were submitted for City consideration. Both Menards and Costco submitted proposal for the southern Hadley Area. Pace Properties submitted a proposal for northern Hadley area, south of Dale Avenue. April 2, 2012 The City selected Menards and Pace Properties as preferred developers for the Hadley Township Redevelopment Area. September 14, 2012 Pace withdrew its proposal for development of the Hadley Township Redevelopment Area. Menards continued its project. December 3, 2012 Menards and the City executed a Preliminary Funding Agreement to begin formal negotiations for the Menards Hadley project.

HISTORICAL DEVELOPMENT The Redevelopment Area occupies a portion of the City once known as the Rannells Home Farm, a large family-owned farm dating to the post-Civil War era. In the early twentieth century, the Evans-Howard Fire Brick Company established a refractory at the southwest corner of Hanley and Eager Roads. The brickyard labor force established the semi-rural character of the neighborhood that was to persist until after World War II. A segregated (Old) Lincoln Elementary School was opened to students in 1911 to serve the residents of the neighborhood. It was replaced in 1932. The latter structure still exists as a portion of the Richmond Terrace retirement community just east of the Area. The City was incorporated in 1913 and Hadley Township was annexed in 1918. The Lincoln Terrace subdivision was platted in 1925 and home construction commenced along Banneker and Stockard Avenues. Elinor Place was platted in 1928, but developed slowly, due in large part to the absence of convenient streetcar transit into the City of St. Louis and the onset of the Great Depression.
Hadley Township South Redevelopment Area Blight Analysis 4

Following World War II, enhanced automobile access provided a boost to home construction, filling in the established subdivisions and the vacant land. Highway 40 (the Daniel Boone Expressway) was completed north of the Redevelopment Area in the late 1950s (after a rebuilding completed in 2009, the highway now has an average daily traffic count of over 173,000 vehicles). The highway fostered new commercial development along Hanley Road. As commercial development began to encroach on the existing residential neighborhood, it impacted the Redevelopment Area and helped to establish its current character. THE HEIGHTS, a 73,000 square foot Community Center and Memorial Library north of the Area on Dale Avenue, opened in 2001. EXISTING DEVELOPMENT The Redevelopment Area contains approximately 17.2 acres, excluding rights-of-way. Nearly 48% of the Area contains vacant land or land that is occupied by vacant buildings (see Existing Land Use map). Single family residential represents the primary active use in the Area. Residential uses represent roughly 64% of the land in the Area. The balance of the Area is comprised of a variety of uses including office commercial (10%) and institutional/government (9%). EXISTING LAND USE IN THE HADLEY TOWNSHIP SOUTH REDEVELOPMENT AREA
USE Single Family Three-Family Residential Subtotal OCCUPIED SQ. FT. 277,948 0 277,948 % OF TOTAL 37% 0% 37% VACANT SQ. FT. 170,656 30,800 201,456 % OF TOTAL 23% 4% 27% TOTAL SQ. FT. 448,604 30,800 479,404 % OF TOTAL 60% 4% 64%

Institutional/Government

69,840

9%

0%

69,840

9%

Vacant Land

0%

129,439

17%

129,439

17%

Commercial Office

46,568

6%

25,815

4%

72,383

10%

TOTAL

394,356

52%

356,710

48%

751,066

100%

Source: St. Louis County and Development Strategies Hadley Township South Redevelopment Area Blight Analysis 5

Commercial office and institutional development is primarily concentrated along Hanley Road. The balance of the Redevelopment Area contains residential development and vacant land. Within the Redevelopment Area, there are a total of 74 single family residences and two threefamily buildings. The recent field survey of the Redevelopment Area found 30 of the single family residences and both of the three-family buildings to be vacant. There is a total of 46,568 square feet of land occupied by office commercial space in the Area.

Hadley Township South Redevelopment Area Blight Analysis

EXISTING ZONING As part of the ongoing efforts to redevelop the Redevelopment Area, all of the property was zoned PDM Planned Development Mixed Use in 2008.

Hadley Township South Redevelopment Area Blight Analysis

NEIGHBORING DEVELOPMENT The Redevelopment Area is surrounded by a variety of uses. To the north is THE HEIGHTS complex and residential neighborhoods that lie within the City of Richmond Heights. Residential neighborhoods are also located to the east. To the south is the 450,000 square foot Maplewood Commons Shopping Center, which includes a number of big box stores and inline shops, as well as restaurants. To the west is a mix of commercial and residential developments, including the residential and retail Hanley Station development and the Home Depot in the City of Brentwood.

Hadley Township South Redevelopment Area Blight Analysis

DATA GATHERING METHODOLOGY This study of the Redevelopment Area has been conducted and complies with the specific requirements of Sections 353.020 and 523.274.1, RSMo, as amended (see Appendix B for map parcels and locator numbers in the Redevelopment Area). Fieldwork was performed during February 2013. Each parcel and building was inspected from the exterior and rated by Development Strategies personnel experienced in such evaluations. The occupancy of all buildings and land was also catalogued. In addition, a visual inspection was made of the condition of all streets, curbs, and sidewalks in the Redevelopment Area. Real estate tax assessments for 2007 and 2012 were obtained from records of the St. Louis County Assessors Office. This allowed aggregate tax assessments to be calculated for the Redevelopment Area and comparisons to be made where appropriate. Appendix B contains each parcels tax assessment along with a compilation of factors describing relevant conditions and related data. In addition, data regarding ownership, parcel size, building square feet, number of residential units, date of construction, and existing zoning were obtained from real estate information available from St. Louis County. The City provided additional information regarding crime statistics, traffic accidents, and taxes.

