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Cletis Kendrick Petitioner Vs. City Of Detroit Respondent · 26-002687-TT

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EXHIBIT 6 

DETROIT CITY CODE DIVISION 8 — MANDATORY AUTHORITY-CHAIN 

REQUIREMENTS FOR SMS/SWF SPECIAL ASSESSMENTS 

Exhibit 6 — Page 1 of 17

Source Record: 

Detroit City Code, Chapter 44, Article III, Division 8, “Special Assessments for Snow Removal, 

Mosquito Abatement, and Security Services.” Division 8 implements MCL 117.5i and governs 

Detroit’s claimed authority to finance snow removal, mosquito abatement, and security services by 

special assessment. 

Short Title: 

Division 8 / Governing SMS/SWF Authority Chain 

Purpose of Exhibit: 

This exhibit is offered to identify the mandatory Detroit ordinance requirements governing the 

SMS/SWF special assessment charge challenged in this appeal. Division 8 is the City Code framework 

Detroit purports to use for special assessments financing snow removal, mosquito abatement, and 

security services/patrol. 

This exhibit is material because the current 2026 SMS/SWF charge is derivative of Detroit’s claimed 

2023 Sherwood Forest SAD renewal. Detroit cannot establish lawful authority merely by placing a 

charge on a tax bill or by generating later billing records. Detroit must prove that it satisfied the 

mandatory authority-chain requirements of MCL 117.5i and Detroit City Code Division 8 before 

relying on the claimed 2023 Sherwood Forest SAD renewal to impose and continue collecting the 

SMS/SWF charge. 

This exhibit does not establish that Detroit complied with Division 8. It establishes the rules Detroit 

had a legal duty to follow when invoking Division 8 special assessment authority. 

Material Record Points: 

1. Division 8 implements MCL 117.5i for special assessments financing snow removal, mosquito

abatement, and security services.

2. Division 8 defines the services covered by the SMS/SWF charge as snow removal from streets,

mosquito abatement, and security services.

3. Division 8 requires the sponsoring neighborhood organization to qualify as a designated

neighborhood improvement organization, including Michigan nonprofit good-standing status.

4. Division 8 requires the completed petition to be signed by record owners of not less than 51%

of the land within the proposed special assessment district.

5. Division 8 requires the City Clerk to receive the petition, file the original petition, report receipt

to City Council, and forward a copy to the Administering Department.

6. Division 8 requires the Administering Department to review petition compliance and, if the

petition satisfies the ordinance, submit a report to City Council verifying petition validity.

7. Division 8 requires the Administering Department to obtain a tentative assessment roll from the

Board of Assessors and include that roll with its report to City Council.

8. Division 8 requires City Council, after receipt of the report and tentative assessment roll, to

adopt a resolution fixing the time and place of the public hearing.

9. Division 8 requires hearing notice to state that the plans, term, estimated costs, and tentative

assessment roll are on file in the City Clerk’s Office for public examination.

10. Division 8 requires City Council, after the required hearing process, to adopt a resolution

containing the petition sufficiency determination, district boundaries, services, estimated

assessed cost, estimated tax parcel share, benefit finding, term, redetermination dates, and date

for the roll-confirmation hearing.

11. Division 8 requires the Board of Assessors to prepare and file the special assessment roll with the

City Clerk, the Clerk to forward the roll to City Council for confirmation, and City Council to

confirm the special assessment roll.

12. Division 8 requires the Clerk, after confirmation, to endorse the confirmation date on the roll

and deliver a copy of the confirmed roll to the Board of Assessors, Treasurer, and sponsoring

designated neighborhood improvement organization.

13. Division 8 allows the Treasurer to collect the special assessment annually during the term only

after the special assessment roll is confirmed and delivered.

14. Division 8 requires annual accounting, reporting, reassessment, recalculation of tax parcel

share, and new roll procedures during the term.

15. Division 8 requires continuation of an existing special assessment district beyond its term to

occur in the same manner that a special assessment district is created.

16. Petitioner offers this exhibit to identify the mandatory authority-chain requirements Detroit must

prove before relying on the claimed 2023 Sherwood Forest SAD renewal to support the 2024,

2025, and current 2026 SMS/SWF billing sequence.

Tribunal Relevance: 

This exhibit is material because it establishes the legal framework Detroit had to follow before relying 

on the claimed 2023 Sherwood Forest SAD renewal to impose and continue collecting the SMS/SWF 

charge through the property-tax system. 

Division 8 matters to the current 2026 appeal because the 2026 SMS/SWF charge is derivative of the 

claimed 2023 renewal. If Detroit did not satisfy the mandatory authority-chain requirements for the 

2023 renewal, later billing records, Treasury processing, annual assessment extracts, or administrative 

records cannot independently cure the defective renewal. 

This exhibit also explains why the missing records identified in later exhibits are material. The required 

records are not optional paperwork. They are the records that should show petition sufficiency, 51% 

land-area verification, Administering Department review, tentative roll preparation, lawful hearing 

notice, roll confirmation, Clerk endorsement, Treasury delivery, annual accounting, and continued 

billing authority. 

Exhibit 6 — Page 2 of 17

This exhibit therefore supports the controlling question for the Tribunal: whether Detroit can prove that 

it satisfied the mandatory authority-chain requirements of MCL 117.5i and Detroit City Code 

Division 8 before relying on the claimed 2023 Sherwood Forest SAD renewal to impose and continue 

collecting the current 2026 SMS/SWF special assessment charge. 

Record Limitation: 

Petitioner does not offer Division 8 as proof that Detroit complied with the ordinance. Petitioner offers 

Division 8 to identify the governing legal requirements Detroit had to satisfy. 

Petitioner does not contend in this exhibit that Division 8 itself is invalid. Petitioner contends that 

Detroit has not produced the authority-chain records showing compliance with Division 8 for the 

claimed 2023 Sherwood Forest SAD renewal and the resulting 2024, 2025, and current 2026 SMS/SWF 

billing sequence. 

Petitioner contends that a tax-bill entry, billing explanation, later billing record, Treasury processing 

record, or annual administrative record cannot substitute for the original authority-chain records required 

by Division 8 to support a compulsory special assessment imposed through the property-tax system. 

Insert Behind This Cover Sheet: 

1. Detroit City Code, Chapter 44, Article III, Division 8, Special Assessments for Snow Removal, 

Mosquito Abatement, and Security Services. 

 

Exhibit 6 — Page 3 of 17

- CITY CODE (Chapters 44—49)

Chapter 44 - TAXATION

ARTICLE III. - IMPROVEMENTS AND SPECIAL ASSESSMENTS 

DIVISION 8. SPECIAL ASSESSMENTS FOR SNOW REMOVAL, MOSQUITO ABATEMENT, AND SECURITY SERVICES 

Detroit, Michigan, Code of Ordinances 

(Supp. No. 4) 

DIVISION 8. SPECIAL ASSESSMENTS FOR SNOW REMOVAL, MOSQUITO 

ABATEMENT, AND SECURITY SERVICES 

Subdivision A. General Matters 

Sec. 44-3-171. Statement of purpose; legislative findings. 

(a)

The purposes of this division are to implement the provisions of Section 5i of the Michigan Home Rule City

Act, being MCL 117.5i, which grants cities with a population of more than 600,000 the power to "provide by

ordinance a procedure to finance by special assessments the provision by private contractors of snow

removal from streets, mosquito abatement, and security services" and to "authorize the use of petitions to

initiate the establishment of a special assessment district."

(b)

The City Council finds that:

(1)

The population of the City exceeds 600,000;

(2)

Adequate provision of snow removal from streets, mosquito abatement, and security services will

strengthen property values and enhance the quality of life in City neighborhoods, provided, that the

cost of such services may be above and beyond the basic level of services the City must provide to all of

its residents and business owners;

(3)

The geographic communities within the City will benefit by allowing them to decide the appropriate

level of additional services to provide and pay for themselves;

(4)

As a matter of fundamental fairness, those benefiting from such additional services should share in the

cost of the services. This principle has been recognized in Section 5i of the Michigan Home Rule City

Act, being MCL 117.5i, which provides for the financing of certain additional services by special

assessment, as, by its legal nature, the cost of a special assessment is limited to the level of benefit

provided by the services financed through the special assessment, and only properties so benefited are

subject to assessment. The increased level of benefits provided under this division will be reflected in

the enhanced value of the properties so benefited;

(5)

There are many neighborhood or community associations within the City actively working to maintain

and improve the quality of life in their communities;

(6)

The close involvement with their communities enables neighborhood or community associations to be

responsive to the particular needs and desires of their communities, which may vary from community

to community;

(7)

In light of these findings, designated neighborhood or community associations are an appropriate

vehicle for the practical implementation of the powers provided in this division to finance, contract for,

and deliver the specified additional services authorized by Section 5i of the Michigan Home Rule City

Act, being MCL 117.5i;

(8)

In accordance with the Preamble and Declaration of Rights of the Charter, implementation of this

division will help the City realize its goals of addressing the services and needs of the People of the City

Exhibit 6 — Page 4 of 17

(Supp. No. 4) 

of Detroit, fostering an environment and structure that reflects citizen participation and desires, and, 

as a service institution, providing for the public peace, health, and safety of its residents. 

(Code 1984, § 18-12-120; Ord. No. 07-14, § 1(18-12-120), eff. 6-9-2014) 

Sec. 44-3-172. Definitions. 

For purposes of this division, the following words and phrases shall have the meaning respectively ascribed 

to them in this section: 

Administering Department means the Office of Chief Financial Officer. 

Assessed cost means the total annual cost to be paid by special assessment for the provision of all services 

within a special assessment district, including amounts paid directly to private contractors and any reasonable 

costs incurred by the City and/or designated neighborhood improvement organization for initiating, implementing, 

and administering the special assessment district. 

Board of Assessors means the Board of Assessors as provided for in Section 6-304 of the Charter. 

Designated neighborhood improvement organization means an organization that meets all of the following criteria 

as certified by the Administering Department: 

(1)

Be a Michigan non-profit corporation in good standing;

(2)

Exist for the purpose of maintaining and improving the quality of life in a neighborhood or community

with specific geographic boundaries that are identified in its articles of incorporations or bylaws;

(3)

Satisfy at least one of the following requirements:

a.

Have a board with more than 50 percent of its board members residing within the geographic

boundaries identified in its articles of incorporation or bylaws; or

b.

Have a demonstrated history of serving the geographic boundaries identified in its articles of

incorporation or bylaws;

(4)

Have meetings open to the public, maintain records of such meetings, and compile financial reports;

and

(5)

Not be in default in any obligations to the City.

Record owner means each owner of, or party in interest in, property to be assessed whose name appears 

upon the last local tax assessment record. The last local tax assessment record means the last assessment roll for 

ad valorem tax purposes that has been reviewed and endorsed by the local board of review, as supplemented by 

any subsequent changes in the names or the addresses of the owners or parties listed on that roll, including, but 

not limited to, property transfer affidavits or forms required to be submitted to the Office of Chief Financial 

Officer, Assessment Division, in accordance with Section 27a(10) of the Michigan General Property Tax Act, being 

MCL 211.27a(10), and pursuant to Section 2 of the Michigan Notice of Special Assessment Hearings Act, being MCL 

211.742. 

Service means the provision by private contractors of any of the following within a special assessment district for 

the benefit of all tax parcels for which a tax parcel share is assessed for such service: 

(1)

Snow removal from streets, which may include the portion designed for vehicular travel, the portion

designed for pedestrian travel, or both;

(2)

Mosquito abatement; and

(3)

Security services.

Exhibit 6 — Page 5 of 17

(Supp. No. 4) 

Special assessment district means a geographic area in which one or more services are financed by special 

assessment as established under this division. 

Street means, as likewise defined by Section 43-3-1 of this Code, the entire width between the boundary 

lines of every public right-of-way that is maintained, in whole or in part, by the City and is opened for vehicular and 

pedestrian traffic. 

Tax parcel means a parcel of real property identified for the separate assessment of ad valorem and other 

property taxes by a ward and item number according to the records of the Board of Assessors. 

Tax parcel share means the total annual amount assessed throughout the term of a special assessment 

district to each tax parcel within a special assessment district for the provision of all services. Tax parcel share for a 

tax parcel is determined annually for each year of the term so that each tax parcel will pay an even share of the 

total annual assessment by dividing anticipated assessed cost for that year in accordance with Section 44-3-215 of 

this Code by the total number of tax parcels within a special assessment district, excluding those that are exempt 

pursuant to Section 44-3-217 of this Code pursuant to the following formula: "Tax Parcel Share = Assessed Cost ÷ 

Total Number of Non-Exempt Tax Parcels within special assessment district." 

