HomeMy WebLinkAbout04-04-2017 Item 18, TEFRA Hearing - 3175 Violet St Meeting Date: 4/4/2017
FROM: Michael Codron, Community Development Director
Prepared By: Jenny Wiseman, Acting Housing Programs Manager
SUBJECT: TAX AND EQUITY FISCAL RESPONSIBILITY ACT (TEFRA) HEARING
REGARDING THE HOUSING AUTHORITY OF SAN LUIS OBISPO
ISSUANCE OF TAX EXEMPT DEBT OBLIGATIONS TO FINANCE 36
AFFORDABLE HOUSING UNITS TO BE LOCATED AT 3175 VIOLET
STREET
RECOMMENDATION
1. Conduct a public hearing under the Tax and Equity Fiscal Responsibility Act (TEFRA) of
1982 and pursuant to the requirements of the Internal Revenue Code of 1986.
2. Adopt a resolution allowing the issuance of a tax -exempt bond by the Housing Authority of
the City of San Luis Obispo (HASLO) to finance 36 affordable multi-family housing units at
3175 Violet Street.
DISCUSSION
Background
The Housing Authority of the City of San Luis Obispo (“HASLO”) is requesting that the Council
hold a public hearing regarding the issuance of a tax -exempt debt obligations to finance the
development of Courtyard at the Meadows, a 36-unit multi-family affordable housing
development located at 3175 Violet Street (“Project”).
Although there is no financial participation (or liability, direct or indirect) by the City in
approving the issuance of this “conduit” financing, Council conduct of a public hearing and
approval of the reissuance is required under federal regulations for tax-exempt financing.
The Housing Authority is committed to providing much needed additional affordable housing in
the City of San Luis Obispo. The primary funding source for this project will be low income
housing tax credits awarded by the California Tax Credit Allocation Committee (TCAC). These
tax credits are then purchased by investors who become a limited partner. California statue does
not allow housing authorities to be a party in these partnerships, so HASLO will hold its interest
through its related entity the San Luis Obispo Non-profit Housing Corporation (“SLONP”).
SLONP will serve as the sole Managing General Partner for Courtyard at the Meadows. The
partnerships have a 15-year compliance period over which the tax credits are earned. After the 15
years, the limited partner has the option to seek a buyer for its interest. The project will feature
an affordability requirement for a minimum of 55 years.
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Project Summary
1. Courtyard at the Meadows will consist of 100% of the units to be rented to households at
60% Area Median Income and below for a minimum of 55 years. The project consists of
36 units: 9 one bedroom units, 18 two bedroom units, and 9 three bedroom units.
2. Estimated total development costs are projected to be $11.6 million. Of this, an amount
not to exceed $10 million in tax exempt bond financing will be utilized to finance the
project development.
3. A resolution (Attachment B) has already been approved by the Housing Authority’s
Board of Directors setting forth HASLO’s official intent to incur the tax-exempt
obligation in order to finance construction of the project.
4. The issuance of the Bond requires that the Council conduct a public hearing regarding the
financing of the Project under the Tax Equity and Fiscal Responsibility Act of 1982
(“TEFRA”), and pursuant to the requirements of the Internal Revenue Code of 1986. The
TEFRA public hearing allows Council to adopt a resolution (Attachment A) approving
the issuance by HASLO of the debt obligations, in order to finance development of the
affordable housing units.
No City Liability for the Financing
There is no City liability in approving the issuance of conduit financing. The bonds are payable
solely from the payments by the borrower on a loan made to it (the “Borrower Loan”) by
HASLO from the proceeds of the bonds. The rental payments by tenants in the Project are the
source of revenue used by the borrower to repay the borrower loan. The City has no financial,
legal, or moral obligation, liability or responsibility for the project or for the repayment of the
bonds or the repayment of the Borrower Loan. The documents for the bonds clearly provide that
the bonds are payable solely from payments on the Borrower Loan made by the borrower.
Outside of holding this hearing and adopting the required resolution, no other participation or
activity of the City with respect to the bonds will be required.
City’s Conduit Financing Policy
While the Council is not obligated to approve this request, it would be consistent with past City
actions regarding conduit financing. Under the City’s debt financing and management policies,
consideration of a request for conduit financing is generally a two-step process:
1. First asking the Council if they are interested in considering the request and establishing
the ground rules for evaluating it; and then
2. Return with the results of this evaluation and recommending approval of appropriate
financing documents if warranted.
