September Budget Hearings – Some Background

At the end of September, the 2012 budget will be in place.

In spite of 4 years of decline in real estate values, the county keeps raising the tax rates to prevent any decline in tax revenue. If the private sector worked like government, all you would need to do to maintain your standard of living as a business owner would be to raise your prices. Everyone would have to pay it, whether they could afford it or not. Of course in the real world your customers would leave.

According to a national research group, tax-rates.org, Palm Beach County is in the top 8% of all the counties in the country for the tax on the median priced property. When measured compared to the median income in the county we are in the top 6%. It wasn’t always this way, but as the housing bubble inflated, local governments (including the county) collected more and more taxes, and now are trying to maintain that high level after the bubble has burst.

The total tax burden varies with the municipality (or unincorporated area) in which you live, but is typically about 2.2% of the value of your property each year when you include school taxes, municipal taxes, and a variety of special taxing districts. On top of that, there are non ad-valorem taxes on utilities, communications, gasoline, etc. It may be worse in New York or California, but few would say the taxes in Palm Beach County are low.

So what can you do about it?

First we have to stop the increases. The county commission voted 4-3 in July to set the “maximum millage” at “rollback”. This means the most that they can levy this year will collect about the same revenue as last year. Even though valuations have declined again, many properties are under water, and the county unemployment rate is in double digits, the county would like to continue collecting what it did last year.

TAB believes that county spending in some areas continues to be excessive, and the first step in turning things around is to refrain from raising the tax rate again this year.

The Legislature has done its part by passing pension reform, estimated to save the county between $26M and $35M depending on how you calculate it. Upwards pressure on costs though, including contracted pay raises for employees of the Sheriff’s Office make it hard to restrain the spending. It should be noted that during the time the county departments have trimmed back substantially, PBSO has not. The Sheriff’s budget now consumes 58% of the county-wide ad-valorem tax revenue, up from only 36% in 2003. Clearly that agency should be doing more to help the county balance their books at flat millage.

TAB proposes a plan with four actions:

1. Maintain the county-wide millage at 4.75
2. Take any further cuts from PBSO, not the county departments
3. Take action to reduce the inventory of county property and reduce the debt
4. Cover any remaining shortfall from current fund balances (reserves) which are excessive compared to peer counties.

The 9/13 meeting will be well attended by those who benefit from county programs and oppose any budget cuts. Typically, those who oppose tax increases are fewer and less vocal. You can help change the equation this year if you show up at the meeting and let the commissioners know you oppose a rate increase. TAB will provide specific arguments you can use on the website after we review the coming budget package. In the meantime, here are some references that may help prepare you to support the TAB proposal at the September 13 budget hearing:

• Higher Tax Rates in our Future – a synopsis of the July budget workshop
• County Budget Update – July 8 – Published prior to the July meeting and covering the origin of the $45M “budget hole”
• The TAB proposal and the County Budget – published in June prior to the first budget workshop
• Powerpoint Charts for the latest version of the TAB presentation
• Synopsis of last year’s budget hearings:
  • County Commission Hikes Taxes Yet Again
  • Synopsis of 9/14 Budget Hearing

Fire Salaries Frozen in Martin County

Martin fire-rescue workers forgo raises in contract approved by County Commission

Tuesday, August 23, 2011

STUART — Martin County’s 300 fire-rescue workers will not receive raises in the next three years under a contract approved Tuesday by a divided County Commission.

That, combined with additional givebacks could total as much as $460,000 in savings.

Read the entire story by George Andreassi in TCPalm HERE

TAB Proposals for Charter Changes

Back in June, the County began public meetings about its ongoing Charter Review. The County Charter is its ‘constitution’ and describes Home Rule. There are 20 Home Rule or Charter Counties in Florida. Palm Beach County does not have a formalized Charter Review process, and this is the first comprehensive review to have taken place.

The Charter and the county’s charter review website can be found here. While there are a few changes that the Commissioners would like, citizens can input their own suggestions via the County Website. Suggestions are limited to 300 words per suggestion. Here is a link to the survey page. You can make as many submissions as you like.

There are many significant proposals that have surfaced, including county-wide commission districts, non-partisan elections, and converting some (or all) constitutional offices into county departments. We do not favor any of these as they appear to risk too many unintended consequences.

