FINAL REPORT REVOLVING FUND FEASIBILITY STUDY FOR THE CONNECTICUT TRUST FOR HISTORIC PRESERVATION

FINAL REPORT REVOLVING FUND FEASIBILITY STUDY FOR THE CONNECTICUT TRUST FOR HISTORIC PRESERVATION Prepared by DLJ Consulting November 10, 2011 Exec...
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FINAL REPORT REVOLVING FUND FEASIBILITY STUDY FOR THE CONNECTICUT TRUST FOR HISTORIC PRESERVATION

Prepared by DLJ Consulting November 10, 2011

Executive Summary In June 2011, the Connecticut Trust for Historic Preservation (CTHP) engaged DLJ Consulting to conduct a revolving fund feasibility study. The purpose of the study is to assist CTHP consider the ways in which a revolving fund would support and help to expand its existing grant programs. The study will serve as an information resource for the CTHP Board of Trustees and will help guide the Board in making a decision on the most appropriate type of fund for the organization, while balancing historic preservation finance needs across the state. The multiple-phase study started with an analysis of CTHP’s existing programs. Subsequent phases of the study consisted of: a comparison of four revolving funds that represented best practices in historic preservation revolving funds; a needs survey; a Board and staff retreat; and three case studies. The survey identified the need for additional historic preservation financing in the form of short-term and long-term loans. The results implied that there were opportunities to expand the use of the Historic Homeowner Tax Credit, as well as federal and state historic tax credits. The survey also suggested that historic preservation activities had more impact if they were focused on a particular location. The Board and staff retreat identified objectives of a new revolving fund that might include: Providing financial assistance that fills funding gaps for preservation projects Implementing a comprehensive approach to using historic preservation as an economic development tool Providing technical assistance to property owners using historic tax credits Creating new and stronger partnerships Leveraging other CTHP programs The case studies provided “live” examples of how a revolving fund might be used. The case study analyses highlighted both opportunities and challenges that might impact the success of a revolving fund. They also provided some insight into how a fund might be structured. An options-based revolving fund and/or a revolving loan fund seem to fit best with CTHP’s objectives and risk tolerance. This feasibility study concludes by encouraging CTHP to take the next steps to further clarify the organization’s goals and objectives for a fund, to define the structure of a potential revolving fund and then develop a business and capitalization plan to make sure that the proposed fund is based on sound financial principals and will be attractive to potential funders. Out of the case studies, it appears that Norwich might provide an excellent demonstration for a new revolving fund (potentially as an options-based fund and a revolving loan fund), and CTHP is encouraged to explore this possibility further. It represents an opportunity to work with partners, an opportunity to focus preservation efforts, encourages economic development, and fits well with CTHP programs.

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Project Description In June 2011, the Connecticut Trust for Historic Preservation (CTHP) engaged DLJ Consulting to conduct revolving fund feasibility study. The purpose of the study is to assist CTHP consider the ways in which a revolving fund would support and help to expand its existing grant programs. As a statewide organization with a mission of protecting and preserving historic buildings, landscapes, and communities, a revolving fund could be a valuable tool to revitalize and stabilize communities throughout the state of Connecticut. CTHP, in particular, wants to examine how endangered house museums, privately-owned National Register or locallydesignated properties, and urban affordable housing projects could benefit from such a fund. The goal of the feasibility study is to serve as an information resource for the CTHP Board of Trustees and to help guide the Board in making a decision on the most appropriate type of fund for the organization, while balancing historic preservation finance needs across the state. To accomplish this, DLJ Consulting has worked with CTHP’s board and staff to provide an analysis that includes: Understanding and evaluating the success of CTHP’s existing programs, Researching and summarizing basic information about various revolving fund models, Reviewing options for structuring a loan fund; Identifying potential borrowers and evaluating the financial needs for their projects; Reviewing risks associated with various types of revolving loan funds; Exploring the type(s) of loan funds that best match CTHP’s mission; and Using three property types identified by CTHP as test cases, evaluate how the proposed fund structure could meet CTHP’s preservation goals. Methodology and Scope of Work The scope of work was designed to solicit a variety of viewpoints regarding the role of a CTHPsponsored revolving fund and consisted of four phases: Phase I: Information Gathering and Analysis, including: 1. A SWOT (Strengths, Weaknesses, Opportunities, and Threats) Analysis of CTHP’s existing programs to better understand which program(s) would be complementary to a revolving fund. The SWOT analysis was accomplished by reviewing written materials about CTHP’s grant programs, as well as interviewing (by phone) key CTHP staff. The programs that were included in the analysis were: The Historic Preservation Technical Assistance Grant program (HPTAG), the Historic Building Finance Fund (HBFF), the Historic Properties Exchange (HPX), Vibrant Communities, and Historic Barn Grants; 2. A Comparison Study of four revolving funds that represent “best practices” in historic preservation. The funds selected included a variety of revolving fund formats including loan funds and options-based funds, as well as funds focused on affordable housing and neighborhood revitalization. The four funds compared were: Final Report - Revolving Fund Feasibility Study Prepared by DLJ Consulting Page 2

