Reassessing Subsidies for Economic Development

This week, the Wall Street Journal reported on an interesting portion of President Obama’s proposed 2016 budget: the barring of tax-exempt bonds in the financing of professional sports facilities. The Treasury Department believes the trend toward this practice has “shifted more of the costs and risks from the private owners to local residents and taxpayers in general.”

These costs and risks have been all too familiar to Georgians over the past two years — the promise of economic development prompted quick (some would argue hasty) action committing a massive amount of public money to both the Braves and Falcons projects.

Stadiums are just one of the many examples of public give-aways to subsidize private buisness that are sold to the legislature and the public as economic development and job growth projects in which the costs to the public far exceed the public benefits. Georgia is among a majority of states that does not perform any real analysis before granting these exemptions or subsidies for business development or other purposes.

Georgia apparently also does not follow up to determine whether a business such as the Caterpillar or Kia plants actually deliver on their promises to employ X numbers of people at certain wages or salaries, or otherwise deliver on their promised economic benefits.

For example, the state grants tens of millions of dollars annually in tax credits to the movie industry (and maybe other exemptions from sales or other taxes that we don’t know about). The effect of these and other tax exemptions and credits is to shift the burden of taxation to finance state operations to other taxpayers and revenue sources.

The citizens of Georgia are asked to take it on faith that  these tax credits to the movie industry are economically justified—but the catch is that no one really knows whether that is true or not—much less the extent of the public benefit in excess of the cost to the public of those tax credits.

The General Assembly made no study before enacting the tax credits and has no economic data to show whether the public benefits from the expenditures by the movie industry in Georgia are sufficient to outweigh the cost of the lost revenue  from these tax credits.

Common sense as well as sound fiscal policy would require that the state perform a competent and thorough cost-benefit analysis before granting tax exemptions, tax credits or subsidies either to lure new business to Georgia or retain or expand existing businesses. The state should be prohibited from giving away public funds (because that is precisely what grants, exemptions and subsides are) on faith or based on a show of hands without clear and convincing evidence that the public at large (and not a select few) will derive tangible benefits that are at least equal to or exceed the cost of the foregone tax revenues.

The state should also be required by law to follow up and enforce the promises made by promoters and developers to create new jobs in Georgia for Georgia residents (and not residents living in Alabama, as is true of many of the workers at the Kia plant).

Our elected officials are supposed to be trustees and fiduciaries of the people, yet consistently expose them to increasing amounts of risk in the name of economic development year after year.

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Rapidly Decreasing Transparency in Savannah

To underscore the need for increased transparency and accountability across the state, we are calling today for the Savannah-Chatham County School Board to recommit to providing the public with robust and timely access to their business. In recent months the board has eliminated easy access to their minutes, dramatically reduced their reporting details on payments to vendors, and ceased providing printed materials to members of the public attending their meetings.

As recently reported by the Savannah Morning News, Connie Hall, a member of the board and the sole dissenting voice on this recent slew of changes, put it best: “We’re going down a slippery slope…I don’t see a reason for that.”

CCGA believes the Board should treat the taxpayers of Savannah and Chatham County with the respect they deserve. Our organization is committed to holding power accountable; the elimination of the public’s access to basic minutes is in violation of state law and actions like this further erode the public’s trust in government. How can a citizen of Chatham County be engaged in the business of public education when their local elected officials actively discourage them from participating in the process?

The citizens of Chatham County deserve greater transparency to prevent even the appearance that the public is being shut out.

The formal letter from CCGA to School Board President Jolene Byrne can be seen here.

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Distrust in Government Tops Year End Charts

Each year, Gallup compiles monthly results on surveys gauging what Americans view as their nation’s biggest problem. This year, after averaging combined results of about 12,000 adults, the research company announced that poor government leadership was 2014’s top problem.


These results should come as little surprise to those in the peach state. 2014 in Georgia was marked by scandal after scandal; a trend that continues to erode the public trust and exacerbate the state’s last-place ranking on ethics.

The state paid over $3 million in taxpayer dollars to whistleblowers at the state ethics commission this past year, including a $1.15 million jury award to its former executive director, Stacey Kalberman. In DeKalb county, disgraced county commissioner Elaine faces 1-2 years in federal prison after abusing county credit cards and pleading guilty to fraud. The county’s former CEO also spent 2014 on trial for allegedly shaking down county contractors for campaign contributions. A mistrial was declared in October, but Burrell Ellis will be back in the courtroom in 2015.

