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HomeMy WebLinkAbout09-10-18 Community Investment U d PEACE ra 1865 OFFICE OF THE CITY CLERK KAREEMAH FOWLER, CITY CLERK COMMUNITY INVESTMENT SEPTEMBER 10, 2018 4:00 P.M. Committee Members Present: Gavin Ferlic, Regina Williams-Preston, Sharon McBride Committee Members Absent: Oliver Davis Other Council Present: Tim Scott, Jo M. Broden, Jake Teshka, Karen White Other Council Absent: John Voorde Others Present: Kareemah Fowler, Bianca Tirado, Graham Sparks, Bob Palmer Presenters: James Mueller, Dan Buckenmeyer Agenda: Bill No. 18-42-Modifying and Reconfirming Resolution for Historic JMS Building Bill No. 18-43-Modifying and Reconfirming Resolution for JSK Development(Ireland Hospitality/Holiday Inn Express) Bill No. 18-44-Modifying and Reconfirming Resolution for JSK Development(Southhold/Courtyard Marriott Downtown) Bill No. 18-45- Modifying and Reconfirming Resolution for JSK Development(Southhold/Hall of Fame) Bill No. 18-46-Modifying and Reconfirming Resolution for RDistrict One (Studebaker Building 84) Bill No. 18-47- Modifying and Reconfirming Resolution for Imagineering Enterprises (Personal Property) Bill No. 18-48- Modifying and Reconfirming Resolution for Imagineering Enterprises (Real Property) Bill No. 18-49-Modifying and Reconfirming Resolution for Tower at Washington(Hotel) Bill No. 18-50- Modifying and Reconfirming Resolution INTEGRITY1 SERVICES ACCESSIBILITY JE<v;v TLR M.COFFMAN BLANCA L.T�RADO JosRFEC R MOINAR CHIEF DEPOTY/DIRECTOR OF OPERATIONS DEPUTYJDiRE=R OF POLICY ORDMANTCE VIOLATION CLERK EXCELLENCE I ACCOUNTABILITY I INNOVATION I INCLUSION I EMPOWERMENT 455 County-City Building 1 227 W.Jefferson Blvd.I South Bend,Indiana 466011 p 574.235.92211 f 574.235.9173 1 www.southbendin.gov ®CITY OF SOUTH BEND I OFFICE OF THE CLERK for Tower at Washington(Parking Garage) Bill No. 18-51- Modifying and Reconfirming Resolution for Tower at Washington(Retail) Bill No. 18-52- Modifying and Reconfirming Resolution for Tower at Washington (Apartments) Committee Chair Gavin Ferlic called to order the Community Investment Committee meeting at 4:00 p.m. He introduced members of the Committee. Committeemember Sharon McBride made a motion to, for purposes of public hearing,to hear Bill Nos. 18-42, 18-43, 18-44, 18-45, 18-46, 18-47, 18-48, 18-49, 18-50, 18-51, and 18-52 together. Committeemember Regina Williams-Preston seconded this motion which carried by a voice vote of three (3) ayes. Bill No. 18-42- Modifying and Reconfirming Resolution for Historic JMS Buildin; Bill No. 18-43- Modifying and Reconfirming Resolution for JSK Development (Ireland Hospitality/Holiday Inn Express) Bill No. 18-44- Modifying and Reconfirming Resolution for JSK Development (Southhold/Courtyard Marriott Downtown) Bill No. 18-45- Modifying and Reconfirming Resolution for JSK Development (Southhold/Hall of Fame) Bill No. 18-46- Modifying and Reconfirming Resolution for RDistrict One (Studebaker Building 84) Bill No. 18-47- Modifying and Reconfirmin6 Resolution for Imagincering Enterprises (Personal Property) Bill No. 18-48- Modifying and Reconfirming Resolution for Imagineering Enterprises (Real Property) Bill No. 18-49- Modifying and Reconfirming Resolution for Tower at Washington (Hotel) Bill No. 18-50- Modifying and Reconfirming Resolution for Tower at Washington (Parking Garage) Bill No. 18-51- Modifying and Reconfirming Resolution for Tower at Washington (Retail) Bill No. 18-52- Modifying and Reconfirming Resolution for Tower at Washington (Apartments) EXCELLENCE ( ACCOUNTABILITY ( INNOVATION I INCLUSION I EMPOWERMENT 455 County-City Building l227W.Jefferson BvldI South Bend,Indiana 46601 p574.235.9221 f574.235.9173!TTD574.235.55671www.southbendin.gov 2 ®CITY OF SOUTH BEND I OFFICE OF THE CLERK James Mueller, Director of Community Investment with offices on the 14th floor of the County- City Building stated, We have eleven(11) resolutions today that are modifying the designation period of the tax abatements. This does not extend the actual abatement itself, or the benefits that come along with the abatement. The only thing being modified is the qualifying time period in which they have to get their project done, get it reassessed by the Assessor, and then to have it reviewed by the Auditor. Mr. Mueller referred to a slide on the presentation (available in the City Clerk's Office). He stated, These are tax abatements that are for the familiar projects that you've seen around town: the JMS right around the corner, Holiday Inn south of town,the Courtyard Marriott between the Chocolate Caf6 and the Century Center, the Hall of Fame just north of that, the Studebaker, Imagineering Enterprises has a personal and real property tax abatement, and the Liberty Tower just across the way that had a hotel, garage, retail and apartments. Mr. Mueller continued, There has been an uptick in tax abatements as the economy has picked up. South Bend has seen many booms and busts over the decades, but didn't