Hadley Township South Redevelopment Area Blight Analysis

2.0

SUMMARY AND CONCLUSIONS

SUMMARY This document undertakes, first, to identify those particular factors that might constitute and contribute to an overall, area-wide blighted condition and then, second, to make an objective determination whether or not those factors in aggregate justify a finding that the Redevelopment Area is blighted under the provisions of the Urban Redevelopment Corporations Law, Chapter 353, RSMo, as amended (Chapter 353), and Section 523.274.1 RSMo. Section 353.020(2) of Chapter 353 defines a blighted area as, that the portions of the City for which the legislative authority of that City shall determine that, by reason of age, obsolescence, inadequate or outmoded design or physical deterioration, have become economic and social liabilities, and that such conditions are conducive to ill health, transmission of disease, crime or inability to pay reasonable taxes. The Redevelopment Area has already been found to be blighted in July 2006 (Ordinance 4991) under Section 99.805(1), RSMo, as amended and in May 2010 (Ordinance 5240) under Section 353.020(2). Despite the former eligibility of these portions of the Redevelopment Area for application of state-enabled redevelopment powers, conditions persist in the Area that contribute to blight. The earlier intended and needed levels of reinvestment in new construction and rehabilitation did not occur and the Area continues to manifest an array of blighted conditions. Based on the research conducted by Development Strategies staff and information obtained from various records of St. Louis County and the City, the Redevelopment Area is clearly blighted by reason of age, obsolescence, inadequate or outmoded design or physical deterioration, has become an economic and social liability, and such conditions are conducive to ill health, transmission of disease, crime or inability to pay reasonable taxes. A preponderance of the Redevelopment Area is blighted per Section 523.274.1. Key factors in reaching this determination of blight are summarized and described in greater detail in the following sections of this report. Age of Existing Buildings The stock of buildings in the Redevelopment Area is aging, particularly the residential structures, which comprise over 90% of all buildings. Nearly 76% of the buildings in the Area were constructed prior to 1963, making them at least 50 years old, and 81% were constructed more than 35 years ago, which is generally used as a criteria for identifying older buildings that are likely to experience electrical and mechanical problems, as well as a tendency for gradual overall deterioration, unless they are very well maintained and updated regularly. This is clearly the case in the Area.
Hadley Township South Redevelopment Area Blight Analysis

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Obsolescence Development in the majority of the Redevelopment Area was determined to be obsolete because: Nearly 48% of all parcels in the Area are either vacant (primarily due to demolitions of dilapidated buildings) or contain vacant buildings, and are therefore no longer supporting viable development. 56% of the parcels do not meet contemporary standards for their current residential or commercial use or zoning. Obsolete infrastructure does not support modern residential or commercial development. Inadequate or Outmoded Design Much of the existing public infrastructure and private development in the Redevelopment Area is inadequate or outmoded as represented by: The functionally outmoded and inadequate street system which inhibits needed modern redevelopment, internal circulation, and is frequented by streets that dead-end without adequate space for cars or emergency vehicles to turn around. An outmoded and inadequate pattern of aging and limited commercial development along the increasingly important Hanley Road commercial corridor. Missing or inadequate sidewalks that inhibit pedestrian circulation, particularly for disabled individuals, and are not in compliance with the Americans with Disabilities Act. Lack of storm sewers for portions of the Redevelopment Area. Based on site visits to the Area by staff of Development Strategies, two Area streets are not equipped with sewers to accommodate storm water runoff Booker Place and the western portion of Elinor Avenue. Inadequate building foundations, given the potential for subsidence resulting from former clay mining operations in the Redevelopment Area. Although Hampton Creek was channelized, two Area properties are at least partially within the 100-year floodplain of the creek.

Physical Deterioration As identified by the field study conducted by Development Strategies, there is physical deterioration throughout the Redevelopment Area as illustrated by: The large number of buildings that are classified as being in poor condition (52%) or fair condition (32%). Over three-quarters of the streets are classified as being in either poor condition (28%) or fair condition (58%). Where sidewalks are provided in the Redevelopment Area, the majority are classified as being in either poor condition (8%) or fair condition (86%).
Hadley Township South Redevelopment Area Blight Analysis 11

The site conditions (private sidewalks, parking areas, fencing, landscaped areas, etc.) of the vast majority of the parcels are classified as being in poor condition (54%) or fair condition (45%).

Economic Liability As a result of the previously mentioned blighting factors, the Redevelopment Area is an economic liability as reflected by: The underutilization of the Redevelopment Area given its prime location near the Hanley Road and I-64 interchange. The existing vacancy in the Redevelopment Area, which inhibits new investment and creates a burden on the City. The significant number of delinquent taxes for properties in the Redevelopment Area. Social Liability The blighting factors also create a social liability due to: The drain on existing city resources and the inability to generate financial resources for city services. The ongoing decline in residential units and owner occupancy. Hazardous conditions resulting from dead-end streets without adequate turning space for emergency vehicles. Crime The aforementioned blighting conditions have created an environment that is conducive to promoting crime as indicated from City police records for 2009 through 2012 that generally reflect a higher rate of crime in the Redevelopment Area as opposed to the City as a whole. Inability to Pay Reasonable Taxes The Redevelopment Area has failed to attract new investment and sufficient reinvestment in existing buildings and infrastructure, and the existing development is outdated and obsolete. As a result, the City has not been able to capitalize on the Areas location along the I-64 commercial corridor to generate needed taxes to provide city services to residents. In addition, over 29% of the taxable properties in the Redevelopment Area are currently delinquent in paying real estate taxes.

