Taking a Hard Look at Historic Tax Credits

tobacco_rowby James A. Bacon

A General Assembly subcommittee is giving well-deserved scrutiny to Virginia’s tax credits for rehabilitating historic properties.

That program, which has provided more than $1 billion in tax credits since its inception in 1997, is widely credited with revitalizing older neighborhoods across Virginia, particularly in the City of Richmond with its wealth of historic properties. However, as the state grapples with a $1.5 billion revenue gap in the current two-year budget, it is encouraging to see lawmakers employ economic thinking for a change.

“It is really hard for us to make a good business decision here when we don’t know what kind of return we are getting on our money,” said Del. Jimmie Massie, R-Henrico, according to the Richmond Times-Dispatch. “If we are getting a 10 to 15 percent return, that is one thing. If we are getting 5 percent, that’s another.”

Virginia allows developers to claim credits of 25 percent of eligible expenses on renovations of certified historic structures, explains the T-D. With a federal historic tax credit of 20 percent, developers can claim total credits of 45 percent. They can use the credits against their own tax liabilities or syndicate the credits for investors.

According to a 2014 study by the Center for Urban and Regional Analysis at Virginia Commonwealth University, 2,375 projects tapping tax credits generated almost $4 billion in economic activity in the state between 1997 and 2013. A survey of developers indicated that 85% would not have made their investment without the credits.

The Richmond regions has benefited disproportionately from the credit. About 1,185 projects generated about $2 billion in expenditures. However, the program also has defenders from other cities, such as Staunton, which has seen a downtown renaissance in recent years.

Bacon’s bottom line: No question, the tax credit has been a boon to urban-core economies. I’m a big fan of restoring and rehabilitating historic buildings. (I restored two ante-bellum houses in Church Hill.) I greatly prefer historic architectural styles to modern motifs.

But saying that developers would not have undertaken historic renovations without the tax credit is not saying that they would have done nothing. Presumably, those developers would not have stayed idle. What the VCU study could not measure is what projects they would have undertaken in the absence of the credits. Thus, while stating that every $1 in tax credits generated $4 in construction activity sounds impressive, it is a meaningless metric of net economic impact.

I see historic tax credits as analogous to conservation tax credits. A decade ago, conservation tax credits were being handed out indiscriminately, sometimes going to properties of dubious conservation value. The General Assembly cracked down, imposing a $100 million cap. Likewise, historic tax credits may have gone to development projects of dubious value. I recall hearing that developers game the system by preserving a small historic structure, or part of a structure like a wall, and incorporating it into a larger project while pocketing credits for the full amount. (Sorry, I don’t have time this morning to document such instances for this blog post.)

The tax credits represent a drain on the state treasury. It’s about time the General Assembly started asking tough questions of the program. I am particularly concerned how much “gaming” the system goes on. Tightening up the requirements might be in order. Further, lawmakers might well consider a yearly cap, as the state does with conservation easements. As much as I personally love historic renovations, preserving the integrity of the public fisc is the greater good.

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34 responses to “Taking a Hard Look at Historic Tax Credits

  1. That’s one way to view it (purely fiscal). However, I think you make good points about architecture. I’d also say this: What are the other difficult-to-quantify aspects? Obviously, the architectural component is one. But I’d ask everyone old enough to think about Virginia back in the mid-90s. Old Town Alexandria was nice. Outside of that? Really hard to remember a true urban core worth visiting. Now? You can make a weekend of the following: Old Town Alexandria, Winchester, Fredericksburg, Charlottesville, Richmond, Norfolk, Staunton, and Roanoke. Lynchburg is getting there. You can’t quantify “vibe”…but I’ve got real doubts that many of these places would be weekend destinations but for the tax credits which helped spur their renaissance. I remember driving through Fredericksburg in 2000 and not even thinking twice. My wife and I spent a weekend there last year, and it was a very nice 48 hours. I’d imagine (can’t prove it w/o deep research) that some of the aspects that we found so appealing were the product of the tax credits. Just a hunch.

    Obviously, a lot of policy and demographic trends have aided these urban revitalizations. But the historic tax credit program is a key component. Who doesn’t like to spend a few hours on a weekend getaway taking a look at unique architecture and history in these places?

    You’re correct that developers simply wouldn’t have remained idle. But my guess is that some of those development dollars would have gone to suburban sprawl (which both the right and left seem to agree is a bad thing.) Is that the better policy outcome?

