HomeMy WebLinkAbout2016-146B (sale of Tax Increment Revenue Refunding Bonds, Territorial Springs and Lofts of Stillwater projects, Series 2016C and providing for 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 19th day of July, 2016 at 7:00 o'clock P.M.
The following Council members were present: Councilmembers Menikheim,
Junker, Weidner, Polehna and Mayor Kozlowski
and the following were absent: None
During said meeting Councilmember Polehna introduced the following resolution
and moved its adoption:
RESOLUTION NO. 2016-146B
RESOLUTION AUTHORIZING SALE OF
TAX INCREMENT REVENUE REFUNDING BONDS
(TERRITORIAL SPRINGS AND THE LOFTS OF STILLWATER PROJECTS)
SERIES 2016C AND
PROVIDING FOR THEIR ISSUANCE
The motion for the adoption of the foregoing resolution was duly seconded by
Councilmember Menikheim, and after full discussion thereof and upon vote being taken thereon,
the following voted in favor thereof: Councilmembers Menikheim, Junker, Weidner, Polehna
and Mayor Kozlowski
and the following voted against the same: None
whereupon said resolution was declared duly passed and adopted.
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RESOLUTION AUTHORIZING SALE OF
TAX INCREMENT REVENUE REFUNDING BONDS
(TERRITORIAL SPRINGS AND THE LOFTS OF STILLWATER PROJECTS)
SERIES 2016C AND
PROVIDING FOR THEIR ISSUANCE
A. WHEREAS, pursuant to Section 469.178 of the Tax Increment Act (as
defined below), 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
B. 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 469.124-469.134, as amended. The Issuer
has approved the establishment of Tax Increment Financing District No. 10 (the "TIF District")
pursuant to authority granted by Minnesota Statutes, Sections 469.174-469.1799, 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 "Territorial Springs Project"), the
City entered into a Contract for Private Redevelopment, dated August 19, 2003, as amended and
restated (the "Territorial Springs Contract"), between the Issuer and Territorial Springs, LLC
(collectively, the "Territorial Springs Developer"). The Territorial Springs 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 Territorial Springs Project, which Series 2003 Note and Series
2004 Note are payable from Available Tax Increments (as described in the Indenture) derived
from the Territorial Springs Project. Phase I of the Territorial Springs Project consists of three
buildings as follows:
Building 1 consists of fourteen (14) for-sale housing units and two (2) commercial units
including 4,000 square feet of retail space.
Building 2 includes forty-two (42) for-sale housing units.
Building 4 includes thirty-six (36) for-sale housing units.
Phase II of the Territorial Springs Project consists of two buildings as follows:
Building 3 consists of forty-six (46) for-sale housing units.
Building 5 consists of thirty-seven (37) for-sale housing units; and
C. WHEREAS, on October 28, 2003, the City Council of the City adopted
Resolution No. 2003-230 (the "2003 Note Resolution"), which provided for the issuance and sale
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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 "Series 2003 Note"), in the principal amount of$3,255,000, dated as of December 10, 2003,
payable solely from a portion of the proceeds of the Series 2003 Note and from tax increment
revenues generated from Phase I of the Territorial Springs Project, to finance Phase I of the
Territorial Springs Project; and
D. WHEREAS, on September 15, 2004, the City Council of the City adopted
Resolution No. 2004-188 (the "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 "Series 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 Series 2004 Note and from tax increment
revenues generated from Phase II of the Territorial Springs Project, to finance Phase II of the
Territorial Springs Project. The Series 2003 Note and the Series 2004 Note are hereinafter
referred to collectively as the "Territorial Springs Notes"; and
E. WHEREAS, pursuant to the terms of the Territorial Springs Contract, the
City agreed to refund the Series 2003 Note and the Series 2004 Note with tax-exempt tax
increment revenue bonds when the conditions set forth in the Territorial Springs 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
F. WHEREAS, in order to provide for the redevelopment of the
Development District and the TIF District, referred to generally as The Lofts of Stillwater, Inc.
