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Resolution No. 7744r 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RESOLUTION NO. 7744 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF VERNON AUTHORIZING THE ISSUANCE OF DEBT SECURITIES TO FINANCE CERTAIN COSTS RELATING TO THE ACQUISITION, CONSTRUCTION, AND IMPROVEMENT OF ELECTRICAL GENERATION, DISTRIBUTION, AND RELATED FACILITIES WHEREAS, the City Council has approved and adopted the Strategic Direction for Resource Procurement and Portfolio Management, prepared by the Utilities Department, (the "Strategic Direction"), for calendar year 2001; WHEREAS, the Utilities Department has recommended, in the Strategic Direction, that a portion of the City's future energy requirements be satisfied by the development, acquisition, construction and improvement of electrical generation assets and related facilities, which may include, without limitation, improvements to the City's local electric, gas and water distribution- systems and the acquisition of required environmental assets (the "Project"); WHEREAS, the City expects to issue debt securities to finance the costs of the Project on a permanent basis (the "Debt"); WHEREAS, the City expects to expend moneys (other than moneys derived from the issuance of the Debt) on expenditures relating to the costs of the Project prior to the issuance of the Debt, which expenditures will be properly chargeable to a capital account under general federal income tax principles; -1- WHEREAS, the City reasonably expects to reimburse certain of such capital expenditures with the proceeds of the Debt; WHEREAS, the City expects that the maximum principal amount of the Debt which will be issued to pay for the costs of the Project (and related issuance costs) will not exceed $175,000,000; and WHEREAS, this Resolution is intended to be a "declaration of official intent" in accordance with Section 1 150-2 of the Department of Treasury Regulations of the United States of America. NOW, THEREFORE`, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF VERNON AS FOLLOWS SECTION 1: The City Council of the City of Vernon does hereby find and determine that the recitals contained hereinabove are true and correct, SECTION 2: The City Council declares, in accordance with Section'1.150-2 of the Regulations issued by the Treasury Department of the United States of America, its intention to issue Debt in a principal amount not to exceed $175,000,000, the proceeds of which will be used to pay for the 'costs of the Project, (and related issuance costs); including the reimbursement to the City for certain capital expenditures relating to the Project made prior to the issuance of the Debt. SECTION 3: The City shall,_, at the time of reimbursement of certain: capital expenditures relating to the Project, evidence the reimbursement in a writing which identifies the allocation of the proceeds of the Debt to the City for the purpose of reimbursing the -2- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 City for the capital expenditures made prior to the issuance of the Debt. SECTION 4: The City expects to make the reimbursement allocation no later than eighteen (18) months after the later of (i) the date on which the earliest original expenditure is paid or (ii) the date on which the Project is placed in service (or abandoned), but in noeventlater than three (3) years after the date on which the earliest original expenditure is paid. SECTION 5: The City shall not, within one (1) year of the reimbursement allocation, use the proceeds of the Debt received in the reimbursement allocation in a manner that will result in the creation of replacement proceeds of the Debt or another debt securities issue (as, for example, the City will not pledge or use the proceeds received, for the payment of debt service on the Debt or another debt securities issue; except that the proceeds of the Debt can be deposited in a bona fide debt service fund). SECTION 6: The City Clerk of the City of Vernon shall certify to the passage of this Resolution and thereupon and thereafter the same shall be in full force and effect. APPROVED AND ADOPTED this 4th day of April, 2001. ATTEST: ,/ BRUCE V. MALKENHORST, City Clerk LEONIS C. MALBU G, Mayo -3- STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES ) I, BRUCE V, MALKENHORST, City Clerk of the City of Vernon, do hereby certify that the "foregoing Resolution, being Resolution No. 7744, was duly adopted by the City Council of the City of Vernon at a regular meeting of the City Council duly held on Wednesday, April 4, 2001,and thereafter was duly signed by the Mayor of the City of Vernon. BRUCE V. MALKENHORST, City Clerk -4- SUPPORTING DOCUMENTS CITY COUNCIL LEONIS C. MALBURG Mayor THOMAS A. YBARRA Mayor Pro-Tem WM. 