Attached are five proposals that we believe would improve county governance. One of these, “Smart Cap”, would have a direct affect on the county budget and we have explored that in depth in “Smart Cap – Good for the State, Good for the County”.

If you agree with any or all of these proposals, you can participate in the process by submitting the text contained within the box yourself using the county tool referenced above. To submit any of the ones listed below, just click on the [COPY] to the right of the suggestion you would like to copy, and then cut/paste from the text that comes up and submit that to the survey link above. All of the descriptions fall within the 300 word limit. Friday, August 26, is the last date on which submissions will be accepted on the county website.

Little Progress in the IAFF Contract

The “negotiations” between Palm Beach County and the International Association of Fire Fighters, local 2928 have now been in progress for three months. With the exception of some minor cleanup in the text, there has been no agreement on anything. The major issues of starting salary (the county wants a 22% reduction) or employee contributions toward health insurance (3%) have not even been broached in the public meetings.

Seemingly minor issues, such as posting the seniority list on the intranet rather than on bulletin boards give rise to heated discussion, complete with implausible hypotheticals and the predictions of dire consequences. The county proposal to allow internal raters on promotional boards is treated by the union as if it was a wholesale rejection of a merit system for one of abject cronyism.

Yet with the exception of one heated exchange between attorneys over the “impasse” of qualifying overtime on a weekly rather than daily basis, the discussions have been cordial. The only problem is that they have accomplished absolutely nothing.

TAB volunteers have sat through these meetings, joined at various times by members of the press and a representative of the county Inspector General’s office. While the meetings have been about as exciting as watching paint dry, the way they have been conducted has been instructive in how public sector unions maintain their control over the functions of government.

Why this lack of progress?

The county, for their part, have proceeded in a workmanlike manner. Led by Attorney Robert L. Norton and Chief Steve Jerauld, their 6 member team has put their cards on the table in the form of detailed modifications to the existing contract document and walked through it in painstaking detail for the union representatives. They showed up for the meetings on time, and have been reasonable in the representation of their position. Of course their negotiating position is modest – other than the reduction in starting salary that affects nobody currently represented by the IAFF, there is no attempt to pare down the salaries and luxurious benefits enjoyed by current employees. The county team appears to be serious about completing the negotiations in a timely manner, and have tried multiple times to get additional meetings scheduled to expedite the process.

The union on the other hand, seems content to let the talks drift along. Led by Attorney Matthew J. Mierzwa, they have avoided agreeing to anything, even minor changes in wording. They showed up an hour late for the August session, a public meeting that had been on the county web calendar for quite a while, claiming “miscommunication”. (The county team was there on time, as were the observers). In the first meeting, halfway through the first “caucus”, they abruptly terminated the discussion and did not return until the next month’s meeting. One of their team of nine negotiators made the incredible statement that he had not read major sections of the county proposal because “he knew he wouldn’t agree with it”.

It appears to an outside observer that the county wants to conclude a new contract and the IAFF does not. Why would that be?

The contract expires at the end of September. The new county proposal contains new hire salary reductions, benefit cost sharing, and other things that disadvantage the union. The union version omits the reductions but does agree to forgo across the board salary increases in the new contract, subject to the condition: “Should the assessed value of properties in Palm Beach County or total revenues for Fire Rescue increase during the term of this agreement, the Union may reopen this Article for further negotiations.”

Maybe they want to run out the clock the way Congress does on major legislation. Perhaps they feel an improving economy will strengthen their hand. It is hard to say.

Although it is early to speculate, what if no agreement were to be reached? In that case, resolution would follow the rules of Florida Statutes Chapter 407.403 – “Resolution of Impasse” which involves mediation by a special magistrate. You may recall that this was a step in the resolution of the Fire/Rescue contract in the Town of Palm Beach. Ultimately it fell to the city council to impose what was a significant setback to the IAFF in that town. In this case, it would fall to the County Commission to impose a settlement.

The process continues in a planned all-day session on September 14, unless the proposal for four additional meetings requested by Mr. Norton is accepted. It should be pointed out that all participants in these discussions (6 for the county and 9 for the union) are being paid by the taxpayers. The attorneys of course are generating billable hours.

Two TAB Coalition Partners Organize Phonebank to oppose Tax Rate Increase

Is there really a swing vote who will decide if our tax rates are increased this year? It is possible.

