Governance Standards

How Does It Compare?

The Government Finance Officers Association (GFOA) publishes best practices for how local governments should manage economic development, Tax Increment Financing (TIF — known in Georgia as a TAD), public-private partnerships (P3s), and capital coordination. This page applies nine of those standards to three documented transactions in Avondale Estates, spanning 2018 to 2026.

The GFOA is the professional association for government finance officers in the United States and Canada. Its best practices represent peer-reviewed standards developed through decades of consulting with local governments. They carry no legal force — governments are not required to follow them. But they represent what professional governance at this scale looks like, and they are the standards larger cities and better-resourced governments routinely apply.

Sources: Capital Coordination · Incentive Policy · TIF Evaluation · Fund Balance · P3 Due Diligence · Public Engagement · Negotiating Development Agreements

1/9
Standards met

One standard met across nine applicable GFOA best practices

The city's general fund reserve level meets the GFOA minimum threshold — the one area where standard practice applies directly to the elected government's own finances. The remaining eight standards — all governing economic development negotiations, public-private partnerships, TAD management, and capital coordination — are not met or are met only partially across the three transactions documented on this site.

The original standards page evaluated six standards against the DJJ and Willis transactions and found 1 of 6 conforming. Adding the Avila Development Contract (2026) introduces three additional applicable standards — all of which are also not met — and the Avila record worsens the rating on two of the original six. The pattern holds consistently across eight years and three separate transactions.

None of these gaps are unique to Avondale Estates. Georgia's Downtown Development Authorities statute creates the structural conditions for this pattern by design.

The Pattern Across Three Transactions

The table below shows how each of nine GFOA standards applies to each of the three documented transactions. The consistent pattern across 2018, 2019–2020, and 2025–2026 is the central finding: these are not isolated incidents but recurring structural features.

GFOA Standard DJJ Building Sale
2019–2020		 Willis Abatement
2018		 Avila Development
2025–2026
Capital CoordinationEconomic development and capital planning integrated before commitments No No No
Incentive Evaluation"But for" analysis; cost/benefit before approval; opportunity cost review No No No
TIF / TAD EvaluationDistrict periodically evaluated; "but for" documented; school district impact assessed No No No
Fund Reserve PolicyTwo-month general fund reserve; formal policy; DDA deploying accumulated reserves Yes Yes Partial
P3 Due DiligenceFeasibility study; independent appraisal; private entity assumes most risk; finance officer on team No No No
Public EngagementCommunity education before formal hearings; development terms disclosed before vote Partial Partial No
Competitive SelectionDeveloper selected through open RFP/RFQ; non-competitive process justified and documented No No No
Community BenefitsPerformance metrics; affordable housing; local hiring; clawback provisions negotiated No No No
Independent Financial AdvisorIFA with fiduciary duty retained; separate from bond counsel and deal counsel No No No

Reserve Comparison: City General Fund vs. DDA Fund Balance vs. GFOA Minimum

City general fund unassigned balance estimated from 2024 ACFR; GFOA minimum = 2 months of general fund expenditures (~$750K at 2024 spending levels); DDA fund balance confirmed from 2024 ACFR Component Unit schedule. DDA reserve policy: none published.