The City of Atlanta has also been dogged by issues of ethical conduct and transparency. City Councilmember Michael J. Bond faces questions of ethical misconduct after 11Alive’s Catie Beck found discrepancies and suspicious activity in the city official’s expense account records, sparking an investigation by the Atlanta Ethics Office.

Bond’s fellow city councilmember Felicia Moore has received steely responses from the city’s administration over transparency issues that have been swirling around massive payouts that essentially traded city employee’s unused vacation time for cash from the city’s coffers.

Those are just a sampling of why Georgians have had plenty of reasons to distrust their government in 2014.

The legislative session is upon us and, in 2015, Common Cause Georgia will continue to attempt to close the gap of distrust that has lodged itself firmly between the public and their elected officials. We’ll be working hard this year to create a more independent ethics commission, with an independent appointment and funding process that can restore faith in the work it does and serve as a foundation for repairing the damaged reputation of the agency. We will also be working to pass civil asset forfeiture reform, which would prevent abuses by law enforcement agencies and other government agents who engage in the punitive practice of confiscation of assets when no crime is committed.

Restoring trust in government is always a top priority for us and we will once again take up the fight to hold power accountable.

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He Called Her a Liar!

So perhaps he didn’t use the word “liar”, but consider the words that were used by a Fulton County Superior Court Judge to describe the Executive Secretary of our state ethics commission, as well as her actions:

-       Dishonest                                           -   Secrecy

-       Non-transparent                                 -   Document-hiding

-       Appallingly                                         -   Injustice

-       Flagrant Disregard                             -   Undermining of Confidence

“Liar” doesn’t appear in those words, but it’s not a stretch to say the word could have easily been used within the shocking ruling. Perhaps at today’s hastily called special meeting of the ethics commission these harsh words will lead to what we at Common Cause Georgia have called for since June – the termination or resignation of Holly LaBerge. We have called publicly not once, but twice for LaBerge’s resignation or termination. We’ve also long called for substantive reform of the ethics commission, and while comprehensive reform will require action from the state legislature, a change in leadership must take place now to ensure effectiveness of future, structural upgrades to the agency.

Late Wednesday afternoon, Judge Ural Glanville handed down sanctions damning LaBerge, the current Executive Secretary of the Georgia Government Transparency and Campaign Finance Commission; ordering her to personally pay a fine of $10,000 for failing to cooperate in discovery during the Kalberman trial.

The judge was straightforward and firm in his nine-page order detailing the misconduct by both Ms. LaBerge and the Attorney General’s office (who he also ordered to pay a $10,000 fine). In her testimony, LaBerge pointed her finger at Brian Webb and the AG’s office, claiming it was their responsibility to make sure Kalberman’s team received the bombshell memo she kept locked in a drawer in her office for two years. The judge, however, was unmoved. “Rather than erring on the side of transparency and a fair resolution of the legal issues raised in this matter, the Department chose nondisclosure and Defendant LaBerge chose, purportedly for her own personal reasons, secrecy and document-hiding.”

He “is extremely troubled by the behavior of Defendant LaBerge, who has been dishonest and non-transparent throughout these proceedings.” He reiterated that point later on in the order, in describing the scope and long-term effect of this misconduct which he argued “not only amounts to a flagrant disregard for the basic rules governing litigation and the fair resolution of legal disputes in the State of Georgia, but also an injustice and an undermining of confidence imposed by the citizens of the State of Georgia in the legal system…most appallingly, Defendant LaBerge, who has repeatedly proven herself to be dishonest and non-transparent.”

When asked by the AJC what he thought of the decision, Georgia State University Law Professor and director of the National Institute for Teaching Ethics & Professionalism, Clark Cunningham, observed, “The judge clearly wants to send a message to the ethics commission and the attorney general about their unethical conduct.”

When current chair of the commission Hillary Stringfellow was asked to justify how the commission could keep LaBerge employed, she hesitantly responded “I would rather not respond to that question right now.”

Today could truly be the start of the changes we need to have an independent and honest state ethics commission – and that’s no lie!

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501(c)(4) Donor Disclosures and Free Speech

Note the following post was authored by Terry Taylor, a Common Cause Georgia board member. It should be read, and sits alongside, with the previous post by another CCGA board member, Jon Sinton.

