HomeMy WebLinkAbout2015-023 (Authorizing Sale of Variable Rate Demand Tax Increment Revenue Refunding Bonds (Territorial Springs, LLC Project) Series 2015 and providing for their Issuance) Extract of Minutes of a Meeting of the
City Council of the
City of Stillwater, Minnesota
Pursuant to due call and notice thereof, a regular or special meeting of the City
Council of the City of Stillwater,Minnesota,was duly held at the City Hall in said City on Tuesday,
the 20th day of January, 2015 at 7:00 o'clock P.M.
The following Council members were present: Council member Menikheim,
Council member Weidner, Council member Polehna, and Mayor Kozlowski,
and the following were absent: none.
During said meeting Council member Menikheim introduced the following
resolution and moved its adoption:
RESOLUTION NO. 2015-023
RESOLUTION AUTHORIZING SALE OF VARIABLE RATE DEMAND
TAX INCREMENT REVENUE REFUNDING BONDS
(TERRITORIAL SPRINGS, LLC PROJECT) SERIES 2015 AND
PROVIDING FOR THEIR ISSUANCE
The motion for the adoption of the foregoing resolution was duly seconded by
Council member Polehna, and after full discussion thereof and upon vote being taken thereon,the
following voted in favor thereof: Council member Menikheim,Council member Weidner,Council
member Polehna, and Mayor Kozlowski,
and the following voted against the same: none
whereupon said resolution was declared duly passed and adopted.
6862173v3
RESOLUTION AUTHORIZING SALE OF VARIABLE RATE DEMAND
TAX INCREMENT REVENUE REFUNDING BONDS
(TERRITORIAL SPRINGS, LLC PROJECT) SERIES 2015 AND
PROVIDING FOR THEIR ISSUANCE
A. WHEREAS, the City of Stillwater, Minnesota (the "City") established a
municipal development district designated as Development District No. 1 (the "Development
District") pursuant to Minnesota Statutes, Sections 469.124 through 469.134, as amended. The
City approved the establishment of Tax Increment Financing District No. 10 (the "TIF District")
pursuant to authority granted by Minnesota Statutes, Sections 469.174 through 469.1799, as
amended(the "Tax Increment Act"),within the Development District,and adopted a tax increment
financing plan for the purpose of financing certain improvements within the TIF District. In order
to provide for the redevelopment of the Development District and the TIF District and,specifically,
to provide for the redevelopment of the Minnesota Territorial State Prison Site, referred to
generally as Territorial Springs, LLC Project (the "Project"), the City entered into a Contract for
Private Redevelopment,dated August 19,2003,as amended and restated(the "Contract"),between
the City and Territorial Springs, LLC (collectively, the "Developer"). The Project consists of the
construction of five(5)separate buildings of for-sale housing. The City previously issued its Series
2003 Note and its Series 2004 Note, both defined hereinafter, for the purpose of paying site
improvement costs of the Project,which Series 2003 Note and Series 2004 Note are payable from
Available Tax Increment (as described in the Indenture) derived from the Project.
Phase I of the Project consists of three buildings as follows:
Building 1 consists of thirteen (13) for-sale housing units and three commercial units
including 4,000 square feet of retail space.
Building 2 includes forty (40) for-sale housing units.
Building 4 includes thirty-six (36) for-sale housing units.
Phase II of the Project consists of two buildings as follows:
Building 3 consists of forty-six (46) for-sale housing units.
Building 5 consists of thirty-six(36) for-sale housing units; and
B. WHEREAS,pursuant to Section 469.178 of the Tax Increment Act,the City
is authorized to issue and sell its bonds or notes for the purpose of financing capital and
administration costs in development districts and to pledge tax increment revenues derived from a
tax increment financing district established within the development district to the payment of the
principal of and interest on such obligations; and
C. WHEREAS, on October 28, 2003, the City Council of the City adopted
Resolution No. 2003-230 (the "Original 2003 Note Resolution"),which provided for the issuance
and sale of a tax increment revenue note. Pursuant to the terms of the 2003 Note Resolution, the
City issued its Taxable Tax Increment Revenue Note (Territorial Springs, LLC Project), Series
2003 (the "Original 2003 Note"), in the principal amount of$3,255,000, dated as of December 10,
2
6862173v3
2003, payable solely from a portion of the proceeds of the Original 2003 Note and from tax
increment revenues generated from Phase I of the Project,to finance Phase I of the Project; and