Standards in Detail

Does Not Conform 1. Coordinating Economic Development and Capital Planning
GFOA Standard Economic development strategies and capital improvement planning should be coordinated and integrated within and among governments. The finance officer should be involved from the outset, well before commitments are made. Proposed investments should be evaluated using cost/benefit and debt affordability analysis before capital plan development. Finance officials should be on guard against ad-hoc, unplanned development opportunities that supplant established priorities.
NoDJJ Sale
The DDA sold its largest asset and received $7.45M in proceeds, which were then reinvested in the Georgia Fund 1 pool. No public record of analysis of how that capital would be coordinated with the city's capital plan or bond issuance decisions.
NoWillis
The abatement reduced the assessed value available to the city and school district without a public analysis of the fiscal impact on capital-dependent services. DeKalb County Schools bore approximately half the cost with no consultation.
NoAvila
The DDA committed $5M from its reserve fund for Avila infrastructure while the city carries $12.4M in bond debt and pays approximately $520,000/year in debt service. No joint analysis of these parallel capital positions appears in any public record.
Does Not Conform 2. Evaluating Economic Development Incentives
GFOA Standard Evaluate opportunity costs and other potential uses for funds. Determine whether the project would proceed without the incentive — the "but for" test. Conduct cost/benefit analysis before approval. Set maximum funding limits. "Private entities are motivated to request as much as possible in incentives — governments should be very cautious about providing funding above what is necessary."
NoDJJ Sale
No analysis of whether selling the building was necessary versus retaining it as an income-producing asset. The state lease ($2.16M/year) was available as a retained-asset option. The DDA chose sale without a documented comparison of financial outcomes.
NoWillis
No "but for" analysis of whether the Willis development required a tax abatement to be financially viable. No cost/benefit analysis was published. No limit was placed on how long the abatement could remain with subsequent owners.
NoAvila
Avila held the 13-acre site for 10 years before the Avila/Hedgewood announcement. No public document establishes that $7.2M in public infrastructure was necessary for the project to proceed. No "but for" analysis appears in the variance hearings, IGA, or Development Contract.
Does Not Conform 3. TIF / TAD District Evaluation
GFOA Standard "Local governments should carefully evaluate whether TIF districts are the most appropriate and effective tool." Evaluation should include impact on other taxing jurisdictions, whether the district is achieving its original objectives, and whether the structure still serves its stated public purpose. TAD spending must conform to the adopted redevelopment plan.
NoDJJ Sale
The TAD captured commercial increment that funded DDA reserves. No formal BOMC evaluation of whether the TAD was achieving its stated purpose of commercial growth and residential tax relief. The commercial share of the tax digest has been flat at 21% since 2019.
NoWillis
The Willis development is located outside the TAD boundary. The school district participated in the Bond for Title abatement structure with no consultation or analysis of impact on school district finances. No formal TAD evaluation conducted during this period.
NoAvila
The Development Contract commits all TAD #1 revenues as first priority to the Avila infrastructure agreement through December 2041. The Avila development is 789 primarily residential units — the 2007 TAD was created for commercial redevelopment. No conformance analysis of whether this use aligns with the 2007 Redevelopment Plan appears in any public record.
Conforms (City) / Partial (DDA) 4. General Fund Reserve Policy
GFOA Standard Maintain unrestricted fund balance of at least two months of general fund operating expenditures. Establish a formal reserve policy. Fund balance above the policy ceiling should be used for nonrecurring expenses or outstanding liabilities — not accumulated indefinitely without a plan.
ConformsDJJ / City
The city's general fund reserve appears to meet the GFOA two-month minimum throughout the documented period. This is the one area of consistent conformance for the elected city government.
ConformsWillis / City
Same as DJJ period: city general fund meets the GFOA minimum. The DDA's $10.96M balance — 13 times the city's reserve — has no formal policy governing its level, deployment triggers, or ceiling.
PartialAvila / DDA
City general fund still conforms. But the Avila Development Contract commits $5M of DDA reserves — 46% of its $10.96M balance — to a single private development with no formal reserve policy, no spending plan approved by elected officials, and no GFOA-equivalent ceiling.
Does Not Conform 5. Public-Private Partnership Due Diligence
GFOA Standard Conduct a feasibility study before P3 commitments. The private entity "should assume most of the financial risk for the ultimate project outcomes." Conduct cash flow and net present value analysis. Retain a team including a financial advisor with economic development expertise. Determine consistency with community strategic plans. Compare to public-sector alternatives.
NoDJJ Sale
No feasibility study published. No independent appraisal — only a Broker Opinion of Value (BOV). No analysis of retaining the building as an income-producing asset. No independent financial advisor retained. The bond structure placed the DDA as issuer with KDP 3048 LLC as simultaneously lessee, landlord, and bond purchaser.
NoWillis
The Bond for Title structure placed the DDA as nominal owner while the developer retained beneficial ownership. No feasibility study of the abatement terms. No analysis of the financial risk transferred to the school district. No independent financial advisor. The transfer mechanism was structured to pass automatically to subsequent owners without further review.
NoAvila
No feasibility study conducted before sewer denial was known. The Development Contract was signed while DeKalb County had already denied sewer connection. No independent financial advisor. Developer selects all construction contractors "in its sole discretion" — no competitive bidding for $7.2M in publicly-funded infrastructure. No independent construction manager appointed.
Does Not Conform 6. Public Engagement in Economic Development
GFOA Standard Governments should encourage effective public engagement "through local economic development strategic plans and per individual development agreements before required public hearings occur." Development agreement terms should be disclosed publicly before formal hearings, not introduced on the day of the vote.
PartialDJJ Sale
The DDA Chair published a public letter explaining the transaction terms. Multiple public presentations preceded the vote. However, the deliberation on whether to sell (versus retain) the building as an income-producing asset did not occur in any accessible public meeting before the vote.
PartialWillis
The DDA published a FAQ on the Bond for Title structure. However, the mechanism that would automatically transfer the abatement to future owners was not disclosed as a feature of the structure before approval, and the school district had no notice or opportunity to respond.
NoAvila
Five public variance hearings were held — but the Development Contract governing the $7.2M public financial commitment was presented at a DDA Zoom meeting at 5:15 PM on April 23, one day after the BOMC voted on the IGA. The contract was not available for public review before either vote.
Does Not Conform 7. Competitive Developer Selection
GFOA Standard P3 opportunities should be open to competition. The public entity should determine "what is the expectation for competition in determining the best private partner?" A non-competitive process requires explicit justification and documentation. Competitive selection produces better terms and better public return than negotiating with a single party over an extended period.
NoDJJ Sale
Forum Management's offer was "unsolicited" — the DDA Chair's own letter confirms this. No competitive bidding process was conducted. No Request for Proposals was issued. The sale price was set through negotiation with a single buyer.
NoWillis
South City Partners and ELV Associates were selected for the Bond for Title abatement without a competitive process for the subsidy itself. No RFP for the tax benefit was issued; the developer applied and the DDA approved.
NoAvila
The PAZB minutes confirm negotiations had been ongoing "over 8 years" with Avila exclusively. No RFP was issued for the development opportunity. No competing bids were solicited for the $7.2M public infrastructure package. The Development Contract gives the developer sole discretion to select all construction contractors.
Does Not Conform 8. Community Benefits Negotiation
GFOA Standard When negotiating development agreements, governments should "establish what community benefits the government desires from the developer or another entity and any of its contractors and eventual tenants, including, but not limited to local hiring, payment of living wages, construction or preservation of affordable housing, open space, etc."
NoDJJ Sale
The Purchase and Sale Agreement contains no community benefit requirements. No job creation targets, no local hiring, no affordable housing, no clawback provision if the buyer subsequently sold the building within a defined period.
NoWillis
The Bond for Title abatement contained no affordable housing requirement, no local hiring provision, and no restriction on transferring the public subsidy to a subsequent owner. The school district absorbed approximately half the abatement cost with no compensating community benefit.
NoAvila
The Development Contract contains no affordable housing requirement, no local hiring provision, no job creation targets, and no clawback of variance value if the developer sells within a defined period. All 789 units are market-rate. The public committed $7.2M in confirmed financial support and an estimated $21–$30M in regulatory value with no community benefit conditions attached.
Does Not Conform 9. Independent Financial Advisor with Fiduciary Duty
GFOA Standard "For all P3 Agreements, the organization will need to gather a team that contains analysts, legal counsel, resources with industry related expertise, potentially a financial advisor/municipal advisor with economic development expertise, and/or bond counsel." The finance officer should be a key participant in evaluating economic and fiscal impacts before commitments are made. An independent financial advisor (IFA) with fiduciary duty to the public entity — separate from bond counsel, transaction counsel, or any advisor whose fee depends on the transaction closing — is standard practice for decisions of this scale.
NoDJJ Sale
No independent financial advisor retained. Bond counsel whose compensation depended on the bond transaction closing was involved. The DDA Chair later noted the BOV range ($6.2–$7.3M) was the only external financial analysis; no IFA evaluated whether sale or retention was the more financially sound choice.
NoWillis
No independent financial advisor retained to evaluate the abatement terms, the NPV of the subsidy being granted, or the implications of the transfer mechanism for future ownership changes. The structure that allowed the $3M subsidy to pass automatically to SEDCO Capital was not independently reviewed before approval.
NoAvila
No independent financial advisor retained before the variances, the eminent domain authorization, the IGA, or the Development Contract were approved. The DDA's General Counsel approved the contract "as to form" — legal review only. No financial advisor evaluated the regulatory value of the variances, the "but for" case, or the risk of committing $7.2M before sewer approval was obtained.