501(c)(4) Donor Disclosures and Free Speech Many organizations such as Common Cause that are calling for 501(c)(4) donor disclosure have a sincere desire for openness. The concept is straightforward: Citizens have a right to know who is trying to influence them in political ads and other media. That makes a great deal of sense.

But it doesn’t end there, because these responsible disclosure advocates aren’t the only voices asking for this information. For every one of them, there’s a zealot whose goal is to use disclosure as a cudgel to silence those with different views.

Disclosure opponents aver that, if identities were made known, donors would suffer reprisals. We are told by disclosure advocates that the fear-of-reprisal argument is a red herring. They tell us – with the measured patience of an adult talking to a small child or a yellow lab – that when you advocate for something publicly, you sacrifice any right to anonymity. If you speak in the public square, you must run the risk of reprisal and be comfortable with the consequences. That’s all there is to it.

Consider Brendan Eich, the Mozilla CEO who was forced to resign because he made a $1,000 contribution to an anti-same sex marriage campaign in California. He was hounded out of his job for having the identical belief as Obama at the time, along with 48 percent of his state. Eich never made public comments about the subject, and he made the contribution as a private citizen, not as CEO or on Mozilla’s behalf. But he lost his job in 2014 because he wrote a check in 2008. The message to Mr. Eich: You may only write checks as a private citizen to support “correct” opinions.

Another example is Georgia’s Dan Cathy, who made a public statement against same-sex marriage based on his religious beliefs. In this case, it’s government that’s punishing him for having the temerity to talk about his faith-based views. Because of this, the City of Chicago, along with Boston, said that Chick-fil-A was not welcome and prohibited the company from expanding there. Here’s what journalist Glenn Greenwald, who is in a same-sex relationship, said about the subject in a article:

“Obviously, it’s perfectly legitimate for private citizens to decide not to patronize a business with executives who have such views. Beyond that, if a business is engaging in discriminatory hiring or service practices in violation of the law — refusing to hire gay employees or serve gay patrons in cities which have made sexual orientation discrimination illegal — then it is perfectly legitimate to take action against them. But that is not the case here; the actions are purely in retribution against the views of the business’ top executive on the desirability of same-sex marriage.

“Having mayors and other officials punish businesses for the political and social views of their executives — regardless of what those views are — is as pure a violation of the First Amendment’s guarantee of free speech as it gets, and beyond that, is genuinely dangerous.

“If you support what (Mayor Rahm) Emanuel is doing here, then you should be equally supportive of a mayor in Texas or a governor in Idaho who blocks businesses from opening if they are run by those who support same-sex marriage — or who oppose American wars, or who support reproductive rights, or who favor single-payer health care, or which donates to LGBT groups and Planned Parenthood, on the ground that such views are offensive to Christian or conservative residents. You can’t cheer when political officials punish the expression of views you dislike and then expect to be taken seriously when you wrap yourself in the banner of free speech in order to protest state punishment of views you like and share.”

The belief that, if you speak in the public square you must run the risk of reprisal and accept the consequences, is central to the 501(c)(4) disclosure argument. I’d agree that if a company takes a public stand on an issue, customers are free to make their own decisions and patronize the company or not. But if the political statements or donations are made by an employee as a private citizen, is it appropriate to attack the company? Or to force the company to fire the employee? Is it the government’s role to sanction a company because of a CEO’s faith and beliefs? If they were being honest, many ideologues would say yes, because the real goal is to silence the speech.

These examples were not 501(c)(4) donor issues. But we can expect a lot more of this type of free-speech mugging with 501(c)(4) donor disclosure. This is a cost we’ll pay, and I’m not sure how high it will be.

I agree with my friend Jon Sinton who said in another blog post that money is smart and will find a way to make its influence felt. The same can be said for political organizations on the right and left. SEIU’s so-called worker centers – composed not of laborers but professional demonstrators — can be mobilized at a moment’s notice to create large demonstrations that pretend to be spontaneous worker uprisings. The Tea Party is active for its causes, and electronic media has the potential to destroy people and organizations with great ease and speed. They are learning just as quickly as money is about how best to wield the weapons at their disposal.