Term means the duration of a special assessment district created pursuant to this division as specified in the 

City Council's resolution pursuant to Section 44-3-213(a)(7) of this Code, but shall not be less than seven years. 

The term of a special assessment district shall commence from the date of the City Council's confirmation of a 

special assessment roll pursuant to Section 44-3-214 of this Code. A term may be discontinued pursuant to Section 

44-3-222 of this Code prior to its expiration. Any reassessment pursuant to Section 44-3-215 of this Code shall not

affect the term of a special assessment district.

(Code 1984, § 18-12-121; Ord. No. 07-14, § 1(18-12-121), eff. 6-9-2014) 

Sec. 44-3-173. Certification of a neighborhood organization as a designated neighborhood 

improvement organization. 

A neighborhood organization may apply to the Administering Department for certification as a designated 

neighborhood improvement organization by demonstrating in writing that it meets the definition of a designated 

neighborhood improvement organization in Section 44-3-172 of this Code. The Administering Department shall 

require the applicant to submit appropriate documentation to assist in its evaluation. The Administering 

Department may request assistance from other City departments or agencies, including, but not limited to the Law 

Department, the Planning and Development Department, the City Planning Commission, and the City Council 

Legislative Policy Division. Based on its review of the documents submitted by the applicant, the Administering 

Department shall determine whether the applicant meets the definition of a designated neighborhood 

improvement organization in Section 44-3-172 of this Code. Upon completion of its evaluation, the Administering 

Department shall provide a letter to the applicant either certifying that the applicant is a designated neighborhood 

improvement organization or indicating the deficiencies in the application. Where a neighborhood organization 

fails to qualify as a designated neighborhood improvement organization, it may reapply for certification after 

curing any deficiency identified in the letter. The Administering Department shall keep a register of all designated 

neighborhood improvement organizations and shall provide a copy of such register and of all certification letters to 

the City Clerk. 

(Code 1984, § 18-12-122; Ord. No. 07-14, § 1(18-12-122), eff. 6-9-2014) 

Exhibit 6 — Page 6 of 17

(Supp. No. 4) 

Sec. 44-3-174. Administrative rules; establishment, approval, publication, and payment of 

fees. 

(a)

In accordance with Section 2-111 of the Charter, the Director of the Administering Department may

promulgate administrative rules for the implementation and administration of this division.

(b)

In accordance with Section 9-507 of the Charter, the Director of the Administering Department is authorized

to establish, with the approval of the City Council through adoption of a resolution, a schedule of fees for the

services provided by the City under this division. The schedule and rules may require that all such fees be

paid in advance of provision of the service, or may provide that some or all of such fees may be deferred

until establishment of the special assessment district. Such fees are eligible expenses of the assessed cost of

the special assessment district.

(c)

After adoption of a resolution by the City Council and approval of the resolution by the Mayor, the fees that

are provided for in Subsection (b) of this section shall be:

(1)

Published in a daily newspaper of general circulation and in the Journal of the City Council;

(2)

Made available at the Administering Department and at the Office of the City Clerk; and

(3)

Reviewed by the Director of the Administering Department at least once every two years.

(Code 1984, § 18-12-123; Ord. No. 07-14, § 1(18-12-123), eff. 6-9-2014) 

Sec. 44-3-175. Special assessment districts not to be created in areas where unpaid City 

general taxes or special assessments equal 40 percent or more of total. 

No special assessment district shall be created under this division where the amount of unpaid general city 

taxes equals 40 percent or more of the total tax assessments in such district or where the amount of delinquent 

special assessments in such district amount to 40 percent or more of the total special assessments therein. The 

Board of Assessors, or other applicable City agency or department, shall provide this information to a designated 

neighborhood improvement organization for inclusion in the petition submitted under Section 44-3-193 of this 

Code and to the Administering Department for its report submitted pursuant to Section 44-3-211 of this Code. 

(Code 1984, § 18-12-124; Ord. No. 09-15, § 1(18-12-124), eff. 4-28-2015) 

Secs. 44-3-176—44-3-190. Reserved. 

Subdivision B. Petition 

Sec. 44-3-191. Petition sponsored by a designated neighborhood improvement organization. 

(a)

In accordance with this division, a designated neighborhood improvement organization may sponsor, on

behalf of the neighborhood or community it represents, a petition for the creation of a special assessment

district to provide for services within its geographic boundaries. Where a group of residents wishes to

circulate a petition under this division, they may form a designated neighborhood improvement organization

solely for the purpose of petitioning to create a special assessment district under this division and

administering the contracts for services. The geographic boundaries of a proposed special assessment district

need not be contiguous, but may be composed of only the area or portion thereof constituting the

designated neighborhood improvement organization's specific geographic boundaries.

Exhibit 6 — Page 7 of 17

(Supp. No. 4) 

(b)

Where a designated neighborhood improvement organization desires to sponsor more than one service at a

time, it may combine the information related to all proposed services on one petition. In such a case, only

one signature per record owner of a tax parcel is required despite the number of services reflected on a

petition.

(Code 1984, § 18-12-125; Ord. No. 07-14, § 1(18-12-125), eff. 6-9-2014) 

Sec. 44-3-192. Form of petition; information to be provided with petition. 

(a)

The Administering Department shall prepare a form of petition to be used to initiate a special assessment

district described in this division and shall make the form available upon request to any certified designated

neighborhood improvement organization. The form of petition shall provide for the inclusion of all of the

following information at the top of each sheet:

(1)

The name and address of the designated neighborhood improvement organization associated with the

petition and contact information for one or more designated neighborhood improvement organization

representatives;

(2)

A description of the geographic boundaries of the proposed special assessment district;

(3)

A description of the services to be funded by special assessment;

(4)

A preliminary estimate of the assessed cost for the services described in Subsection (a)(3) of this

section. The estimate shall be based in part on the designated neighborhood improvement

organization's acquisition of three estimates of the costs of providing the services to be paid by special

assessment. Such estimates shall be from contractors licensed to conduct business in the City under all

applicable laws;

(5)

The estimated tax parcel share for the services to be provided within the proposed special assessment

district. The petition shall state that the estimated tax parcel share may change after a record owner

signs the petition and that any such change shall not impact the validity of the petition, although a

hearing may be required pursuant to Section 44-3-215(b) of this Code during the term of a special

assessment district as a result of such a change;

(6)

The proposed term of the special assessment district.

(b)

The remainder of each sheet of the petition shall contain a table with columns for "Tax Parcel," "Record

Owner," "Record Owner's Signature," and "Date of Signature." The petition form may contain blank

underlined spaces for rows of data for each column, or the petition may be prepared with the data for tax

parcel and record owner pre-printed on the petition form and blank underlined spaces for the signature and

date.

(c)

Each sheet of the petition shall have below the table of signatures a place for certification by the person

collecting the signatures of the record owners on that sheet, including the printed and signed name of the

collector and the date of certification.

(d)

To prepare the form of petition described in Subsection (a) of this section for circulation, a designated

neighborhood improvement organization may request from the Board of Assessors, or from any other

applicable City agency or department, as needed, the following information:

(1)

A listing of all tax parcels, with ward and item numbers, within the geographic boundaries of the

proposed special assessment district, the record owner of each tax parcel, and the area in square feet

of each tax parcel; and

(2)

Identification of each tax parcel that would be exempt from assessment pursuant to Section 44-3-217

of this Code.

Exhibit 6 — Page 8 of 17

(Supp. No. 4) 

(e)

The designated neighborhood improvement organization shall be responsible for circulating the petition to

the record owners within the proposed special assessment district and submitting the completed petition to

the City Clerk in accordance with Section 44-3-193 of this Code. Prior to circulating an unsigned petition, the

designated neighborhood improvement organization shall submit the proposed petition to the Administering

Department for approval as to its form and content. Where the Administering Department denies the form

and content of the unsigned petition, it shall specify any deficiency. The designated neighborhood

improvement organization shall have the opportunity to cure any such deficiency and resubmit the unsigned

petition for approval.

(Code 1984, § 18-12-126; Ord. No. 07-14, § 1(18-12-126), eff. 6-9-2014) 

Sec. 44-3-193. Submission of completed petition. 

(a)

A designated neighborhood improvement organization seeking to establish a special assessment district

pursuant to this division shall submit the completed petition to the City Clerk. A completed petition may

consist of multiple signed counterparts. The Administering Department may require the designated

neighborhood improvement organization to submit on a form provided by the Administering Department a

summary of the petition to include such items as the number of exempt, nonexempt, and total tax parcels in

the special assessment district, the area of land in the special assessment district, the number of signatures, the 

total area of the tax parcels whose record owners signed the petition, a statement confirming that the amount of 

unpaid general city taxes within the special assessment district does not equal 40 percent or more of the total tax 

assessments therein and that the amount of delinquent special assessments in the special assessment district does 

not amount to 40 percent or more of the total special assessments therein, and the percentage of the land 

comprising the special assessment district receiving signatures. To be complete, and in compliance with Section 5i 

of the Michigan Home Rule City Act, being MCL 117.5i, the petition must be signed by the record owners of not less 

than 51 percent of the land within the geographic boundaries of the proposed special assessment district.

(b)

Where, pursuant to Section 44-3-194 of this Code, the Administering Department finds that a petition lacks

sufficient signatures or is deficient in any other manner, a designated neighborhood improvement organization

may submit to the City Clerk a supplemental petition containing additional signatures or otherwise correcting the

deficiencies.

(c)

For purpose of the calculation in Subsection (a) of this section, the identities of the record owners of tax

parcels within a special assessment district and the validity of the signatures on a petition shall be determined as of

the records existing on the date a designated neighborhood improvement organization submits a petition to the

City Clerk in accordance with the definition of "record owner" under Section

44-3-172 of this Code.

(d)

The City Clerk shall report receipt of the petition to the City Council, file the original petition and any

supplemental petitions in the records of the Office of City Clerk, and forward a copy of the petition and any

supplemental petitions to the Administering Department.

(Code 1984, § 18-12-127; Ord. No. 07-14, § 1(18-12-127), eff. 6-9-2014; Ord. No. 09-15, § 1(18-12-127), eff. 4-28-

2015) 

Sec. 44-3-194. Determination of compliance with requirements. 

After its receipt of the copy of the petition and any supplemental petitions from the City Clerk, the 

Administering Department shall review the submitted materials to determine whether they satisfy the 

requirements of this division. Where the Administrating Department denies the validity of the petition and any 

supplemental petitions, it shall specifically describe any deficiency in writing to the designated neighborhood 

Exhibit 6 — Page 9 of 17

(Supp. No. 4) 

improvement organization, after which the designated neighborhood improvement organization shall have the 

opportunity to cure any such stated deficiency and resubmit the petition or supplemental petitions. 

(Code 1984, § 18-12-128; Ord. No. 07-14, § 1(18-12-128), eff. 6-9-2014) 

Secs. 44-3-195—44-3-210. Reserved. 

Subdivision C. Establishment of District and Assessment 

Sec. 44-3-211. Report from Administering Department; tentative assessment roll. 

Where, pursuant to Section 44-3-194 of this Code, the Administering Department determines that the 

petition and any supplemental petitions meet the requirements of this division, it shall submit a report to the City 

Council verifying the validity of the petition, containing a statement confirming that the amount of unpaid 

general city taxes within the special assessment district does not equal 40 percent or more of the total tax 

assessments therein and that the amount of delinquent special assessments in the special assessment district 

does not amount to 40 percent or more of the total special assessments therein, and including such other 

information as the Administering Department shall deem appropriate. The Administering Department shall obtain 

from the Board of Assessors a tentative assessment roll for the proposed special assessment district, which it 

shall include with its report to City Council. The Administering Department shall provide the designated 

neighborhood improvement organization that submitted the petition a copy of the report and tentative 

assessment roll. 

(Code 1984, § 18-12-130; Ord. No. 07-14, § 1(18-12-130), eff. 6-9-2014; Ord. No. 09-15, § 1(18-12-130), eff. 

4-28-2015)

Sec. 44-3-212. 

of hearing; 

City Council 

hearing. 

resolution of intent to establish special assessment district; notice

(a)

Upon receipt of the report and tentative assessment roll from the Administering Department, the City

Council shall adopt a resolution fixing the time and place of a public hearing. Notice of the public hearing

shall be given in accordance with the Michigan Notice of Special Assessment Hearings Act, being MCL

211.741 et seq., and shall also be published in a newspaper of general circulation at least five days prior to

the date fixed for the hearing.