D. WHEREAS, on August 20, 2008,the City Council adopted Resolution No.
2008-104, which provided for the amendment of the Original 2003 Note, on October 6, 2009, the
City Council adopted Resolution No. 2009-166, which further amended the Original 2003 Note,
and on April 5, 2011, the City Council adopted Resolution No. 2011-58 (collectively with the
Original 2003 Note Resolution,the "2003 Note Resolution"),which provided for the issuance and
sale of its Taxable Tax Increment Refunded Revenue Note (Territorial Springs, LLC Project),
Series 2003,which refunded the Original 2003 Note(collectively with the Original 2003 Note,the
"Series 2003 Note"); and
E. WHEREAS, on September 15, 2004, the City Council of the City adopted
Resolution No. 2004-188 (the "Original 2004 Note Resolution"), which provided for the issuance
and sale of a tax increment revenue note. Pursuant to the terms of the 2004 Note Resolution, the
City issued its Taxable Tax Increment Revenue Note (Territorial Springs, LLC Project), Series
2004(the "Original 2004 Note"),in the principal amount of$2,923,000,dated as of September 15,
2004, payable solely from a portion of the proceeds of the Original 2004 Note and from tax
increment revenues generated from Phase II of the Project,to finance Phase II of the Project; and
F. WHEREAS, on August 7, 2007, the City Council adopted Resolution No.
2007-152,which provided for the amendment of the Original 2004 Note, on August 20, 2008,the
City Council adopted Resolution No. 2008-105, which further amended the Original 2004 Note,
on October 6, 2009, the City Council adopted Resolution No. 2009-167, which further amended
the Original 2004 Note, and on April 5, 2011, the City Council adopted Resolution No. 2011-58
(collectively with the Original 2004 Note Resolution, the "2004 Note Resolution"), which
provided for the issuance and sale of its Taxable Tax Increment Amended Revenue Note
(Territorial Springs, LLC Project), Series 2004, which refunded the Original 2004 Note
(collectively with the Original 2004 Note,the "Series 2004 Note"). The Series 2003 Note and the
Series 2004 Note are hereinafter referred to collectively as the "Notes"; and
G. WHEREAS,pursuant to the terms of the Contract,the City agreed to refund
the Notes with tax-exempt tax increment revenue bonds when the conditions set forth in the
Contract for the issuance of such revenue bonds have been satisfied. Such conditions have been
satisfied for the issuance of the tax-exempt tax increment revenue bonds; and
H. WHEREAS,it is proposed that the City and U.S.Bank National Association
("Trustee")enter into an Indenture of Trust dated as of February 1,2015 (the"Indenture")pursuant
to which the City has agreed to issue its Variable Rate Demand Tax Increment Revenue Refunding
Bonds (Territorial Springs, LLC Project) Series 2015 in the aggregate principal amount not to
exceed $[5,305,000] (the "Bonds") to redeem and prepay the outstanding principal amount of
Notes issued to finance the Project; and
I. WHEREAS, the City and the Trustee will agree in the Indenture that the
Bonds will be payable solely from certain Available Tax Increment (as defined in the Indenture)
derived from the Project; and
3
6862173v3
J. WHEREAS,it is also proposed that the Bonds be further secured by a Letter
of Credit (the "Letter of Credit") to be provided by Bridgewater Bank, a Minnesota banking
corporation (the "Bank"), which shall be issued pursuant to a Reimbursement Agreement (the
"Reimbursement Agreement") between the City and the Bank; and
K. WHEREAS, the Letter of Credit shall be secured by an Irrevocable
Confirming Letter of Credit (the "Confirming Letter of Credit") issued by Federal Home Loan
Bank of Des Moines (the "Confirming Bank").
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of
Stillwater, Minnesota, as follows:
4
6862173v3
SECTION 1 ISSUANCE OF THE BONDS.