I believe in disclosure and transparency, but I admit to having mixed feelings about a full-throated call for 501(c)(4) donor disclosure. I believe there are many who seek this information for the sole purpose of limiting the speech of others, and it’s naïve to think otherwise. And as Greenwald said, we can’t complain when someone of our ideology suffers unfairly when we have cheerfully embraced the punishment of opponents for the same thing. Because it’s bad enough to be naïve without being hypocritical too.

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Note the following post was authored by Jon Sinton, a Common Cause Georgia board member.


There is a dangerous and specious argument afoot that says big money political advertisers should not have to disclose their identities.

While money does not appear to have been decisive in the high profile elections where profligate spenders Carly Fiorini and Meg Whitman were defeated, it may be that the very public nature of their profile prevented the overwhelming spending from being effective. Secretive spending in lower profile cases may have been effective, but absent disclosure, we will never know. Moreover, as a long time media owner/operator, consultant, and researcher, I can tell you that the money is smart and will learn from its mistakes. They will correct their errors, refine their processes, and reach their goal of exercising anonymous influence in the market of ideas, and over an unsuspecting electorate. This strikes me as patently un-American.

Fear of undue influence and unscrupulous behavior is precisely why the Federal Trade Commission demands identification of commercial sponsors. We decided long ago, and properly, in my estimation, that “truth in advertising” was a basic consumer right. We banned outlandish, unsupported claims, outright lies, and the anonymous wielding of the huge power of advertising. Why in the world would we demand less of something as critical as our political speech?

The fear of reprisal argument that disclosure opponents are proffering is a red herring. The plutocrats–that is people whose power derives from their wealth– suggest that if their identities are known, they risk personal, potentially violent, reprisal and commercial boycotts. But simply put, the public’s right to know trumps any advertiser’s professed right of anonymity. When you enter the public square, you do so with the knowledge that speech has consequences. Not wanting to endure the consequences of unpopular speech is not reason enough to be allowed to act anonymously in the public square.

The fix is also simple: require the 501(c)(4) organizations that bundle money for the Super PACs to disclose the identity of their donors. It’s the American Way.

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Cobb Judge Must Recuse Himself

Note the following post was authored by Terry Taylor, a Common Cause Georgia board member.


On July 7, Cobb County Superior Court Judge C. LaTain Kell, Sr., is scheduled to preside over a validation hearing for bonds to secure public funding for the new Atlanta Braves stadium. The hearing is a necessary step in the project to bring the Braves to Cobb County, one that everyone knew was coming. There’s a problem, however, and a big one as things currently stand.

The Atlanta Journal-Constitution (“Judge in Braves hearing has personal ties to Cobb chairman,” June 26, 2014) reports that Judge Kell has personal ties to Cobb County Board of Commissioners (BOC) Chairman Tim Lee: His mother worked as chairperson for Chairman Lee’s 2012 re-election campaign. In addition, Judge Kell serves as a “special appointee” to the Cobb Chamber of Commerce’s board of directors. The AJC reports that “chamber has 28 special appointees, which are voting members of the board, including Braves executive vice president Mike Plant.”

Chairman Lee was the driving official force in the stadium deal, and he continues to be the most prominent advocate for public funding. The Cobb Chamber of Commerce has been the biggest privet-sector promoter for the stadium and the issuance of bonds that put Cobb citizens on the hook for hundreds of millions of dollars over 30 years.

Impartiality in our judicial system is absolutely essential, and the perception of impartiality is equally important for the  public to have faith that our courts are fair. Given the facts of the situation, Judge Kell should recuse himself from the hearing and make way for someone who has no connections with the deal’s most ardent supporters.

This is not a question of Judge Kell’s integrity, nor am I claiming that something sinister happened in his selection to preside over the hearing. As the AJC noted, cases are assigned to Superior Court judges randomly by computer. It’s simply an issue of ensuring that the public has no reason to perceive that conflicts of interest are seeping into the process. I would make the same call for recusal if the judge involved was associated with anti-stadium groups.

Common Cause Georgia doesn’t oppose the stadium or the county’s involvement. Before the deal was approved by the Cobb BOC, we advocated for a referendum that would have allowed citizens to make their voices heard. We continue to focus is on transparency and full details as the stadium moves forward — and no conflicts of interest, whether real or perceived.

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Is there “nothing there” when you look at the SCLC?