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FINDING OF BLIGHT As summarized above and discussed in detail in the balance of this report, the data overwhelmingly demonstrates that conditions in the Redevelopment Area are above the established threshold standards for blight under Chapter 353 and that a preponderance of the Redevelopment Area is blighted per Section 523.274.1, RSMo. The data supports a finding that the Redevelopment Area is blighted by reason of age, obsolescence, inadequate or outmoded design or physical deterioration, has become an economic and social liability, and that such conditions are conducive to ill health, transmission of disease, crime or inability to pay reasonable taxes. The fact that the Area was found to be blighted in 2006 under Section 99.805(1), RSMo and in 2010 under Section353.020 (2), and is still blighted today, demonstrates the depth and long-term nature of conditions that require effective public intervention through state-enabled redevelopment powers to reverse the negative course of economic, social and physical decline that is further documented here. Looking beyond the individual factors of blight described here, it is important to understand the collective impact of these factors. The Redevelopment Area is clearly not contributing to the economic and social welfare of the City and its residents. It is an area of extensive economic underutilization, particularly given its potential to capitalize on the considerable benefits of its location near the recently enhanced I-64 and Hanley Road interchange. The high costs of assembling efficient development sites from lots under different and often absentee ownership, demolishing or extensively rehabilitating old and functionally obsolete buildings, effectively precludes, in most instances, investment in redevelopment that capitalizes on the location assets that the Area enjoys. Without access to the powers of redevelopment under Chapter 353, the Area will likely continue to be economically underutilized and fail to produce fiscal and economic benefits necessary to contribute to the long term viability of the City.

Hadley Township South Redevelopment Area Blight Analysis

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3.0

BLIGHTING FACTORS

As described below, the Redevelopment Area suffers from a variety of blighting factors including age of development, obsolescence, inadequate or outmoded design and physical deterioration, which have become economic and social liabilities, and such conditions are conducive to ill health, transmission of disease, crime or the inability to pay reasonable taxes. These blighting factors are in evidence in a preponderance of the Redevelopment Area, as illustrated on the following Blighting Conditions map.

Appendix B provides a summary of a number of blighting factors on a parcel by parcel basis. A predominance of the parcels (91%) and acreage (82%) in the Redevelopment Area has at least one blighting factor present, and 82% of the parcels and 73% of the acreage contain multiple blighting conditions. A separate appendix provides a photograph and conditions survey of each property.
Hadley Township South Redevelopment Area Blight Analysis 14

BLIGHTING FACTORS FOR PARCELS IN THE HADLEY TOWNSHIP SOUTH REDEVELOPMENT AREA
Blighting Factors Multiple One None Total
Source: Development Strategies

Parcels 85 9 9 103

% Parcels 82% 9% 9%

SF of Parcels 550,744 65,812 134,510 751,066

% of Total SF 73% 9% 18%

AGE OF BUILDINGS Although the age of a building does not automatically constitute a blighted condition, older structures, unless well maintained and updated regularly, tend to have problems with their electrical and mechanical systems, and often suffer from deferred maintenance, functional obsolescence, and gradual overall deterioration. Such is the case with the majority of the buildings in the Redevelopment Area. The stock of buildings in the Area is aging, particularly the residential structures, which comprise nearly 92% of all buildings. Over half of the structures in the Area were constructed prior to World War II. Over 73% of the buildings in the Area were constructed by 1960, making them at least 50 years old, and 81% were constructed more than 35 years ago, which is generally used as a criteria for identifying older buildings that are likely to experience electrical and mechanical problems, and a tendency for gradual overall deterioration. No new construction has occurred during the last 13 years.

DATE OF CONSTRUCTION OF BUILDINGS IN THE HADLEY TOWNSHIP SOUTH REDEVELOPMENT AREA

Year Built Res. Cumulative % Res. 53% 57% 78% 84% 91% 100% 5 7% Off. Com. 1920 -- 1930 1931 -- 1945 1946 -- 1960 1961 -- 1975 1976 -- 1990 1991 -- 1999 Total % of Total 40 3 16 5 5 7 76 92% 2 1 2 0% 0% 33% 17% 50% 100% 1 1 1% Cumulative % Off. Com. Inst. Govt. Cumulative % Inst. Govt. 0% % % % % 100% Total Cumulative % Total 48% 52% 73% 81% 90% 100%

40 3 18 6 7 8 82

100%

Source: Development Strategies and St. Louis County Hadley Township South Redevelopment Area Blight Analysis 15