Given the Council’s prior approval of conduit financing to HASLO in the past, and due to the
close and ongoing relationship between the City and HASLO; staff finds that HASLO is capable
of achieving the public purpose of providing these debt obligations to finance much needed
affordable housing using tax exempt bonds.
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City’s Past Experience with Conduit Housing Bonds
The City has approved eleven “conduit” housing bond issues in the past as reflected in the
following summary, with the majority being issued by HASLO. There have been no financial
difficulties with any of these bond issues.
1. 1985. 168-unit apartment development on Southwood Drive (refinanced in 1993).
2. 1998. 30-unit development (all affordable for seniors and persons with disabilities) on
Brizzolara Street.
3. 1999. 122-unit apartment development by the De Vaul Ranch Company, of which 26 units
will be affordable: 24 for “very-low” and 2 for “moderate” income households.
4. 2002. 19-unit senior apartment development at 433 Pacific Street (Pacific and Carmel).
5. 2005. 40 affordable one-bedroom units for seniors as well as one manager’s unit in an
existing historic single-family residence at 2005 Johnson Avenue (“Del Rio Terrace”).
6. 2009 and 2011. 8-unit housing project at 1468 East Foothill Boulevard for the University
Board of the Santa Barbara Presbytery.
7. 2012. 120-unit apartment project affordable to low and very-low income households located
at 1550 Madonna Road.
8. 2013. 19-unit apartment project affordable rental apartment facility for seniors located at 433
Pacific (“Carmel Street Apartments”).
9. 2013. 40-unit affordable rental apartment facility for seniors located at 2005 Johnson Avenue
(“Del Rio Terrace”).
10. 2015. Rehabilitation of 55 affordable rental units located at 1092 Orcutt Road, 1102
Ironbark, and 1363 Pismo Street.
11. 2016. 46-unit affordable apartment development at 3680 Broad Street (“Iron Works”).
Next Steps
After the TEFRA public hearing and adoption of the Resolution of the Council approving the
issuance of the debt obligations, HASLO or its managing general partner will apply for low
income housing tax credits and tax exempt bonds in Summer of 2017. There will be no further
actions required by the City.
ENVIRONMENTAL REVIEW
This action is exempt from environmental review per Section 15061(b)(3) of the California
Environmental Quality Act Guidelines because the action is in regards to financing a future
affordable housing project. The financing activity in question will not have a significant impact
on the environment. A Mitigated Negative Declaration (Resolution No. 10512) was approved for
Tract 2353 (Serra Meadows), which included the future development of the Project. The project
was found to be in conformance with the MND at time of entitlement.
FISCAL IMPACT
There are no fiscal impacts to the City associated with this matter. As noted above, the City has
no liability, directly or indirectly, for the financing.
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ALTERNATIVES
1. Do not approve the issuance of bonds by HASLO. The project has already received all
necessary entitlements. Due to lack of liability for repayment of the Bonds by the City, this
option is not recommended.
2. Defer consideration of the request. Due to the critical need for tax exempt bond financing
in order to construct the apartments, this option is not recommended.