During the July budget workshop, the vote to raise the maximum millage to rollback (4.8751) was 4-3. Commissioners Abrams, Marcus and Burdick voted no to the increase and all had good reasons to avoid a third hike in so many years. Commissioners Aaronson, Santamaria, and Taylor voted for the hike. They also gave reasons that are not likely to change in September.

Which leaves District 3 Commissioner Shelley Vana. Her votes on tax increases have been mixed, voting against the 14.9% hike in 2009 but supporting the 9.4% increase in 2010. This year, she voted to raise the maximum millage to keep “options open”, but suggested that there were more savings to be had and she would like to keep the tax rate unchanged when it comes up for the final vote in September.

After the July budget hearing, TAB sent the following in an email to Commissioner Vana:

In response, and to her credit, she got in touch with us and made a convincing case that there was another $12M to be had and she just might “.. be the fourth vote ..” for flat millage in September.

We found this encouraging, but we also know that there are powerful interest groups in the county for continuing programs and taxes that speak very loudly to the commissioners. Those who do not want to see a tax rate increase are rarely heard. More to the point, it is the citizens of District 3 that should matter the most to the Commissioner, not any of the special interests, or even TAB.

Along these lines, two of TAB’s coalition partners have decided to reach out to the constituents of District 3 and educate them on the 2012 budget, and their Commissioner’s role as the potential “swing vote”.

The recently formed Palm Beach County Tea Party, with chapters in Jupiter, Wellington and Boca Raton will join forces with the South Florida 912 which meets in Palm Beach Gardens, Wellington and Lantana. Each of these groups is organizing a phone bank to contact District 3 citizens and ask them to make their wishes known to Commissioner Vana. They believe that many of the citizens would oppose a third year of tax rate hikes. If so, perhaps they can help the Commissioner find the additional $12M in cuts it will take to not raise our taxes again.

TAB applauds this effort and believes it is a new approach to broadening the county budget discussion beyond the commission chambers and the pages of the Palm Beach Post. It may turn out more attendees at the budget hearings who oppose another tax increase. At a minimum, it will have educated a larger group of county residents about the way their taxes are set.

If you would like to assist one of these organizations in their effort, you can contact them as follows:

Palm Beach County Tea Party: action@palmbeachcountyteaparty.org

South Florida 912: action@southflorida912.org

Fire / Rescue Contract Talks Continue

The July meeting of the negotiating teams for the 2012 IAFF contract did not move the ball very much, at least as far as we could see. As the meeting wrapped up, Chief Jerauld proposed holding additional sessions prior to the scheduled one on August 17 as there is a lot to do and little time to complete it.

More observers for the public attended this session, including TAB members, a reporter for the Palm Beach Post, and a representative of the Office of Inspector General. As this was anticipated, the county moved the meeting to a larger conference room at the Pike Road Headquarters.

The meeting consisted of much discussion of several draft agreements that had been prepared, and numerous “side agreements”, referenced by page number or paragraph position. None of the observers had copies of the referenced documents so it was difficult to follow. (We have asked for copies of all the materials prior to the next meeting). Much of the 3 hours were interrupted by “caucus time” when all the participants left the room for each side to confer among themselves – one of them 45 minutes in length. When we asked, it was explained that the referenced “side agreements” were contract modifications that were negotiated since the last contract was signed. None of these (or the current contract proposals) are available on the county website, but they are public documents which we will seek.

The major proposal by the county – reducing starting salary for new employees by 22%, was not discussed. It is our understanding that a counter-offer by the IAFF consists of an agreement for no raises for the next three years (subject to renegotiation if economic conditions improve), in return for retaining the existing starting salary of about $50K.

As described in Andrew Marra’s editorial “Cut these Alarming Salaries“, the problem is the existing salaries, which are approximately 50% higher than the national average and unaffordable in the long run without significant tax hikes or reduction in staff. Cutting the starting salaries would help, as would eliminating raises. If both were done, it may at some point bring Fire / Rescue Compensation down to earth. It would take a long time to do so however. There is nothing that we have heard in these current negotiations that will solve the problem near term, and choosing between starting salaries and wage freezes is a false choice. Both are needed, at a minimum.

We will continue to report on these negotiations as they progress.

Higher Tax Rates in our Future

On Monday, the county commission voted 4-3 to set the maximum millage at 4.8751, which would be a 2.6% increase over 2011. Maximum millage is the number that may not be exceeded when public hearings on the budget resume on September 13.