  2. All policies corrupt over time. Likely the tax credit policy in practice now in Virginia is riddled with corruptions of all sorts, given the ingenuity of man.

    In addition the total of 45%s credit strikes me a positively obscene.

    Suggestion:

    Take an ax to corrupt practices and scale the State Credit program back with also possibly a short term moratorium while doing so. But thereafter reassert state program on some scale if only to influence critical cases of real import.

  3. Good post. And there has been fraud in Richmond.

  4. My understanding is that the tax credits and tax relief only apply to properties within designated historic districts that have formal standards and processes..

    DHR keeps the maps. Here’s an example :

    http://www.dhr.virginia.gov/tax_credits/Historic_District_Maps/Charlottesville.pdf

    perhaps other readers here have more info…

    Fredericksburg has multiple different kinds of districts -historic and otherwise that they incentivize for the kind and type of development they would like to see occur. It ranges from heavy duty historic districts to commercial districts along I-95 and downtown …

    it seems like almost anything these days can get “something” unless it’s like a tattoo parlor or payday loan outfit!

  5. James –

    It’s more complicated and there are other factors than you’ve laid out here.

    First, without the credit, a lot of these older buildings would have simply been demolished and rebuilt. The credit makes historic renovations feasible. The credit is a key piece of preserving older buildings and a sense of place in many of our older communities. I certainly don’t want Roanoke, Norfolk, or Richmond looking like LEED certified glass towers everywhere.

    Second, the STATE tax credit is also available to homeowners who perform renovations that total more than 25% of the tax assessed value of their building (excluding real estate value). This is not just an issue about developers.

    Third, the credit only applies to properties that are listed on the National Register of Historic Properties. It’s not easy to get on this list. It does NOT apply to every building over 50 years old. There are some historic districts, but not every property in a district counts.

    Fourth, Senator Warner, Former Congressman Cantor, and others have been pushing legislation to expand the use of these credits to finance school rehabilitation. Many of our older schools are being demolished when they should be preserved.

    The public debate so far as been too limited.

    There are many checks and balances on this process and the policy debate is about far more than (a) developers and (b) economic return to the state.

    • Nobody appreciates tax credits for historic preservation than I do. The key question is the amount necessary in this day and time to achieve the desired results needed today, and how the law is administered today to achieve today’s needs. To assume that people are angels in perpetuity and that laws that were passed with the best of intentions decades ago to address real and pressing problems back then do not over time get abused and bent out of shape to point of dysfunction in many unnecessary cases, and/or that the circumstances that formed the basis of those laws’ original passage never change is bad governance and poor public policy. All good laws regulating who gets taxed and who does not get taxed, and who pays for it, and who gets the free ride on other peoples money, become over time pork barrels. Unless they be judged and changed as necessary and right over time.

      I should think, however, that a 45% tax credit is obscene most any time, with few if any exceptions.

    • Scott, I agree with each of the four points you make. But when the state is staring down the barrel of a $1.5 billion deficit — and, as you know, I think we face even bigger deficit issues down the road — something has to give. I would not support eliminating the tax credit entirely, but I think it’s totally reasonable to take a good hard look at the program and see where it can be tightened up.

  6. That sense of “vibe” you mention is far more than a single building. The whole point is, creating an incentive to preserve neighborhoods means preserving a critical portion, the critical mass, of what’s there, involving hundreds of diverse owners and back stories. To accomplish that requires a pretty powerful inducement. And of course, the greater the handouts, the greater the risk of abuse.

    And the results do indeed preserve a sense of history and continuity in our smaller towns. I’d throw into CV’s list the old centers of Culpeper, Gordonsville and Orange, to name three I drive through often, not to mention places like Lexington.

    • “I’d throw into CV’s list the old centers of Culpeper, Gordonsville and Orange, to name three I drive through often, not to mention places like Lexington.”

      So would I. Virginia is full of these wonderful old towns. They need a new contract with the State to find the best ways to bring them back to life. This is the time for such a movement, the stars are aligned, given emerging realities. Set the stage right for these towns, and people and prosperity will find them.

