Item 18 - CONDUCT TAX EQUITY AND FISCAL RESPONSIBILITY ACT (TEFRA) HEARINGAGENDA ITEM NO. 18
AGENDA STAFF REPORT
City of West Covina I Office of the City Manager
DATE: December 6, 2022
TO: Mayor and City Council
FROM: David Carmany
City Manager
SUBJECT: CONDUCT TAX EQUITY AND FISCAL RESPONSIBILITY ACT (TEFRA) HEARING AND
CONSIDER ADOPTION OF A RESOLUTION CONDITIONALLY APPROVING THE
ISSUANCE OF NOT -TO -EXCEED $20,000,000 OF CALIFORNIA ENTERPRISE
DEVELOPMENT AUTHORITY REVENUE BONDS FOR THE BENEFIT OF OPTIONS
FOR LEARNING
RECOMMENDATION:
It is recommended that the City Council:
1. Conduct a public hearing as required by Section 147(f) of the Internal Revenue Code of 1986 to
receive comments relating to the issuance by the California Enterprise Development Authority
(Authority) of not -to -exceed $20,000,000 of the Authority's Revenue Bonds (Bonds) for the benefit
of Options for Learning, a California nonprofit public benefit corporation (Borrower).
2. Adopt the attached resolution approving the issuance of the Bonds by the Authority to finance and
refinance facilities for the benefit of the Borrower, contingent upon the execution of a payment in
lieu of taxes agreement between the City and the Borrower:
RESOLUTION NO. 2022-126 - A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
WEST COVINA, CALIFORNIA, APPROVING THE ISSUANCE BY THE CALIFORNIA
ENTERPRISE DEVELOPMENT AUTHORITY OF NOT TO EXCEED $20,000,000
AGGREGATE PRINCIPAL AMOUNT OF THE CALIFORNIA ENTERPRISE
DEVELOPMENT AUTHORITY'S REVENUE BONDS FOR THE PURPOSE OF FINANCING,
REFINANCING AND/OR REIMBURSING THE COST OF ACQUISITION, CONSTRUCTION,
INSTALLATION, EQUIPPING AND FURNISHING OF CERTAIN FACILITIES FOR THE
BENEFIT OF OPTIONS FOR LEARNING, CONTINGENT UPON EXECUTION OF A
PAYMENT IN LIEU OF TAXES AGREEMENT BETWEEN THE CITY AND OPTIONS FOR
LEARNING, AND OTHER MATTERS RELATING THERETO HEREIN SPECIFIED
3. Authorize the City Manager to negotiate and execute a payment in lieu of taxes agreement (PILOT)
with Options for Learning and any future amendments to the agreement, in such form as approved
by the City Attorney.
BACKGROUND:
The purpose of the California Enterprise Development Authority Joint Powers Authority (JPA or Authority)
established by the California Association for Local Economic Development (CALED) is to issue
tax-exempt and taxable conduit revenue bonds to fund commercial and industrial development projects
within member jurisdictions. Federal and state laws provide the ability for cities and counties to join
together under cooperative agreements to form joint powers authorities to issue tax-exempt and taxable
bonds. These bonds fund projects that provide a public benefit and serve the needs of residents within
the jurisdictions of the participating members. Cities and counties in California utilize joint powers
authorities primarily for economies of scale, to access specialized transaction knowledge and resources,
and to avoid using valuable local staff time on these types of transactions.
This JPA is a joint powers authority created by the cities of Selma, Lancaster and Eureka. There are
approximately 250 cities and counties who are associate members of the Authority. The Authority's
activities are dedicated to providing economic development assistance to member jurisdictions as an
extension of the economic development assistance provided by CALED to its members. The City
became an associate member of the Authority on April 3, 2018, pursuant to Resolution No. 2018-26. As
an Associate Member of the Authority, the City is eligible to participate in the Authority's programs.
DISCUSSION:
Options for Learning has been serving children and families since 1981 providing affordable childcare,
before and after school programs and quality programs designed to provide personalized attention for
students in an enriching, and caring environment. Options for Learning also offers training, resources
and support to community childcare providers to improve the quality of care for the children served.
Options for Learning operates at more than 90 locations, serving more than 15,000 children. Options for
Learning also trains and supports thousands of childcare providers. Options for Learning is a leader in
preparing children and their families for successful life through innovative quality child development
programs so that all children will achieve their potential.