Following back-to-back increases totaling over 25% in the last 2 years, the commissioners had directed staff in February to create a budget that did not include a tax increase. This would have resulted in $12M less tax revenue collected because of still declining property values, but was offset by cost savings of $25M from reform of the Florida Retirement System (FRS) by the legislature. Other factors however, including reduced interest income and fund balance issues, resulted in a shortfall estimated at $40M and led to a proposal of cuts to popular programs.

Commissioner Aaronson, who is known for ongoing support for raising taxes on others to pay for services in his district, assured us that “it is only a starting point”.

Like Groundhog Day (the movie), the budget discussion plays out in a similar fashion year after year. A low or minimal rate increase is presented, combined with cuts sure to bring out the supporters (Palm Tran Connection, Nature Centers, Financially Assisted Agencies). A “reasonable alternative” that raises tax rates “just a little” for “pennies a day” is offered by Administrator Weisman, and after several hours of public comment, mostly by beneficiaries of those programs, the commissioners vote in July to set the “maximum millage” to the larger figure. Then, in September, after 8 weeks of “trying” to find additional savings, the commissioners decide they have no choice but to adopt the maximum as the final tax rate. Then the cycle begins again. Any guess as to how this will end this year?

To their credit, Commissioners Marcus, Abrams and Burdick voted against the higher tax rate. Paulette Burdick, in her first budget season as a commissioner, attempted to actually set priorities – facing down PBSO CIO George Forman over further cuts to the Sheriff’s budget, yet supporting continued funding for the financially assisted agencies.

Accepting the higher rate were commissioners Aaronson (no surprise), Taylor (who didn’t think 2.6% was significant), and Santamaria. None of these were surprises as they had made no moves toward the lower rate in the June workshop.

The more curious vote was by Shelley Vana, who at first seemed to be seeking additional savings (efficiency, etc) to prevent the tax hike, but voted for it anyway. Like Aaronson, she said it was a starting point and they can “try” to find additional savings before the September sessions. Actions speak louder than words commissioner. Don’t expect any credit for rhetoric.

From a TAB perspective, those of us who spoke against the tax hike were outnumbered by those seeking program dollars. While it is difficult to get working people to attend a morning meeting, we hope those of you who did not attend were able to send email or other communication to let your voice be heard.

Those who did speak for the lower tax rate, included Jack Borland, Francisco Rodriguez, Mel Grossman, Pam Wohlschlegel, Carol Hurst, Victoria Thiel, Dionna Hall, and Fred and Iris Scheibl.

For the next 8 weeks, TAB will be refining the argument against the higher rate and attempting to increase citizen awareness and involvement in the budget process.

Next Fire/Rescue Contract Negotiation Scheduled

At the initial meeting between County Fire/Rescue and the IAFF on the 2011 contract, the county proposed a 22% reduction in starting salary among other changes. (See Genesis of a Collective Bargaining Agreement) The union response was deferred to the subsequent meeting which has now been scheduled for July 19.

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NOTICE OF PUBLIC MEETING
PALM BEACH COUNTY FIRE RESCUE
Contract Negotiations

Please be advised that a Contract Negotiations meeting between Palm Beach County Fire Rescue and the IAFF Professional Firefighters/Paramedics of Palm Beach County will be taking place on:

July 19, 2011
9:00 a.m.

This meeting will take place at the Palm Beach County Fire Rescue, Room 101/102, 405 Pike Road, West Palm Beach, Florida 33411

(NOTE: This location has changed as of July 12 – it was to be held at the Trauma Hawk hanger on Southern Boulevard)

County Budget Update – July 8

The next county budget workshop is Monday, July 11, at 9:30AM at 301 N. Olive, WPB in the 6th Floor Commission Chambers. Because of a scheduling issue, the BCC action to set the maximum millage rate that was scheduled for July 19 has been moved up to the 7/11 meeting. We expect the County Administrator to ask that this be set to rollback, currently estimated at 4.8751 (about a 2.6% increase in tax rate), or higher. The majority of homestead property owners would see a larger increase of course, because their valuations are still catching up.

TAB opposes a tax rate increase of any size and is calling for the millage to remain at 4.75.