What This Means

Nine GFOA standards. Three transactions over eight years. The same structural gaps appear in every case: no competitive selection, no independent financial advisor, no "but for" analysis, no community benefits, no public disclosure before the vote. The conformance rate did not improve from 2018 to 2026.

This is not a story about bad actors. The officials who approved these transactions are volunteers acting within the law and in what they believed to be the public interest. The problem is structural: Georgia's Downtown Development Authorities Law creates the conditions for this pattern by design. It requires four of seven DDA directors to have a direct economic interest in the downtown — a feature, not a flaw, of the statute. It places significant public funds outside the city's capital planning process. It does not require the professional infrastructure — competitive selection, fiduciary advisors, feasibility analysis — that GFOA recommends as standard practice for decisions of this scale.

Small cities have less staff capacity, smaller budgets for professional services, and greater informality in their governance processes. GFOA's standards exist precisely because these conditions create predictable vulnerabilities. The documentation on this site is not a record of corruption. It is a record of what happens when those vulnerabilities go unaddressed across multiple transactions and multiple years.

See the proposed structural reforms →

GFOA Sources: All best practices cited on this page are published by the Government Finance Officers Association at gfoa.org and are publicly available. Direct links are provided throughout. GFOA best practices represent professional consensus standards — they are not legally binding requirements.

Local record sources: All findings about Avondale Estates are sourced from primary government records cited in the Fiscal Analysis and Case Studies sections. The comparison applies the documented record to the published standards; it does not make inferences beyond what the documents show.