(b)

In addition to the requirements of such statute, the notice shall set forth all of the following:

(1)

That the plans and specifications for the proposed services, including the proposed term, the estimated

annual and aggregate costs for such services, and the tentative assessment roll are on file in the Office

of the City Clerk for public examination. The notice shall set forth the address and hours of the office.

(2)

A description of the geographic boundaries of the proposed special assessment district.

(3)

The estimated tax parcel share, as set forth in the tentative assessment roll.

(4)

Where periodic redeterminations of cost will be necessary without a change in the special assessment

district, a statement that those redeterminations may be made without further notice in accordance

with Section 44-3-215(b) of this Code.

(c)

At the hearing, the City Council shall receive public comment regarding the establishment of the special

assessment district. The president, executive director, or other authorized qualified representative of the

designated neighborhood improvement organization shall attend the hearing and, as may be requested by

the City Council, provide testimony regarding the petition, which may include testimony to support the

Exhibit 6 — Page 10 of 17

(Supp. No. 4) 

finding described in Section 44-3-213(a)(6) of this Code. Where, after the hearing, the City Council is not 

satisfied that the proposed special assessment district is consistent with the purposes and requirements of 

this division, the Body may vote at the hearing to revise the proposed special assessment district, in which 

case a second public hearing shall be scheduled as soon as practicable, but not later than 60 days after the 

first hearing. Notice of the second hearing shall be provided as set forth in Subsection (a) of this section. 

After considering further comments at the second hearing related to the establishment of the special 

assessment district, the City Council may revise the terms of the special assessment district. 

(Code 1984, § 18-12-131; Ord. No. 07-14, § 1(18-12-131), eff. 6-9-2014) 

Sec. 44-3-213. Final City Council resolution regarding proceeding with establishment of 

special assessment district. 

(a)

At the completion of the hearings required under Section 44-3-212 of this Code, the City Council may adopt a

resolution determining that a petition to create a special assessment district is consistent with the purposes

and requirements of this division, approving establishment of the special assessment district, and directing

the Board of Assessors to prepare and submit to City Council for confirmation a special assessment roll for

the proposed special assessment district. The resolution shall include all of the following:

(1)

A determination as to the sufficiency of the petition;

(2)

The geographic boundaries of the special assessment district;

(3)

A description of the services to be provided as originally presented or as revised;

(4)

The total annual estimated assessed cost as originally presented or as revised;

(5)

The estimated tax parcel share for the services to be provided within the special assessment district;

(6)

A preliminary finding that the tax parcels will benefit by an amount proportionate to the tax parcel

share;

(7)

The term of the special assessment district as originally presented or as revised;

(8)

Where the nature of a service is such that a periodic redetermination of cost will be necessary without

a change in the special assessment district boundaries, the dates upon which the redeterminations are

expected to be made;

(9)

A determination that any contractual services to be provided pursuant to this division are an expansion

or addition to services already provided by the City and are not a replacement for existing City-

provided services; and

(10) The date upon which the City Council will hold a public hearing to consider the special assessment roll

for confirmation.

(b)

Notice of the public hearing described in Subsection (a)(10) of this section shall be provided in the manner

described in Section 44-3-212(a) and (b) of this Code.

(Code 1984, § 18-12-132; Ord. No. 07-14, § 1(18-12-132), eff. 6-9-2014) 

Exhibit 6 — Page 11 of 17

(Supp. No. 4) 

Sec. 44-3-214. Special assessment roll; confirmation or revision of special assessment roll; 

endorsement; notice of assessment and collection of assessed amounts; appealing 

to the Michigan Tax Tribunal. 

(a)

After preparing the tentative special assessment roll pursuant to Section 44-3-211 of this Code, the Board of

Assessors shall file the roll with the City Clerk, who shall forward the roll to the City Council for confirmation.

Immediately after the public hearing described in Section 44-3-213(a)(10) of this Code, the City Council may

confirm the special assessment roll as prepared by the Board of Assessors. Where the special assessment roll

is inconsistent with the terms of the special assessment district as stated in the City Council's resolution

pursuant to Section 44-3-213 of this Code, the City Council may request that the Board of Assessors revise

the special assessment roll to correct any such inconsistency.

(b)

Once the City Council confirms the special assessment roll, the City Clerk shall endorse on the special

assessment roll the date of the confirmation, and shall deliver a copy of the assessment roll to the Board of

Assessors, Treasurer, and sponsoring designated neighborhood improvement organization. The Treasurer

shall proceed to collect the special assessment, and shall continue to do so annually during the term of the

special assessment district. The Treasurer may invoice the record owners directly for the special assessment,

or the Treasurer may include the special assessment as a separate item on the summer or winter tax bill.

Where the nature of a service is such that a periodic redetermination of cost will be necessary without a

change in the special assessment district boundaries, the Treasurer shall include with, or send

contemporaneously with, the invoice or property tax bill a statement that the cost redeterminations may be

made without further notice to record owners or parties in interest in the property subject to the limitations

in Section 44-3-215(b) of this Code.

(c)

Upon confirmation of the special assessment roll, all assessments on the assessment roll are final and

conclusive. An aggrieved person may appeal the assessment by filing a petition with the Michigan Tax

Tribunal pursuant to the requirements of the Michigan Tax Tribunal Act, being MCL 205.701 through

205.779, but only if the person protested the assessment at the hearing held for the purpose of confirming

the special assessment roll described in Subsection (a) of this section.

(Code 1984, § 18-12-133; Ord. No. 07-14, § 1(18-12-133), eff. 6-9-2014) 

Sec. 44-3-215. Special assessment; periodic redetermination of assessment; when rehearing is 

required; insufficient or surplus amount collected. 

(a)

The Administering Department shall annually conduct an accounting of the status of the special assessment

district collections and the costs incurred under the contracts for services in the special assessment district.

The results of the accounting shall be used to estimate the amount to be assessed the following year for

services to be provided. The Administering Department shall make a report of such accounting and estimates

to City Council and the sponsoring designated neighborhood improvement organization. After considering

the report, the City Council shall ask the Board of Assessors to prepare a new special assessment roll for the

special assessment district for the following year. The reassessment shall incorporate any overassessments

or underassessments from the preceding year, and shall take into account any unpaid assessments, any

collections of delinquent assessments from prior years, and any changes pursuant to Section 44-3-216 of this

Code. The Board of Assessors shall re-calculate the tax parcel share for all tax parcels within the special

assessment district based on this section.

(b)

The revised assessed cost may exceed the original assessed cost, as stated in the City Council's resolution

pursuant to Section 44-3-213(a)(4) of this Code, by up to 15 percent without requiring notice or a public

hearing. Where, at any time during the term of the special assessment district, the amount of the revised

Exhibit 6 — Page 12 of 17

(Supp. No. 4) 

assessed cost exceeds the original assessed cost by more than 15 percent, a reassessment shall be required, 

including notice, public hearing, and confirmation of the revised special assessment roll. No petition shall be 

required for a reassessment. 

(c)

Where any record owner has paid more than its tax parcel share as provided in the assessment roll, the City

Treasurer shall apply such overpayment to that record owner's tax parcel share for the following year. At the

conclusion of the term of the special assessment district, any overpayments in excess of five percent shall be

refunded to the record owner. Overpayments up to five percent shall first be applied to unpaid expenses of

the special assessment district, including unpaid assessments. Any balance remaining shall be applied to the

City's general fund.

(Code 1984, § 18-12-134; Ord. No. 07-14, § 1(18-12-134), eff. 6-9-2014) 

Sec. 44-3-216. Divisions or combinations of land; changes in exempt status. 

(a)

Where, after a special assessment on the tax parcel is confirmed and before a special assessment is

collected, a tax parcel is divided into two or more tax parcels, or two or more tax parcels are combined into

one tax parcel, payment of the current year's tax parcel shares for the original tax parcels shall be due

immediately as a condition to the combination or division. For each subsequent year of the term, each

resultant tax parcel shall be assessed a tax parcel share as if the resultant tax parcel were in existence at the

initial assessment.

(b)

Pursuant to Section 44-3-217 of this Code, the exempt status of a tax parcel shall be determined as of tax day

as that term is defined in Section 2(2) of the Michigan General Property Tax Act, being MCL 211.2(2).

Payment of a tax parcel share shall be required or exempt based on the exempt status as of tax day and not

as of the day payment is due. Where a tax parcel's exempt status changes from exempt to non-exempt, the

tax parcel shall be assessed a tax parcel share for each subsequent year of the term that it is non-exempt.

(Code 1984, § 18-12-135; Ord. No. 07-14, § 1(18-12-135), eff. 6-9-2014) 

Sec. 44-3-217. Exempt tax parcels. 

(a)

Tax parcels that are owned by the following record owners shall be exempt from any special assessment

under this division:

(1)

The United States;

(2)

Any state, including the State of Michigan;

(3)

The City;

(4)

Any public school district; or

(5)

Any authority, municipal corporation, school district, or other governmental or quasi-governmental

entity exempted from payment of special assessments by statute or other applicable law.

(b)

Tax parcels exempt by a record owner listed in Subsection (a) of this section shall be exempt regardless of

the use or purpose of such tax parcel. All other tax parcels are subject to a special assessment created under

this division, even where such tax parcels are exempt from property taxes under the Michigan General

Property Tax Act, being MCL 211.1 et seq., unless such tax parcels are otherwise exempt from special

assessments under applicable law.

(Code 1984, § 18-12-136; Ord. No. 07-14, § 1(18-12-136), eff. 6-9-2014) 

Exhibit 6 — Page 13 of 17

(Supp. No. 4) 

Sec. 44-3-218. Agreement of exempt person to pay special assessments. 

The record owner of any tax parcel that is exempt pursuant to Section 44-3-217 of this Code may 

nonetheless elect to pay a special assessment against an exempt tax parcel by providing written notice of such 

election to the Board of Assessors. Upon receipt of such notice, the Board of Assessors shall proceed to assess such 

an exempt tax parcel as if the parcel were not exempt, and such assessment shall be a valid claim against such tax 

parcel. The election may not be revoked without consent by resolution of the City Council. An election to revoke 

shall only be effective for subsequent years. 

(Code 1984, § 18-12-137; Ord. No. 07-14, § 1(18-12-137), eff. 6-9-2014) 

Sec. 44-3-219. Special assessment as lien. 

From the date of confirmation of the special assessment roll, any unpaid tax parcel share, including any part 

of a tax parcel share deferred as to payment, shall be a lien on the associated tax parcel, and shall also be a debt of 

the record owner. The lien shall be of the same character and effect as the lien created for municipal property 

taxes and shall accrue interest and penalties in the same manner. The lien shall be enforced in the manner 

prescribed in state law, the Charter, and this Code for the enforcement of special assessment liens or tax liens. 

(Code 1984, § 18-12-138; Ord. No. 07-14, § 1(18-12-138), eff. 6-9-2014) 

Sec. 44-3-220. Addition of tax parcels to special assessment districts. 

(a)

A special assessment district shall not be amended so as to add tax parcels to the existing district unless

notice is provided to the record owners of both the tax parcels in the existing special assessment district and

the tax parcels to be added to the existing special assessment district, and the City Council holds a public

hearing regarding the addition of the tax parcels and approves the amended special assessment district.

Where the property to be added to the special assessment district does not reduce the signatures on the

original petition below the 51 percent threshold, no additional petition is needed. Where the property to be

added to the special assessment district does reduce the signatures on the original petition below the 51

percent threshold, a supplemental petition shall be filed containing sufficient additional signatures of record

owners. This section shall not apply to divisions, combinations, or changes in exempt status under Section

44-3-216 of this Code.

(b)

Where, after the hearing regarding the addition of tax parcels to the special assessment district, the City

Council is satisfied that adding the additional tax parcels to the existing special assessment district is

consistent with the purposes and requirements of this division, the Body shall adopt a resolution confirming

the addition of the new tax parcels to the existing special assessment district, after which the Board of

Assessors shall recalculate the tax parcel share for all tax parcels within the special assessment district based

on the inclusion of the newly added tax parcels. Tax parcels added to an existing special assessment district

shall have the same term as the existing special assessment district.

(Code 1984, § 18-12-139; Ord. No. 07-14, § 1(18-12-139), eff. 6-9-2014) 

Sec. 44-3-221. Continuation of special assessment district upon expiration of term. 

Where a designated neighborhood improvement organization wishes to continue an existing special 

assessment district beyond its term, it must take action to continue the special assessment district for an 

additional term in the same manner that a special assessment district is created pursuant to this division. The same 

designated neighborhood improvement organization does not need to serve as the designated neighborhood 

Exhibit 6 — Page 14 of 17

(Supp. No. 4) 

improvement organization during both the initial or subsequent term of a special assessment district and any 

additional term. To avoid a lapse in services, a designated neighborhood improvement organization may begin 

petitioning to initiate an additional term of a special assessment district prior to the expiration of the existing term 

subject to the requirement in Section 44-3-193(c) of this Code regarding the validity of signatures. An additional 

term of a special assessment district shall commence as of the expiration date of the existing term of the special 

assessment district. 