a. b. c. d.

The Georgia Trust for Historic Preservation statewide acquisition fund; Preservation North Carolina’s Endangered Properties Program; Historic Macon’s revolving loan fund; and New York Landmarks Conservancy’s revolving loan fund.

The selected funds were considered best practices based on their successful track records, the longevity of the programs, and because they met the goals and objectives of their respective organizations. The Georgia Trust’s and Preservation North Carolina’s funds both represent statewide funds and are both options-based. Historic Macon has several funds. Its largest fund is an acquisition and rehabilitation loan fund that is focused on a specific neighborhood. Its other funds include an acquisition and rehab loan fund for traditional historic properties and a façade loan program for three residential historic districts. The New York Landmarks’ fund is a citywide revolving loan fund. This program provides loans for residential projects and those undertaken by non-profit organizations. The focus of the residential program is on low and moderate-income homeowners. Like CTHP, all of the organizations that operate these revolving funds also engage in other historic preservation activities. 3. A Needs Survey that evaluated the financing and grant needs of historic preservation across the state of Connecticut, including specific questions regarding the needs for new financial products. DLJ Consulting conducted an online survey sent to a 1,531-name distribution list provided by CTHP. 204 respondents completed the survey. Phase II: Board Retreat On September 15, 2011, DLJ Consulting facilitated a board and staff retreat to further explore revolving fund possibilities. In addition to reviewing the results of the previous analyses as well as basic components of different types of revolving funds, the board and staff began to identify goals and objectives for a potential fund. The retreat ended with an exercise that asked Board and staff to define what their “dream” (or ideal) fund might look like, based on the earlier discussions in the retreat. Phase III: Case Studies CTHP selected three preservation projects for use as “case studies.” The purpose of the case studies was to determine how a revolving fund might be used to benefit particular projects, while meeting some of the revolving fund goals and objectives that CTHP has begun to formulate. Each of the selected case studies received previous assistance through one of CTHP’s grant programs. They presented a variety of scenarios in which a revolving fund might be used, and suggested ways in which a revolving fund might complement current CTHP programs. The case studies discussed fund feasibility, risk factors, and strategies (including additional resources such as historic tax credits to help leverage revolving fund investments). While the case studies suggest likely fund size requirements for each scenario, a capitalization study is recommended as an integral step in determining the optimal size of a potential fund.

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The case studies included: 1. The Strong House in Windsor, Connecticut was selected as a representative of endangered house museums. Owned by a local historical society, the museum needs extensive renovation and faces a challenging fundraising hurdle to accomplish its goals and objectives. This case study highlighted the difficulties of providing financial assistance to house museum properties that lack a sustainable business model or lack funds with which to repay a loan. 2. Downtown Norwich was selected because it represents one of five Vibrant Communities grant recipients. Norwich received a grant to conduct a survey of the downtown’s historic assets and to prepare a revitalization plan for the historic downtown core. The partnership between Norwich Community Development Corporation, the Norwich Historical Society, and the City of Norwich, provides CTHP with an opportunity to work collaboratively and strategically within a local community. In this case, a comprehensive program was suggested, providing technical assistance with historic tax credits, using a revolving loan fund and possibly an options-based strategy as well. 3. The Northside Institutions Neighborhood Alliance (NINA) and its work in Hartford’s Asylum Hill neighborhood was the third case study. This project represents CTHP’s goal of promoting affordable housing in historic districts. Like Norwich, it would provide CTHP with an opportunity to work with an existing partnership and expand on the work that CTHP has already funded in the neighborhood through its HBFF grants. The Connecticut Housing Investment Fund (CHIF) is also a partner in this project, providing financing to the projects and assisting CTHP with the underwriting for its grant investments. This case study suggests a revolving loan fund to assist with gap financing for the historic homeowner tax credit. Key Findings Throughout the initial information and analysis phase, there were many, sometimes conflicting, views on the need for, and role of, a CTHP-sponsored revolving fund. However, there were also consensus views expressed: 1. CTHP’s current grant programs have greatly benefited preservation projects across the state. CTHP’s offerings of financial assistance for historic preservation are currently all grant-based. Each grant program has been successful in meeting CTHP’s goals of helping endangered properties, encouraging affordable housing in historic districts, and providing economic development tools. One program that has tremendous potential for expansion is HPX. While HPX is not a grant program, as a marketing tool, it might fit well with a new revolving fund program. 2. There is a need for CTHP to diversify its funding sources. CTHP’s seemingly greatest strength, a solid relationship with the Connecticut State legislature that results in annual funding for its programs, may also be the source of its greatest weakness. Diversifying