1.1 In order to refund the outstanding principal amount of the Notes, the City Council
hereby authorizes the issuance of tax increment revenue bonds to be designated as the"Variable
Rate Demand Tax Increment Revenue Refunding Bonds (Territorial Springs, LLC Project) Series
2015 in a principal amount not to exceed $[5,305,000]. The Bonds shall be issued on such date
and upon the terms and conditions determined by the Administrator of the City. The Bonds are
authorized to be issued as obligations the interest on which is not includable in gross income for
federal and State of Minnesota income tax purposes. This authorization to issue the Bonds is
effective without any additional action of the City Council and shall be undertaken by the
Administrator on such date and upon the terms and conditions deemed reasonable by the
Administrator. The City Council hereby authorizes the sale of the Bonds to Dougherty &
Company LLC (the "Underwriter") upon the offer of the Underwriter to purchase the Bonds in
accordance with the terms of a Bond Purchase Agreement between the City and the Underwriter
(the "Bond Purchase Agreement").
1.2 There have been presented to the City Council forms of the following documents:
(i) an Indenture of Trust(the "Indenture"), between the City and U.S. Bank National Association,
as trustee (the "Trustee"); (ii) the Bond Purchase Agreement; (iii) the Letter of Credit; (iv) the
Reimbursement Agreement and (v) a Remarketing Agreement between the City and the
Underwriter, as remarketing agent (the "Remarketing Agreement"). The Indenture, the Bond
Purchase Agreement, the Letter of Credit, the Reimbursement Agreement, and the Remarketing
Agreement(the "City Documents")are hereby approved in substantially the forms on file with the
City on the date hereof,subject to such changes not inconsistent with this resolution and applicable
law that are approved by the Administrator of the City.
1.3 The Bonds shall have the maturities, interest rate provisions, shall be dated,
numbered, and issued in such denominations, shall be subject to mandatory, optional and special
redemptions and prepayment prior to maturity, shall be executed, sealed,and authenticated in such
manner, shall be in such form, and shall have such other details and provisions as are prescribed
in the Indenture. The form of the Bonds included in the Indenture is approved in substantially the
form in the Indenture,subject to such changes not inconsistent with this resolution and applicable
law, and subject to such changes that are approved by the Administrator. Without limiting the
generality of the foregoing, the Administrator is authorized to approve the original aggregate
principal amount of the Bonds to be issued under the terms of this resolution (subject to the
maximum aggregate principal amount for all series authorized by this resolution), to establish the
terms of redemption, the principal amounts subject to redemption, and the dates of redemption of
the Bonds, and to approve other changes to the other terms of the Bonds which are deemed by the
Administrator to be in the best interests of the City. The issuance and delivery of the Bonds shall
be conclusive evidence that the Administrator has approved the terms and provisions of the Bonds
in accordance with the authority granted by this resolution. The proceeds derived from the sale of
the Bonds, and the earnings derived from the investment of such proceeds, shall be held,
transferred, expended, and invested in accordance with determinations of the Administrator.
1.4 The Bonds shall be secured by the terms of the Indenture and shall be payable solely
from Available Tax Increment (as defined in the Indenture) that are expressly pledged to the
5
6862173v3
payment of the Bonds pursuant to the terms of the Indenture and shall be further secured by the
Letter of Credit.
1.5 It is hereby found,determined and declared that the issuance and sale of the Bonds,
the execution and delivery by the City of the City Documents,and the performance of all covenants
and agreements of the City contained in the City Documents, and of all other acts required under
the Constitution and laws of the State of Minnesota to make the Bonds the valid and binding special
obligations of the City enforceable in accordance with their respective terms, are authorized by
applicable Minnesota law, including, without limitation, the Tax Increment Act and this
Resolution.
