Virginia Regulatory Town Hall
Agency
Department of Housing and Community Development
 
Board
Board of Housing and Community Development
 
Guidance Document Change: Local Zone Administrator’s Management Manual 2019
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11/26/19  9:29 am
Commenter: David M. Sacks

Comments on Local Zone Administrator’s Management Manual
 

Several comments to address in the draft Virginia Enterprise Zone Local Zone Administrator's Management Manual.

  1. Cover Page:  Add a date on the cover page.   My experience is that this document is updated regularly.  Although a year is in the footer on most pages, a date should also be on the cover.
  2. Page 3, second paragraph, last two sentences.   These two sentences seem irrelevant now since FY 2019 ended five months ago.   Recommend deleting these sentences or rewriting.
  3. Page 3, Under “Zone Administration and Oversight”  there is a link to the “Virginia Enterprise Zone Program Regulations”   That link connects to a set of the regulations that does not include the new paragraph in 13 VAC5-112-10  or the new language in 13 VAC5-112-340  with regard to the installation of solar panels as an eligible real property investment.   They also do not include the changes regarding the number of renewal periods (13 VAC5-112-530. My understanding was that these regulatory changes was adopted by the Board of Housing and Community Development on May 13, 2019.
  4. Page 6, Under “Boundary Amendments”  this is also a link to obsolete regulations.
  5. Page 7, “Incentive Amendments”  The language regarding not allowing the removal of an incentive without having an equal or superior incentive "offered" does not appear to be consistent with the regulatory language in 13VAC5-112-490 K.  The regulatory language allows previous amendments that enhanced the incentives to be considered when approving removal of incentives.  In other words, addition of incentives in prior years can be considered as an “equal or superior” replacement for a deletion in a later year.    Please modify the language in the Manual accordingly
  6. Page 13. Under “Marketing Enterprise Zones”.  I would strongly recommend including in the list in the second paragraph a very effective tool we have used in Henrico County:  Monitoring property changes and sending letters on a regular basis to new enterprise zone property owners.
CommentID: 76971