  7. there’s a point of view – that older downtowns and neighborhoods will either get worse – or better – depending on what city fathers do or not.

    when they are neglected they decay -.. the don’t disappear – they just molder in place.

    there are lots and lots and lots of examples across the US these days.

    the places that have come back are much fewer in number and largely celebrated …

    the question is – should tax dollars go for that purpose especially when we have other urban cores that are left to die… which one could argue is a bit incongruous and leads to accusations of gentrification.

    nothing is ever simple, is it?

  8. Full disclosure: I am an architect and my firm receives significant indirect benefits from the historic tax credit programs through our clients’ rehabilitation of eligible structures.

    You raise some good questions and I agree that a balanced assessment is needed. I also agree with some of the commentators here that point out the difficulty in linking the benefits of revitalization to the tax credit program. The “compared to what” question is also relevant – I agree that the economic activity represented in the projects with tax credits would not have been zero without the credits. However, I am reminded of the side-by-side comparisons of tax benefits (sales, property, etc.) to localities represented by traditional urban patterns (think main streets) versus sprawl. The traditional patterns win hands down in terms of income-per-acre, even when perceived as “blighted.” I suspect that tax credit rehabilitation projects contribute to this type of high-value development and the short term economic activity only tells part of the story.

    One note on “gaming the system”: your use of that term implies that the the “players” are using the “system” in ways that are permissible under the rules (through loopholes or similar measures) and achieving their financial goals without satisfying the system’s intent. I don’t think that happens very often, if at all, with the tax credit program. More common, I believe, is flat-out fraud, though it is much less common in Virginia in a post-Justin French world, due to heightened scrutiny.

    The particular instance you allude to in the post may be a recent case of a local developer unsuccessfully trying to receive tax abatement from the City of Richmond, not the historic tax credit program. I can give you enough details to find the source material on that case, if you want them.

    • Your comments are getting interesting fast.

      Historic preservation, urban restorations (formerly called urban renewal), and revitalization of old neighborhoods and towns, there appears to be a rapidly growing need for new policies or action that better address these needs that now seem to be as pressing as the need for historic preservation initiatives was when I was active in the 1970s and 80. Here a revisit of historic preservation law to better update it to meet current realities might result in great benefit to areas that are rapidly falling behind now. (Or perhaps much has been done legislatively in the past few decades about which I am not aware.)

      In any case, one thing seems for sure, namely: something is very wrong and very broken when Petersburg Va. can drop abruptly into abject failure out in the broad daylight of the public square as if by surprise. What kind of preservation of a state’s history can be more critical than Petersburg’s history to that of Virginia’s.

      Any information generally available that might bring me up to date with these modern iterations of historic preservation issues, I will happily read.

    • Mr. Moore –

      I agree with what you say. Our project the Bachelor Apartment on H. Street kicked off that 1976 Federal Historic Tax Credit program in Washington dc. Of course Fredericksburg Va. is a wonderful testament to the success of that program, which saved so much of America’s history that otherwise surely would have been lost to the wreckers ball if not collapse into ruins from neglect.

      But like with all successful legislation there arises over time much paradox and a gaming of the system for negative rather than positive results.

      As for paradox, an example is how the wonderful rebirth of Old Fredericksburg helped spark its reverse. The ill planned strip-retail and cul-de-sac residential that now clog and channelize so much of life outside of the old town and now its spread to most all Northern Virginia, turning Fredericksburg into a hard-to-get to oasis amid a sea of nowhere places.

      As for gaming the system, an example in DC is how faux historic preservation claims have successfully driven residential rents and sales sky high by throttling the construction of nearby higher density uses. This is driving the middle class, the young, and the elderly out of the city while it bankrupts mass transit by drying up the foot traffic mass transit needs to support itself.

      Improperly used, historic preservation statutes can literally shut down the healthy growth of lower density parts of what is or would otherwise be a healthy city.

      Like you say it is a complex and ever changing story. So we must constantly adjust legislation to changing realities.

  9. I would encourage the folks who have the knowledge and experience to offer their views.. nothing like having folks who really know the material to be commenting!!! and thanks for doing so!