Public comment begins at 10:00 but you should be there at 9:30am for the start of the meeting if you plan to speak. Please consider making your thoughts known to the commissioners, either in person at the meeting, or by email or phone prior to next Monday.

Since the June 13 meeting:

1. New estimates of property valuation show a smaller decline that Administrator Weisman sees as $3M more in tax revenue than expected. Consequently, he now calculates “rollback rate” at 4.8751. There is also an expectation for $2M more in revenue from other sources (sales tax and revenue sharing).

2. The Sheriff, who is expected to see a reduction in FRS pension costs of $18M, has objected to the county trying to “share the wealth” and take some of that savings for the county department budget. Bob Weisman has conceded the point and estimates that his shortfall will increase by $12M as a result.

The June budget package at flat (4.75) millage, had a $45M gap versus 2011. $15M of this was from valuation decline ($588M in taxes versus $603M), and $30M from declines “elsewhere”. The Revenue chart on page A-2 only identifies $14M of the “elsewhere” – notably $4M less in interest income, $10M in “other BCC revenue”, and a little more than $1M less from the Sheriff, offset by some small revenue increases in other areas.

Where is the rest of the “budget hole’? We asked Budget Director John Wilson to clarify the $45M, and he gave us this data:

• $15.470M – loss of tax revenue at current millage rate of 4.75
• $9.066M – decrease in one-time funding sources (available funding from existing capital project funds)
• $4.902M – decrease in other revenues (primarily interest income)
• $6.953M – reduction in beginning balances brought forward in Palm Tran, County Transportation Trust Fund & Court Tech. Fund.
• $2.687M – increase in new capital project funding
• $5.184M – increase in General Fund transfer to D/S Funds (additional issue and loss of one-time funding)
• $.781M – increase in non-department operations – primarily due to reduction in indirect cost allocation

 

We are still a little fuzzy on the fund transfers and one-time funding sources, but he assured us that it would be explained in the July budget package.

Now that the package is available, we are still trying to understand it. We are also having some difficulty in bridging our analysis of the 2003-2011 period with 2012, since the budget package is in a different format than last year, and the section “Comparison of Revenues, Appropriations, Net Ad Valorem Requirement and Positions by Department” has been omitted. This section was important to us because it has appeared mostly unmodified in all the budgets since 2003. Now we are dealing with apples and oranges. The OFMB folks assure us the data is there, just spread around between different sections, and (in some cases) between the June and July packages. If we can unravel this Chinese puzzle, we will update our multi-year tracking charts in a future article.

We are adding another point to the TAB proposal. Since the “$45M gap” (now closer to $40M) is related to starting fund balances and interfund transfers, we think it is appropriate to consider using some small amount of reserves to avoid a tax rate increase. In 2006, Florida TaxWatch pointed out that our unreserved fund balances (then 71% of revenue) far exceeded our peer counties and were remarkably high. Today, the levels have come down some but we are still far above Orange, Hillsborough and Miami-Dade, and slightly below Broward. The balances are a significant multiple of a “prudent miminum” of 15-20% of revenue. Consequently, we are adding “Utilize undesignated reserves to fill a one-time budget hole”.

The TAB Proposal:

1. Maintain the county-wide millage at 4.75
2. Take the majority of cuts from PBSO, not the county departments
3. Take action to reduce the inventory of county property and reduce the debt
4. Utilize undesignated reserves to fill a one-time budget hole.

*Note: The TaxWatch study that relates to item #3 is in draft. We hope to share some of its findings in the near future.

Notes and Feedback From June 30 Commission Workshop in Pahokee

I was not able to attend the entire Commissioner Workshop on Thursday in Pahokee, but the following are my notes from the discussion:

Programs identified as potential areas for budget cuts by Robert Weisman and the Commissioners:

• 4-H
• Children’s programs
• Park services
• Drug & alcohol treatment / recovery
• Consumer Affairs
• Pools
• Life guards at the beach
• No increase in funds for economic development
• Events at County amphitheatres

The Commissioners expressed concern and would prefer not to reduce these services.

Feedback to Mr. Weisman and the Commissioners:  Drop the political jargon and start cutting overhead.  Rather than considering a “small” tax increase, your strategy should be to create a budget surplus.  The economic issues we are facing will not go away in a year or two.  A budget surplus is not a pipe dream.  It is possible if you have the will…. And you do not need to reduce services that are valued by your constituents.  Just eliminate waste:  Insist that Mr. Weisman increase productivity, eliminate positions that do not create direct value for constituents, and find synergies between Mr. Weisman’s responsibility functions.