Hadley Township South Redevelopment Area Blight Analysis

16

OBSOLESCENCE Vacant Buildings and Property Given the character of the buildings in the Redevelopment Area, many have outlived their usefulness or lost their functional utility. This is illustrated by the number of buildings that are vacant or only partially utilized today. Of the 82 existing buildings in the Redevelopment Area, 34 are currently vacant. In addition, a number of buildings that were in poor or dilapidated condition, and were functionally obsolete, have been demolished. Today, there are 20 parcels of vacant land in the Area. When combined with parcels that currently have vacant buildings, 48% of all parcels in the Area are no longer supporting viable development. Obsolete Parcel Size The parcels in the Redevelopment Area were platted many years ago and 58 parcels (56%) do not meet the current minimum zoning standards for their current use 5,000 square feet for residential and 10,000 square feet for commercial development. Obsolete Infrastructure The Redevelopment Area was primarily platted approximately 85 years ago and has not significantly changed since that time. Subsequently, the streets and storm water drainage are no longer capable of meeting the modern standards for a residential neighborhood or commercial development. The problem has been compounded by the ever increasing traffic volume on Hanley Road. The result is an obsolete residential neighborhood and an obsolete commercial Hanley Road frontage that is incapable of meeting modern standards without redevelopment.

INADEQUATE OR OUTMODED DESIGN Outmoded and Inadequate Design Street Layout The Redevelopment Area suffers from an access and circulation system that does not accommodate contemporary traffic movements and volumes. Of particular concern are the streets in the Area that terminate abruptly without adequate means of turning around for cars or emergency vehicles. This condition exists on Stockard Avenue to the south of Elinor Avenue and Booker Place.
Hadley Township South Redevelopment Area Blight Analysis 17

Compounding the access and circulation problems in the Area are the interruptions to the grid pattern of streets. Contemporary planning emphasizes the importance of a functional grid street pattern to provide multiple means of access for residents of an area, as well as emergency vehicles, particularly in an urbanized city like Richmond Heights. However, there are no streets internal to the Area that can accommodate north-south vehicular movement that connect to a major eastwest street. Furthermore, Elinor Avenue is the only internal street that accommodates east-west movement.

Hadley Township South Redevelopment Area Blight Analysis

18

Outdated Hanley Road Commercial Corridor Development Over time, Hanley Road between Manchester Road and Highway 40/I-64 has become an important commercial corridor in the continually expanding commercial node which has formed along Highway 40/Interstate 64 between Brentwood Boulevard and Hanley Road. Into the 1960s Hanley Road was only a two lane road which terminated at Manchester Road. Much of the land fronting on Hanley Road within the Redevelopment Area was still in residential use. With the completion of the U.S. Highway 40 and Hanley Road interchange in the early 1960s, the opening of Missouri Route 725 (now Interstate 170) in 1967, and the expansion of Hanley Road to four lanes by 1970, the pattern of development in the Redevelopment Area began to change, primarily with the addition of new office space, much of which remains today. In the late 1970s, Hanley Road was improved as a County arterial with four lanes extending north to Carson Road and south to Laclede Station Road. Recently, major improvements have been completed to I-64, which include enhancements to the Hanley Road interchange. Today, Hanley Road has an average weekday traffic count in excess of 52,000 vehicles with the likelihood that traffic will increase, now that the I-64 improvements have been completed. As a response to the ever increasing traffic volume, it has been proposed by the Hanley Road Corridor Study* that Hanley Road should be expanded to three lanes in both directions with turning lanes. This will clearly impact the existing development fronting on Hanley Road. In response to the evolving improvements and importance of Hanley Road, neighboring municipalities have promoted significant commercial redevelopment. The mixed-use Meridian and Hanley Station developments, as well as a new Home Depot, were constructed along the west side of Hanley Road, opposite the Redevelopment Area, in the City of Brentwood. Immediately south of the Redevelopment Area, the Maplewood Commons retail project was completed in the City of Maplewood. However, while new vital commercial development has grown up along Hanley Road to the west and south of the Redevelopment Area, the commercial development that currently exists along Hanley Road within the Redevelopment Area is obsolete, has been developed over time in an uncoordinated and piecemeal manner, and is often in conflict with its neighboring residential uses.

__________________
*The Hanley Road Corridor Study was prepared by Parsons, Brinkerhoff, Quade & Douglas, Inc. for the St. Louis County Department of Highways and Traffic, the City of Brentwood, the City of Maplewood, and the City of Richmond Heights in 2004. Hadley Township South Redevelopment Area Blight Analysis 19

The piecemeal manner in which structures have been constructed over a 40 year period has also led to functional problems that are not reflective of modern commercial development. Of particular concern are the multiple curb cuts that exist along the very heavily travelled Hanley Road. The Hanley Road Corridor Study foresaw the need to eliminate most of the curb cuts to facilitate traffic movement and increase safety. The study also called for allowing only right-in and right-out movements where traffic signals were not provided. In addition, the manner in which Hanley Road curves between Bruno Avenue and Elinor Avenue further compounds the safety problem presented by multiple curb cuts and lack of traffic signals at several street intersections with Hanley Road. Finally, there is inadequate buffering provided between the commercial uses along Hanley Road and the residential neighborhood to the east, which creates a number of awkward and inappropriate conditions. Of particular concern is the impact on the residences on the east side of Banneker Avenue, which also functions as a service drive for the Richmond Heights Public Works Department. Lack of Adequate Sidewalks and Building Accessibility Many blocks in the Redevelopment Area contain sidewalks that are in poor or fair condition, or are not continuous. In addition, there are intersections in the Area where there are no curb cuts or the curb cuts do not comply with ADA requirements. As a result, the Redevelopment Area inhibits pedestrian movement and is not in compliance with the requirements of the Americans with Disabilities Act (ADA). Two of the office/commercial buildings within the Redevelopment Area are not in compliance with the Americans with Disabilities Act (ADA) regarding barrier free access to primary building entry. In addition only one single family home of the 76 residential structures in the Redevelopment Area provides an accessible route to the front entry for disabled individuals. Lack of Adequate Storm Water Sewers Based on site visits to the Area by staff of Development Strategies, the following streets are not equipped with sewers to accommodate storm water runoff Booker Place and the western portion of Elinor Avenue.