'BILL" DAVIS Councilman H. "LARRY" GONZALES Councilman W. MICHAEL MCCORMICK Councilman BRUCE V. MALKENHORST City Administrator / City Clerk FAX (323) 581-7924 City Council City of Vernon Honorable Members: EDUARDO OLIVO City Attorney r /FAX: (562) 927-8722 KEVIN WILSON Director of Community Services & Water FAX: (323) 588-2761 CITY HALL 4305 SANTA FE AVENUE, VERNON, CALIFORNIA 90058 TELEPHONE (323) 583-8811 March 28, 2001 KENNETH J. DeDARIO Director of Municipal Utilities FAX: (323) 583-1983 STEVEN E. PARKER Fire Chief FAX: (323) 581-1385 BRUCE W. OLSON Police Chief FAX: (323) 583-5236 Staff has been reviewing the matter of purchasing & installing electric generating units that would serve the city's load. At this time it would be prudent to proceed with a resolution allowing the city to take official action to issue tax-exempt bonds to finance the cost of this project. This has been reviewed by our legal consultant, the Utilities Department, and the City Attorney. It is hereby recommended that the following submitted herewith be approved and adopted. Very truly yours, Bruce V. Malkenhorst City Administrator/City Clerk BVM/gjo i CITY COUNCIL LEONIS C. MALBURG Mayor THOMAS A. YBARRA Mayor Pro-Tem WM. 'BILL" DAVIS Councilman H. "LARRY" GONZALES Councilman W. MICHAEL MCCORMICK Councilman BRUCE V. MALKENHORST City Administrator / City Clerk FAX (323) 581-7924 March 27, 2001 CITY HALL 4305 SANTA FE AVENUE, VERNON, CALIFORNIA 90058 TELEPHONE (323) 583-8811 CONFIDENTIAL ATMVOEY VMK PRODUCT EDUARDO OLIVO City Attorney FAX: (562) 927--8722 KEVIN WILSON Director of Community Services & Water FAX: (323) 588-2761 KENNETH J. DeDARIO Director of Municipal Utilities FAX: (323) 583-1983 DAVE TELFORD Fire Chief FAX: (323) 581-1385 BRUCE W. OLSON Police Chief FAX: (323) 583-5236 To: Bruce V. Malkenhorst City Administrator Eddie Olivo City Attorney From: Eric Fresch � Legal Counsel Subject: City Council Resolution Declaring "Official Intent" to Issue Debt for Generation Project The attached draft resolution satisfies the federal tax law requirements for reimbursement bonds and declaring "official intent" to issue debt. (internal Revenue Code Sections 103 and 141-150 and U.S. Treasury Regulations 1.150-2.) This resolution enables the City to issue debt securities at a later time, (whether the transaction is structured as a bond issue or an installment sale) to reimburse the City for moneys paid toward the cost of acquiring electrical generation assets. The United States Treasury has issued a body of rules, termed reimbursement regulations," which dictate how a governmental bond issuer may reimburse itself for costs paid before the issue date of the bonds. The regulations require the City to adopt an official intent for the original expenditure and make the reimbursement from the bond issue not later than 18 months after the later of the date the original expenditure is paid or the date the project is placed in service. The City essentially has three years to issue the bonds from the date the first original expenditure is made toward the generators. March 27, 2001 Page 2 All original expenditures must be for a capital asset or considered made for a capital expenditure, under federal income tax law interpretations and Generally Accepted Accounting Principles. The City's resolution for official action must be made in a reasonable form, which the regulations interpret to mean a specific legislative authorization. The official intent must generally describe the property or project and'state the maximum amount of the obligations expected to be issued. The project description must identify the name and functional purpose of the fund or account to be reimbursed. In this case, it is sufficient that the description of the Project includes electrical generation which identifies the Utilities Department as the fund advancing moneys toward the Project and which shall be reimbursed with bond proceeds. The City