  10. Very good post and responses. I have an idea. Why not take the same examination proposed for historic tax credits at, say, the top ten other tax credit or grant programs in the state budget. When the governor vetoed the coal tax credit, you would have thought that he alone was responsible for the death of the coal industry in Virginia. How about other programs, like the Governor’s Opportunity Fund? Is the HTC the largest or are there others.
    While not related to the state HTC, here is an example how a developer “gamed” the Norfolk tax abatement program:
    “The Pilot reported in March that developer Buddy Gadams was tearing down all but one wall in a structure on Boush and Bute streets to make way for a large new apartment complex. His project was eligible for a 14-year tax abatement because the city code didn’t specify how much of a building had to be retained to qualify for the program.” Bosun

    • I recall a lot of holes (vacant ground) in the downtown urban fabric of Petersburg – how about a tax credit program to restore downtown Peterburg to its look just before the battle began, and so build anew the historic buildings long gone and restore those still standing, as one part of broader scheme to revitalize the whole area, including bringing more of the historic battlements north and south back to life.

      Why not?

      Remember 60, 000 men, black and white, died there or were wounded and maimed there on this sacred ground. Let’s make the restoration of Petersburg a healing project for all of us, in memory of their sacrifice.

  11. ” I recall hearing that developers game the system by preserving a small historic structure, or part of a structure like a wall, and incorporating it into a larger project while pocketing credits for the full amount.”

    The most egregious example of this happening in Richmond was with the infamous Louis Salomonsky’s Tobacco Row project called “The Loft’s at River’s Fall”. I read that he maintained one historic wall and was able to qualify for the tax abatement. You can see from the image below that this place is new from the ground up. Eliminating such cheating of the system is imperative.

    https://www.google.com/maps/@37.5321291,-77.4285415,3a,75y,88.98h,94.57t/data=!3m6!1e1!3m4!1swNsDRULw9bT3-PbVOXVmdQ!2e0!7i13312!8i6656

    • That’s the one I was alluding to in my comment. The little piece of wall in question is hidden behind the tree in the Google Streetview link you shared.

      I haven’t double-checked, but I believe that Salomonsky was ultimately denied tax abatement by the city. And, to be clear, we are talking about two completely different programs: tax abatement of City property taxes administered by the City of Richmond on the one hand and Federal and State tax credits administered by the Virginia Department of Historic Resources on the other. The latter program is the subject of Jim’s post.

  12. One other aspect to add to the discussion: Is it appropriate at this point to consider policy or enforcement? Should the state be looking at more effective enforcement mechanisms (investigations, complaint intake, prosecutions) before looking at policy changes (caps, etc.)?

  13. Same here. Look at the picture about halfway down in this one where only a very small part of one outside wall was preserved in Norfolk for a new 155 apartment complex. http://pilotonline.com/news/government/politics/local/developer-buddy-gadams-says-he-didn-t-ask-for-norfolk/article_631fe9f7-f0b3-57c8-ac7a-ef0a58ef0804.html

  14. ” Petersburg hotel project to receive $600,000 in state funding”

    The state has approved $600,000 in funding for a new hotel project at the former Ramada Inn on East Washington Street in Petersburg, just one block from Interstate 95.
    The money is part of a total of $1.97 million in Industrial Revitalization Fund grants awarded to Petersburg, the towns of Clarksville and South Hill, and the Highland County Economic Development Authority.

    http://www.richmond.com/news/local/central-virginia/article_fb2a8213-fae3-5b8f-aa31-2cae15a19bab.html

    • Thanks for bringing this sort of grant up. Remodeling a Ramada Inn pastes over a problem, solving nothing. Plus $600,000 is peanuts. It won’t not buy a starter home in NW DC. Still $600,000 can make a big difference in Petersburg if it is spent in a smart way. As “seed corn” that jump-starts the beginnings of an altogether new wealth creating engine for Petersburg, the kind of start that lifts Petersburg into a game changer, a new era of prosperity.

      The Center for Urban and Regional Analysis (CURA) in joint venture with its equivalent at UVA should get a grant from the Commonwealth to work with highly experienced and able developers who volunteer their time and experience to help the academics to come up with a holistic and altogether new plan to revitalize Petersburg by building on its unique strengths.

      This should a tightly focused, highly disciplined and serious mission led joint Venture. One that is built to avoid academic nonsense while its starts off as a free wheeling brain storming exploration of ways to build on and leverage off of Petersburg’s latent strengths hidden in its past and present.

      The first goal is to define those strengths, the second is to explore ways that will leverage off those strengths, and do so in practical real world stages that over time will built a new Petersburg into a gift that keeps on giving, generating wealth, prosperity and quality of life where today there is far too little.