Hadley Township South Redevelopment Area Blight Analysis

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Inadequate Building Foundations As previously noted in the discussion of the historical development of the Area, clay mining was prevalent in the Redevelopment Area and adjacent neighborhoods. According to the Blight Analysis of the Redevelopment Area that was completed by PGAV in 2006 (the 2006 Blight Study), information provided by the environmental engineering firm of Geotechnology indicates that there is a mine shaft in the vicinity of Elinor and Banneker Avenues. The 2006 Blight Study goes on to state that: Typically, there are clay mining tunnels that will extend outward from the mine shaft. At this time, these have not been geologically explored and mapped for the Area, but it has been the experience of other neighboring developments that there are extensive clay mining tunnels throughout this part of the County. The Citys Community Center, the Home Depot project across Hanley Road, and the Hanley Station project by MLP Investments, also across the street on Hanley Road, have all experienced problems during construction with clay mines. The potential safety problem for existing uses is subsidence, which can occur suddenly. For new construction, the problem is ameliorated through the use of more extensive foundation systems. Though this adds to the cost of construction, it can protect the building from subsidence. Most older structures, however, will not have been constructed with such extensive foundation systems, including both the commercial buildings along Hanley Road as well as the homes throughout the Area. ( page 3.7) Flooding Hampton Creek was channelized by the Metropolitan Sewer District in the 1990s on the eastern boundary of the Area. However, according to FEMA mapping, two properties in the Redevelopment Area remain in the 100-year floodplain of the creek. The impacted properties include a vacant three-family structure and a vacant lot. PHYSICAL DETERIORATION The buildings, sites, streets, and sidewalks in the Redevelopment Area exhibit varying levels of physical deterioration. Taken together, they contribute to conditions that are both unsafe and unattractive and thereby constitute a deterrent to attracting new quality development in the Area. Condition of Buildings Of the Redevelopment Areas 82 buildings, 84% were found to require either major or moderate repairs, meaning they have various levels of physical deterioration that contribute to the blighting conditions in the Area.
Hadley Township South Redevelopment Area Blight Analysis 21

The condition of all structures in the Redevelopment Area is noted on the following table and Condition of Buildings map.

EXISTING BUILDING CONDITION IN THE HADLEY TOWNSHIP SOUTH REDEVELOPMENT AREA Building Condition Major Deterioration(1) Moderate Deterioration(2) Minor Deterioration(3) TOTAL Number of Buildings 43 26 13 82 % of Total Buildings 52% 32% 16% Cumulative % of Total 52% 84% 100%

(1) Major Numerous critical structural and/or secondary building component deficiencies apparent which could only be corrected with major building renovation, rehabilitation, or repairs, making the building potentially infeasible to rehabilitate. (2) Moderate Multiple deficiencies in secondary building components or problem with a structural building component that could be corrected with major repair work. (3) Minor Defects in one or more secondary building components that could be corrected with minor repair work.

Source: Development Strategies, field inspection, February 2013

Hadley Township South Redevelopment Area Blight Analysis

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Hadley Township South Redevelopment Area Blight Analysis

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Condition of Existing Streets The condition of the existing streets in the Redevelopment Area also has a blighting influence. Over three-quarters of the streets are classified as being in either poor condition (28%) or fair condition (58%). The condition of a street relates to the street surface and adjacent curbs and gutters. It does not consider issues of age or functional obsolescence per se. The only street found to be in good condition is at the southern edge of the Redevelopment Area West Bruno Avenue. The overall condition of the streets in the Redevelopment Area is summarized in the following table and detailed Rights-of-way map.

CONDITIONS OF EXISTING STREETS IN THE HADLEY TOWNSHIP SOUTH REDEVELOPMENT AREA Street Condition Poor (1) Fair (2) Good (3) TOTAL Lineal Feet 1,500 3,070 750 5,320 % of Total 28% 58% 14% 86% 100% % of Total

(1) Poor Potholes, uneven surface, lack of maintenance with former surface revealed, with broken or no curbing and inlets that are damaged, inoperable or not in place required. (2) Fair Patched or cracked surface or rippled asphalt, with some damage to curbing and inlets. (3) Good Generally smooth surface with intact curbing and inlets. Some minor maintenance required.

Source: Development Strategies, field inspection, February 2013

Condition of Sidewalks Another problem in the Redevelopment Area is the lack of adequate sidewalks. Where sidewalks are provided, only 6% are classified as being in good condition. These sidewalks are primarily located at the western edge of the Redevelopment Area along Hanley Road. The overall condition of the sidewalks in the Area is summarized on the following table and illustrated on the Rightsof-Way Conditions map.
Hadley Township South Redevelopment Area Blight Analysis 24

CONDITIONS OF EXISTING SIDEWALKS IN THE HADLEY TOWNSHIP SOUTH REDEVELOPMENT AREA Sidewalk Condition Poor (1) Fair (2) Good (3) TOTAL
(1) Poor Broken or uneven surface. (2) Fair Some cracking with uneven surfaces. (3) Good Generally smooth surface with intact curbing and inlets. Some minor maintenance required.