taking or adopting "official action" toward the proposed project is only the first step. There are still many federal income tax issues to be resolved. Primary among these are the "output" regulations and private activity rules of the Treasury Department. Bonds issued by the City of Vernon bear tax-exempt interest (a significant savings in the cost of capital for the Project) when the bond proceeds are used to finance essential governmental functions. (Internal Revenue Code Section 103.) Bond interest is not tax-free, however, when it is derived from arbitrage bonds, non -registered bonds or bonds that finance private activities to an excessive degree. The federal government has issued numerous rulings and regulations over what is an arbitrage bond or a bond that finance(s) private activities. If the City successfully navigates through these regulations; the interest rate savings for a project of this size could exceed several million dollars per year over the life of the project. How the City characterizes the Project, existing utility assets, including power sales agreements with generators and other utilities and future intentions regarding the use of the new generator could make the difference in meeting the City's objectives. I recommend that all City representatives working on this proposed financing review and agree on what the City's positions will be before talking to underwriters, financial consultants, bond and tax counsels, rating agencies, bond insurers; State of California Debt and Investment Advisory Commission members and staff and any other interested party. Finally, the passage of the official action resolution by the City Council does not obligate the City to do anything. It merely gives the City the capability to issue debt if it chooses at a later time for this defined "Project". E F: rmt c: Kenneth J. DeDario Jorge C. Somoano A CITY COUNCIL ". LEONIS C. MALBURG m Mayor THOMAS A. YBARRA Mayor Pro -Tern WM. "BILL" DAVIS Councilman H. "LARRY" GONZALES Councilman W. MICHAEL MCCORMICK Councilman BRUCE V. MALKENHORST City Administrator / City Clerk FAX (323) 581-7924 CITY HALL 4305 SANTA FE AVENUE, VERNON, CALIFORNIA 90058 TELEPHONE (323) 583-8811 March 28, 2001 Mr. Bruce V. Malkenhorst City Administrator City of Vernon 4305 Santa Fe Avenue Vernon, California 90058 Dear Bruce: Subject: Electrical Generation Project Financing EDUARDO OLIVO City Attorney FAX: (562) 927-8722 KEVIN WILSON Director of Community Services & Water FAX: (323) 588-2761 KENNETH J. DeDARIO Director of Municipal Utilities FAX: (323) 583-1983 DAVE TELFORD Fire Chief FAX: (323) 581-1385 BRUCE W. OLSON Police Chief FAX: (323) 583-5236 I recommend the City consider all available options in financing the cost of the proposed electrical generation assets. I request your permission to meet with bank and institutional lenders in connection with this transaction, in addition to the traditional bond underwriters, like Steve Dworkin of Bear Stearns. Recently, the State of California has proposed issuing billions of dollars in tax-exempt bonds for power projects. This could impact the City's capability of obtaining its tax-exempt bond allocation for a traditional bond issue for the Project. I would like Kenneth J. DeDario, Jorge C. Somoano and me to meet with John Madden, a principal of Bank of America's Investment Management Group, which includes power project finance, about the City's electrical generation project. This Group finances close to 60% of all merchant -generating plants in the United States. Bank of America provides an alternative source of funding for the City to explore in order to finance the costs of the proposed generation project. I look forward to discussing these issues with you at your earliest convenience. Sincerely, Eric Fresch Legal Counsel EF:rmt c: Kenneth J. DeDario Jorge C. Somoano W) M .v a� 0 mr-1 4 .o ,� CV CO et LLy CO 1- CD ., .. O a v v CV C7 i.. EL J 'Q.. M C g CO . iv ESA E�H 6f! ... S.. p W F L. ,= Ip 4ai J in U .O N W U' O � O coQ U 0 co � $ J L. O Ica N a CL CL co m L,, f. m L(9 m U m Z a a (Do _ � k ■ Y Banc of America Securities LLC John R. Madden CA5-705-04-03 Principal 555 California Street, 4th Floor Investment Management 11244 San Francisco, CA 94104.1503 Tel 415.765.1856 fax 415.765.1817 john.r.madden@bankofamerica.com BankofAmerica &G '`�. Official Sponsor Recycled Pape,