HomeMy WebLinkAboutStaff Report 4213
City of Palo Alto (ID # 4213)
City Council Staff Report
Report Type: Action Items Meeting Date: 11/12/2013
City of Palo Alto Page 1
Summary Title: Public Hearing: TEFRA Request; Adopt a Resolution
Approving the issuance of the Bonds by the CMFA
Title: Tefra Hearing Regarding Conduit Financing for the Gideon Hausner
Jewish Day School Project Located at 450, 470, 490 And 560 San Antonio
Road, Palo Alto, and Approving the Issuance of Revenue Bonds by the
California Municipal Finance Authority for the Purpose of Financing and
Refinancing the Acquisition, Construction, Improvement and Equipping of
Various Educational Facilities and Certain Other Matters Relating Thereto
From: City Manager
Lead Department: Administrative Services
Recommendation
1) Conduct a public hearing under the requirements of the Tax Equity and Fiscal
Responsibility Act of 1983 (TEFRA) and the Internal Revenue Code of 1986, as amended
(Code); and
2) Adopt a resolution (Attachment A) approving the issuance of the bonds by the
California Municipal Finance Authority (CMFA) for the benefit of Gideon Hausner Jewish
Day School, Inc.
Executive Summary
Gideon Hausner Jewish Day School, Inc., requested that CMFA serve as the municipal issuer of
tax exempt revenue bonds in an aggregate principal amount not to exceed $14,000,000.
Proceeds will be used to redeem previously issued bonds and to reimburse the School for prior
capital costs. To issue these bonds under federal law (TEFRA) and the Internal Revenue Service
Code, elected representatives of the host government must conduct a public hearing and
approve issuance of the bonds. Since the Gideon Hausner School facilities are located on San
Antonio Road within City limits, the School and CMFA have requested this hearing. The bond
issuance is the sole responsibility of the Gideon Hausner Jewish Day School, Inc. and the City of
Palo Alto will have no financial, legal, moral obligation, liability or responsibility for repayment
of the bonds.
City of Palo Alto Page 2
Background
Gideon Hausner Jewish Day School, Inc. requested that the CMFA serve as the municipal issuer
of bonds for the Gideon Hausner Jewish Day School project in an aggregate principal amount
not to exceed $14,000,000 of tax exempt revenue bonds. Proceeds from the issuance of the
bonds will be used to: redeeming in full the California Municipal Finance Authority Variable
Rate Demand Revenue Bonds (Gideon Hausner Jewish Day School) Series 2008; (2) paying
and/or reimbursing the School for the costs of constructing, improving, renovating, furnishing
and/or equipping of educational facilities and related administrative and support facilities at
the School's campus located at 450, 470, 490 and 560 San Antonio Road, Palo Alto, California
94306, including but not limited to the demolition of pre-existing buildings and construction of
additional educational facilities, including but not limited to a full size gymnasium, a performing
arts facility and multipurpose facilities; and (3) paying costs of issuance with respect to the Loan
(collectively, the “Project”). The Project will be owned and operated by the Corporation.
In order for all or a portion of the bonds to qualify as tax-exempt bonds, the City of Palo Alto
must conduct a public hearing (TEFRA Hearing), providing the members of the community an
opportunity to speak in favor of or against the use of tax-exempt bonds for the financing of the
project. Prior to the hearing, reasonable notice must be provided to the members of the
community. Following the close of the TEFRA hearing, an “applicable elected representative” of
the governmental unit hosting the proposed project must provide its approval of the issuance
of the bonds for the financing of the project.
Discussion
Since the facilities to be financed with the proceeds of the CMFA’s debt are located within the
jurisdiction of the City of Palo Alto, the City has been asked to conduct a TEFRA hearing and
adopt a resolution (Attachment A) that approves both the issuance of bonds by the CMFA for
the benefit of Gideon Hausner Jewish Day School.
As cited in the published notice of October 25, 2013 in the San Jose Mercury News and the Palo
Alto Weekly, the public hearing is simply an opportunity for all interested persons to speak or
to submit written comments concerning the proposal to issue the debt and the nature or
location of the facility to be financed; however, there is no formal obligation on the part of the
borrower or the Council to respond to any specific comments made during the hearing or
submitted in writing.
The financing includes, but is not limited to, financing acquisition, construction, improvement,
and equipping of educational facilities and certain other matters relating thereto located at
450, 470, 490 and 560 San Antonio Road, Palo Alto, California 94306.
City of Palo Alto Page 3
The CMFA is a joint exercise of powers authority that the City became a member of on April 14,
2008. The Joint Exercise of Powers Agreement provides that the CMFA is a public entity,
separate and apart from each member executing such agreement. The debts, liabilities and
obligations of the CMFA do not constitute debts, liabilities or obligations of the members
executing such agreement. The bonds to be issued by the CMFA for the project will be the sole
responsibility of the borrower, and the City of Palo Alto will have no financial, legal, moral
obligation, liability or responsibility for the project or the repayment of the bonds for the
financing of the project. All financing documents with respect to the issuance of the bonds will
contain clear disclaimers that the bonds are not obligations of the City of Palo Alto or the State
of California but are to be paid for solely from funds provided by the borrower.