Lineal Feet 605 6,660 450 7,715

% of Total 8% 86% 6%

% of Total 8% 94% 100%

Source: Development Strategies, field inspection, February 2013

Site Improvements The Redevelopment Area suffers from a variety of deteriorated site improvements (private walkways, driveways, parking lots, fencing and yard maintenance) that significantly detract from the safety and appearance of the Area and the ability to attract and retain new investment. As indicated by the following table, just 1% of the parcels are classified as having good site conditions.

CONDITION OF SITE IMPROVEMENTS IN THE HADLEY TOWNSHIP SOUTH REDEVELOPMENT AREA Condition Poor Fair Good Total Number of Parcels 56 46 1 103 % Total Parcels 54% 45% 1% SF of Parcels 330,319 414,507 6,240 751,066 % of SF of Parcels 44% 55% 1%

Source: Development Strategies, field inspection, February 2013

Hadley Township South Redevelopment Area Blight Analysis

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ECONOMIC LIABILITY As a result of the blighting factors previously discussed, the Redevelopment Area constitutes an economic liability. The City is a mature city that is surrounded by other cities and therefore has no opportunities to expand its corporate limits. Subsequently, the only opportunity for economic growth that is possible is through redevelopment of existing areas and buildings. Given the significant vacancy of the existing buildings and land and the location near the I-64 and Hanley Road interchange, the Redevelopment Area is clearly underutilized and significantly short of the economic benefit it could provide for the City and other taxing jurisdictions.

Hadley Township South Redevelopment Area Blight Analysis

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The economic decline in the Redevelopment Area is illustrated by the extensive vacancy of residential units and commercial space. Almost half (45%) of the residential units in the Area are vacant and 48% of the office commercial space is currently vacant. The high vacancy in the Redevelopment Area tends to foster an image of abandonment and decline that typically results in an unwillingness of property owners to invest in their property, which further exacerbates the situation. Vacant properties are also a burden on municipalities that are left with the problem of seeing that vacant buildings are adequately secured and that vacant lots are appropriately maintained through a management program with property owners or often their own resources and efforts. The vacancy and ongoing decline of the Redevelopment Area is also creating problems in delinquent taxes, which is creating an economic liability. According to the records of the County Assessor, there are 26 properties (29% of taxable parcels) that are currently delinquent on their real estate taxes. Of this total, 13 are two years delinquent and 7 are three years delinquent. SOCIAL LIABILITY Another indicator of social decline in the Area is the reduction of the number of residential units through demolitions and the increasing shift from owner occupancy to rental. As indicated by the following table, the number of residential units in the Redevelopment Area has continued to decline since 2000. The owner occupancy in the Redevelopment Area has also declined. Numerous studies over the years have indicated that home ownership is a key factor in providing stability for neighborhoods and the maintenance of property1. As is the case in the Redevelopment Area, neighborhoods tend to decline when they are actively in transition from owner occupancy to renter occupancy, particularly where there is a large amount of absentee owners of the rental property.

Chasing the American Dream: New Perspectives on Affordable Homeownership, Edited by William Rohe and Harry C. Watson, 2007. Home and Neighborhoods: A Guide to Comprehensive Revitalization Techniques, U.S. Department of Housing and Urban Development, 2004. Social Benefits and Costs of Homeownership, Affordable Housing Issues, Volume XI, Number 3, April 2000. Homeownership and Neighborhood Stability, Housing Policy Debate, Volume 7, Issue 1, William M. Rohe and Leslie S. Stewart, 1996. 27

Hadley Township South Redevelopment Area Blight Analysis

OWNER AND RENTER OCCUPIED RESIDENTIAL UNITS IN THE HADLEY TOWNSHIP SOUTH REDEVELOPMENT AREA
Occupied Units Owner Occupied Renter Occupied TOTAL 2000(1) 40 34 74 % Total 53% 47% 2010(1) 29 25 54 % Total 54% 46% 2013(2) 19 25 44 % Total 43% 57%

(1) U.S. Census Bureau (2) Development Strategies field investigation February 2013

In addition, as previously noted, almost half (45%) of the residential units and 48% of the office commercial space in the Redevelopment Area are currently vacant. In neighborhoods where this type of high vacancy occurs, there typically is an increase in fires, vandalism, and health problems associated with rodents and disease. Finally, the poor vehicular circulation in the Redevelopment Area, particularly the dead-end streets without adequate space for turning movements by fire and other emergency vehicles, creates hazardous conditions for many of the residents of the Area. This problem cannot be easily addressed without significant cost and disruption to many of the existing residences.

CRIME The blighting factors in the Redevelopment Area discussed above are conducive to promoting increased crime. According to the records of the City, over the past four years there has been 1 murder (the only one in the City), 18 reports of assaults, 13 reports of burglary, 10 reports of larceny, 2 reports of motor vehicle theft, and 8 reports of destruction of property. As indicated by the following table, based on available information from the Richmond Heights Police Department, with the exception of robberies and thefts, crime activity in the Redevelopment Area is higher than the City as a whole. Crimes against people, such as murder and assaults, are significantly above the city average in the Redevelopment Area. Burglaries are also high. It is also important to note that statistics on thefts are somewhat skewed because of the many petty thefts, such as shoplifting, credit fraud and bad checks, at large commercial areas, such as the St. Louis Galleria.