1.6 Under the provisions of the Tax Increment Act, and as provided in the Indenture
and under the terms of the Bonds,the Bonds are not to be payable from or chargeable against any
funds other than the revenues pledged to the payment thereof; the City shall not be subject to any
liability thereon other than from such revenues pledged thereto; no holder of any Bonds shall ever
have the right to compel any exercise by the City of its taxing powers (other than as contemplated
by the pledge of tax increment revenues under the terms of the Indenture) to pay the principal of,
premium, if any, and interest on Bonds, or to enforce payment thereof against any property of the
City other than the property expressly pledged thereto;the Bonds shall not constitute a charge,lien
or encumbrance,legal or equitable,upon any property of the City other than the revenues expressly
pledged thereto;the Bonds shall recite that the Bonds are issued without a pledge of the general or
moral obligation of the City, and that the Bonds,including interest thereon, are payable solely
from the revenues pledged to the payment thereof;and the Bonds shall not constitute a debt of the
City within the meaning of any constitutional or statutory limitation of indebtedness.
SECTION 2 DISCLOSURE DOCUMENTS AND CLOSING CERTIFICATES.
2.1 The preparation of an Official Statement in conjunction with the offer and sale of
the Bonds is hereby authorized. When approved by the Administrator of the City, the Official
Statement is authorized to be distributed in conjunction with the offer and sale of the Bonds. In
order to provide for continuing disclosure with respect to the Bonds,the City Clerk may execute
and deliver an agreement or certificate providing for continuing disclosure with respect to the
Bonds.
2.2 Unless litigation shall have been commenced and be pending questioning the
Bonds, the proceedings for approval of the Bonds, tax increment revenues generated or collected
for payment of the Bonds, revenues pledged for payment of the Bonds, or the organization of the
City, or incumbency of its officers, the City Clerk shall also execute and deliver a suitable
certificate as to absence of material litigation,and the Administrator shall also execute and deliver
a certificate as to payment for and delivery of the Bonds, and the signed approving legal opinion
of Briggs and Morgan,Professional Association, as to the validity and enforceability of the Bonds
and the tax-exempt status of interest on the Bonds.
2.3 The City Clerk,the Administrator, and other members of the City Council, agents,
officers, and employees of the City are hereby authorized and directed, individually and
collectively, to furnish to the attorneys approving the Bonds, on behalf of the purchasers of the
Bonds, certified copies of all proceedings and certifications as to facts as shown by the books and
6
6862173v3
records of the City, and the right and authority of the City to issue the Bonds,and all such certified
copies and certifications shall be deemed representations of fact on the part of the City. Such
members of the City Council, officers, employees, and agents of the City are hereby authorized to
execute and deliver, on behalf of the City, all other certificates, instruments, and other written
documents that may be requested by bond counsel, the Underwriter, the Trustee, or other persons
or entities in conjunction with the issuance of the Bonds and the expenditure of the proceeds of
the Bonds. Without imposing any limitations on the scope of the preceding sentence, such officers
and employees are specifically authorized to execute and deliver one or more UCC-1 financing
statements, a certificate relating to federal tax matters including matters relating to arbitrage and
arbitrage rebate, a receipt for the proceeds derived from the sale of the Bonds, an order to the
Trustee,a general certificate of the City,and an Information Return for Tax-Exempt Governmental
Obligations, Form 8038-G.
SECTION 3 REDEMPTION OF NOTES.
3.1 The City elects to apply the net proceeds of the Bonds to the optional prepayment
of the Notes in accordance with their terms. Upon the sale and issuance of the Bonds, the City
Clerk, as Registrar of the Notes, is directed to take all other actions necessary to cause the
redemption and prepayment of the Notes to occur as soon as possible after the date of issuance of
the Bonds.
SECTION 4 MISCELLANEOUS.
4.1 All agreements, covenants, and obligations of the City contained in this resolution
and in the above-referenced documents shall be deemed to be the agreements, covenants, and
obligations of the City to the full extent authorized or permitted by law, and all such agreements,
covenants, and obligations shall be binding on the City and enforceable in accordance with their
terms. No agreement, covenant, or obligation contained in this resolution or in the above-
referenced documents shall be deemed to be an agreement,covenant,or obligation of any member
of the City Council, or of any officer, employee, or agent of the City in that person's individual
capacity. Neither the members of the City Council, nor any officer executing the Bonds shall be
liable personally on the Bonds or be subject to any personal liability or accountability by reason
of the issuance of the Bonds.