The City is in no way exposed to any financial liability by reason of its membership in the CMFA.
In addition, participation by the City in the CMFA does not impact the City’s appropriations
limits and will not constitute any type of indebtedness by the City. Outside of holding the TEFRA
hearing, adopting the required resolution, no other participation or activity of the City or the
City Council with respect to the issuance of the bonds will be required. Based on the benefits of
the project to the Palo Alto community and the lack of any financial obligations on the part of
the City, staff recommends that Council approve the attached resolution.
Resource Impact
As stated, the City will incur no financial obligation from approval of the recommendations.
Gideon Hausner Jewish Day School, Inc. is requesting authority to issue up to $14 million in
bonds through the CMFA. The City will receive a fee for its services when the bonds are issued.
The City would receive approximately $7,000 if the par amount of the bonds issued is $14
million.
Policy Implications
Actions recommended in this report are consistent with Council’s prior actions in supporting
non-profit financings under TEFRA.
Environmental Review
Action on this item does not constitute a project under Section 21065 of the Public Resources
Code.
Attachments:
Attachment A: Resolution Gideon Hausner Jewish Day School TEFRA (PDF)
NOT YET APPROVED
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Resolution No. _____
Resolution of the City Council of the City of Palo Alto Approving the Issuance of Tax-
Exempt Obligations of the California Municipal Finance Authority in an Aggregate
Principal Amount Not To Exceed $14,000,000 for the Purpose of Financing and
Refinancing the Acquisition, Construction, Improvement and Equipping of Various
Educational Facilities and Certain Other Matters Relating Thereto
A. Gideon Hausner Jewish Day School, a California nonprofit religious corporation and
an organization described in Section 501(c)(3) of the Internal Revenue Code of 1986, as
amended (the “School”), has requested that the California Municipal Finance Authority (the
“Authority”) participate in the issuance of one or more series of tax exempt loans in an
aggregate principal amount not to exceed $14,000,000 (collectively, the “Loan”) for the
purposes of (1) redeeming in full the California Municipal Finance Authority Variable Rate
Demand Revenue Bonds (Gideon Hausner Jewish Day School) Series 2008; (2) paying and/or
reimbursing the School for the costs of constructing, improving, renovating, furnishing and/or
equipping of educational facilities and related administrative and support facilities at the
School's campus located at 450, 470, 490 and 560 San Antonio Road, Palo Alto, California
94306, including but not limited to the demolition of pre-existing buildings and construction of
additional educational facilities, including but not limited to a full size gymnasium, a performing
arts facility and multipurpose facilities; and (3) paying costs of issuance with respect to the Loan
(collectively, the “Project”).
B. Pursuant to Section 147(f) of the Internal Revenue Code of 1986 (the “Code”), the
issuance of the Loan by the Authority must be approved by the City because the Project is to be
located within the territorial limits of the City.
C. The City Council of the City (the “City Council”) is the elected legislative body of the
City and is one of the “applicable elected representatives” required to approve the issuance of
the Loan under Section 147(f) of the Code.
D. The Authority has requested that the City Council approve the issuance of the Loan
by the Authority in order to satisfy the public approval requirement of Section 147(f) of the
Code and the requirements of Section 4 of the Joint Exercise of Powers Agreement Relating to
the California Municipal Finance Authority, dated as of January 1, 2004 (the “Agreement”),
among certain local agencies, including the City.
E. Pursuant to Section 147(f) of the Code, the City Council has, following notice duly
given, held a public hearing regarding the issuance of the Loan, and now desires to approve the
issuance of the Loan by the Authority.
The City Council of the City of Palo Alto RESOLVES as follows:
SECTION 1. The City Council hereby approves the issuance of the Loan by the Authority.
It is the purpose and intent of the City Council that this resolution constitute approval of the
issuance of the Loan by the Authority for the purposes of: (a) Section 147(f) of the Code, by the
applicable elected representative of the governmental unit having jurisdiction over the area in
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which the Project is to be located, in accordance with said Section 147(f), and (b) Section 4 of
the Agreement.
SECTION 2. The issuance of the Loan shall be subject to approval of the Authority of all
financing documents relating thereto to which the Authority is a party. The City shall have no
responsibility or liability whatsoever with respect to repayment or administration of the Loan.
SECTION 3. The adoption of this Resolution shall not obligate the City or any
department thereof to (i) provide any financing with respect to the Project; (ii) approve any
application or request for or take any other action in connection with any planning approval,
permit or other action necessary with respect to the Project; (iii) make any contribution or
advance any funds whatsoever to the Authority; or (iv) take any further action with respect to
the Authority or its membership therein.
SECTION 4. The officers of the City are hereby authorized and directed, jointly and
severally, to do any and all things and to execute and deliver any and all documents which they
deem necessary or advisable in order to carry out, give effect to and comply with the terms and
intent of this resolution and the financing transaction approved hereby.
SECTION 5. This resolution shall take effect immediately upon its adoption.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
____________________________ ___________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ___________________________
Senior Assistant City Attorney City Manager or Designee
___________________________
Director of Administrative Services