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CRIME REPORTS 2009 2012 IN RICHMOND HEIGHTS AND THE REDEVELOPMENT AREA Richmond Heights (1)
Event Murder Robberies Assaults Burglaries Thefts Auto Thefts
(1) (2) (3)

Redevelopment Area (2)

Total Per Capita

Total

Per Capita

1 30 269 165 2,670 (3) 106

.000 .003 .003 .019 .310 .012

1 0 18 13 10 2

.007 .000 .138 .094 .072 .014

Based on 2010 population of 8,603 Based on 2010 population of 188 Large number of thefts include shoplifting at regional shopping mall

Source: City of Richmond Heights and Development Strategies

INABILITY TO PAY REASONABLE TAXES The failure of the Redevelopment Area to attract new investment and sufficient reinvestment in existing buildings and infrastructure, coupled with general obsolescence and decline of existing development, has created a downward pressure on the ability of the businesses and property owners in the area to pay reasonable taxes. The fact that nearly a third of the parcels and nearly half of the acreage in the Redevelopment Area are either vacant or contain vacant buildings represents a major loss of tax revenue for the City and other taxing jurisdictions, which include the State of Missouri, St. Louis County, the Maplewood Richmond Heights School District, Metro, and the Regional Parks and Recreation District. The City has a 6% utility tax for all utilities except electric, which has a tax rate of 5.625%. The rate is applied to both residential and commercial property. Therefore, the ongoing decline in the number of residential units and the vacancy in both residential and commercial development negatively impact the taxes that can be collected by the City to support needed services. In addition, as noted previously, 26 of the 88 properties that are commercially or residentially assessed are currently tax delinquent, which compounds the inability to collect reasonable taxes.
Hadley Township South Redevelopment Area Blight Analysis 29

As indicated by the following table, the Redevelopment Area has also seen a significant decrease in assessed value over the last five years, particularly with respect to the assessed value of improvements. It is important to note that while the total assessed value of the Redevelopment Area has decreased by 45 % since 2007, the total assessed value of the City of Richmond Heights has only decreased by 7% during this same period.

CHANGE IN ASSESSED VALUE 2007 - 2012 IN THE HADLEY TOWNSHIP SOUTH REDEVELOPMENT AREA
Date 2007 2012 % change Land $420,750 $553,850 +24% Improvements $1,803,620 $968,790 -86% Total $2,225,690 $1,529,710 -45%

Source: St. Louis County Assessors Office

The clear conclusion of this analysis of the Redevelopment Areas relative inability to pay reasonable taxes is that it is failing to contribute to the economic and fiscal wellbeing of the City, County, school district, and other taxing jurisdictions. As a largely obsolete residential and commercial district, the Area is economically underutilized and is not producing the taxes to contribute to economic growth and greater prosperity required to support public services and public infrastructure required by the Citys residents, businesses, and property owners. This is despite the Areas strategic commercial location in the City and region. Effective application by the City of state-enabled redevelopment powers, including Chapter 353, is needed to remove the presence of the blighting conditions enumerated here, and capitalize on the assets associated with the location of the Redevelopment Area.

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APPENDIX A
LEGAL DESCRIPTION OF HANLEY TOWNSHIP SOUTH REDEVELOPMENT AREA