necessarily take part in the booms. Referring to the presentation, he stated, Here is the significant increase in tax abatements and business activity since 2010. There has been an explosion in investment over the last couple of years. Many of these projects represented today are the reason why. With these larger projects,the scale and complexity has increased.Unanticipated issues even come with small scale developments because there are unforeseen challenges with every project. A lot of times you get through them on time,other times it delays the project from what you originally anticipated. If you finish your project on time within the designation period, but given the timeline of the tax abatement process, you may not receive your assessed value in time before the designation period ends. Looking at the private investments from the property associated with tax abatements over the years, you see that 2015 is a peak year, as many of these tax abatements before you are from the 2015-2016 time period. As the economy tightened and the unemployment rate decreased, we are almost at full employment, and you aren't seeing as many commitments for job creation. He referred to the presentation, stating, Overall, we're exceeding what was announced in the"actual" categories. In the investment levels, we are a little behind. This is because some of the projects have not completed yet. Once they are completed, the actuals will go up. It is important to note that they have the period of the tax abatement to phase in the jobs. The period is still ongoing, so they still have time to meet those goals. Also, some of the assessed values aren't exactly what we projected. In our meeting with Councilmembers Broden and Ferlic and the Assessor's Office, we went over our methodology and they said it was a sound approach. Still,we're seeing a mismatch between our estimated and assessed value. Mr. Mueller explained the process of tax abatements, stating, The petitioner comes in with an application,the SB-1 Form. DCI analyzes it and presents it to the Common Council for an up or down vote. If the Council approves the abatement, there would be a designating resolution, a confirming resolution,then a memorandum of agreement(MOA). Then the project gets started. Then projects can change and on the back end, the companies are submitting their CF-1 Forms. The Assessors reassess the value of the investment. The abatement is on the increase in value, so we are not losing any money, it is basically phasing in the taxes on the new value being generated by the new investment. That is an important distinction. We are looking at the personal abatements which could be a five (5) year abatement, real property tax abatements can be three (3) to ten(10) years, and the vacant building is two (2) years. The designation period, which is EXCELLENCE I ACCOUNTABILITY I INNOVATION I INCLUSION I EMPOWERMENT 455 County-City Building!,227 W.Jefferson Bvld I South Bend,Indiana 466011 p 574.235.9221 If 574.235.9173 I T 0574.235.5567 I www.southbendin.gov 3 CITY OF SOUTH BEND I OFFICE OF THE CLERK when all of this stuff can happen, is what we are looking at extending today. A lot of these are two (2) years, and we have some that are longer. January 1St is the effective date for the new assessed value of properties. The Assessor does not go around to every property on January, but whatever is thought to be the value on January 1't is what will be the assessment for that property for the year, and then it will be paid the next year. The CF-1 Forms are due on May 15th, we submit the Annual Tax Abatement report to the Common Council on June 15u', summarizing where every abatement is. In the July to September range,the recipients receive their reassessment from the Assessor's Office in a Form 11, which is set by statute. Mr. Mueller showed an example in the presentation. He stated, If we start the project in October, you've approved the tax abatement and the project commences. If they didn't face any delays, they've been able break ground before winter and the project is on schedule. Theoretically, by January 1St there is some new value on the property so there is a partial reassessed value. As the project continues throughout that year, you get to next year and whatever value had been added that year would be partially reassessed on January st the following year. This project would complete in April, months before the two (2) year designation period would end in October, but they won't receive full assessed value until the next January, and they wouldn't pay the taxes on that until the next year. So even if you're on time, you're oftentimes going to blow through this two (2) year designation period. Mr. Mueller referred to a slide explaining the new designation periods that are being proposed alongside when they were set to expire. He stated, Some projects ran into a delay, so they need an additional year. The two (2) "not completed"categories are the Imagineering Real and Personal Property