You should also make peace with the Constitutional Officers.  They are the Commissions peers, not Mr. Weisman’s peers.  The Chair of the Commission should take the lead to open communications and build trust.  There are massive synergies that can be achieved through shared services of information technology, fleet management, real estate management, procurement of commodities, logistics, telecommunications, and other support functions.

Cruzan Amphitheater losses – If you have not attended concerts at Cruzan you should:

• Great entertainment which is often sold out…. Hmm…. Maybe we should raise the ticket price?
• The prices of concessions are similar to that charged at a Dolphins game.  The quality of the product and service is substandard.  Needs quality and price gouging oversight by the County + check to make sure that the County is receiving a fair share of the concession revenue.
• Alcohol sales are incredible, with literally wheel barrels full of beer carted throughout the venue.  Sounds like fun for boomers…. But at what cost on the road after the event?  Checking ID’s: right!  Interestingly, I’ve never seen a sobriety check point on Southern Blvd after an event. I guess we want to make sure that the vendors don’t get in trouble.

Mr. Weisman:

• We are not going to reduce staff.  Layoffs will be avoided.
• Cut the Sheriff’s budget….. no further cuts in his budget
• Questions value of drug and alcohol program, given low success rate

Feedback to Mr. Weisman:

• The County Administrator and Commissioners have a fiduciary responsibility to reduce staff when work volumes decline.  There is also a fiduciary responsibility to establish best in class processes, training, and technology to advance productivity while at least maintaining current levels of service to the public.  You should ask an unemployed homeowner whether he/she believes their tax payments should be used to retain County employees that are not required or could be laid off without a significant change in the quality of service delivered to the public.
• Any position that is not directly involved in meeting the needs of the public should be subject to elimination.  The County Administrator should be a role model by taking a voluntary salary reduction, requiring all employees (and encouraging constitutional officers to do the same) to take one unpaid furlough day per month for the entire budget cycle. Martin County instituted such a program some time ago:  Reduced operating expenses by between $1 and 2 million during the fiscal year (approximately 900 employees).  Feedback from their employees was mixed, but I understand that most agreed that they would rather reduce their compensation than layoff massive numbers of employees.  By the way, Martin County also reduced their staff levels during this same period.
• Drug and alcohol programs:  Mr. Weisman should talk to the people that manage these programs to learn that relapse is the norm.  Many people relapse more than 10 times before recovery.  Of course, he should review the effectiveness of the County program and consider alternative means of delivery (private sector) to insure that cost and quality is effective.

Commissioner Taylor:

• Inspector General is spending $3.4 million even now that we have ethics policies
• Need to replace break walls
• Need to rebuild bridges
• A tax increase to balance the budget is insignificant:  $.04 per taxpayer per day….. Most will accept it rather than reduce service levels.

Feedback to Commissioner Taylor:

• Palm Beach County has a national reputation that will not easily be overcome.  Our reputation is a significant disadvantage for job creation and economic development.  I am thankful that we have an Inspector General.  It is up to elected officials to demonstrate that they can be trusted.
• If increasing taxes is “not that big a deal”, then reducing the expenditures to balance the budget is “not that big of a deal?”
• I understand you have a survey at your website asking people if they would rather reduce services than increase tax rates.  There should be a third option:  Don’t increase taxes and maintain current service levels.
• I agree that infrastructure like aging bridges and break walls are important.  This should also be taken into consideration when the County evaluates new infrastructure, including parks, community centers, and the beaches.  A question that needs to be addressed:  Can we afford the upkeep cost of infrastructure?

Performance Measurement

This is a great topic.  I have reviewed Mr. Weisman’s recent performance measurement report provided to Commissioner Marcus.  The information included in the report is solely units of activity, not performance.  Performance measurement should track productivity, cost per unit, and quality of work (error free work flow – rework is very expensive) of the most important aspects of a person, department and/or organization.  In the private sector such measures are called key performance indicators (KPI’s).

The Commissioner discussion included comparing groups like to Sheriff’s Office to other municipalities. Benchmarking should only be based on best in class, and it should not be limited to government comparisons.

Prepared by Dale Gregory

Boca Raton, Florida

July 1, 2011

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