Options for Learning is seeking to issue $20 million in tax-exempt bonds in order to purchase the office
building located at 2934 East Garvey Avenue South, West Covina, California 91791 for their
administrative headquarters. They will be relocating their headquarters from Covina to West Covina with
the acquisition of the property. Options for Learning currently has a childcare school program facility in
West Covina located at 203 South Azusa Avenue. As Options for Learning is a non-profit, the property
would be removed from the tax rolls (or any portion occupied by a non-profit impacting property taxes
received by the City on the property).
Options for Learning (aka the Borrower) and the JPA have requested that the City conduct a Tax Equity
and Fiscal Responsibility Act of 1982 ("TEFRX) hearing and approve a resolution in accordance with
Internal Revenue Code (the "Code") Section 147(f) authorizing the issuance of tax-exempt obligations by
the JPA in an amount not -to -exceed $20,000,000. A TEFRA hearing is required by the Internal Revenue
Code before tax-exempt debt can be issued for the benefit of a private nonprofit corporation. The hearing
gives the public an opportunity to comment on the use of tax-exempt funds by the Borrower.
The proceeds of the Bonds will be loaned to the Borrower for the purpose of (a) financing, refinancing
and/or reimbursing the cost of acquiring, construction, improving, equipping and furnishing a three-story
office building with approximately 106,000 square feet located at 2934 East Garvey Avenue South, West
Covina, California 91791 (the "Facility") for use as the Borrower's administrative headquarters, and (b)
paying certain costs of issuance and other costs related in connection with the Bonds.
The issuance of the Bonds as tax-exempt will reduce financing costs and debt service costs for the
Borrower. In order to satisfy the requirements for the obligations to be issued as tax-exempt, an
applicable elected representative which is also a member of the JPA is required to conduct the TEFRA
hearing and approve the issuance of the tax-exempt obligations in accordance with Section 147(f) of the
Code. The City Council of the City of West Covina constitutes an applicable elected representative
under Section 147(f) of the Code.
A public notice (Attachment No. 2) of today's public hearing was published at least seven days prior to
the hearing in the San Gabriel Valley Tribune newspaper.
If Options for Learning acquires the property, as a non-profit organization, a portion or all of the property
taxes will be exempt. Taxing entities, including the City will forfeit a portion or all of the property taxes
from the property. The majority of TEFRA hearings the City has held have not required removing
properties off the assessor property tax roll. The following are the last two TEFRA hearings the City held:
. 2020 - Emanate Health Queen of the Valley Hospital expansion bond issuance 1 $260 million
. 2019 - Cameron Park Apartments acquisition & rehabilitation of an affordable multifamily rental
housing complex 1 $63 million
The City's receives 37% of its general fund revenues from property taxes. The subject property currently
generates approximately $17,100 annually to the City in property taxes. The sale of the subject property
will increase its value, in addition, any investment to rehabilitate the building for the Options for Learning
headquarters could further increase the property's valuation. The increase in valuation could generate
over approximately $30,500 annually to the City.
Options for Learning is anticipating only a portion of the building to be utilized by non-profit, as such, only
that percentage would be tax-exempt from the assessor tax roll. Options for Learning has indicated up
to 60% of the property could be occupied by non-profit organizations, meaning the City would only
receive 40% of property taxes from the property. To compensate the City for the loss of property tax
revenues, staff is recommending the City and Options for Learning consider entering into a Payment In
Lieu Of Taxes (PILOT) Agreement. A PILOT agreement is an agreement between a business
development project and a municipality that allows a company to make property tax payments on an
agreed schedule instead of paying the standard tax amount. The PILOT agreement takes into account
the property's market value and the amount of taxes the company would actually pay if it did not have a
PILOT agreement in place.
In addition, staff recommends the City seek reimbursement from Options for Learning for costs of the
transaction, including the public hearing notice and legal costs associated with review and preparation of
the TEFRA hearing and any documents associated with TEFRA hearing, including the PILOT agreement.
LEGAL REVIEW:
The City Attorney's Office has reviewed the resolution and approved it as to form and will review and
approve the PILOT agreement as to form prior to execution.