A tract of land being all of Lots 1 through 9, 9A, 10 through 67, 73 through 85, part of Lots 68 through 72, all of Alabama Avenue, Booker Place, McKinley Avenue, Aberdeen Avenue and Jones Avenue all in Lincoln Terrace as recorded in Plat Book 22 Page 14; being all of Lots 37 through 46 of Lincoln Terrace Addition as recorded in Plat Book 20 Page 94; being all of Lots 6 through 26, and part of Elinor Avenue all in Elinor Place as recorded in Plat Book 26 Page 8; being all of Lots 1 and 2 of the Resubdivision of part of Lot 57 of Rannells Subdivision of the Home Farm as recorded in Plat Book 312 Page 100; also being part of Lots 55 and 57 of Rannells Home Farm Subdivision as recorded in Plat Book 9 Page 30 all in Township 45 North, Range 6 East of the 5th P.M., in the City of Richmond Heights, St. Louis County, Missouri and being more particularly described as follows: Beginning at the intersection of the east right-of-way line of Hanley Road with the north right-of-way line of West Bruno Avenue; thence along said east right-of-way line of Hanley Road N254410W 155.64 feet to a point; thence N260523W 83.99 feet to a point; thence along a curve deflecting to the left having a radius of 353.25 feet , an arc length of 127.37 feet, a chord course of N131944W 126.68 feet to a point; thence N000821E 21.75 feet to a point at the intersection of said east right-of-way line of Hanley Road with the south right-of-way line of Alabama Avenue (50 feet wide); thence along said south right-ofway line of Alabama Avenue S895438E 29.81 feet to a point; thence leaving said south right-of-way line N000158E 50.00 feet to the intersection of the north right-of-way line of said Alabama Avenue with the east right-of-way line of Booker Place (40 feet wide); thence along said east right-of-way line of Booker Place N000158E 191.00 feet to the northwest corner of Lot 79 of Lincoln Terrace as recorded in Plat Book 22 Page 14; thence leaving said east right-of-way line N895438W 40.00 feet to a point on the west right-of-way line of Booker Place, also being the northeast corner of Lot 86 of Lincoln Terrace; thence leaving said west right-of-way line along the north line of said Lot 86 N895438W 104.37 feet to the northwest corner of said Lot 86, also being on the east right-of-way line of Hanley Road; thence along said east right-of-way line along a curve deflecting to the right having a radius of 301.46 feet, an arc length of 26.47 feet, a chord course of N022335W 26.46 feet to a point; thence N000719E 254.02 feet to the intersection of said east right-of-way line of Hanley Road with the south right-of-way line of Elinor Avenue (50 feet wide); thence along said south right-of-way line of Elinor Avenue S895933E 358.09 feet to a point; thence S895933E 50.00 feet to a point; thence S895933E 242.41 feet to a point; thence leaving said south right-of-way line N002337W 50.00 feet to a point on the north right-of-way line of Elinor Avenue; thence N002337W 140.88 feet to a point; thence S895544E 564.56 feet to the northeast corner of Lot 6 of Elinor Place; thence along the east line of said Lot 6 S000355W 140.25 feet to the southeast corner of said Lot 6, also being on the north right-of-way line of Elinor Avenue; thence leaving said north right-of-way line S000355W 50.00 feet to a point on the south right-of-way line of said Elinor Avenue; thence along said south right-of-way line S895933E 43.87 feet to the northeast corner of Lot 26 of said Elinor Place; thence leaving said south right-of-way line along the east line of said Lot 26 S000621W 140.93 feet to the southeast corner of said Lot 26; thence along the south line of said Lot 26 N895941W 30.98 feet to the northeast corner of a tract of land conveyed to Beyond Housing Inc. in Deed Book 12607 Page 872; thence leaving the south line of said Lot 26 along the east line of said Beyond Housing Inc. tract S000240W 140.13 feet to a point at the southeast corner of said Beyond Housing Inc. tract, also being on

the north right-of-way line of Jones Avenue (50 feet wide); thence along said north right-ofway line N895842W 342.67 feet to a point; thence leaving said north right-of-way line S000343W 50.00 feet to the intersection of the south right-of-way line of Jones Avenue with the west right-of-way line of Berkley Avenue (50 feet wide); thence along said west right-of-way line of Berkley Avenue S000343W 551.43 feet to the intersection of said west right-of-way line with the north right-of-way line of West Bruno Avenue (60 feet wide); thence along said north right-of-way line N895841W 213.15 feet to a point ; thence N895841W 50.00 feet to a point; thence N895841W 212.00 feet to a point; thence N895841W 50.00 feet to a point; thence N895841W 108.93 feet to the point of beginning, containing 20.46 acres or 891,168 square feet. Subject to any and all easements, restrictions, conditions, etc. of record.

APPENDIX B
PARCEL NUMBERS MAP AND PARCEL INFORMATION

APPENDIX C
PHOTOGRAPHS OF BLIGHTED CONDITIONS

Vacant three family building in poor condition at 7929 Elinor Avenue

Vacant home with deteriorated roof, gutters and windows 1621 Stockard Avenue

Hadley Township South Redevelopment Area Blight Analysis

Appendix C - 1

Deteriorated public street lacking appropriate turn around 1600 block Stockard Avenue

Vacant, underutilized ground at 1618 and 1620 Stockard Avenue

Hadley Township South Redevelopment Area Blight Analysis

Appendix C - 2

Poor condition of fencing, lack of accessible entry at vacant home 1632 Stockard Avenue

Deteriorated site and building conditions at vacant home 1706 Stockard Avenue

Hadley Township South Redevelopment Area Blight Analysis

Appendix C - 3

Vacant home in poor condition constructed in 1923 1712 Stockard Avenue

Deteriorated condition of shared parking surface at 7927-7929 Jones Avenue

Hadley Township South Redevelopment Area Blight Analysis

Appendix C - 4

Deteriorated roof and guttering at vacant home 1707 Stockard Avenue

Poor condition of site and structure 1709 Stockard Avenue

Hadley Township South Redevelopment Area Blight Analysis

Appendix C - 5

Vacant and partially secured structure in poor condition at 1701 Stockard Avenue

Vacant and unsecured structure in poor condition at 1700 Banneker Avenue

Hadley Township South Redevelopment Area Blight Analysis

Appendix C - 6

Vacant home in deteriorating condition at 1629 Banneker Avenue

Vacant office commercial building at 1600 South Hanley Road

Hadley Township South Redevelopment Area Blight Analysis

Appendix C - 7

Lack of sidewalk on west side of 1600 block of Banneker Avenue

Deteriorated siding, guttering and windows at rear of 8030 Elinor Avenue

Hadley Township South Redevelopment Area Blight Analysis

Appendix C - 8

Occupied home with roof in deteriorated condition at 1712 Banneker Avenue

Lack of sidewalks and appropriate vehicle turn around 1600 block of Booker Place

Hadley Township South Redevelopment Area Blight Analysis

Appendix C - 9

Vacant, underutilized lots at the northwest corner of Alabama and Stockard Avenues

Poorly maintained landscaping and site conditions rear of 1622 Stockard Avenue

Hadley Township South Redevelopment Area Blight Analysis

Appendix C - 10