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the funding base for CTHP programs would also demonstrate to potential future financial supporters that CTHP has the organizational capacity to attract broad support. 3. CTHP may benefit from expanding its constituency to include more non-profits, institutions, developers, and other groups outside of the preservation community. These groups were not well-represented in the list of survey participants. By expanding its constituency to include these groups, CTHP may find new partnering opportunities and may be able to attract new funding sources. 4. There is a need for increased historic preservation financing in the state of Connecticut. . In general, preservation is underfunded. More than half of the survey respondents suggested that CTHP provide long-term financing and over a third indicated a need for short-term financing. The Needs Survey identified a strong need for financial assistance to private homeowners for maintenance and repair; a need that CTHP could satisfy through a revolving fund. This may also be a way for CTHP to match its desire to establish a revolving fund to address its interest in affordable housing. However, the current real estate market and real estate values must be strong enough to support the cost of rehabilitation. The Asylum Hill case study is indicative of the significant subsidy needed in order to make many single-family affordable housing rehab projects financially feasible. 5. The Historic Homeowners Tax Credit is under-utilized. Few survey respondents reported working with historic tax credits, including the state’s Historic Homeowner Tax Credit. There is an opportunity for CTHP to provide valuable technical assistance to homeowners, commercial property owners, and non-profits who can utilize the credits in their historic preservation projects. A revolving loan fund could be used to “bridge” the pay-in of the credits. 6. Historic Preservation activities will be more successful and will gain more visibility if the efforts are focused. The survey responses indicated that the most economic impact would be demonstrated through working with commercial and mixed-use projects, suggesting that more could be done with the Vibrant Communities program. The survey respondents also felt preservation had more of an impact if focused on a particular community or neighborhood. CTHP’s stated goal of providing financial assistance that produces the most economic impact may be best served by focusing on commercial properties and market rate/mixed income housing. 7. CTHP’s programs have the potential to support and complement a revolving fund. More effective use of the Historic Properties Exchange program could be an important marketing component to a new options-based revolving fund. Both the Georgia Trust for Historic Preservation and Preservation North Carolina have robust marketing operations which support their revolving funds and provide opportunities for a wide variety of preservation projects to be sold and saved. Such a program may also be a source of revenue generation through advertising fees. The Historic Building Finance Fund could provide additional subsidy for a wider variety of preservation projects than just affordable Final Report - Revolving Fund Feasibility Study Prepared by DLJ Consulting Page 5