(Code 1984, § 18-12-140; Ord. No. 07-14, § 1(18-12-140), eff. 6-9-2014) 

Sec. 44-3-222. Discontinuance of special assessment district through discontinuance petition. 

(a)

Pursuant to Section 5i(2) of the Michigan Home Rule City Act, being MCL 117.5i(2), a special assessment

district created under this division may be discontinued at any time during its term through a discontinuance

petition. A discontinuance petition may be completed and submitted to the City Clerk by any record owner

or owners within a special assessment district, or by a designated neighborhood improvement organization.

A discontinuance petition is subject to the same rules as a petition to initiate a special assessment district as

set forth in Sections 44-3-192 and 44-3-193 of this Code, including among other applicable rules the

requirements for signatures of record owners of 51 percent of the land comprising the special assessment

district, provided, that no information regarding assessed cost, tax parcel share, or term shall be required on

a discontinuance petition.

(b)

After receipt of a completed discontinuance petition, the City Clerk shall report receipt of the petition to the

City Council, file the original petition in its record, and forward a copy to the Administering Department and,

if not the submitting party, the designated neighborhood improvement organization. The Administering

Department shall confirm or reject the validity of the discontinuance petition. Where the Administering

Department rejects the validity of the discontinuance petition, it shall specifically explain to the petitioner in

writing any deficiency in the discontinuance petition, after which the petitioner shall have the opportunity to

cure any such stated deficiency and resubmit the discontinuance petition. Where the Administering

Department confirms the validity of the original or re-submitted discontinuance petition, it shall submit a

report to the City Council verifying the validity of the petition and including such other information as the

Administering Department shall deem appropriate.

(c)

Upon receipt of the report from the Administering Department, the City Council shall hold a public hearing

with notice provided as set forth in Section 44-3-212 of this Code. After the public hearing, the City Council

shall adopt a resolution either accepting or rejecting the discontinuance petition. Where the resolution

rejects the discontinuance petition, the special assessment district shall continue. Where the resolution

accepts the discontinuance petition, the contract for services pursuant to Section 44-3-241 of this Code shall

be terminated, and the Administering Department shall conduct a final accounting consistent with Section

44-3-215 of this Code. The Administering Department shall report the results of the final accounting to the

City Council. Upon receipt of the final accounting, the City Council shall adopt a resolution terminating the

special assessment. No further assessments shall be made except for reassessment required to address any

deficit shown in the final accounting. Such reassessment shall be subject to notice and public hearing. Any

surplus shown by the final accounting shall be distributed as set forth in Section 44-3-215(c) of this Code.

(d)

Only an entire special assessment district may be discontinued through a petition under this section, and not

a portion of a special assessment district. Any such discontinuance shall not impair any current obligations of

the City or the special assessment district.

(Code 1984, § 18-12-141; Ord. No. 07-14, § 1(18-12-141), eff. 6-9-2014) 

Exhibit 6 — Page 15 of 17

(Supp. No. 4) 

Sec. 44-3-223. Provision of services under this division not to reduce provision of general City 

services. 

Services funded by a special assessment district are supplemental to City-provided services. Notwithstanding 

the establishment of a special assessment district under this division, the City shall continue to provide services to 

a special assessment district at the same level and frequency that it provides services to other comparable areas of 

the City that do not contain a special assessment district. The existence of a special assessment district shall not be 

a basis for the subsequent discontinuance or diminution of City-provided services within a special assessment 

district. 

(Code 1984, § 18-12-142; Ord. No. 07-14, § 1(18-12-142), eff. 6-9-2014) 

Secs. 44-3-224—44-3-240. Reserved. 

Subdivision D. Contracting for Provision of Services 

Sec. 44-3-241. Contracting for services. 

(a)

Section 5i of the Michigan Home Rule City Act, being MCL 117.5i, requires that the services under this

division be provided by private contractors. The City prefers to enter into a contract with the designated

neighborhood improvement organization for the services with the exception that the designated

neighborhood improvement organization will enter into one or more subcontracts with the service

providers. Where the designated neighborhood improvement organization desires to administer the special

assessment district services, and the Administering Department determines that the designated

neighborhood improvement organization is qualified, the Administering Department shall negotiate a

contract with the designated neighborhood improvement organization in form satisfactory to the Law

Department for administering the special assessment district. The contract shall address the methods by

which the designated neighborhood improvement organization shall solicit and obtain bids from potential

providers of the services for which the special assessment district was established, and the awarding of

subcontracts for such services, the procedures for requesting and obtaining prompt payment from the City,

which shall include invoices from private contractors that a designated neighborhood improvement

organization has contracted with for the provision of services within a special assessment district, and a

statement of the designated neighborhood improvement organization's reasonable costs incurred for

administering the special assessment district, if any, auditing and accounting procedures, establishment or

determination of appropriate administration fees, and such other issues as the designated neighborhood

improvement organization, the Administering Department, and the Law Department shall deem appropriate.

Where the designated neighborhood improvement organization does not desire to administer the contract

for services, the Administering Department may identify another entity to administer the contract for

services, or may elect to contract directly for such services in accordance with standard City procedures.

Where both the designated neighborhood improvement organization and the Administering Department

decline to administer the contract for the services, and the Administering Department is unable to identify

another entity to administer the contracts, the special assessment shall be canceled.

(b)

The contract shall contain provisions requiring the designated neighborhood improvement organization and

all subcontractors to provide in a timely manner all information needed for redetermining costs in

accordance with Section 44-3-215 of this Code.

(c)

The contract shall terminate upon acceptance of a discontinuance petition pursuant to Section 44-3-222 of

this Code, and shall contain a provision so stating.

Exhibit 6 — Page 16 of 17

(Supp. No. 4) 

(d)

A designated neighborhood improvement organization may agree to, but shall not be required to, administer

contracts for services in a district outside its own geographical area.

(Code 1984, § 18-12-145; Ord. No. 07-14, § 1(18-12-145), eff. 6-9-2014) 

Sec. 44-3-242. City Council approval of contracts; source of funds for payment of assessed 

cost. 

The contract with the designated neighborhood improvement organization or other administering entity 

described in Section 44-3-241 of this Code, but not the subcontracts with the service providers, shall be submitted 

for approval by City Council in accordance with the requirements of the Charter and this Code. The assessed cost 

of the improvement shall be paid by the City Treasurer out of funds collected pursuant to the special assessment 

roll. The City's payment obligations under this division shall be limited to payment under the contract entered into 

by the City pursuant to Section 44-3-241(a) of this Code. The City shall be under no obligation to pay the 

subcontractors of the designated neighborhood improvement organization. 

(Code 1984, § 18-12-146; Ord. No. 07-14, § 1(18-12-146), eff. 6-9-2014) 

Secs. 44-3-243—44-3-260. Reserved. 

Exhibit 6 — Page 17 of 17

EXHIBIT 7 

JUNE 7, 2023, BFA MISSING-RESOLUTION RECORD 

Exhibit 7 — Page 1 of 6

Source Record: 

June 7, 2023, Budget, Finance and Audit Standing Committee record concerning the Office of the Chief 

Financial Officer / Office of the Assessor request to set public-hearing dates to renew the Sherwood 

Forest, Detroit Golf Club, and Palmer Woods Special Assessment Districts. 

Short Title: 

June 7, 2023 / Missing Hearing-Setting Resolution 

Purpose of Exhibit: 

This exhibit is offered to show an early authority-chain defect in Detroit’s claimed 2023 Sherwood 

Forest SAD renewal process. On June 7, 2023, the Office of the Assessor asked City Council’s Budget, 

Finance and Audit Standing Committee to set public-hearing dates to renew the Sherwood Forest, 

Detroit Golf Club, and Palmer Woods Special Assessment Districts. 

The record shows that the item was not presented as a complete resolution package. Committee Clerk 

Cindy Golden stated that a resolution was required to set the public hearing and that no resolution was 

attached. Deputy CFO / Assessor Alvin Horhn acknowledged that the resolution had not been submitted 

and stated that he should have known to submit it before the hearing date was set. 

This exhibit is material because the current 2026 SMS/SWF charge is derivative of Detroit’s claimed 

2023 Sherwood Forest SAD renewal. Detroit cannot rely on later billing, Treasury processing, or annual 

administrative records to cure a defective renewal process. Detroit must prove that it satisfied the 

mandatory authority-chain requirements before relying on the claimed 2023 renewal to impose and 

continue collecting the SMS/SWF charge. 

Material Record Points: 

1. The June 7, 2023, BFA item concerned a request to set public-hearing dates to renew the

Sherwood Forest, Detroit Golf Club, and Palmer Woods Special Assessment Districts.

2. The item was submitted by the Office of the Chief Financial Officer / Office of the Assessor.

3. The item was presented as a request to set public-hearing dates, not as a completed Sherwood

Forest authority-chain package.

4. Committee Clerk Cindy Golden stated that, in order to set the public hearing, the Clerk would

need a resolution.

5. Golden stated that no resolution was attached.

6. Deputy CFO / Assessor Alvin Horhn acknowledged that the resolution had not been submitted.

7. Horhn stated that he “should have known better” and would make sure a resolution was

submitted.

8. Horhn also stated that the City Clerk needed at least 10 business days to receive mailing labels

from the Office of the Assessor and notify affected residents.

9. The Committee moved the item to Formal Session with a recommendation to approve pending

the attachment of the resolution.

10. The record therefore shows that the hearing-setting process was advanced while the required

resolution was still missing.

11. The record does not identify a Sherwood Forest-specific resolution, Administering

Department report, tentative assessment roll, City-certified 51% land-area verification,

Clerk-filed public-examination record, confirmed special assessment roll, Clerk

endorsement, Treasury transmittal, or billing-authority record.

12. Petitioner offers this exhibit to show that Detroit’s claimed 2023 Sherwood Forest SAD renewal

process had an identified authority-chain defect before the public-hearing process was set in

motion.

Tribunal Relevance: 

This exhibit is material because it shows that Detroit’s claimed 2023 Sherwood Forest SAD renewal 

process began with a known missing-resolution defect. The June 7, 2023, BFA record did not merely 

show a later clerical omission. It shows that City Council staff identified the missing resolution before 

the hearing-setting process moved forward, and Deputy CFO / Assessor Alvin Horhn acknowledged 

that the resolution had not been submitted. 

That defect is material to the current 2026 appeal because the 2026 SMS/SWF charge is derivative of 

Detroit’s claimed 2023 Sherwood Forest SAD renewal. If Detroit did not satisfy the mandatory 

authority-chain requirements at the renewal stage, later billing records, Treasury processing, 

assessment extracts, or annual administrative records cannot independently cure the defect. 

The record is also material to notice. Horhn stated that the Clerk needed at least 10 business days to 

receive mailing labels from the Assessor and notify affected residents. That admission links the missing 

hearing-setting resolution to the notice sequence that followed. The issue therefore began at the front 

end of the renewal process, before public-hearing notice, hearing procedure, roll confirmation, Treasury 

billing, or later annual collection could lawfully depend on the claimed renewal. 

This exhibit therefore supports the controlling question for the Tribunal: whether Detroit can prove that 

it satisfied the mandatory authority-chain requirements of MCL 117.5i and Detroit City Code 

Division 8 before relying on the claimed 2023 Sherwood Forest SAD renewal to impose and continue 

collecting the current 2026 SMS/SWF special assessment charge. 

Record Limitation: 

Petitioner does not offer this exhibit as proof that no Sherwood Forest resolution exists anywhere in City 

possession. Petitioner offers this exhibit to show that, on June 7, 2023, the renewal record itself 

identified a missing resolution before the hearing-setting process moved forward. 

This exhibit is limited to the June 7, 2023, BFA missing-resolution record and its relationship to 

Detroit’s claimed 2023 Sherwood Forest SAD renewal process. The exhibit shows an inception-stage 

authority-chain defect: the Assessor sought to advance the renewal hearing process while the required 

resolution had not been submitted. 

Petitioner contends that advancing the hearing-setting process pending a missing resolution cannot 

substitute for the original authority-chain records required to support a compulsory special assessment 

Exhibit 7 — Page 2 of 6

imposed through the property-tax system. Later billing records, Treasury processing, annual 

administration, or tax-bill entries cannot independently cure a renewal process that began without the 

required authority-chain materials. 