4.2 Nothing in this resolution or in the above-referenced documents is intended or shall
be construed to confer upon any person (other than as provided in the Indenture, the Bonds, and
the other agreements, instruments, and documents hereby approved) any right, remedy, or claim,
legal or equitable, under and by reason of this resolution or any provision of this resolution.
4.3 If for any reason the City Clerk, Administrator, or any other members of the City
Council, officers, employees, or agents of the City authorized to execute certificates, instruments,
or other written documents on behalf of the City shall for any reason cease to be an officer,
employee, or agent of the City after the execution by such person of any certificate, instrument, or
other written document, such fact shall not affect the validity or enforceability of such certificate,
instrument, or other written document. If for any reason the City Clerk, Administrator, or any
other members of the City Council,officers,employees,or agents of the City authorized to execute
certificates, instruments, or other written documents on behalf of the City shall be unavailable to
7
6862173v3
execute such certificates,instruments,or other written documents for any reason, such certificates,
instruments, or other written documents may be executed by a deputy or assistant to such officer,
or by such other officer of the City as in the opinion of the City Attorney is authorized to sign such
document.
4.4 The City shall not take any action or authorize any action to be taken in connection
with the application or investment of the proceeds of the Bonds or any related activity which would
cause the Bonds to be deemed to be "private activity bonds," within the meaning of Section 141
of the Internal Revenue Code of 1986,as amended(the "Code"). The City shall not take any action
or authorize any action to be taken in connection with the application or investment of the proceeds
of the Bonds or any related activity which would cause the Bonds to be deemed to be "arbitrage
bonds," within the meaning of Section 148 of the Code. Furthermore, the City shall take all such
actions as may be required under the Code to ensure that interest on the Bonds is not and does not
become includable in gross income for federal income tax purposes.
4.5 The authority to approve, execute,and deliver future amendments to the documents
executed and delivered by the City in connection with the transactions contemplated hereby is
hereby delegated to the City Clerk, subject to the following conditions: (a) such amendments do
not require the consent of the holders of the Bonds or, if required, such consent has been obtained;
(b) such amendments do not materially adversely affect the interests of the City as the issuer of
the Bonds; (c) such amendments do not contravene or violate any policy of the City; (d) such
amendments are acceptable in form and substance to the City Attorney, bond counsel or other
counsel retained by the City to review such amendments; (e) the City has received, if necessary,
an opinion of bond counsel to the effect that the amendments will not adversely affect the tax-
exempt character or interest on the Bonds, if the Bonds are then tax-exempt obligations; and (1)
such amendments do not materially prejudice the interests of the owners of the Bonds. The
authorization hereby given shall be further construed as authorization for the execution and
delivery of such certificates and related items as may be required to demonstrate compliance with
the agreements being amended and the terms of this resolution. The execution of any instrument
by the City Clerk shall be conclusive evidence of the approval of such instruments in accordance
with the terms hereof In the absence of the City Clerk, any instrument authorized by this
paragraph to be executed and delivered by the City Clerk may be executed by such other officer
of the City as in the opinion of the City Attorney is authorized to execute and deliver such
document.
8
6862173v3
Passed and adopted by the city council of the City of Stillwater, Minnesota,this 20th day
of January, 2015.
Ted Kozlowski,Mayor
ATTEST:
0 [Q t€
Diane F. Ward, City Clerk
9
6862173v3
STATE OF MINNESOTA
COUNTY OF WASHINGTON
CITY OF STILLWATER
I, the undersigned, being the duly qualified and acting City Clerk of the City of
Stillwater, Minnesota, DO HEREBY CERTIFY that I have compared the attached and foregoing
extract of minutes with the original thereof on file in my office, and that the same is a full, true
and complete transcript of the minutes of a meeting of the City Council duly called and held on
the date therein indicated, insofar as such minutes relate to the City's Variable Rate Demand Tax
Increment Revenue Refunding Bonds (Territorial Springs, LLC Project) Series 2015.
WITNESS my hand on January 20, 2015.
f 4��
Diane F. Ward,City Clerk
10
6862173v3