housing. By using this program in conjunction with a revolving loan fund and as a part of an overall revitalization strategy, it could help projects that might not be done otherwise. The Historic Preservation Technical Assistance Grant program could fund valuable technical assistance to those using historic tax credits. By providing this additional assistance to potential borrowers, this could help build a pipeline of future loans. CTHP’s board and staff retreat reinforced some of the above findings and incorporated them into the preliminary goal setting and fund vision exercises. There was consensus that one goal of the fund was to enable CTHP to be a more effective and proactive player in saving historic places throughout the state. CTHP’s most pressing concerns seemed to be managing risk, enhancing its ability to assist endangered properties, and the determining the optimal size of a fund. Common ideas and themes that emerged from the retreat included: The need for strategic focus through a revolving fund that stimulates relevant economic revitalization, works strategically in target markets, encourages active use of historic buildings, and builds credibility for CTHP. The desire for a self-sustaining revolving fund so that CTHP’s financial health is not adversely affected by the fund’s operations. Sustainability will be a function of the kind of fund, its size, capitalization, and the type of activities in which CTHP engages. The desire to manage risk in such a way that CTHP’s liability is limited to the amount of the revolving fund and the integrity of CTHP’s balance sheet is maintained. The desire to work through partnerships, with CTHP creating new partnerships that share risk and leverage other financing and skills. Target partners were clearly identified in the discussions, and include institutions, municipalities, community development corporations, and corporations. Target audiences seemed harder to define and ranged from house museums, developers, and homeowners to municipalities. The need for synergy so that the revolving fund supports and complements other CTHP programs. There also seemed to be some agreement that the three most relevant programs for complementing a revolving fund are HPTAG, HBFF, and Vibrant Communities. The need for flexibility with respect to the types of the projects that the revolving fund invests in and the terms of repayment options. CTHP wants to be able to respond quickly to endangered properties. The need for early intervention with a revolving fund that is proactive and allows CTHP to be involved in the planning stage of potential revolving fund projects.

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CTHP would be well served to use these themes as guiding principles as it further refines its revolving fund concept.

Conclusion The findings suggest a mix of opportunities and challenges for CTHP. There are clearly opportunities to work with existing partners and to expand upon the work that CTHP grant funding has supported. DLJ Consulting compared the guiding principles developed during the board retreat with the financing and sector gaps identified in the needs analysis. The principles were also compared with the risks and opportunities presented by the three loan fund types. The result of that comparison is shown below:

Guiding Principles

Strategic Focus Sustainability Credit Risk* Market Risk** Partnerships Synergy Flexibility Early Intervention

Fund Type

Loan Type

Acq

Option

Loan

X X

X X

X

X X X X X

X X X X X

X X X X X

Acq

Sector

Predevel

Const

Mini Perm

House Museum X

Afford. Housing X

Econ. Devel X

Private Homeowner X

X

X X X

X X X X X

X X X X

X X X X

X

X X

X X X X X

X X X X X X X

X

X X

X

* Credit risk: repayment source is the borrower’s income or other ability to repay. ** Market risk: source of repayment is the property’s value in a refinancing and/or sale. The analysis shows that a revolving loan fund, an acquisition fund, and/or an options-based fund would address many of the goals that CTHP has identified. The acquisition and options funds may provide more opportunities for sustainability as earned income from property sales could help to diversify CTHP’s income stream. However, these funds may also carry an inherent market risk that may prove challenging in a depressed real estate market. It appears that an acquisition fund has a higher risk profile than many of CTHP’s board members are comfortable with. However, if options can be obtained at low or no cost, an option-based fund may be a way to maximize the impact of limited revolving fund dollars. Should CTHP establish an options-based fund, there is an opportunity to expand the HPX program and use it as a marketing tool for properties acquired under options. There are also opportunities for CTHP to couple their existing grant programs, such as HPTAG and HBFF, to further leverage a revolving fund loan. This leverage could help achieve affordability for housing or commercial projects. Revolving loan funds are a more indirect investment vehicle than acquisition funds since they don’t involve a direct ownership interest in the property. The primary risk in a loan fund is credit Final Report - Revolving Fund Feasibility Study Prepared by DLJ Consulting Page 7