Insert Behind This Cover Sheet: 

1. June 7, 2023, Budget, Finance and Audit Standing Committee record concerning the request to 

set public-hearing dates to renew the Sherwood Forest, Detroit Golf Club, and Palmer Woods 

Special Assessment Districts, including the transcript showing the missing-resolution issue and 

the motion to move the item forward pending submission or attachment of the resolution. 

 

Exhibit 7 — Page 3 of 6

BUDGET, FINANCE AND AUDIT STANDING COMMITTEE 

June 7, 2023 

Budget, Finance And Audit Standing Committee - June 07, 2023 

OFFICE OF THE CHIEF FINANCIAL OFFICER/OFFICE OF THE ASSESSOR 

Line Item 8.4 

Submitting report relative to: 

Request to Set Public Hearing Dates To Renew Special Assessment Districts for Sherwood Forest, 

Detroit Golf Club and Palmer Woods. (REFERRED TO THE BUDGET, FINANCE AND AUDIT 

STANDING COMMITTEE ON 6/7/2023) 

Attachments 

1. Special Assessment District Renewals.pdf

2. SAD Renewal.pdf

MOTION TO SEND TO THE FORMAL SESSION AGENDA WITH A RECOMMENDATION 

TO APPROVE (PENDING THE SUBMISSION OF THE RESOLUTION) 

(Motion made by YOUNG; All Committee Members were in favor; Motion carried 3-0) 

(Transcript) 

BFA Committee Chair, Fred Durhal, “Next, we will move to line item 8.4, submitting a report 

relative to request to set public hearing dates to renew special assessment districts for Sherwood 

Forest, Detroit Golf Club and Palmer Woods. Is there a motion to discuss line item 8.4 discussion? 

Thank you member Santiago-Romero. Mr. Horhn is joining us, our assessor good afternoon, can 

you tell us a little bit more about line item 8.4 and setting public hearing dates to renew our 

special assessment districts for Sherwood Forest, Detroit Golf Club, and Palmer Woods?” 

Deputy CFO/Assessor, Alvin Horhn, “Thank you Sir. Through the chair each of these special 

assessment districts currently in in effect in the city of Detroit are due to expire this year. They were 

originally created by this honorable body in 2016. They have a seven-year term. Under Section 

44-3-221 of the Detroit City code, to continue a special assessment district beyond its original term,

the steps to renew it are the same as it was to create it. Each of the districts have started the first

process, which is to submit petitions to the Office of the Assessor verifying the majority of the

residents want the district to continue. Those petitions have been received by my office and we have

reviewed and verified them. The second step is the first of two public hearings, the first before this

honorable body in which members/residents who both support and oppose the districts have the

opportunity to present their arguments to City Council. Council can chose to vote, to accept the

petitions and recommendations and forward everything to commit the whole, they can ask for

another hearing or they can reject them but for cause. So, we're simply asking council to

continue the process to take the second step in renewing the three existing districts, which is a

public hearing before this honorable body. Thank you, Sir,"

Exhibit 7 — Page 4 of 6

Durhal, “And to you Mr. Horhn, is this just a report or is this a resolution to Mr. Corley or Miss 

Barcliff? Our action is to receive and filed this report, will there be another request or line item 

coming before us to set the public hearings?” 

Alvin Horhn, “My apologies, Mr. Chair, this was intended to be a request for your honorable body 

to set a date for a public hearing. The city clerk needs at least 10 business days to receive the mailing 

labels from the office of the assessor and then to notify the residents in the affected areas. So, this 

was a request to you to set that first date for a first public hearing.” 

Durhal, “OK, to the clerk, because I see we have it again on our agenda as a report, submitting 

report relative to, this is not a resolution, so that is my question about setting the public hearing?” 

Asst. City Council Committee Clerk, Ms. Cindy Golden, “To Mr. Chair, we, in order for us to 

set the public hearing, we would need a resolution to do so. When this came on the last agenda we 

did have a resolution to set the public hearing.” 

Durhal, “OK, so is this a Scrivener’s error? Possibly?” 

Ms. Cindy Golden, “There was no resolution attached, so it was submitted in form of the title 

requesting to set a public hearing, but there was never a document attached in the form of a 

resolution to do so. So that's why it was written out as a report.” 

Durhal, “Thank you Madam Clerk. And to the assessor, do you have that, has that been submitted 

through E-scribe for the resolution, Mr. Horhn?” 

Alvin Horhn, “My apologies, Mr. Chair, that has not been submitted, I wasn’t aware that I needed 

to submit the resolution before the date was set and I should have known better, my apologies to the 

committee. I will make sure a resolution is submitted before the weeks end.” 

Durhal, “So, with that what I will ask for is a motion to bring back this line item 8.4 in one week. 

And then at that point to the clerk, when the resolution is attached through escribe will it be attached 

to this line item or will it come as a separate line item?” 

Ms. Cindy Golden, “It's gonna come as a separate item if these resolution is uploaded to escribe 

between today by 5:30 PM, if not today by Friday at 1:00 o’clock it can show up on next Tuesday's 

formal session agenda the new business side as a referral back to this committee.” 

Durhal, “To come back and possibly make it to next Wednesday’s BFA agenda?” 

Ms. Cindy Golden, “Unless we get in a time to place it on new business, it would be your decision to 

move it on to new business for a vote and that way the public hearing could be set said Tuesday.” 

Durhal, “Right, Mr. Horhn?” 

Alvin Horhn, “I will work some magic Sir, and get that done before 5:00 today.” 

Durhal, “OK, if not please be in communication with our office so we are aware that when formal 

session comes Tuesday if that has to be moved to new business and voted on by the entire council.” 

Durhal, “Chair recognizes member vice chair.” 

BFA Vice Chair, Coleman Young II, “Thank you Mr. Chair. I don't have any questions for you 

Mr. Horhn but thank you. I just have a question in general for maybe Mr. Graham. I don't know if 

this would be to you or not, but I mean, there's been some questions about the legality in terms of

Exhibit 7 — Page 5 of 6

approval to form, in terms to the property tax reform ordinance? Are you going to be there or 

somebody going to be there from law to really kind of answer some of these questions in terms of, you 

know, why it's not being approved the form, and in terms of, you know, does it encroach on certain 

things that it’s not supposed to be encroached on? I just want to make sure that we're having this 

discussion and everybody is there so we can answer these questions, both from a legal standpoint, 

from a charter standpoint, and potentially from a constitutional standpoint and a stay if necessary?” 

Law Department, Graham Anderson, “Absolutely, through the Chair, Graham Anderson, Law 

Department. This is beyond my wheelhouse of expertise, but I can promise you I'll make sure someone 

from the Law department who's familiar with this matter will be able to speak on the matter next 

week.” 

Ms. Cindy Golden, “Thank you, Mr. Chair. The other option is we can move this item out pending 

the resolution to be received by Tuesday if you like. That's also an option.” 

Durhal, “I'm fine with that, noting that again, this is only to set a public hearing and we will hear 

from the public about the special assessments in those areas. I'm fine with moving this out pending 

the resolution. I don't know if there is any objection for that. OK, alright Mr. Horhn, we're gonna do

you a solid, you gotta have that resolution by Tuesday, so do I have a motion to send line item 8.4 to 

formal session with the recommendation to approve pending the attachment of the resolution? 

(Young, motion.) Hearing no objection, that action shall be taken. Line item 8.4 will be sent to 

formal session with the recommendation to approve pending the attachment of the resolution to set 

public hearing dates to renew special assessment districts for Sherwood Forest, Detroit Golf Club and 

Palmer Woods.” 

Exhibit 7 — Page 6 of 6

EXHIBIT 8 

JUNE 13, 2023, FORMAL SESSION eSCRIBE AGENDA PACKAGE AND COMPARATOR 

ATTACHMENT RECORD 

Exhibit 8 — Page 1 of 6 

Source Record: 

June 13, 2023, City Council Formal Session eSCRIBE Agenda Package; June 13, 2023, Formal Session 

minutes / attachment-list record; departmental submission OCFO-Office of the Assessor-0041; and 

Deputy CFO / Assessor Alvin Horhn’s June 2, 2023, request letter concerning renewal of the Sherwood 

Forest, Detroit Golf Club, and Palmer Woods Special Assessment Districts. 

Short Title: 

June 13, 2023 / Formal Session Item Still “PENDING THE RESOLUTION” 

Purpose of Exhibit: 

This exhibit is offered to show that the authority-chain defect identified at the June 7, 2023, BFA 

meeting continued into the June 13, 2023, Formal Session. The June 13 Formal Session record shows 

that the SAD hearing-setting item proceeded while still marked “PENDING THE RESOLUTION.” 

This exhibit is material because Detroit moved the claimed Sherwood Forest SAD renewal process 

forward even though the record still did not identify a completed Sherwood Forest-specific hearing-

setting resolution package. The departmental submission was classified as CORRESPONDENCE, not 

as a completed resolution package, and the attachment-list record identified district-specific resolution 

files for Detroit Golf Club and Palmer Woods but did not identify a comparable Sherwood Forest-

specific resolution file. 

The current 2026 SMS/SWF charge is derivative of Detroit’s claimed 2023 Sherwood Forest SAD 

renewal. Detroit cannot rely on later billing, Treasury processing, annual administration, or tax-bill 

entries to cure an inception-stage renewal defect. Detroit must prove that it satisfied the mandatory 

authority-chain requirements before relying on the claimed 2023 renewal to impose and continue 

collecting the SMS/SWF charge. 

Material Record Points: 

1. The June 13, 2023, Formal Session item concerned a request to set public-hearing dates to renew

the Sherwood Forest, Detroit Golf Club, and Palmer Woods Special Assessment Districts.

2. The official agenda record identifies the item as Line Item 16.3 under the Office of the Chief

Financial Officer / Office of the Assessor.

3. The agenda record states: “Request to Set Public Hearing Dates To Renew Special

Assessment Districts for Sherwood Forest, Detroit Golf Club and Palmer Woods.

(PENDING THE RESOLUTION).”

4. The June 13 record therefore shows that the missing-resolution defect identified on June 7, 2023,

remained unresolved when the item proceeded to Formal Session.

5. The departmental submission is identified as OCFO-Office of the Assessor-0041.

6. The departmental submission is classified as CORRESPONDENCE, not as a completed

resolution package.

7. The departmental submission summary states: “Renewals of Special Assessment Districts —

request to establish dates for public hearings.”

8. Horhn’s June 2, 2023, request letter states that his office received renewal applications and

petitions from Sherwood Forest, Detroit Golf Club, and Palmer Woods.

9. Horhn’s June 2, 2023, request letter cites City Code Section 44-4-221, although the governing

Division 8 continuation provision is Detroit City Code § 44-3-221.

10. Horhn’s June 2, 2023, request letter states that the City received renewal applications and

petitions from “a majority of the property owners” in each SAD.

11. The June 13 Formal Session record shows approval of the hearing-setting item with waiver.

12. The attachment-list record identifies Special Assessment District Detroit Golf Club

Resolution.pdf and Special Assessment District Palmer Woods Resolution.pdf.

13. The attachment-list record does not identify a comparable Special Assessment District

Sherwood Forest Resolution.pdf or other Sherwood Forest-specific resolution file.

14. The record does not identify a Sherwood Forest-specific resolution, Administering Department

report, tentative assessment roll, City-certified 51% land-area verification, Clerk-filed public-

examination record, confirmed special assessment roll, Clerk endorsement, Treasury transmittal,

or billing-authority record.

15. Petitioner offers this exhibit to show that Detroit’s claimed 2023 Sherwood Forest SAD renewal

process advanced at Formal Session while the required Sherwood Forest-specific authority-chain

materials remained missing from the reviewed record.

Tribunal Relevance: 

This exhibit is material because it shows that the missing-resolution defect did not end at the June 7, 

2023, BFA meeting. The June 13, 2023, Formal Session record shows the same hearing-setting item still 

marked “PENDING THE RESOLUTION” when City Council approved it with waiver. 

That fact is important because Detroit’s claimed 2023 Sherwood Forest SAD renewal could not lawfully 

rest on assumption, departmental correspondence, or a later billing record. The governing question is 

whether Detroit satisfied the mandatory authority-chain requirements before relying on the claimed 

renewal to impose and continue collecting the SMS/SWF charge. 

The comparator attachment record is also material. It identifies district-specific resolution files for 

Detroit Golf Club and Palmer Woods, but the reviewed record does not identify a comparable 

Sherwood Forest-specific resolution file. That omission matters because Sherwood Forest had its own 

boundaries, petition set, proposed fee, tax parcel share, notice requirements, assessment roll, 

confirmation process, and Treasury billing authority. 