tax abatements, and the second phase of Liberty Tower. As you see,the first phase of the Liberty Tower well exceeded the investment level projected for the entire project for both phases. Construction costs were higher, and there were challenges to working on a building this tall and having to get the right people to do that. They have met their investment level on that project and they're looking to work on the retail this fall, and get started on the apartments next year. That extra year of the designation period would help get these projects going. Mr. Mueller presented a slide with the status of each of the assessments, and when the Form 11 s were sent. He stated, If you see where the assessed values are, you can see that some of them are only partial and the values aren't very high. The assessed value of the Liberty Tower land is $1.5 million, it was $1.1 million. We just saw all of the money going into the building, so it is safe to assume the whole value hasn't been accounted for yet by the Assessor's Office. We included some of the policy goals and the reasons why tax abatements are beneficial incentives. Committee Chair Ferlic asked, Do you expect a longer lag, the bigger the project is? If there is more investment going into a project, it is going to take longer? Mr. Mueller answered, Yes,there is usually more complexity, so there is more that can go wrong. Committee Chair Ferlic asked, Can we go back to the wages? It looks like more than we anticipated. It's fifty percent(50%) greater than what we anticipated for salaries, is that just because of a tight labor market and the growing economy? EXCELLENCE ( ACCOUNTABILITY I INNOVATION I INCLUSION I EMPOWERMENT 455 County-City Building I227W.Jefferson BvldI South Bend,Indiana 46601Ip574.235.9221If574.235.9173ITTD574.235.5567 www.southbendin.gov 4 ®CITY OF SOUTH BEND I OFFICE OF THE CLERK Mr. Mueller stated, Yes, our wages have been growing faster than the national average over the past couple of years. Also,we want these investments to succeed, so we don't try to create unrealistic goals. Sometimes when they come,they are under promising because there are a lot of uncertainties. Councilmember Karen White asked Mr. Mueller to share the extent of the conversation from his meeting with the other councilmembers and the Assessor. Mr. Mueller stated, Before that meeting, we didn't have the full appreciation of the timeline. Even if you are on schedule for an eighteen(18) month project with a two (2) year designation period, you are still likely to blow through that deadline. Councilmember White asked, Are you saying that we may need to look at the length of it differently? If so, what would that look like? Mr. Mueller responded, One (1) idea is to start with a longer timeline and designation period knowing that the process takes a while to actually work, even when projects stay on schedule. Developments will always face issues and potential delays, so we may have to come back over time. This would only apply to tax abatements this year forward, so there are still probably some in the queue from 2017 and earlier. 2015 was a peak year for the number of tax abatements. Councilmember Jake Teshka stated, So it was a peak year in the number of investments. I just want to clarify that we're extending the period for which they can complete the project. That is what is up for the vote. Mr. Mueller answered, Correct. We're not extending the abatement period itself,we are just extending what improvements can qualify. We're just trying to capture the original agreement that we had for the project. Councilmember Teshka stated, So it's that increase in value that is being abated, it's not like we're losing money on any of these things. Mr. Mueller stated, Right. It would be better to call it a tax phase in. The county calls it a tax phase in. In our code and elsewhere, we call them abatements. Councilmember Tim Scott stated, This is a proactive process. You guys are going to do this every year? Do you have timelines where you're going to sit down with the Assessor's Office to review them? We might be seeing this type of thing before Council every year, where we haven't in the past. Oftentimes its "Oh by the way..." This is like that but it is also proactive. Do you feel that we should just write this in the schedule for next year now? Mr. Mueller stated,As you know,there's the CF-1 that is due. Sometimes people forget to submit them after we send reminders. When we are doing the tax abatement report, sometimes we realize they forgot to send them in, so we'll always have those. As part of the annual process, we review it and look at the assessed value coming in. We don't get the Form 11 until the summer, after we submit the annual tax abatement report. We don't know whether the full value has been reassessed until later in the year. EXCELLENCE I ACCOUNTABILITY I INNOVATION I INCLUSION I EMPOWERMENT 455 County-City Building j 227W Jefferson Bvld I South Bend,Indiana 466011 p 574.235.9221 