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Affidavit of Collette Greenwood
Not an official copy.
Attachment to affidavit of Henry Miggins - Thurston County Case
002 02068 2
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
FOR SPOKANE COUNTY
CITY OF SPOKANE, a Washington municipal corporation, and its Water,
Sewer and Solid Waste Utility Departments, Plaintiff, vs. SPOKANE COUNTY,
a political subdivision of the State of Washington, SADIE CHARLENE COONEY, Spokane
County Assessor, and STATE OF WASHINGTON, Defendants.
No. 00 2 06758 0
AFFIDAVIT OF COLLETTE GREENWOOD
Collette P. Greenwood, being first duly sworn on oath under penalty of perjury
deposes and says:
1. I am of legal age and competent to testify as to all matters contained herein
on personal knowledge and/or based upon records and practices I would reasonably
rely upon during the course of my employment and professional discipline.
2. I am the Director of the Office of Management and Budget for the City of
Spokane and have held this position for all times pertinent to this Affidavit.
I am the chief budget officer for the City. My job includes budget and revenue
analysis. I am responsible for preparing all City budget documents for review
by the City Manager, other City Officials, the Spokane City Council, and citizens
of Spokane, based upon information furnished to me by all the participating
municipal departments.
3. I have reviewed with Counsel the provisions of Initiative 722 and provisions
of the draft Complaint in this cause.
4. I am familiar with the budgeting process for the City of Spokane, including
revenues and expenditures for various City utility and governmental functions.
Based upon my understanding of the effect of Initiative 722, the following information
stated hereafter is true and reliable for purposes of this affidavit.
5. The City of Spokane would immediately be required to refund at least $1
million, and perhaps $1½ million in local tax revenue increase ordinances enacted
during the period of July 2, 1999 through December 31, 1999 (the "nullification
period"). This estimate is likely understated, in that it only includes
consideration of the Spokane annual property tax levy and municipal utility
taxes derived from stormwater enterprise revenues approved during the nullification
period. It does not take into account other utility rates or other "tax
increases" during the nullification period as defined in Initiative 722.
6. The impact on the 2001 levy would be approximately an additional $$600,000
(on top of the amounts stated in the previous paragraph). These reductions would
necessitate major revisions in basic police and fire services, which comprise
fifty five percent (55%) of the general fund budget provided by general tax
dollars. While the details of executing such reductions would be a policy decision
by the elected officials, examples of how they might be implemented could be
in reduction of the number of police officers. This would, in turn, require
the City to return federal grant funds received based upon non reduction of
our current number of police officers. It would require the City to revise its
agreement with the School District to provide resource officers to elementary
and sEcondary schools. Another example would be closure of one or more municipal
fire stations. The municipal allocation to libraries could be reduced.
7. The Library Director has indicated reductions as might be ordered because
of I-722 could result in the closure of a branch library, as may be determined
by the Spokane City Library Board. There would be a future reduction in the
budget allocation to the municipal park system. The City Council may likewise
decide to eliminate the Spokane City Arts Department, reduce the allocation
to the Spokane Human Services Department that supports services to the homeless
and poor in our community. The impact here would be magnified because such monies
are leverage funding allowing Human Services to obtain funding from federal
grants and other resources.
DATED this__________ day of November, 2000.
________________________________
COLLETTE P. GREENWOOD
SUBSCRIBED AND SWORN to before me this _____ day of November, 2000.
__________________________________
Notary Public in and for the State
of Washington, residing in Spokane.
My Commission expires ____________.
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