Thank you for the opportunity to comment on IDA reform. I teach at the University at Buffalo Law School in the areas of affordable housing and community economic development. I am submitting these remarks on behalf of the Partnership for the Public Good (PPG). PPG has united over 40 Buffalo-area non-profits around a 2009 Community Agenda, which includes this plank regarding subsidy reform: Reform New York State’s Subsidy Programs New York State should reform its major subsidy programs, such as Industrial Development Agencies and Empire Zones, to ensure that economic development dollars are being spent wisely and with maximum community input. Reform legislation should include job quality standards (living and prevailing wages), local hiring, green building requirements, anti-pirating and recapture mechanisms, and anti-sprawl provisions. Locally, the six IDAs in Erie County should be merged into one countywide authority.