If 574.235.9173 TTD 574.235.5567 j www.southbendin.gov 5 CITY OF SOUTH BEND I OFFICE OF THE CLERK Councilmember Jo M. Broden stated, The overview is appreciated. The Auditor has a key role to play in this as well, because they are tracking the abatement schedule and the payments, correct? After our meeting, that was my thought. What has been done to connect all of the parts in a timely manner? Between Council's approval and the time that the building permits are pulled, that will flag everybody down the chain. And it may not be full, because it might only be year one (1) or two (2) of the project. My overview of the meeting was that there were a lot of right hands not knowing what the left hands were doing between City offices and what the developer was doing. I would rather look at expanding the designation period because it looks like we've missed, at least in the 2015 period which predated you. It seems to me that there needs to be an adjustment on that. I'd like to know a little bit more. This is important not only for large scale developers, but also residential properties. What does the cleanup on this process look like? Committee Chair Ferlic asked, Would it be best to have a standard, much longer period for everyone, or is there something for those smaller developments that you want to incentivize quicker completion? We could just say it is four(4) years for everyone. Councilmember Broden stated, And timeliness is important when someone comes to us with a project. Timeliness matters in getting these off the ground. I get delays, but hearing these all en masse today, we are not getting the opportunity as a Council or as the public to understand. It could be instructive if we had a sense of each one (1) of these. Mr. Mueller interjected, We have representatives from each of these projects. Councilmember Broden stated, And that would be helpful, the designation periods, the communications and the timing between all of the parties. I have at least one (1) vote that I regret on this Council, and it was from an earlier petitioner who said they didn't get a Form 11. Everybody gets Form 11 s one (1)way or another, and if you don't get them and you're living in the City and you have a residence, then you're getting those at the same time. It should be coming to your commercial address, or there is.a communication error with the Auditor on the property information. All of the other information about taxing periods and if you want to appeal that, to me, that is a huge communication thing that we all go through as a community. We need to get to the bottom of that, where the Form 11 s weren't sent. To me, there's a general awareness that we all have as tax payers in this community, and of course that then triggers all of these different steps. I just want to make sure the communication level is increased. There is a certain level of hand holding that goes into these, but at some point, your investment is your investment. After getting these abatements, I don't know why the subsequent paperwork isn't being filed. Mr. Mueller stated, You can receive a Form 11, but if it doesn't have the updated full new assessed value, it doesn't do you any good if that value comes in the next.year. We know from our other conversation with the Assessor's Office,they don't assess every property every year. You'd like to do every property so you don't have big jumps, you'd also probably have fewer appeals, but that's one (1) issue. From our perspective, we can proactively tell the Assessor's Office, "here are the properties with tax abatements,please look at these". As we discussed in the meeting, we can give them an architectural drawing and the design costs if that helps them start, but they have their own process that they're going to follow. EXCELLENCE I ACCOUNTABILITY I INNOVATION I INCLUSION I EMPOWERMENT 455 County-City Building 1227 W.Jefferson Bvld I South Bend,Indiana 466011 p 574.235.9221 If 574.235.9173 T 0574.235.5567 I www.southbendin.gov 6 ®CITY OF SOUTH BEND I OFFICE OF THE CLERK Councilmember Broden stated, But that's the Building Department,right?As soon as that permit is pulled,there are going to be some calculations. My last point is, embedded in each of these agreements was an annual compliance check. Was it done in 2016 or 2017? Were there annual compliance checks? Mr. Mueller stated, Those are the waivers we bring to you, when they're out of compliance. We find those when we do the annual reports, that's when we bring them to you. Council Member Broden stated, So everyone is submitting their paperwork to you, and there is a duty to do the survey in these agreements. Mr. Mueller answered, Yes. They're upholding their requirements. Last year, before we instituted the new process of notification,there were a lot of cases. We had a number of waivers. Councilmember Broden stated, Obviously I'm thrilled with the investments, but some of these are mixed in the actual applications that we got. We had X amount of money, but then