Attachments:
a - Council Resolution
b - Housing Authority Board Resolution No. 19 (2016 Series)
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R ______
RESOLUTION NO. ______ (2017 SERIES)
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN LUIS
OBISPO, CALIFORNIA, APPROVING THE HOUSING AUTHORITY OF
THE CITY OF SAN LUIS OBISPO ISSUANCE OF TAX EXEMPT DEBT
OBLIGATIONS TO FINANCE 36 AFFORDABLE HOUSING UNITS
LOCATED AT 3175 VIOLET STREET
WHEREAS, the Housing Authority of the City of San Luis Obispo (the "Authority") is
authorized by Chapter 1 of Part 2 of Division 24 of the Health and Safety Code of the State of
California, as amended (the "Act"), to incur indebtedness and to make loans for housing purposes
specified in the Act; and
WHEREAS, the Authority has expressed an interest in establishing a California limited
partnership (the “Borrower”) and in assisting the Borrower in constructing the Courtyard at the
Meadows affordable rental project at 3175 Violet Street (referred to in this Resolution as the
“Housing Facility”); and
WHEREAS, such assistance will involve the issuance by the Authority of debt obligations
(which may be in the form of a loan evidenced by a note or tax-exempt revenue bonds, and referred
to in this Resolution as the “Bonds”) in the amount not to exceed $10,000,000, and a loan of the
proceeds of the Bonds to the Borrower; and
WHEREAS, all housing units in the Housing Facilit y will be rented to persons and
families of low or very low income as required by the Act and the Internal Revenue Code of 1986,
as amended (the "Code"); and
WHEREAS, the Bonds will be considered to be a "qualified exempt facility bonds" under
Section 142(a) of the Code; and
WHEREAS, Section 147(f) of the Code requires that the "applicable elected
representative" with respect to the Authority approve the issuance by the Authority of the Bonds
following the holding of a public hearing with respect thereto; and
WHEREAS, the Authority has determined that the City Council is the "applicable elected
representative" to approve the issuance by the Authority of the Bonds because the Housing Facility
is located within the City; and
WHEREAS, notice of a public hearing by the Council regarding the financing of the
Housing Facility has been duly given as required by the Code; and
WHEREAS, the Council has held the public hearing at which all interested persons were
given an opportunity to be heard on all matters relative to the location, operation and financing of
the Housing Facility, including the Authority's issuance of the Bonds and subsequent lending of
the proceeds thereof to the Borrower to pay costs of the construction by the Borrower of the
Housing Facility; and
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Resolution No. ______ (2017 Series) Page 2
R ______
WHEREAS, the City will not be a party to any of the agreements or other documents
related to the Bonds and the financing of the Housing Facility, the City will have no liability or
responsibility related to the repayment or administration of the Bonds, and the issuance of the
Bonds and the financing of the Housing Facilit y will not impose any legal, financial or moral
obligation on the City; and
WHEREAS, it is in the public interest, for the public benefit and in furtherance of the
public purpose of the City that the Council approve the issuance by the Authority of the Bonds for
the aforesaid purposes.
NOW, THEREFORE, BE IT RESOLVED that the Council of the City of San Luis
Obispo does declare, determine and order as follows:
SECTION 1. The Council of the City of San Luis Obispo hereby approves the issuance
by the Authority of the Bonds for purposes of the Code.
SECTION 2. Environmental Determination. The City Council has determined that the
above actions will not have a signification impact on the environment, as defined by Section
15061(b)(3) of the California Environmental Quality Act, and is exempt from environmental
review. A Mitigated Negative Declaration (Resolution No. 10512) was approved for Tract 2353
(Serra Meadows), which included the future development of the Project. The project was found to
be in conformance with the MND at time of entitlement.
SECTION 3. This Resolution shall take effect immediately upon its adoption.
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Resolution No. ______ (2017 Series) Page 2
R ______
Upon motion of _______________ seconded by _______________ and on the following vote:
AYES:
NOES:
ABSENT:
The foregoing Resolution was adopted this ______ day of ____________ 2017.
Mayor Heidi Harmon
ATTEST:
Carrie Gallagher
City Clerk
APPROVED AS TO FORM:
J. Christine Dietrick
City Attorney
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the City
of San Luis Obispo, California, this ______ day of ______________, _________.