risk: the success of the fund will in large measure depend upon CTHP’s ability to adequately underwrite and mitigate the risk of repayment. CTHP will need to develop sufficient staff and the expertise to develop a loan pipeline, underwrite, and monitor active loans or partner with another organization which has these skill sets. Sustainability may also be more challenging with a loan fund as most loan funds require some degree of fundraising or annual operating support. Selfsufficiency is not typically achieved until the fund reaches a significant enough size to generate sustained income from interest payments and loan repayments. The survey also suggested the need for acquisition, pre-development and construction loans, as well as revolving loan funds to assist private homeowners in maintaining and repairing their homes. Each of these loans would provide CTHP with an opportunity to form new partnerships and (with the exception of homeowner repair loans) to build off the success of other CTHP programs. In addition to underwriting the market risk, CTHP would also need to underwrite the borrower’s ability to repay the loan. As such, CTHP might consider working with a local bank as a partner, allowing the bank to do much of the financial underwriting. With respect to homeowner loans, the challenge will be in finding neighborhoods where market values can support the cost of rehabilitation. Even with the Historic Homeowner Tax Credit, additional subsidy may be needed to cover the renovation costs. Depressed market values may be a problem outside of low-income areas as well. When the acquisition cost plus renovation costs exceed market values, there is little incentive to make the improvements. There is even less incentive to borrow funds to make improvements. Non-profit organizations responding to the survey suggested a need for assistance in the affordable housing sector. However, the Asylum Hill case study did not indicate a compelling need for CTHP intervention. Rehabilitation costs far exceeded neighborhood market values. As a result, the projects were heavily grant-subsidized, making additional layers of financing infeasible. CTHP may wish to explore whether there is a compelling need (such as gap financing to bridge the pay-in of the Historic Homeowner Tax Credit) for affordable housing work in this or other neighborhoods and/or for multi-family housing projects. CTHP’s goal of assisting historic house museums through a revolving fund also poses challenges. As was shown in the Strong House case study, a house museum may not hold enough value to serve as collateral for a loan, and in some cases, the owner of the house museum may not have enough of an income stream to repay a loan. An options-based fund is possible, if the owner of the house museum is willing. The survey results indicated that there may be a small market for such opportunities. 15 out of 39 historic house museums (or 38% of those responding that they owned historic property) would be willing to donate that property to CTHP. This is a high enough percentage that CTHP may wish to follow up with further research to understand the circumstances under which such a donation might take place. Rather than start a fund that is based on individual projects, it is recommended that CTHP start with a broader initiative and partnering opportunity, working with partners it already has an established relationship with. This not only provides the ability to work more in-depth on a project that has prior CTHP involvement, but it also might include a partner who could provide Final Report - Revolving Fund Feasibility Study Prepared by DLJ Consulting Page 8

some underwriting or other technical assistance to CTHP. It is also recommended that CTHP initially focus a revolving fund on a specific geographic area or locality. As indicated in the survey, concentrating historic preservation efforts provides more visibility and may have more of an impact. The Vibrant Communities program offers such an opportunity and would allow CTHP to focus its efforts on a specific community, generating economic development opportunities. A revolving loan fund for one of CTHP’s Vibrant Communities such as Norwich could provide valuable technical assistance to property owners, while providing financing that is historicpreservation specific. Assisting property owners to use historic tax credits, including identifying or helping to establish a small deal tax credit fund with a local investor, would significantly leverage CTHP’s investment. By adding an options-based financing alternative, CTHP could also help property owners locate purchasers who may be willing to make the investment in the downtown revitalization initiative. Furthermore, HPX might be able to play a role in marketing residential and commercial spaces along with CTHP-optioned property. As suggested by the retreat discussion outcomes, objectives of a new revolving fund might include: Providing financial assistance that fills funding gaps for preservation projects; Implementing a comprehensive approach to using historic preservation as an economic development tool; Providing technical assistance to property owners using historic tax credits; Creating new and stronger partnerships; and Leveraging other CTHP programs As with any initiative that involves real estate and investment, whether in the form of a loan or an option, there is risk involved. Risks cannot be totally eliminated, but they can be mitigated. In the case of a loan fund, risk can be partially mitigated through thorough underwriting practices. CTHP will need to decide whether it wants to take this on and build staff capacity to do the underwriting in-house. Alternatively, CTHP could contract with one of its project partners to do the underwriting, which will add some incremental cost to the operation of the fund. Risk can also be mitigated through partnering with another financial institution in a colender situation. In the case of an option-based fund, risk will be dependent on the real estate market, how much CTHP must pay for the option, and, in some instances, the adaptability of the property to a new or different use. Finally, risk for either type of fund can be managed by developing clear investment criteria and a process for evaluating fund opportunities. CTHP has indicated that it would like a revolving fund to be self-supporting. This, in part, will depend on the type of fund and the size of the fund. An option-based fund requires strong real estate marketing skills. If projects are carefully selected, CTHP may be able to consistently increase the fund balance when they are resold. With a loan fund, there are more variables that contribute to making the fund self-supporting: loan volume and size of loans, interest rate spread between the cost of funds and the rate to borrowers, staff time for underwriting or cost of underwriting by others, the cost of specialized staff with underwriting or real estate investment expertise, and the loan terms. The larger the loan fund is, the longer it has been in operation, and Final Report - Revolving Fund Feasibility Study Prepared by DLJ Consulting Page 9