it was across three (3) different projects within a particular address. What's what, and have we actually hit the marks in terms of what's anticipated,that's a little bit more difficult to track. I am more interested in not seeing this process become a catch up going forward. Councilmember Scott stated, I agree with a lot of the things that Jo says. Since I've been on Council, we've had four (4) directors of Community Investment, so we average a new director every twenty-one (21)months. Hopefully you're around a little bit longer, but we've seen you put together a team with the City, and right or wrong, I like the fact that this is a proactive process. Our predecessors need to understand that, and yours do too,that putting processes like this is place is good. Is there a statutory limit on the length of the designation period? Dan Buckenmeyer, Department of Community Investment on the 14th Floor of the County-City Building, stated, From a general sense, we are looking at changing the designation period from a standard two (2) years to a standard four(4) years,to avoid this in the future. We're going to try that and balance it. We don't want to sacrifice incentives for them to move forward in a timely fashion. It will take a few years for this to take effect, but this will help us avoid this in the future. Committee Chair Ferlic stated, There are certainly greater incentives. Your tax abatement is pushing the projects forward in terms of trying to cash flow your project. They're continuously improving, and we appreciate that. I don't think that we can expect them to have all of the problems solved forever, or that something isn't going to get dropped at some point by any of the offices involved. People make mistakes, and that's why we have a process for people to come back and rectify those mistakes. This is the reason there is a process for a waiver. Maybe we're decreasing the percentage of mistakes, but since there are a lot more projects going on, we'll probably continue to see these. Mr. Mueller stated, It seems like a no brainer when you've invested more money than you anticipated, we're happy to have you continue to invest, we want you to invest more. Committee Chair Ferlic opened the floor for public comment. EXCELLENCE I ACCOUNTABILITY I INNOVATION I INCLUSION I EMPOWERMENT 455 County-City Building 1227 W.Jefferson Bvld I South Bend,Indiana 46601.1 p 574.235.9221 If 574.235.9173 TTD574.235.5567 iwww.southbendin.gov 7 CITY OF SOUTH BEND I OFFICE OF THE CLERK Jamie Reese, 112 W. Jefferson stated, I'm here representing the building owners and developers of the Studebaker Lofts project. This project was done previous to the two (2)year extension, so we received this abatement in June of 2015. The project opened on March 15, 2017,which was prior to the June 22nd 2017 expiration. However,based on the timeline that Mr. Mueller shared earlier,that Form 11 didn't get picked up until July 17, 2018 because as of Jules, the building was not technically fully completed. The 322 has been filed based on that Form 11 that we received in July of this ye , so everything should be fine other than the timing issue of just one (1)month. AJ Patel, President of JSK Development, 247 Dixie Way North, stated, We finished the courtyard back in April of 2018, and the Hall of Fame just closed recently. We opened the [Holiday Inn] Express on the south side in Jam, so we're pretty close to our time limits. Kevin Smith, 635 S. Lafayette Blvd., representing the Studebaker District stated, The major pieces that we found were 40,000 yards of bricks in the parking lot which we didn't anticipate. The other is that because of the age of the building, the water mains were old and much more difficult than expected. We just had to work around things to reestablish them. Also, because of all of Notre Dame's investment, it was a challenge to get resources, contractors and materials. Those were the three (3) main elements that drove our timetable up. Matthew Huff, 1302 W. Sample Street, representing Imagineering, stated, Our project was originally going to be developed for one (1) customer in a very large facility. That ended up falling through at the end, so we had to reevaluate the whole situation.Now instead of adding one (1) line, we're adding three (3) lines and so our project became much larger. Mark Neal, 112 W. Jefferson Blvd., representing the Tower at Washington Square, stated, The building was expected to have a$30 million renovation, the focus was on the shell of the windows, hotel and garage. We are already about $10 million over the original investment amount expected for the entire building with just the hotel and the garage completed. The residential and retail portions are looking to be completed in the next year. The owner is spending quite a bit more than expected, so he wants to make sure that all of the decisions he makes are good ones. He is excited to complete the project in 2019. Sue Kessim, 4022 Kennedy Drive, stated, I am probably