OPTIONS:
The City Council has the following options:
1. Approve staffs recommendation; or
2. Provide alternative direction.
Prepared by: Paulina Morales, Assistant City Manager
Fiscal Impact
FISCAL IMPACT:
The TEFRA hearing has no fiscal impact to the City. The adoption of the resolution approving the
financing and refinancing of the Facilities and the issuance of the Bonds complies with the requirements
of Section 147(f) of the Internal Revenue Code of 1986. The City does not bear any responsibility for
the tax-exempt status of the interest on the Bonds, the debt service on the Bonds or any other matter
related to the Bonds.
Acquisition of the property by the non-profit organization will result in the City's loss of property tax
revenues. The City currently receives approximately $17,100 annually.
The approval of the Bonds to finance and refinance the Facilities is not subject to compliance with the
California Environmental Quality Act (California Public Resources Code, Section 21100, et seq.).
Attachments
Attachment No. 1 - Resolution No. 2022-126
Attachment No. 2 - Public Hearing Notice
CITY COUNCIL GOALS & OBJECTIVES: A Well -Planned Community
ATTACHMENT NO. 1
RESOLUTION NO. 2022-126
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
WEST COVINA, CALIFORNIA, APPROVING THE
ISSUANCE BY THE CALIFORNIA ENTERPRISE
DEVELOPMENT AUTHORITY OF NOT TO EXCEED
$20,000,000 AGGREGATE PRINCIPAL AMOUNT OF THE
CALIFORNIA ENTERPRISE DEVELOPMENT
AUTHORITY'S REVENUE BONDS FOR THE PURPOSE OF
FINANCING, REFINANCING AND/OR REIMBURSING THE
COST OF ACQUISITION, CONSTRUCTION,
INSTALLATION, EQUIPPING AND FURNISHING OF
CERTAIN FACILITIES FOR THE BENEFIT OF OPTIONS
FOR LEARNING, CONTINGENT UPON EXECUTION OF A
PAYMENT IN LIEU OF TAXES AGREEMENT BETWEEN
THE CITY AND OPTIONS FOR LEARNING, AND OTHER
MATTERS RELATING THERETO HEREIN SPECIFIED
WHEREAS, Options for Learning, a California nonprofit public benefit corporation
and an organization described in Section 501(c)(3) of the Internal Revenue Code of 1986
(the "Borrower"), has requested the California Enterprise Development Authority (the
"Authority") to issue, from time to time, pursuant to a plan of finance, one or more series
of its tax-exempt bonds, notes, or other evidence of indebtedness in an amount not to
exceed $20,000,0000 (the "Bonds") for the benefit of the Borrower pursuant to the Joint
Exercise of Powers Act, Chapter 5 of Division 7 of Title 1 of the California Government
Code (commencing with Section 6500) (the "Act"); and
WHEREAS, all or a portion of the proceeds of the Bonds loaned to the Borrower
will be applied to (a) finance, refinance and/or reimburse the cost of acquiring,
constructing, installing, equipping and furnishing a three-story office building with
approximately 108,000 square feet located at 2934 East Garvey Avenue S., West Covina,
California 91791 (the "Facility"), for use as the Borrower's administrative headquarters;
and (b) paying capitalized interest and certain costs of issuance in connection with the
Bonds (collectively, the "Project"); and
WHEREAS, pursuant to Section 147(f) of the Internal Revenue Code of 1986 (the
"Code"), the issuance of the Bonds by the Authority must be approved by the City Council
of the City of West Covina (the "City") because the Project is to be located within the
territorial limits of the City; and
WHEREAS, 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 Bonds under Section 147(f) of the Code; and
WHEREAS, the Authority has requested that the City Council approve the
issuance of the Bonds by the Authority in order to satisfy the public approval requirements
of Section 147(f) of the Code; and
WHEREAS, 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 Bonds, and now
desires to approve the issuance of the Bonds by the Authority.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF WEST COVINA,
CALIFORNIA DOES RESOLVE AS FOLLOWS:
SECTION 1. The foregoing recitals are true and correct.
SECTION 2. The City Council hereby approves the issuance, in one or more
series, from time to time, pursuant to a plan of finance, of tax-exempt and/or taxable Bonds
by the Authority in an amount not to exceed $20,000,0000 for financing, refinancing
and/or reimbursing the cost of the Project, contingent upon the execution of a payment in
lieu of taxes agreement between City and Borrower. It is the purpose and intent of the
City Council that this resolution constitutes approval of the issuance of the Bonds by the
Authority for the purposes of Section 147(f) of the Code by an applicable elected
representative of the governmental unit having jurisdiction over the area in which the
Project is located, in accordance with said Section 147(f), contingent upon the execution
of a payment in lieu of taxes agreement between City and Borrower. This resolution shall
also constitute the approval of the issuance of the Bonds by the Authority within the
meaning of the Act, contingent upon the execution of a payment in lieu of taxes agreement
between the City and Borrower.