Note the following post was authored by Terry Taylor, a Common Cause Georgia board member.


The decision by the Cobb Board of Commissioners (BOC) to provide public funding for the new Braves stadium has been controversial from Day One. So it was no surprise that emotions ran high at the May 27 BOC meeting when commissioners voted on a bond resolution needed to move forward.

My thoughts today have nothing to do with how the only public comment speakers that evening were those in support of the stadium project. Nor are my remarks about the way in which the particulars of the bond deal became public or the lack of time allowed for the citizens to review them. Instead, I’d like to focus on a passage that appeared in a June 1 Atlanta Journal Constitution article (“Lee says Cobb County Commission followed rules in limiting speakers”). A vocal proponent of public funding support for the stadium, John Loud was quoted as saying the following about opponents of public funding for the stadium:

“There’s five or eight people who get to be the vocal minority, and when you look at the organizations behind them, there’s nothing there,” Loud said. “So my feeling was … let’s protect Cobb County. Let’s protect the branding. The opposition was spreading a lot of emails around, so let’s pack the room.”

So, if a reader believes Mr. Loud. there’s “nothing there” when you look at the organizations behind the folks who oppose the stadium deal. But on May 27 at the BOC meeting, Dr. Benjamin Williams was the lead spokesperson for the group that night and was the one who asked to be heard. In fact, he was only a few feet away from Mr. Loud that night when he made the request.

Dr. Williams is the chapter president of the Cobb County SCLC, also known as the Southern Christian Leadership Conference. The SCLC is one of our nation’s most important civil rights organization, and it has a long and proud history of advocating for fairness and equality for all citizens. When I look at the SCLC, I don’t think there’s “nothing there.”

In the AJC article, Mr. Loud is identified as a small-business owner who recently was appointed to lead the Cobb Chamber of Commerce’s executive committee. Do these comments also reflect the Cobb Chamber of Commerce’s views, that there is nothing there when you look at the SCLC and other stadium opponents?

Mr. Loud has a right to push for public funding for the stadium if that’s what he believes is appropriate. And Common Cause Georgia doesn’t oppose the stadium or the county’s involvement. Our focus is on transparency and full details. But I find his dismissive comments about opponents to be curious at best. Perhaps Mr. Loud meant to say something else but just articulated it in a clumsy and artless way. That happens.

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Silence Whistle-Blowers?

This Tuesday Governor Deal intimated that he may have a solution to prevent future controversy at our state ethics commission. Sounds like a great idea at first, given that taxpayers got rocked by a $1.15 million award to the commission’s former Executive Director last month, who a jury ruled was fired for aggressively investigating complaints against the Governor’s campaign. However, Deal’s solution takes a sharp turn toward hypocrisy when you hear the details.

His plan? More narrowly define who is and is not a whistle-blower, i.e. reduce the opportunities for state employees to bring a lawsuit against the state for wrongful termination when they are fired for political purposes.

So to get it straight, a jury rules a state employee wrongfully had her salary drastically cut, leading to her resignation, as a result of investigating legitimate complaints against the Governor and these complaints, which were lodged by citizens, would not be allowed to go to court under the Governor’s proposed change?

Here’s our counter offer: true reforms at the commission so its employees are beyond being fire for political purposes.

Making it harder or completely preventing employees to blow the whistle when there is wrongdoing in state government sends the wrong message to a public who is already highly skeptical of how much power can be held accountable in Georgia. Whether or not you agree with the verdict, 12 voters in Fulton County agreed unanimously that Kalberman was fired for investigating the Deal campaign too aggressively.

We need to encourage the establishment of a more independent commission that is beyond even the perception of political influence, one that can effectively investigate complaints. Or, at the very least, allow those with wrongful termination or whistle-blower cases to have their day in court. How else could those courageous enough to stand up when they see wrongdoing, or get fired for blowing the whistle, have protection when they do what is right?

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The Biggest Waste and Inefficiency of All?

Note the following post was authored by Wyc Orr, a Common Cause Georgia board member.

How revealing, last week’s outcry from the Co-Chair of Atlanta Mayor Kasim Reed’s own new Commission on Waste & Efficiency in Government, about the devastating infrastructure costs facing the City – costs which cannot be avoided or put off any longer. Even more, what a key that cry provided to the City’s finally coming to terms with the true costs to the City of the new Falcons’ stadium. On these two critical issues, if the Atlanta City Council is ever going to step up to meet its responsibilities as stewards of the taxpayers’ money – and as a body which is supposed to exercise its own independent judgment as a check on undue mayoral power — the time is NOW.

