The fiscal trade

The instruments here are exact. A thirty-year exemption at one hundred percent, granted per Building, with no exemption commencing after tax year 2035 and none extending past tax year 2065. A payment schedule to the dollar. What they are exact about is worth reading closely, because the precision runs one way.

The $50 million is two instruments, and the split is not even

Press accounts describe “$50 million over 15 years, half to the City and half to Sidney City Schools.” Each half of that sentence needs a correction, and all four come from the executed instruments themselves^rec . [verified]

• The PILOTs are capped at $46,000,000 over fourteen years (CRA Agreement §7(b), Exhibit E) — thirteen years at $3,333,333 and a fourteenth at $2,666,671.
• A separate one-time $4,000,000 Initial Payment (§8), due within 90 days of a City invoice the City may send any time after the effective date. $46M + $4M is where “$50 million” comes from, and only one of the two is a PILOT.
• The schools’ half is not one school district. It divides $21,220,529 to Sidney City Schools and $3,779,471 to Upper Valley Career Center.
• And the City’s half is front-loaded while the schools’ is back-loaded. Years 1–3 run $2,500,000 City against $833,333 schools. Year 12 is the hinge: the City drops to $166,667 while the schools hold at $1,666,667. Years 13–15 the City takes nothing and the schools take $2,500,000. Both columns land on $25,000,000.

What the agreement says cannot be required

The $3,000,000,000 investment and the 75 jobs are in the agreement. They are also, in the same agreement’s own words at §1 and §2, estimates that “will not limit the amount or term of the tax exemptions … or allow the City to compel the Company to make investments” or “to create positions.” [verified] They are R.C. 3735.671(B) good-faith estimates — the recitals the exemption was granted against, not covenants it was granted for.

Set beside that, the rest of the remedies read consistently:

• No clawback of PILOTs already paid. The City’s sole remedy for material breach is to terminate, suspend or modify the exemptions going forward (§12); for unpaid taxes, rescission (§6). [verified]
• The Company may terminate at will, for any reason, on thirty days’ notice (§28). [verified]
• Both school boards irrevocably waived their statutory objection rights. Resolution 81-25 §3.1: the boards approve every exemption grantable under the agreement, and waive the notice requirements of R.C. 3735.671, 5709.83 and 5715.27, the right to grant approvals required by R.C. 3735.671, and any defects or irregularities in the authorization. [verified] §4.2 adds that this agreement and the income-tax sharing agreement are “the entirety of the compensation” the City and the boards may be entitled to.
• Years 16–30 hang on a certificate this corpus does not hold — see the megaproject question in governance. ⚠️ And the test the City described to Council is one prong of four: R.C. 122.17(A)(11) requires all of (a) through (d), including a prong nobody in the City record mentions — that the operator compensate the project’s employees at “an average hourly wage of at least three hundred per cent of the federal minimum wage”. [verified] from the Legislative Service Commission’s authenticated text.
• A state-published check exists, and it is pre-declared public. R.C. 122.17(D)(12) requires a megaproject operator to file an annual economic impact report reporting, at (e), “The number of employees working at the site of the megaproject and the counties in which those employees reside” — and the statute closes: “Any information contained in the report is a public record … and shall be published on the department of development’s web site.” That is the only officer-certified check on the 75 jobs the City accepted. ⚠️ Do not assume one is due: the report begins “in the year specified in the agreement”, and this corpus holds neither the agreement nor a designation.

None of that is unusual for an Ohio CRA agreement, and none of it is hidden: every clause above is printed in a document the City published. It is recorded here because the shape of the bargain is not what a total and a term convey.

When the abatement actually took effect

Not on 2025-10-27. §34 conditions the exemptions on the prior execution of a separate Development Agreement for public infrastructure [verified] — and that agreement is Resolution 27-26^rec , authorized six months later on 2026-04-27. A reader dating the abatement from the vote that authorized it will be half a year early.

The other side of the trade, in the City’s own numbers

This study said the record priced the payments and not the exemption. The City had priced the exemption — in the packet it handed Council on the night of the vote.

The Council Action Summary for Resolution 80-25^doc , PDF page 65 of the 123-page agenda packet (0-based index 64):

“The estimated value of the abatement is in the range of $180 to 350 million over 30 years. The tax abatement estimates are based upon actual construction costs and valuations for similar buildings in Ohio: tax valuation, and therefore the value of the abatement, may be more or less than that amount.”

Against the $50,000,000 the company pays, that is 3.6× to 7×. [inference] — arithmetic on two figures, both [verified].

It is also a lesson in sourcing. This corpus already carried the identical range — tagged [reference] to an advocacy site, and specifically to one of the two third-party trackers that mislabel this campus with a codename belonging to a different Amazon site ninety miles away. The same number was available from the City. Prefer the City’s copy; the value here is provenance, not novelty.

What still cannot be computed

The estimate is not an accounting. Nothing on this record says what the exemption has actually cost in any given year, against what the parcels would otherwise have carried — that is the county auditor’s abatement report and an exemption ledger, and neither is here.

The monitoring fee is a small fact that reads large: under Resolution 69-25 §5 as amended, the City charges 1% of the incentives, minimum $500 and a maximum of $2,500 a year, to administer an exemption of any size. [verified]