most familiar with the Renaissance Project. I've been to a lot of meetings there and I think it's a great thing to save that building. I really appreciate not putting it in the landfill, especially with all of the asbestos and lead, so I really appreciate, not only from an economic standpoint, but from an environmental standpoint, all that you've done to repurpose and reuse and do it properly. I know that project has taken way longer, but I think it was a good investment and I appreciate all that you've done. I took a tour recently and it was really nice. I researched abatements from 2011 to 2017. In 2017 there were $36 million given in abatements. Hopefully they will make good on the promises. A lot of them they call a phase in,there's no phase in if there is zero (0)taxes for ten(10) years. In other communities in my research on the TIFs, when you give TIF money, the taxpayer is already investing. They don't typically get the abatements. The taxes are where the taxpayer gets paid back for making the investment with the TIF. South Bend seems to be more unusual in that. In Chicago,they're in financial crisis because they used TIF and abatements. As you're considering this, I want you to consider in general, the process of having so many abatements. A lot of the EXCELLENCE I ACCOUNTABILITY I INNOVATION I INCLUSION I EMPOWERMENT 455 County-City Building 1227 W.Jefferson Bvid I South Bend,Indiana 466011 p 574.235.9221 If574.235.91731TTD574.235.5567Iwww.southbendin.gov 8 CITY OF SOUTH BEND I OFFICE OF THE CLERK figures in the 2017 report from Community Investment were left blank, so it was hard to analyze. To Mrs. Broden's point,the process needs fixing. The Council needs to be cognizant of how much this is going to cost. The packet did not tell us how much money we're giving up in taxes, so how do you make a decision when you don't know the return on investment or the amount of taxes? The taxpayers see their property value go up, so I think there needs to be a real evaluation. The City posted a$62 million deficit last year. I don't know if we can afford tax abatements. I want to bring these points out as a citizen, a taxpayer and a homeowner. Looking at the City deficits and that our cash reserves are down$87 million in the last three (3) years. I would like to know how much money we are giving these people. Mr. Mueller stated, We are talking about tax abatements, and we mentioned earlier today that this is a tax phase in so we're losing zero (0) dollars. I can assure you that these projects would not have moved ahead without the incentives. All of the benefit that we are going to get from this increased assessed value would not exist, so we would actually be losing money by not incentivizing these projects. Regarding the comment about TIF versus tax abatements, we talked about the philosophy of incentives in December and one (1)of those slides is in our appendix in this presentation. This shows that the benefits of using tax abatements include mitigating risks, and closing financing gaps because the market does not necessarily support the costs of construction right now. Construction costs are high, and you aren't going to make that up through the rent you're charging, so you have to fill in the gaps. Larger projects are more complicated, and sometimes we challenge developers to do larger projects than what they bring to us. There are also competitiveness issues, and other policy goals such as sustainability, equity, or other things we like to promote with incentives. We're trying to move more of the development to tax abatements because that is an inexhaustible supply with less risk. It is lower risk to the taxpayer than TIF, and it scales with new investment levels. It also only goes into effect if and when a project investment occurs, as opposed to putting TIF into a project that starts and then fails, and you're left with a half-completed project. The tax abatement only goes into effect if the project is done. You're not limited by geography or competition of other supported projects. We're trying to free up TIF funds for use with more public investments such as the Parks and Trails Investment, neighborhood plans and public infrastructure. Committee Chair Ferlic reminded committee members, We are just looking at extending that time period specifically. Committeemember Sharon McBride made a motion to send Bill Nos. 18-42, 18-43, 18-44, 18-45, 18-46, 18-47, 18-48, 18-49, 18-50, 18-51, and 18-52 to the full Council with a favorable recommendation. Committeemember Regina Williams-Preston seconded this motion which carried by a voice vote of three (3) ayes. With no further business, Committee Chair Ferlic adjourned the Community Investment Committee meeting at 4:46 p.m. Respectfully Submitted, v` Gavin Ferlic, Committee Chair EXCELLENCE I ACCOUNTABILITY I INNOVATION I INCLUSION I EMPOWERMENT 455County-City Building 227 W.Jefferson BvldI South Bend,Indiana 46601Ip574.235.9221 f574.235.9173 TM574.235.5567;www.southbendin.gov 9 I