      This can be done. Just like downtown Arlington County or Wilmington SC was done not so long ago. Petersburg can come roaring back. It has the critical ingredients, however latent or hidden now, for success, if folks come together to do it right. But $600,000 grants to remodel Ramada Inns will not get the job done but instead sends monies and energies off in the wrong direction to end up crushing hopes instead igniting them long term.

  15. and another:

    Meat processing company expanding in Harrisonburg
    September 1, 2016 |

    T&E Meats is investing more than $600,000 to expand its meat processing facility in Harrisonburg. The project is expected to create seven new jobs.
    Gov. Terry McAuliffe approved a $50,000 grant from the Agriculture and Forestry Industries Development (AFID) Fund, which Harrisonburg will match with local funds.
    As part of the deal, T&E Meats has agreed to increase its capacity by one third and source 90 percent of its meat from Virginia livestock producers.”

    • T&E Meats is a local abattoir that serves as a regional slaughterhouse for growers of grass-fed beef. Such establishments were common in nearly every county in the 1950s and 60s. Now they are rare because of the paperwork burden required to keep the great inhumane factory slaughterhouses from killing you.

      If Virginia were to grass feed its beef and slaughter them in this state rather than shipping them to feedlots in the West it would add at least $200 million per year to the Virginia economy. And it would build topsoil and sequester carbon.

      I don’t know the details of this grant, but from what I know of this business, it is intending to revitalize to our local main street economies and give independent farmers a chance to make a living on the land once again.

  16. LtG, do you suppose anyone does an ROI on this stuff like T&E?

    So the company now gets $100K off its project.

    I’m not qualified to do ROI but I hope someone does.

    • well heckfire… one must wonder , eh?

      and christakes why it is an issue with historic tax credits and not these?

      where did this idea of ROI for tax credits come from?

      it sounds very “irregular” … gawd… I can only imagine what
      such a requirement in the wrong hands would do – wreak havok on the whole idea of incentivizing as a concept!!!

      good lord – can you imagine if we put that requirement on all these new trendy craft beer outfits!

      or the Redskins training camp…

      or… or… lord.. I can’t stand it… next thing you know folks are gonna want PROOF of actual returns !!

  17. As to the ROI on T&E Meats deal I suggest the real answer is found in word PORK in return for something having to do with POLITICS.

    As to historic preservation? That’s interesting question.

    What is the ROI on restoring the Mona Lisa?

    To ask the question and demand an specific answer shows that the questioner does not understand with subject. What is the ROI of water? Of Air? Of Culture? Of history? Of your own home? Of a battlefield? Of a historic town as opposed to a generic town with no history?

    One thing is surely plain – old well maintained historic cities or towns strongly tend on the average to live far better lives. And ill kept, plain vanilla generic ones tend over time to slowly fail and get throw away, to be bypassed for generations, and then if they are lucky to be started over with all this new history destroyed.

    Study the current success of historic towns in Hungary versus the success of the new towns or projects built there by governments in the Soviet era. Or study much of South West Washington rebuild into to brand new history free “projects” built by “master planners” into so called communities, the 1950s and 60s. Then ask yourself what is the RIO of historic preservation done right?

  18. and the more subjective – the better it is for all those folks who would suggest that their favorite “good” things are also not so easily measured for ROI.

    right?

    your wonderful historic preservation is my wonderful economic development.

    goose and gander here..

  19. Mr. Bacon:

    Obviously imperfect….but it would be interesting to see how each city’s transient occupancy tax increased or decreased since 1997 relative to inflation. Again…if you think back to the mid-90s (before this credit), I really don’t know of many who were weekending in Virginia cities outside of Alexandria. (I’d obviously exempt VaBeach from this due to it already being a tourist destination).

  20. http://m.richmond.com/food-drink/article_4792ced0-775a-11e5-b716-5b4b46f28ef9.html?mode=jqm

    250,000 state grant last year, with the hopes of 45 jobs. They started with 15 jobs and invested a healthy chunk of money (close to 3m). I do think that there is certainly a return on these kind of projects; after all, this was business that was being sent out of state. It also revitalized a large facility in Lynchburg that has been vacant for several years.