Project (the "Lofts Project" and, with the Territorial Springs Project, the "Projects"), the City
entered into an Amended and Restated Contract for Private Redevelopment, dated February 3,
2005 (the "Lofts Contract" and, with the Territorial Springs Contract, the "Contracts"), between
the City and The Lofts of Stillwater, Inc. (the "Lofts Developer" and, with the Territorial Springs
Developer, the "Developers"). The Lofts Project consists of the construction of an
approximately 109,000 square foot four-story residential condominium building containing
approximately sixty-six (66) for-sale housing units; and
G. WHEREAS, on June 20, 2006, the City Council of the City adopted
Resolution No. 2006-137, which provided that the City and U.S. Bank National Association (the
"Trustee") enter into an Indenture of Trust dated as of July 1, 2006 (the "Lofts Indenture")
pursuant to which the City agreed to issue its Tax Increment Revenue Bonds (The Lofts of
Stillwater, Inc. Project), Series 2006 in the aggregate principal amount of$2,390,000 (the "Series
2006 Bonds")to finance the Lofts Project; and
H. WHEREAS, it is proposed that the City and the Trustee enter into an
Indenture of Trust dated as of July 1, 2016 (the "Indenture") pursuant to which the City has
agreed to issue its Tax Increment Revenue Refunding Bonds (Territorial Springs and The Lofts
of Stillwater Projects) Series 2016C in the aggregate principal amount of $6,585,000 (the
"Bonds") to redeem and prepay the outstanding principal amount of the Territorial Springs Notes
and Series 2006 Bonds issued to finance the Projects; and
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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.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of
Stillwater, Minnesota, as follows:
SECTION 1 ISSUANCE OF THE BONDS.
1.1 In order to refund the outstanding principal amount of the Territorial Springs
Notes and the Series 2006 Bonds, the City Council hereby authorizes the issuance of tax
increment revenue bonds to be designated as the "Tax Increment Revenue Refunding Bonds
(Territorial Springs and The Lofts of Stillwater Projects) Series 2016C" in a principal amount of
$6,585,000. 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) the Indenture and (ii) the Bond Purchase Agreement. The Indenture and the Bond Purchase
Agreement 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.
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1.4 The Bonds shall be secured by the terms of the Indenture and shall be payable
solely from Available Tax Increments (as defined in the Indenture) that are expressly pledged to
the payment of the Bonds pursuant to the terms of the Indenture.
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 Indenture and the Bond Purchase
Agreement (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 and distribution of an Official Statement in conjunction with the
offer and sale of the Bonds was previously authorized. 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 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 records of the City, and the
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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 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 TERRITORIAL SPRINGS NOTES AND THE SERIES
2006 BONDS.
3.1 The City elects to apply the net proceeds of the Bonds to the optional prepayment
of the Territorial Springs Notes and the Series 2006 Bonds in accordance with their terms.
Following the sale and issuance of the Bonds, the City Clerk, as Registrar of the Territorial
Springs Notes, is directed to cause notice of redemption of the Territorial Springs Notes to be
given to the holders of the Territorial Springs Notes in accordance with the terms of the
Territorial Springs Notes, and to give notice to the Trustee to give notice of redemption to the
holders of the Series 2006 Bonds in accordance with the terms of the Series 2006 Bonds, and to
take all other actions necessary to cause the redemption and prepayment of the Territorial
Springs Notes and the Series 2006 Bonds 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, or any other officers, employees, or agents of the
City authorized to execute certificates, instruments, or other written documents on behalf of the
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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, or any other 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 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 (f) 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.
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Passed and adopted by the city council of the City of Stillwater, Minnesota, this 19th day
of July, 2016.
Mayor
ATT ST:
4g-7 ila?4A/
City Clerk
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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 Tax Increment Revenue
Refunding Bonds (Territorial Springs and The Lofts of Stillwater Projects) Series 2016C.
WITNESS my hand on July 12016.
/06A, .,eu
2,1)M
City Clerk
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