SECTION 3. The issuance of the Bonds shall be subject to the 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 the Bonds.
SECTION 4. 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 the Borrower; or (iv)
take any further action with respect to the Authority or its membership therein.
SECTION 5. 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 6. The City Manager is hereby authorized to take whatever actions are
necessary and appropriate to carry out the purpose and intent of this resolution.
SECTION 7. The City Clerk shall certify to the adoption of this resolution and shall
enter the same in the book of original resolutions and it shall become effective
immediately.
APPROVED AND ADOPTED this 6th day of December, 2022.
APPROVED AS TO FORM
Thomas P. Duarte
City Attorney
Dario Castellanos
Mayor
ATTEST
Lisa Sherrick
Assistant City Clerk
I, LISA SHERRICK, Assistant City Clerk of the City of West Covina, California, do
hereby certify that the foregoing Resolution No. 2022-126 was duly adopted by the City
Council of the City of West Covina, California, at a regular meeting thereof held on the
6th day of December 2022, by the following vote of the City Council:
AYES:
NOES:
ABSENT:
ABSTAIN:
Lisa Sherrick
Assistant City Clerk
ATTACHMENT NO.2
NOTICE OF PUBLIC HEARING
PUBLIC NOTICE IS HEREBY GIVEN that at 7:00 p.m., or as soon thereafter as the matter may
be heard, on December 6, 2022, at City Hall Council Chambers, 1444 West Garvey Avenue
South, West Covina, California 91790, the City Council of the City of West Covina (the "City
Council") will conduct a public hearing (the "Public Hearing") at which the City Council will
hear and consider information concerning the issuance, from time to time, pursuant to a plan of
finance, of one or more series of tax-exempt qualified 501(c)(3) revenue bonds as defined by
Section 145 of the Internal Revenue Code of 1986, as amended (the "Code") by the California
Enterprise Development Authority (the "Authority") in an aggregate principal amount not to
exceed $20,000,000 (the "Bonds") for the benefit of Options for Learning, a nonprofit public
benefit corporation, duly organized and existing under the laws of the State of California (the
"Borrower"). The Authority will loan the proceeds of the Bonds to the Borrower pursuant to one
or more financing agreements. All or a portion of the proceeds of the Bonds loaned to the
Borrower will be applied to (a) finance, refinance and/or reimburse the cost of acquiring,
constructing, improving, equipping and furnishing a three-story office building with
approximately 108,000 square feet and subterranean and surface parking located at 2934 East
Garvey Avenue South, West Covina, California 91791 (the "Facility"), for use as the Borrower's
administrative headquarters, and (b) paying capitalized interest and certain costs of issuance in
connection with the Bonds. The Facility will be owned and operated by the Borrower in
connection with the Borrower's mission to prepare children and their families for life success
through innovative, quality child development programs.
Neither the faith and credit nor the taxing power of City of West Covina (the "City"), the State of
California (the "State") or any other political corporation, subdivision or agency of the State is
pledged to the payment of the principal of, premium, if any, or interest on, the Bonds, nor shall
the City, the State or any other political corporation, subdivision or agency of the State be liable
or obligated to pay the principal of, premium, if any, or interest on, the Bonds. The Public
Hearing is intended to comply with the public approval requirements of Section 147(f) of the
Code.
Interested persons wishing to express their views on the nature and location of the Facility or the
proposed financing and refinancing of the Facility may attend the public hearing or, prior to the
time of the hearing, or contact the City Clerk's Office by email at city clerk(a)westcovina.org.
The City complies with the Americans with Disabilities Act (ADA). If you will need special
assistance at Council meetings, please call (626) 939-8433 (voice) or (626) 960-4422 (TTY)
from 8 to 5 Monday through Thursday. Do call at least one day prior to the meeting date to
inform us of your particular needs and to determine if accommodation is possible. For sign
language interpreter services at Council meetings, please request no less than four working days
prior to the meeting. Advance notification within this guideline will enable the City to make
reasonable arrangements to ensure accessibility.
Date: November 29, 2022
4870-7033-7084.1