It is remarkable that the little-noticed dire disorder in the City of Atlanta’s financial house — including the looming infrastructure backlog “trauma [which] will follow for many years” (as described by City Council member Howard Shook, that Co-Chair of the mayor’s newly-appointed Commission) resulting from the City’s failure to have budgeted or provided for some One Billion Dollars in overdue infrastructure improvements — has not been related by anyone to the City’s profligate authorization to help finance the Falcons’ stadium.

Worst still, the Mayor now wants that Commission to support a bond referendum to the tune of as much as $250M, as a partial step toward dealing with this “trauma.” How ironic that Mayor Reed wants this referendum, only because the law requires it for such bonds to be issued, while he so steadfastly resisted a public referendum for approval of the stadium spending. Why does the Mayor want this bond issue? Because he doesn’t want to impose a tax hike now on City residents. In other words, he isn’t willing to face up to the fact that taxes may indeed eventually have to be raised because hotel/motel taxes were diverted to the stadium instead of critical infrastructure needs. The City’s excuse that state law doesn’t allow those hotel/motel taxes to be used for infrastructure just doesn’t hold up — not only is a serviceable and safe infrastructure clearly related to the promotion of tourism and convention trade to which those taxes are dedicated — who would want to come to a city where there are crumbling streets and bridges, unsafe conditions from that, and poor water and sewerage?  — but if a change in State law is required (and there are already more exceptions under State law to use of the hotel/motel taxes than potholes in Atlanta’s streets), that should be easy enough to obtain where a local legislative delegation comes together in support. (Besides, presumably state legislators don’t want to collapse through dilapidated streets or bridges when they are in town.)

So why’s Common Cause Georgia on this issue once again? Simple. As oft repeated, we are not against the stadium, or even public financing of it. But we ARE for open, accountable, responsible and responsive government at all levels. And assisting “the people” in having meaningful input and a real voice in critical planning and implementation of major pocketbook decisions is at the heart of what we do at CCGA. And those hallmarks — open and accountable government — have simply been ignored by the City in this entire “stadium versus infrastructure” debacle.

It is obvious that the Mayor is so in lock-step with the Falcons and National Football League that he is impervious to any reconsideration of any aspect of the City’s financing of the stadium. But what of the City Council? What of its responsibilities as City stewards? — especially given the new Commission Co-Chair’s description of the infrastructure backlog as “the world caved in on us.”  Doesn’t this “trauma” mandate a thorough Council reconsideration of the full amount of the hotel/motel taxes which will be diverted to the stadium over its anticipated life? If City Council members are ever going to act, this is the time — NOW — not indefinitely and timidly over the next few weeks or months if at all. They should band together, call their own press conference, decry this traumatic crisis in the City’s finances, link it to the true stadium numbers, push for an emergency council session if necessary, and call for a reassessment of the hotel/motel tax moneys that will flow into the stadium. IF the ordinance which authorized the $200M for the stadium is truly murky and doesn’t in fact authorize hundreds of millions of dollars (maybe up to $1B or more) above and beyond the $200M – that is, if the Falcons and others have not gained vested contractual rights to sums far above the $200M — then an ordinance which clarifies or otherwise documents that the council only authorized $200M and not infinite sums above that would be in order. Such a move by the City Council could further address any needed amendments to the hotel/motel state law if necessary, so that those moneys could be directed toward the infrastructure crisis. On the other hand, if the City is now legally locked into a commitment to vast sums beyond the advertised $200M, including having committed the hotel/motel tax so that it is no longer available for the huge infrastructure liabilities, then that fact should clearly be made known, and included among the true costs of the stadium to the City.

And finally – note to the new Commission on Waste and Efficiency: you can expedite your work, and avoid becoming the oft-used “fig leaf” or mere “window dressing,” by looking squarely at – and forcing the mayor who appointed you to face up to – the inescapable connection between the City’s hotel/motel tax and the City’s as yet still unquantified total sum to be lavished upon a stadium. That stadium may be shown to be the biggest waste and inefficiency which you have been appointed to identify and root out. Resolve that, and your work may be largely done.

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