the higher its loan volume, the better the chance that the fund can be self-supporting. CTHP should recognize that any fund will have a start-up phase during which additional funding and/or operating support may be needed. It may wish to consider a fund that strikes a balance between options and loans, with the goal being revenue-neutrality as the fund matures. As was mentioned above, the size of the fund will impact whether the fund is self-supporting or whether it is more mission-driven. A fund that is mission-driven will most likely require sustained fund-raising over the life of the fund. CTHP will need to analyze the economics of the types of loans it wants to do, the appropriate loan size, the acceptable risk, and other objectives to suggest an optimal size for the loan fund. The optimal size of an options-based fund will be dependent on CTHP’s goals, how many projects it wants to do, how long it will take to market the properties, and the average cost of the option. This type of fund would most likely take less to capitalize initially, and provides the best opportunity to support the staff and operating cost of the fund. The length of the loan term also needs consideration. Short-term loans (less than 18 months) will revolve much faster. Short-term loans may also have an identified source of repayment such as a permanent loan or infusion of tax credit equity. While there are still risks, such as an inability to complete a project, the risk may be less than underwriting an income stream, in the case of a commercial property, or an individual’s income over a longer period of time. DLJ Consulting does not recommend that CTHP consider financing with more than a 3-5 year term. Longer term loans require a more significant capital and/or equity base, as well as longer term capitalization sources that allow lenders to spread the risk and leave loans outstanding for a longer timeframe. Finally, the size of the fund will depend on the capital available to fund it and the cost of those funds. The traditional approach to capitalizing a fund is through grants or loans. However, as was seen in the case of New York Landmarks Conservancy, there are also creative and innovative ways to raise capital for a revolving fund. CTHP could consider raising equity through a capital campaign. The advantage of equity is that it allows the fund to be more flexible, lowers the overall cost of the fund’s capital and there is no lender to repay. A fund that blends equity and debt for its sources of capitalization may be able to lower its lending interest rate, allowing for competitive below-market rate loans. In either approach, CTHP will need to develop an attractive package of benefits and goals to encourage funders to invest. Next Steps The next step for CTHP, should it decide that it wants to pursue establishing a revolving fund, would be to develop a business plan. The business plan should include the following components: Fund goals and objectives; Strategy and type of revolving fund; Investment criteria for loans or options; Identification and mitigation of risks associated with the fund; and Final Report - Revolving Fund Feasibility Study Prepared by DLJ Consulting Page 10

Description of current operational capacity to operate a fund, and identification of additional staff expertise and capacity to carry out the implementation of a new fund. CTHP might consider holding another board and staff retreat to help work through the refinements to be addressed in the business plan. Once the business plan is complete, this should be followed up with a capitalization study. A capitalization study and resulting capitalization plan should be designed to bring CTHP’s resource development in alignment with the fund’s business model and programmatic goals, with the goal of building sustainability over the long term. Consideration would be given to the following: Current human and financial resources; The form of fund’s capital (debt and/or equity), as well its cost; The terms and conditions of the revolving fund’s investments and/or loans; The amount of capital needed; and Operating expenses and support. The business and capitalization plans would give CTHP a solid marketing tool to approach potential investors for a new revolving fund. When CTHP selected the projects to be examined as case studies, it hoped to identify at least one opportunity to create a revolving fund. Based on the analyses, Norwich might present the best opportunity. Working with the city of Norwich, CTHP could provide an integrated set of preservation solutions, including a revolving loan fund and/or an options-based program, to support downtown commercial district revitalization. The fund could complement other CTHP programs such as HPTAG and HBFF and would allow CTHP to focus its efforts on a particular community, providing more visibility to promote the benefits of historic preservation. The partners involved in the Vibrant Communities project seemed eager to explore this possibility. As such, CTHP may wish to meet with the Norwich Community Development Corporation, Historic Norwich, and the City of Norwich to further refine specific needs and opportunities. This could help CTHP to define its goals and objectives for a new revolving fund that could be initiated in Norwich, and potentially replicated in other communities around the state. Further, work on the business and capitalization plans discussed above, could be focused on the steps necessary to launch a Norwich-based demonstration project.

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