This exhibit is directly relevant to the current 2026 appeal because the 2026 SMS/SWF charge is 

derivative of Detroit’s claimed 2023 Sherwood Forest SAD renewal. If Detroit did not satisfy the 

mandatory authority-chain requirements at the renewal stage, later billing records, Treasury processing, 

assessment extracts, annual administration, or tax-bill entries cannot independently cure the defect. 

Exhibit 8 — Page 2 of 6

This exhibit therefore supports the controlling question for the Tribunal: whether Detroit can prove that 

it satisfied the mandatory authority-chain requirements of MCL 117.5i and Detroit City Code 

Division 8 before relying on the claimed 2023 Sherwood Forest SAD renewal to impose and continue 

collecting the current 2026 SMS/SWF special assessment charge. 

Record Limitation: 

Petitioner does not offer this exhibit as proof that no Sherwood Forest resolution exists anywhere in City 

possession. Petitioner offers this exhibit to show that, as of the June 13, 2023, Formal Session record 

reviewed here, the SAD hearing-setting item still appeared as “PENDING THE RESOLUTION” and 

the reviewed attachment record did not identify a comparable Sherwood Forest-specific resolution file. 

This exhibit is limited to the June 13, 2023, Formal Session eSCRIBE Agenda Package, departmental 

submission, Horhn’s June 2, 2023, request letter, and the comparator attachment-list record. 

Petitioner does not offer the Detroit Golf Club or Palmer Woods attachment references to challenge 

those districts or to prove their compliance. Petitioner offers them only as comparator record evidence 

showing that Detroit’s reviewed attachment record identified district-specific resolution files for other 

SAD districts while not identifying a comparable Sherwood Forest-specific resolution file. 

Petitioner contends that approving the hearing-setting item while it remained “PENDING THE 

RESOLUTION” cannot substitute for the original authority-chain records required to support a 

compulsory special assessment imposed through the property-tax system. Later billing records, Treasury 

processing, annual administration, or tax-bill entries cannot independently cure a claimed renewal 

process that advanced without the required Sherwood Forest-specific authority-chain materials. 

Insert Behind This Cover Sheet: 

1. June 13, 2023, City Council Formal Session record showing Line Item 16.3, “PENDING THE

RESOLUTION” status, approval with waiver, attachment-list references, and transcript excerpt.

2. Departmental Submission, OCFO-Office of the Assessor-0041.

3. Deputy CFO / Assessor Alvin Horhn’s June 2, 2023, request letter concerning renewal of the

Sherwood Forest, Detroit Golf Club, and Palmer Woods Special Assessment Districts.

Exhibit 8 — Page 3 of 6

CITY COUNCIL FORMAL SESSION 

June 13, 2023 

City Council Formal Session - June 13, 2023 

OFFICE OF THE CHIEF FINANCIAL OFFICER/OFFICE OF THE ASSESSOR 

Line Item 16.3 

Budget, Finance, and Standing Committee Chair, Durhal, reso. autho. 

Request to Set Public Hearing Dates To Renew Special Assessment Districts for Sherwood Forest, 

Detroit Golf Club and Palmer Woods. (PENDING THE RESOLUTION) 

CM Durhal III: Motion to give Approval by Council (with Waiver). 

All Council Members in favor (9-0) No Objections. Motion Carried. 

Attachments 

Special Assessment District Renewals.pdf 

SAD Renewal.pdf 

Special Assessment District Detroit Golf Club Resolution.pdf 

Special Assessment District Palmer Woods Resolution.pdf 

(Transcript) 

Council President, Mary Sheffield, “From the Office of the Chief Financial Officer, Office of the 

Assessor, Councilmember Durhal?” 

BFA Committee Chair, Durhal, “Thank you, Madam President. Resolution item 16.3 is a resolution 

of authorization to request to set public hearing dates to renew special assessment districts for 

Sherwood Forest, Detroit Golf Club and Palmer Woods, moved for approval.” 

Mary Sheffield, “Motion has been made, any objections to the motion? Hearing no objections, the 

resolution will be approved to schedule a public hearing.” 

Durhal, “Request a waiver for line item 16.3.” 

Mary Sheffield, “Waiver has been requested, hearing no objections, that action will be taken.” 

Exhibit 8 — Page 4 of 6

DEPARTMENTAL SUBMISSION 

DEPARTMENT: 

OCFO-Office of the Assessor 

FILE NUMBER: 

OCFO-Office of the Assessor-0041 

* ITEM TYPE:

CORRESPONDENCE:

* Council Member:

Choose an item.

Correspondence relative to (summary below): 

* SUMMARY:

Renewals of Special Assessment Districts – request to establish dates for public

hearings.

* RECOMMENDATION:

Click or tap here to enter text.

* COMMITTEE REFFERED TO:

Budget, Finance, and Audit

* DEPARTMENTAL CONTACT:

Name: 

Jeanet Kulcsar 

Position: 

Chief of Staff to the Board of Assessors 

*= REQUIRED 

Exhibit 8 — Page 5 of 6

June 2, 2023 

The Honorable Detroit City Council 

Coleman A Young Municipal Center 

Detroit MI 48226 

Re: Request to Set Public Hearing Dates To Renew Special Assessment Districts for 

Sherwood Forest, Detroit Golf Club and Palmer Woods 

Honorable Detroit City Council: 

My office has received Special Assessment Renewal Applications including petitions 

from the following Special Assessment Districts (“SADs”): 

1. Sherwood Forest

2. Detroit Golf Club

3. Palmer Woods

All three SADs will expire December 2023. Pursuant to City Code Section 44-4-221: 

 “Where a designated neighborhood improvement organization wishes to continue 

an existing special assessment district beyond its term, it must take action to continue 

the special assessment district for an additional term in the same manner that a 

special assessment district is created pursuant to this division… An additional term of 

a special assessment district shall commence as of the expiration date of the existing 

term of the special assessment district.” 

Therefore, as we have received the renewal applications and petitions from a majority of the 

property owners in each of the SADs, I respectfully request this honorable body to set a time 

for three public hearings, or one hearing for all three at the chair’s discretion, to discuss the 

matter of renewing each SAD for Sherwood Forest, Detroit Golf Club, and Palmer Woods. 

Sincerely, 

Alvin Horhn 

Deputy CFO/ Assessor

Exhibit 8 — Page 6 of 6

EXHIBIT 9 

DETROIT GOLF CLUB AND PALMER WOODS COMPARATOR RESOLUTION RECORDS 

Exhibit 9 — Page 1 of 11

Source Record: 

Detroit Golf Club and Palmer Woods district-specific Assessor records dated June 7, 2023. The records 

request public-hearing action for renewal of those districts and are identified in the June 13, 2023, 

Council attachment record. 

Short Title: 

DGC / Palmer Woods Comparator Resolution Records 

Purpose of Exhibit: 

This exhibit is offered as comparator evidence. It shows that, during the same June 2023 SAD renewal 

process, Detroit prepared district-specific renewal-resolution materials for Detroit Golf Club and Palmer 

Woods. 

This exhibit is material because Exhibits 7 and 8 show that the Sherwood Forest hearing-setting item 

moved forward while the required resolution remained missing or unproduced in the reviewed record. 

Exhibit 9 shows that the absence of a comparable Sherwood Forest-specific resolution was not merely a 

formatting issue. Detroit had separate district-specific resolution materials for the other two SAD 

districts in the same renewal process. 

The current 2026 SMS/SWF charge is derivative of Detroit’s claimed 2023 Sherwood Forest SAD 

renewal. Detroit cannot rely on later billing, Treasury processing, annual administration, or tax-bill 

entries to cure a missing or defective Sherwood Forest-specific renewal record. Detroit must prove that 

it satisfied the mandatory authority-chain requirements before relying on the claimed 2023 

Sherwood Forest SAD renewal to impose and continue collecting the SMS/SWF charge. 

Material Record Points: 

1. The Detroit Golf Club source pages show a district-specific hearing-request / preliminary

renewal-resolution record dated June 7, 2023.

2. The Palmer Woods source pages show a district-specific hearing-request / preliminary renewal-

resolution record dated June 7, 2023.

3. Both comparator records identify the district by name.

4. Both comparator records request that a public hearing be scheduled for renewal of that specific

SAD.

5. Both comparator records contain district-specific renewal language, including proposed services,

term, cost or tax parcel share information, and hearing-setting language.

6. Both comparator records include language purporting to address petition compliance, benefit,

term, periodic redetermination, and public-hearing scheduling.

7. The June 13, 2023, attachment record identified Special Assessment District Detroit Golf Club

Resolution.pdf and Special Assessment District Palmer Woods Resolution.pdf.

8. The reviewed June 13, 2023, attachment record does not identify a comparable Special 

Assessment District Sherwood Forest Resolution.pdf or other Sherwood Forest-specific 

resolution file. 

9. This comparator evidence is read together with Exhibit 8, which shows the June 13, 2023, 

Formal Session item still marked “PENDING THE RESOLUTION” when City Council 

approved the hearing-setting item with waiver. 

10. The comparator records show that Detroit knew how to prepare and identify district-specific 

SAD renewal-resolution materials when those materials existed in the June 2023 renewal record. 

11. The reviewed record does not identify a comparable Sherwood Forest-specific resolution, 

Administering Department report, tentative assessment roll, City-certified 51% land-area 

verification, Clerk-filed public-examination record, confirmed special assessment roll, 

Clerk endorsement, Treasury transmittal, or billing-authority record. 

12. Petitioner offers this exhibit to show that the missing Sherwood Forest-specific resolution 

problem was material to Detroit’s claimed 2023 Sherwood Forest SAD renewal authority chain. 

Tribunal Relevance: 

This exhibit is material because it shows that Detroit’s missing Sherwood Forest resolution problem was 

not an unavoidable administrative format issue. In the same June 2023 renewal process, Detroit’s 

reviewed record identified district-specific resolution files for Detroit Golf Club and Palmer Woods but 

did not identify a comparable Sherwood Forest-specific resolution file. 

That omission matters because Sherwood Forest was not interchangeable with Detroit Golf Club or 

Palmer Woods. Sherwood Forest had its own boundaries, petition set, proposed fee, tax parcel share, 

notice requirements, assessment roll, confirmation process, and Treasury billing authority. Detroit 

therefore had to prove a Sherwood Forest-specific authority chain before relying on the claimed 

Sherwood Forest renewal to impose and continue collecting the SMS/SWF charge. 

This exhibit is directly relevant to the current 2026 appeal because the 2026 SMS/SWF charge is 

derivative of Detroit’s claimed 2023 Sherwood Forest SAD renewal. If Detroit did not satisfy the 

mandatory authority-chain requirements for Sherwood Forest at the renewal stage, later billing 

records, Treasury processing, assessment extracts, annual administration, or tax-bill entries cannot 

independently cure the defect. 

This exhibit therefore supports the controlling question for the Tribunal: whether Detroit can prove that 

it satisfied the mandatory authority-chain requirements of MCL 117.5i and Detroit City Code 

Division 8 before relying on the claimed 2023 Sherwood Forest SAD renewal to impose and continue 

collecting the current 2026 SMS/SWF special assessment charge. 

Record Limitation: 

Petitioner does not offer the Detroit Golf Club or Palmer Woods comparator records to challenge those 

districts, to prove their compliance, or to ask the Tribunal to adjudicate those districts. Petitioner offers 

them only as comparator record evidence. 

This exhibit is limited to showing that Detroit’s reviewed June 2023 record identified district-specific 

renewal-resolution materials for Detroit Golf Club and Palmer Woods while not identifying a 

comparable Sherwood Forest-specific resolution file. 

Exhibit 9 — Page 2 of 11

Petitioner does not contend that comparator records alone prove no Sherwood Forest resolution exists 

anywhere in City possession. Petitioner contends that the reviewed and produced record does not 

identify the corresponding Sherwood Forest-specific authority-chain record, even though comparable 

district-specific records appear for the other two SAD districts. 

Petitioner contends that a later combined document, tax-bill entry, billing explanation, Treasury 

processing record, annual administration record, or assessment extract cannot substitute for the original 

Sherwood Forest-specific authority-chain records required to support a compulsory special assessment 

imposed through the property-tax system. 

Insert Behind This Cover Sheet: 

1. Detroit Golf Club district-specific hearing-request / preliminary renewal-resolution record dated 

June 7, 2023. 

2. Palmer Woods district-specific hearing-request / preliminary renewal-resolution record dated 

June 7, 2023. 