  21. don’t want to be a naysayer…. but is it really a NEW business or is it one more competitor to share the same aggregate demand pie?

    are people eating more meat or are there already companies providing meat to meet demand and this will be a new competitor taking over some of the existing demand which will mean other companies currently doing it will see decreased sales?

    from the article; ” As the industry consolidates, it opens up opportunities for a differentiated product,” Ford said. That product is home-grown Virginia beef.

    “It’s very similar to the thing with craft beer,” he said, adding, “We have a chance to make Virginia beef the best in the country.”

    But market conditions were just one factor in a confluence of events that made Seven Hills Food possible.

    The space formerly was used by the Dinner Bell Meat Company, which closed its doors about eight years ago.”

    well I gotta ask what the DOODA was Dinner bell doing before? and how did it get closed if there was demand?

    So – what we are seeing is market competition… new guys finding opportunities but perhaps at the expense to other operations not nimble or flexible enough to evolve and adapt their operations to changing markets?

    So.. you have the government stepping in to not only put it’s fingers on the scale but in a totally arbitrary way – such that in doing so it may actually be undercutting and disadvantaging other existing operations who could have also used some extra money to reconfigure and sharpen their competitive stance?

    I note in Fredericksburg – that existing business owners will actually complain when the city incentivizes “new” businesses that are, in fact, competitors to the existing businesses – and who can blame them?

    Giant Food closed a store when the city incentivized – agreed to reduce property taxes on a new Wegmans located less than a mile away.. Giant just shut down that store. So what was gained?

    Well the Wegmans was in the city and the Giant was in Spotsylvania.

    I’m not at all sure – that this KIND of “assistance” has a genuine ROI in the bigger picture…

    Just as the city poached from the county – Lynchburg is poaching from other cities and Virginia from other states for the SAME business – they just gain the jobs and taxes but at expense to others who lose.

    • What I would say is that people are more aware and discriminating in regards to where their meat comes from. There are plenty of producers who were driving to NC or PA for processing. You are going to find few VA processors who are doing what Seven Hills is doing (with the same capacity) and if it keeps local or state products from seeking out of state processors, it certainly is a better choice than some of the dumb things the state has granted money for in the past (Lindenberg).

  22. In the widening discussion from the original thread of historic tax credits and their value and intended purpose – I think an important distinction between the Federal and the State tax credits was overlooked and, in fact, the Federal credits illustrate a much tighter and precise qualification that is not near so easy to game.

    To wit: ” For both credits, the rehabilitation must be substantial and must involve a depreciable building. The substantial rehabilitation test means that the cost of rehabilitation must exceed the pre rehabilitation cost of the building. Generally, this test must be met within two years or within five years for a project completed in multiple phases.

    A depreciable building is one that after rehabilitation must be used for an income-producing purpose for at least five years. Owner occupied residential properties do not qualify for the federal rehabilitation tax credit.”

    http://www.achp.gov/docs/BRAC/Federal_Historic_Preservation_Tax_Incentives_Program-June_06.pdf

    Obviously if the State credits were written that way – it would pretty much do away with residential tax credits all together.

    My point here is two-fold:

    1. – first – this is an example of “regulation” that is so much discussed here in BR and in political discourse pejoratively and yet, clearly it is necessary … more than necessary… in fact even when done, deficient in discouraging what some would consider “gaming” of the system.

    2. – that the Feds typically are better are designing and implementing regulations to achieve intended purposes – better than the states …

    I think Virginia could likely tighten up their Historic tax credits – perhaps not to the level of requiring them to be “income producing” but certainly to require more formal valuation as well as stipulations as to whether it applies only to the facades to foster streetscapes but not to areas that are solely for the benefit of the owner and that value accrues to the owner. That ought not to be the primary purpose of the credit.

    What the city wants is to preserve the facades… the look and feel of the buildings – that’s a legitimate public purpose but on the inside especially when retrofitted with modernized equipment and appliances… that probably ought to be on the owner who should bear the risk of the cost of the upgrades versus the increase in value that would accrue to him/her own wealth.

    and obviously what would be a inappropriate use of tax credits would be to benefit some locations owners in a city and not others such that some benefit from subsidized renovation while others do not.

    Inevitably – when the govt is involved in doing things that deliver dollars to recipients for whatever supposed good reasons there’s going to be that bad old red tape regulation… and, in fact, I bet a LOT of regulation is associated with things LIKE tax credits and other govt programs and benefits right on down to requiring companies to provide the promised octane on their gas or active ingredients on drugs.

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