______________________________
Carrie Gallagher
City Clerk
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RESOLUTION NO. 19 (2016 SERIES)
A RESOLUTION OF THE HOUSING AUTHORITY OF THE CITY OF
SAN LUIS OBISPO SETTING FORTH THE AUTHORITY'S OFFICIAL
INTENT TO INCUR A TAX-EXEMPT OBLIGATION IN ORDER TO
FINANCE THE ACQUISITION AND CONSTRUCTION OF COURTYARD
AT THE MEADOWS APARTMENTS, AND AUTHORIZING RELATED
ACTIONS
WHEREAS, the Housing Authority of the City of San Luis Obispo (the "Authority") is
authorized by Chapter 1 (commencing with Section 34200) of Part 2 of Division 24 of the Health
and Safety Code of the State of California, as amended (the "Act") to incur indebtedness and to
make loans for the purpose of financing the acquisition and construction of multifamily rental
housing facilities located within the area of operation of the Authority; and
WHEREAS, the Authority expects to enter into agreements necessary to sell multifamily
housing revenue bonds or otherwise incur indebtedness (referred to in this Resolution as the
"Bonds") and to lend the proceeds of the Bonds to a limited partnership to be established by the
Authority (the "Borrower") that will use proceeds of the loan to acquire and construct a 36 unit
affordable rental housing facility to be located at 408 Prado Road in the City of San Luis Obispo
(the "Housing Facility"); and
WHEREAS, the Authority, in the course of assisting the Borrower in financing the
Housing Facility, expects that the Borrower, once it is formed, may pay certain expenditures (the
"Reimbursement Expenditures") in connection with the Housing Facility prior to the date of
issuance of the Bonds; and
WHEREAS, Section 1.150-2 of the United States Treasury Regulations (the "Treasury
Regulations") requires that the Authority declare its official intent to reimburse the
Reimbursement Expenditures for the Housing Facility with proceeds of a subsequent tax-exempt
borrowing if the proceeds of the borrowing are to be used to finance the Reimbursement
Expenditures; and
WHEREAS, the Authority wishes to declare its intention to authorize the issuance of the
Bonds for the purpose of financing costs of the acquisition and construction by the Borrower of
the Housing Facility (including reimbursement of the Reimbursement Expenditures) upon such
terms and conditions as may be agreed upon by the Authority, the Borrower and the purchaser of
the Bonds, in an aggregate principal amount not to exceed $10,000,000; and
WHEREAS, Section 146 of the Internal Revenue Code of 1986 limits the amount of
multifamily housing bonds that may be issued in any calendar year by entities within a state (the
"state ceiling") and authorizes the governor or the legislature of a state to provide the method of
allocation within the state; and
WHEREAS, Chapter 11.8 of Division 1 of Title 2 of the California Government Code
governs the allocation of the state ceiling among governmental units in the State of California
having the authority to issue private activity bonds; and
WHEREAS, Section 8869.85(b) of the California Government Code requires a local
agency desiring an allocation of the state ceiling for a particular financing to file an application
with the California Debt Limit Allocation Committee ("CDLAC") for such an allocation, and
CD LAC has certain policies that are to be satisfied in connection with any such allocation; and
WHEREAS, it is in the public interest, for the public benefit and in furtherance of the
public purposes of the Authority that the Authority declares its official intent to issue the Bonds to
finance the Housing Facility and to authorize the Executive Director to take all actions necessary
to apply to CDLAC for an allocation of tax-exempt bond authority for the Bonds.
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NOW, THEREFORE, BE IT RESOLVED by the Housing Authority of the City of San
Luis Obispo, that:
1. The Authority hereby finds and determines that it is necessary and desirable to
provide financing for the acquisition and construction by the Borrower of the
Housing Facility (including reimbursement of the Reimbursement Expenditures)
by the issuance and sale of the Bonds pursuant to the Act in the aggregate principal
amount not to exceed $10,000,000.
2. This Resolution is being adopted by the Authority for the purpose of establishing
compliance with the requirements of Section 1.150-2 of the Treasury Regulations.
In that regard, the Authority declares its official intent that the Authority use
proceeds of the Bonds to reimburse the Reimbursement Expenditures. This action
is taken expressly for the purpose of inducing the Borrower to undertake the
acquisition and construction of the Housing Facility.
3. The Executive Director of the Authority is hereby authorized and directed to apply
to CD LAC for an allocation of the state ceiling of private activity bonds for the
Bonds in an amount not to exceed $10,000,000, and to take any and all other actions
as may be necessary or appropriate in connection with such application, including
but not limited to the payment of fees, the posting of a performance deposit and the
provision of certificates.
4. The law firm of Quint & Thimmig LLP is hereby designated as bond counsel to the
Authority for the Bonds. The Executive Director is hereby authorized to execute
an agreement with such firm for its services related to the Bonds in a form
acceptable to the Executive Director; provided that any and all compensation to
such firm is contingent upon the successful issuance of the Bonds.
5. Notwithstanding the foregoing, the issuance of the Bonds shall only occur on terms
that are satisfactory to the Authority, and subject to the adoption by the Authority
of a resolution approving the documents providing for the terms of the Bonds.
6. This Resolution shall take effect immediately upon its adoption.
On motion of Commissioner Souza
and on the following roll call vote:
, seconded by Commissioner Chubon
AYES:
NOES:
ABSENT:
ABSTAINED:
Commissioners Souza, Chubon, Booker, La Rue, Beck
None
Commissioners Steinberg, Reed
None
The foregoing Resolution was duly adopted and passed this 8th day of December, 2016.
ATTEST:
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