HomeMy WebLinkAbout08-10-26 Public Comment - J. Pape - Please see that the Commission get this...From:Jerry Pape
To:Mike Maas
Subject:[EXTERNAL][SUSPECTED SPAM] Please see that the Commission get this...
Date:Tuesday, August 11, 2026 11:24:47 AM
Attachments:SUD_OZ2.0_Commission_Supplemental_Substantiation_Tract11.02.pdf
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Bozeman City Commission,
Please review the attached PDF.
JP
--Jerry Pape, Supervising BrokerTriple Creek Realty of Bozemanwww.triplecreek.com(406) 579-3636
Supplemental Note to the Bozeman City
Commission — Further Substantiation for Census
Tract 11.02, Opportunity Zone 2.0
To:Mayor and Members of the Bozeman City Commission From:Jerry
Pape, Triple Creek Realty, for the Bozeman Development Consortium
Re:Further substantiation for reconsidering Census Tract 11.02 for Op-
portunity Zone 2.0 Date:August 10, 2026
Mayor and Commissioners,
This note supplements my comment to the Commission and the follow-
up I provided immediately afterward. It sets out, concisely, the further
substantiation behind the request that the Commission reconsider and
forward Census Tract 11.02.
By way of disclosure: I am a Bozeman broker, for thirteen years the
Realtor for Gallatin County, and I hold a brokerage interest in Census
Tract 11.02 that is well under one percent of the tract. The projects
named below are not mine. I make this case on its public merits.
On June 23 the Commission forwarded a single tract, Census Tract 6.
What may not have been before you that evening is that the City’s own
economic-development staff had prepared a complete, letter-supported
application for Census Tract 11.02 as well — a strong application that,
because only one tract went forward, never reached the state.
Three points bear on the choice.
Your own priorities.In March the Commission adopted priorities cen-
tered on housing — the affordability gap, starter homes — and the Com-
munity Plan points the same way, to compact residential and mixed-
use growth. By its own terms, the Tract 6 application is an industrial
and employment-redevelopment case. The 11.02 application is housing:
roughly fifteen residential projects already in review, anchored by the
nearly 300-home Alpenglow development at Kagy and South 19th, break-
ing ground this September. Measured against your own priorities, the
tract forwarded is the industrial one, and the tract left off is where the
housing is.
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How the incentive actually behaves.Across the program’s decade,
Opportunity Zone capital has gone overwhelmingly to housing, not in-
dustry. Novogradac — the national firm that tracks this investment for
the industry — reports that less than two percent of Opportunity Fund
equity went into operating businesses. The Joint Committee on Taxation
and the U.S. Treasury’s Office of Tax Analysis both found that roughly
two-thirds of the businesses receiving Opportunity Zone capital were
in real estate, construction, or lodging — not the industrial or traded-
sector enterprises the incentive was meant to seed. The Urban Institute
concludes plainly that the program became a housing-and-real-estate
program, not a jobs-and-economic-development one. And the ground-
level data agree: the best project-level reporting available, from Ohio,
shows residential development drawing 64 percent of Opportunity Zone
capital against just 6 percent for industrial, and an independent analysis
of Colorado found roughly three-fourths of its Opportunity Zone projects
were multifamily housing.The industrial redevelopment and adap-
tive reuse at the center of the Tract 6 application is not simply a
different use from 11.02’s housing — it is the one use Opportu-
nity Zone investors have most consistently passed over, in every
dataset that has examined the question, across the entire ten-year
life of the program.
Whether Tract 6 can deliver at all.An Opportunity Zone supplies
equity, not debt — and every project needs both. Two of the largest
regional commercial lenders will not finance construction on ground-
leased land or on a Superfund parcel, and Tract 6’s near-term pipeline
includes the Idaho Pole Superfund site; layered on the pattern above,
that leaves both halves of the capital stack failing there. The physical
obstacles are structural too: two Superfund footprints (Idaho Pole and
the Bozeman Solvent Site), very little remaining greenfield, brownfield
assembly and scrape costs, and a tract boxed in by rail, Interstate 90,
and the foothills, beside an active siding and a neighborhood of small
railroad-era homes. Whatever the aspiration, redevelopment there is
obstructed at nearly every step that turns a plan into a building. Census
Tract 11.02 has none of these impediments.
It is not too late. The Governor retains discretion to add tracts, and the
nomination window remains open into the fall. I respectfully ask that
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the Commission reconsider and forward Census Tract 11.02 — the tract
your own staff made the case for, and the one your own priorities point to
— so the incentive lands where you have said you want it: on Bozeman’s
housing — the one tract that has delivered, and will continue to deliver,
for Montana, Gallatin County, and the City of Bozeman.
Bozeman’s Tract 11.02 application is attached; I am glad to provide any
further detail, and to make myself available to the Commission or staff.
Respectfully,
Jerry Pape — Triple Creek Realty, for the Bozeman Development Con-
sortium · 11 N. 25th Avenue, Bozeman, MT 59718 · (406) 522-8314
Sources: Novogradac QOF tracking; U.S. Joint Committee on Taxation
and Treasury Office of Tax Analysis OZ reports; Urban Institute OZ as-
sessments (2026); Ohio project-level OZ data and an independent Col-
orado OZ analysis; City of Bozeman OZ applications for Census Tracts
11.02 and 6 (2026); Commission Priorities Resolution 2026-23 (Mar. 3,
2026); Bozeman Community Plan 2020.
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