 

Exhibit 9 — Page 3 of 11

Exhibit 9 — Page 4 of 11

iddb 

led dilation 

Coleman A Young Municipal Center Phone 313+224¢3011 

Office of the Assessor 

2 Woodward Avenue, Suite 824 

Fax 313224¢9400 

Detroit, Michigan 48226 

www detroitmi.gov 

— 

CITY OF 

DETROIT 

June 7, 2023 

The Honorable Detroit City Council 

Coleman A Young Municipal Center 

Detroit MI 48226 

Re: Request to hold a hearing before The Budget, Finance, and Audit Standing Committee 

to renew the existing Special Assessment District for Detroit Golf Club. 

Honorable Detroit City Council 

The provisions of the Home Rule Act, Act 279 of 

1909, as amended, being (MCL) 117.51, 

allows a city with a population of more than 600,000 to, by ordinance, provide a procedure 

to finance by special assessment the provisions by private contractors of snow removal 

from streets, mosquito abatement, and security services. 

Detroit City Code Sec 44-3-212 states (in part) the following: 

Notice of the public hearing shall be given in accordance with the Michigan Notice of 

Special Assessment Hearing Act, being MCL 211.74 ef seq, and shall also be published 

in a newspaper of general circulation at least five days prior to the date fixed for the 

hearing. 

Detroit City Code Sec 44 -3 -221 states (in part) the following: 

When a designated neighborhood improvement organization (DNIO) wishes to continue 

an existing special assessment district beyond its term, it must take action to continue the 

special assessment district for an additional term in the same manner that a special 

assessment district is created pursuant to this division. To avoid a lapse in services, a 

designated neighborhood improvement organization may begin petitioning to initiate an 

additional term of a special assessment district prior to the expiration of the existing term 

subject to the requirements Section 44 -3 193(c) of this Code regarding the validity of 

signatures. 

At the hearing, the Budget, Finance, and Audit Standing Committee shall receive public 

comment regarding the renewal of the special assessment district. Notice of the hearing 

before the Budget, Finance, and Audit Standing Committee of the Detroit City Council 

shall be provided as set forth in Subsection (a) of this section. After considering further 

comments at this hearing related to the renewal of the special assessment district the 

Budget, Finance, and Audit Standing Committee of Detroit City Council may revise the 

terms of the special assessment district. 

Exhibit 9 — Page 4 of 11

Exhibit 9 — Page 5 of 11

— 

CITY OF 

une 

7, 

20 

DETROIT 

Page 20f 4 

The Office of the Chief Financial Officer — Office of the Assessor respectfully request 

that this honorable body set a date for a hearing before The Budget, Finance, and Audit 

Standing Committee of Detroit City Council 

to consider the renewal of a Special 

Assessment District for the Detroit Golf Club DNIO. 

Alvin Horhn 

Deputy CFO/Assessor 

Exhibit 

9 — Page S of 11

Exhibit 9 — Page 6 of 11

June 7, 2023 

Page 3 of 4 

WHEREAS, pursuant to the provisions of the Home Rule City Act, Act 279 of 1909, as 

amended, being MCL 117.51 (the act), a request to create a Special Assessment District 

(SAD) has been received; and 

‘WHEREAS, a city with a population of more than 600,000 may provide by ordinance a 

procedure to finance by special assessments the provision by private contractors of snow 

removal from streets, mosquito abatement, and security services. The ordinance shall 

authorize the use of petitions to initiate the establishment of a special assessment district. 

The record owners of not less than 51% of the land comprising the actual SAD must have 

signed the petitions. 

WHEREAS, the City of Detroit has amended Chapter 18, Article XII of the 1984 Detroit 

City Code, by adding 

Division 7, “Special Assessments for Snow Removal, Mosquito Abatement, and Security 

Services”, 

Subdivision A, “General Matters”, Sections 18-12-120 to 18-12-123, Subdivision B, 

“Petition”, 

Sections 

18-12-125 

to 

18-12-128, 

Subdivision 

C, “Establishment 

of District 

and 

Assessment”, 

Sections 18-12-130 to 18-12-142, and Subdivision D, “Contracting for Provision of 

Services”, 

Sections 18-12-145 to 18-12-146, to specifically implement the provisions of Section 5i 

of the Home Rule City Act, MCL 117.51, which grants the power to “provide by ordinance 

a procedure to finance by special assessments the provision by private contractors of snow 

removal from streets, mosquito abatement, and security services [and] authorize the use 

of petitions to initiate the establishment of a special assessment district.”; and 

Section 44-3-222 “Continuation of special assessments district upon expiration of term”. 

WHEREAS, The Detroit Golf Club Association, acting as the Designated Neighborhood 

Improvement Organization (DNIO), is proposing to renew a SAD for the benefit of all 

Tax Parcels for which a Tax Parcel Share is assessed the services of: 

1. 

Snow removal from streets, which may include the portion designed for vehicular 

travel, the portion designed for pedestrian travel, or both. 

2. 

Mosquito abatement; and 

3. 

Security Services; and 

WHEREAS, The Office of the Chief Financial Officer — Office of the Assessor, as the 

Administering Department, certifies that the Detroit Golf Club has submitted petitions in 

compliance with MCL 117.5i, containing the signatures of at least 51% of the property 

owners in the designated area in support of the renewal of a SAD, and that at least 51% 

of the property owners are current with their property taxes as of December 31, 2022 

Exhibit 

9 — Page 6 of 11

Exhibit 9 — Page 7 of 11

WHEREAS, the Office of the Chief Financial Officer — Office of the Assessor has 

verified the validity of the petition and any other information that the Administering 

Department deems appropriate; and 

WHEREAS, the proposed estimate of the cost of the services is $ 70,000, which equates 

to approximately $474/parcel; and 

WHEREAS, the City Council hereby preliminarily finds that the tax parcels will be 

benefited by an amount proportionate to the tax parcel share; and 

WHEREAS, the term of the SAD is seven (7) years beginning in 2024; and 

WHEREAS, due to the nature of the services being provided, a periodic redetermination 

of the cost will be necessary without a change in the SAD boundaries; that redetermination 

of the cost will occur in April of each year; and 

WHEREAS the services to be provided are an extension or expansion to services already 

provided by the City of Detroit and are not a replacement for existing City-provided 

services; and 

WHEREAS, the revised assessed cost may exceed by up to 15% the original assessed 

cost included in the resolution approving the district without further notice to residents in 

the SAD and 

WHEREAS, The Office of the Assessor request that a public hearing be scheduled before 

a session of the Budget, Finance, and Audit Standing Committee of The Detroit City 

Council on the issue of renewing the Special Assessment District for the Detroit Golf 

Club Area constant with the provisions of the Home Rule City Act, Act 279 of 1909, as 

amended, being MCL 117.51 and Chapter 18, Article XII of the 1984 Detroit City Code, 

“Special Assessments for Snow Removal, Mosquito Abatement, and Security Services” 

along with Section 44-3-221 “Continuation of special assessment district upon expiration 

of term”. 

NOW BE IT RESOLVED that a Public Hearing shall be scheduled before a session of 

the Budget, Finance, and Audit Standing Committee 

of The Detroit City Council 

regarding the renewal of a Special Assessment District for the Detroit Golf Club 

Association in the City of Detroit 

Exhibit 

9 — Page 7 of 11

Exhibit 9 — Page 8 of 11

OFFICE OF THE CHILE PINMIDIAL OFFICER 

Coleman A Young Municipal Center 

Phone 3132243011 

Ҥ| 

Office of the Assessor 

2 Woodward Avenue, Suite 824 

Fax 31302249400 

= 

Detroit, Michigan 48226 

www detroitmi.gov 

CITY OF 

~—— 

DETROIT 

June 7, 2023 

The Honorable Detroit City Council 

Coleman A Young Municipal Center 

Detroit MI 48226 

Re: Request to hold a hearing before The Budget, Finance, and Audit Standing Committee 

to renew the existing Special Assessment District for Palmer Woods. 

Honorable Detroit City Council 

The provisions of the Home Rule Act, Act 279 of 

1909, as amended, being (MCL) 117.51, 

allows a city with a population of more than 600,000 to, by ordinance, provide a procedure 

to finance by special assessment the provisions by private contractors of snow removal 

from streets, mosquito abatement, and security services. 

Detroit City Code Sec 44-3-212 states (in part) the following: 

Notice of the public hearing shall be given in accordance with the Michigan Notice of 

Special Assessment Hearing Act, being MCL 211.74 et seq, and shall also be published 

in a newspaper of general circulation at least five days prior to the date fixed for the 

hearing. 

Detroit City Code Sec 44 -3 -221 states (in part) the following: 

When 

a designated neighborhood improvement organization wishes to continue an 

existing special assessment district beyond its term, it must take action to continue the 

special assessment district for an additional term in the same manner that a special 

assessment district is created pursuant to this division. To avoid a lapse in services, a 

designated neighborhood improvement organization may begin petitioning to initiate an 

additional term of a special assessment district prior to the expiration of the existing term 

subject to the requirements Section 44 -3 193(c) of this Code regarding the validity of 

signatures. 

At the hearing, the Budget, Finance, and Audit Standing Committee shall receive public 

comment regarding the renewal of the special assessment district. Notice of the hearing 

before the Budget, Finance, and Audit Standing Committee of the Detroit City Council 

shall be provided as set forth in Subsection (a) of this section. After considering further 

comments at this hearing related to the renewal of the special assessment district the 

Budget, Finance, and Audit Standing Committee of Detroit City Council may revise the 

terms of the special assessment district. 

Exhibit 

9 — Page 8 of 11

Exhibit 9 — Page 9 of 11

CITY OF 

DETROIT 

Page 2 of 4 

une 

7, 

The Office of the Chief Financial Officer — Office of the Assessor respectfully request 

that this honorable body set a date for a hearing before The Budget, Finance, and Audit 

Standing Committee of Detroit City Council 

to consider the renewal of a Special 

Assessment District for the Palmer Woods. 

A 

« 

Deputy CFO/Assessor 

Exhibit 

9 — Page 9 of 11

Exhibit 9 — Page 10 of 11

_ 

|Honorable 

City Council 

< 

~ CITY OF 

June 

DETROIT 

Page 3of4 

WHEREAS, pursuant to the provisions of the Home Rule City Act, Act 279 of 1909, as 

amended, being MCL 117.51 (the act), a request to create a Special Assessment District 

(SAD) has been received; and 

WHEREAS, a city with a population of more than 600,000 may provide by ordinance a 

procedure to finance by special assessments the provision by private contractors of snow 

removal from streets, mosquito abatement, and security services. The ordinance shall 

authorize the use of petitions to initiate the establishment of a special assessment district. 

The record owners of not less than 51% of the land comprising the actual SAD must have 

signed the petitions. 

WHEREAS, the City of Detroit has amended Chapter 18, Article XII of the 1984 Detroit 

City Code, by adding 

Division 7, “Special Assessments for Snow Removal, Mosquito Abatement, and Security 

Services”, 

Subdivision A, “General Matters”, Sections 18-12-120 

to 18-12-123, Subdivision B, 

“Petition”, 

Sections 

18-12-125 

to 

18-12-128, 

Subdivision 

C, 

“Establishment 

of District 

and 

Assessment”, 

Sections 18-12-130 to 18-12-142, and Subdivision D, “Contracting for Provision of 

Services”, 

Sections 18-12-145 to 18-12-146, to specifically implement the provisions of Section 5i 

of the Home Rule City Act, MCL 117.51, which grants the power to “provide by ordinance 

a procedure to finance by special assessments the provision by private contractors of snow 

removal from streets, mosquito abatement, and security services [and] authorize the use 

of petitions to initiate the establishment of a special assessment district.”; and 

Section 44-3-222 “Continuation of special assessments district upon expiration of term”. 

WHEREAS, The Palmer Woods Association, acting as the Designated Neighborhood 

Improvement Organization (DNIO), is proposing to renew a SAD for the benefit of all 

Tax Parcels for which a Tax Parcel Share is assessed the services of: 

1. 

Snow removal from streets, which may include the portion designed for vehicular 

travel, the portion designed for pedestrian travel, or both. 

2. 

Mosquito abatement; and 

3. 

Security Services; and 

WHEREAS, The Office of the Chief Financial Officer — Office of the Assessor, as the 

Administering Department, certifies that the Palmer Woods has submitted petitions in 

compliance with MCL 117.5i, containing the signatures of at least 51% of the property 

owners in the designated area in support of the renewal of a SAD, and that at least 51% 

of the property owners are current with their property taxes as of December 31, 2022 

Exhibit 

9 — Page 10 of 11

Exhibit 9 — Page 11 of 11

Honorable City 

Council 

PAG 

| une 

7, 2023 

DETROIT |For 

WHEREAS, the Office of the Chief Financial Officer — Office of the Assessor has 

verified the validity of the petition and any other information that the Administering 

Department deems appropriate; and 

WHEREAS, the proposed estimate of the cost of the services is $ 225,000, which equates 

to approximately $495/parcel; and 

WHEREAS, the City Council hereby preliminarily finds that the tax parcels will be 

benefited by an amount proportionate to the tax parcel share; and 

WHEREAS, the term of the SAD is seven (7) years beginning in 2024; and 

WHEREAS, due to the nature of the services being provided, a periodic redetermination 

of the cost will be necessary without a change in the SAD boundaries; that redetermination 

of the cost will occur in April of each year; and 

WHEREAS the services to be provided are an extension or expansion to services already 

provided by the City of Detroit and are not a replacement for existing City-provided 

services; and 

WHEREAS, the revised assessed cost may exceed by up to 15% the original assessed 

cost included in the resolution approving the district without further notice to residents in 

the SAD and 

WHEREAS, The Office of the Assessor request that a public hearing be scheduled before 

a session of the Budget, Finance, and Audit Standing Committee of The Detroit City 

Council on the issue of renewing the Special Assessment District for the Palmer Woods 

Area constant with the provisions of the Home Rule City Act, Act 279 of 1909, as 

amended, being MCL 117.51 and Chapter 18, Article XII of the 1984 Detroit City Code, 

“Special Assessments for Snow Removal, Mosquito Abatement, and Security Services” 

along with Section 44-3-221 “Continuation of special assessment district upon expiration 

of term”. 

NOW BE IT RESOLVED that a Public Hearing shall be scheduled before a session of 

the Budget, Finance, and Audit Standing Committee of The Detroit City Council 

regarding the renewal of a Special Assessment District for the Palmer Woods Association 

in the City of Detroit 

Exhibit 

9 — Page 11 of 11

EXHIBIT 10 

OCTOBER 13, 2023, POST-FIRST-HEARING COMBINED MULTI-DISTRICT RENEWAL 

RESOLUTION 

Exhibit 10 — Page 1 of 5 

Source Record: 

October 13, 2023, combined Detroit Golf Club / Palmer Woods / Sherwood Forest renewal resolution 

submitted after the October 11, 2023, Budget, Finance and Audit Standing Committee public hearing. 

Short Title: 

October 13, 2023 — Post-First-Hearing Combined Renewal Resolution 

Purpose of Exhibit: 

This exhibit is offered to show that the combined multi-district renewal resolution for Detroit Golf 

Club, Palmer Woods, and Sherwood Forest was submitted after the October 11, 2023, first public 

hearing and therefore could not have served as the pre-hearing resolution, tentative assessment roll, 

Clerk-filed public-examination record, land-area verification record, or notice-supporting authority 

material required before that hearing. 

Material Record Points: 

1. The document is dated October 13, 2023.

2. The document is a combined resolution for Detroit Golf Club, Palmer Woods, and Sherwood

Forest.

3. The document states that the Budget, Finance and Audit Standing Committee held a public

hearing at its October 11, 2023, meeting concerning the SAD renewal request.

4. The document references MCL 117.5i and the requirement that record owners of not less than

51% of the land comprising the actual SAD must have signed the petitions.

5. The document states that the Administering Department certified petition compliance, but the

certification language refers to signatures of at least 51% of property owners, even though the

governing statutory standard referenced in the same document is record owners of not less than

51% of the land comprising the actual SAD.

6. The document describes Detroit Golf Club, Palmer Woods, and Sherwood Forest together in a

combined format rather than as separate district-specific resolutions.

7. The document lists the proposed fees as:

a. Detroit Golf Club — $494;

b. Palmer Woods — $495; and

c. Sherwood Forest — $300.

8. The document states that the term of the SAD is seven years.

9. The document states that periodic redetermination of cost will occur in April of each year.

10. The document forwards the petitions for Detroit Golf Club, Palmer Woods, and Sherwood

Forest with a recommendation for approval.

11. Because the combined resolution is dated October 13, 2023, it post-dates the October 11,

2023, first public hearing and could not have been available as a pre-hearing resolution,

tentative assessment roll, Clerk-filed public-examination record, land-area verification record,

or notice-supporting authority material for that hearing.

Tribunal Relevance: 

This exhibit is material because it shows the combined document Detroit used after the October 11, 

2023, first public hearing in the 2023 SAD renewal process. The October 13, 2023, combined 

resolution post-dates that hearing and therefore was not part of the pre-hearing attachment record 

available to affected Sherwood Forest owners before the hearing. 

The document is also material because Detroit’s own post-hearing resolution language does not clearly 

apply the statutory land-area standard to Sherwood Forest. The document references MCL 117.5i and 

the 51% land-area requirement, but the certification language refers to 51% of property owners. That 

is not the same legal standard as 51% of the land comprising the actual SAD. 

The document may show what the Assessor submitted after the first hearing, but it cannot 

retroactively establish that the October 11, 2023, hearing was properly supported by the required 

Sherwood Forest-specific authority-chain records before the hearing occurred. 

The exhibit does not show a Sherwood Forest-specific confirmed special assessment roll, a resolution 

confirming a Sherwood Forest special assessment roll, Clerk endorsement of a confirmed roll, delivery 

or transmittal of a confirmed roll to Treasury, proof of statutory mailed notice, certified 51% land-

area calculation, or Treasury billing-authority record. 

This exhibit therefore supports Petitioner’s position that a post-hearing combined multi-district 

document cannot substitute for the Sherwood Forest-specific authority chain required to support the 

current 2026 SMS/SWF charge imposed under Detroit’s claimed 2023 renewal of the Sherwood 

Forest Special Assessment District. 

Record Limitation: 

Petitioner does not deny that this combined document exists. Petitioner disputes that this combined 

document is legally sufficient to support the 2026 SMS/SWF charge without the confirmed Sherwood 

Forest special assessment roll, resolution confirming that roll, Clerk endorsement, Treasury transmittal, 

proof of statutory mailed notice, certified 51% land-area calculation, and billing-authority record. 

Petitioner further disputes that a document dated October 13, 2023, can retroactively supply the pre-

hearing resolution, tentative assessment roll, Clerk-filed public-examination record, land-area 

verification record, or notice-supporting authority material required before the October 11, 2023, first 

public hearing. 

Insert Behind This Cover Sheet: 

October 13, 2023, combined multi-district renewal resolution. 

Exhibit 10 — Page 2 of 5

Exhibit 10 — Page 3 of 5

OFFICE OF THE CHIEF FINANCIAL OFFICER 

3 

Coleman A Young Municipal Center 

Phone 3132243011 

Office of the Assessor 

2 Woodward Avenue, Suite 824 

Fax 3130224+9400 

Detroit, Michigan 48226 

www.detroitmi 

gov 

BY COUNCIL MEMBER 

WHEREAS, pursuant to the provisions of the Home Rule City Act, Act 279 of 1909, as 

amended, being MCL 117.5i (the act) a request to renew the Special Assessment District 

(SAD) for Detroit Golf Club, Palmer Woods, and Sherwood Forest has been received; 

and 

WHEREAS, a city with a population of more than 600,000 may provide by ordinance a 

procedure to finance by special assessments the provision by private contractors of snow 

removal from streets, mosquito abatement, and security services. The ordinance shall 

authorize the use of petitions to initiate the establishment of a special assessment district. 

The record owners of not less than 51% of the land comprising the actual SAD must have 

signed the petitions. 

WHEREAS, the City of Detroit has amended Chapter 18, Article XII of the 1984 

Detroit City Code, by adding 

Division 7, “Special Assessments for Snow Removal, Mosquito Abatement, and 

Security Services”, 

Subdivision A, “General Matters”, Sections 18-12-120 to 18-12-123, Subdivision B, 

“Petition”, 

Sections 18-12-125 to 18-12-128, Subdivision C, “Establishment of District and 

Assessment”, 

Sections 18-12-130 to 18-12-142, and Subdivision D, “Contracting for Provision of 

Services”, 

Sections 18-12-145 to 18-12-146, to specifically implement the provisions of Section 5i 

of the Home Rule City Act, MCL 117.51, which grants the power to “provide by 

ordinance a procedure to finance by special assessments the provision by private 

contractors of snow removal from streets, mosquito abatement, and security services 

[and] authorize the use of petitions to initiate the establishment of a special assessment 

district.”; 

Sec 44-3-221 Continuation of a Special Assessment District Upon expiration of term. 

WHEREAS, the Detroit Golf Club, Palmer Woods, and Sherwood Forest Neighborhood 

Associations, 

acting 

as 

the 

Designated Neighborhood 

Improvement 

Organization 

(DNIO), are proposing to renew the existing the Special Assessment District in their 

respective areas for the benefit of all Tax Parcels for which a Tax Parcel Share is assessed 

the services of: 

1. 

Snow removal from streets, which may include the portion designed for vehicular 

travel, the portion designed for pedestrian travel, or both; 

2. 

Mosquito abatement; and 

3. 

Security Services; and 

Exhibit 10 — Page 3 of 5

Exhibit 10 — Page 4 of 5

CITY OF 

DETROIT 

WHEREAS, The Office of the Chief Financial Officer — Office of the Assessor, as the 

Administering Department, certifies that the Detroit Golf Club, Palmer Woods, and 

Sherwood Forest Designated Neighborhood Improvement Organizations have submitted 

petitions in compliance with MCL 117.5i, containing the signatures of at least 51% of the 

property owners in the designate area in support of the creation of a SAD, and 

Whereas, the Office of the Chief Financial Officer — Office of the Assessor has provided 

to the Budget, Finance, and Audit Standing Committee of the Detroit City Council 

assurances verifying the validity of the petition and any other information that the 

Administering Department deems appropriate; and 

Whereas, the boundaries of the proposed SAD are as follows: 

For the Detroit Golf Club: 

That part of the East one-half of Section 10 and a part 

of the Southwest one-quarter of Section 11, Town 

I 

South, Range 11 East lying west of Woodward Ave, 

Detroit Michigan 

For Palmer Woods: 

That part of the Southwest one-quarter of Section 2 and part of the 

Southeast one-quarter of Section 3, T.1., S.R. ILE, lying west of 

Woodward Avenue, Detroit, Wayne County, Michigan 

For Sherwood Forest: 

The residential properties located south of Pembroke Ave. 

north of 7 Mile Road West (including homes on the north 

side of 7 Mile Road West from Livernois Ave. to Parkside 

St.), 

east 

of Livernois Ave., and west 

of the Woodlawn 

Cemetery. 

Whereas, the proposed fee for each Special Assessment District is as follows: 

Detroit Golf Club - $494 

Palmer Woods - $495 

Sherwood Forest - $300 

Exhibit 10 — Page 4 of 5

Exhibit 10 — Page 5 of 5

CITY OF 

DETROIT 

Whereas, the Budget, Finance, and Audit Standing Committee of the Detroit City 

Council hereby preliminarily finds that the tax parcels will be benefited by an amount 

proportionate to the tax parcel share; and 

Whereas, the term of the SAD is seven (7) years; and 

Whereas, due to the natures of the services being provided, a periodic redetermination of 

cost will be necessary without a change in the SAD boundaries, that redetermination of 

the cost will occur in April of each year; and 

Whereas, the services to be provided are an extension or expansion to services already 

provided by the City and are not a replacement for existing City-provided services; and 

Whereas, the Budget, Finance, and Audit standing subcommittee of the Detroit City 

Council held a public hearing at its October 11, 2023 meeting to support the hearing 

request; and 

Whereas, the revised assessed cost may exceed by up to 15% the original assessed cost 

included in the resolution approving the district without further notice to residents in the 

SAD and 

Now be it Resolved, the Budget, Finance, and Audit Standing Committee of the Detroit 

City Council hereby forwards with a recommendation for approval the petitions of the 

Detroit Golf Club, Palmer Woods, and Sherwood Forest Designated Neighborhood 

Improvement Organizations to continue with their respective Special Assessment 

Districts for seven years; and 

Now be it further resolved that a public hearing to consider the petitions of Detroit Golf 

Club. Palmer Woods, and the Sherwood Forest Designated Neighborhood Improvement 

Organizations shall be held before the Committee of the Whole of the Detroit City 

Council. Notice of the public hearing shall be given in accordance with Act 162 of 1962, 

the Notice of Special Assessment Hearings Act, MCL 211.741 et seq., and shall also be 

published in a newspaper of general circulation at least five (5) days prior to the date 

fixed for the hearing. Per Sec. 18-12-131 of City Code, and to the taxpayers of record 

within the proposed SAD. 

Exhibit 10 — Page 5 of 5

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