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HomeMy WebLinkAboutR07-City Administrator " " . CC'ITY eF SAN BE~ARDINO CL MEMORANDUQ To THE HONORABLE MAYOR AND COMMON COUNCIL Subject Conmunity Facil i ti es Di stri ct Proposal From JOHN MATZER, JR. City Administrator Date January 18, 1985 Approvsd Date It is recommended that any Council action relating to the proposed Cable Lake Conmunity Facilities District be postponed until the first or second meeting in February in order 'to provide you sufficient time to review the information in this report as well as additional information which will be provided within the next week. At our request, Mr. Tim Sabots staff is preparing an analysis of the Mello-Roos approach as compared to the special assessment approach to financing developer improvements. In addition, Mr. Sabo's staff and Mr. Allen Briggs are reviewing questions which we have proposed relating to the Communities Facilities concept as well as the specific Cable Lake proposal. Their questions along with ours will be forwarded to the developer for a response. The following information is presented to assist you in your review of the proposed Cable Lake Community Facilities District: 1. A chronology of actions taken to-date. (EXHIBIT A) 2. Potential policy issues involved in the adoption of a Community Facilities District, 3. Questions relating to the Mello-Roos Conmunity Facilities Act of 1982 and the Cable Lake Project. (EXHIBIT B) 4. Departmental evaluations of the estimated impact of the proposed Conmunity Facilities District upon their operations. CHRONOLOGY Exhibit "A" provides a chronology of events that have occurred in connection with the proposed Cable Lake Community Facilities District. In summary, on November 5, 1984, Council adopted resolutions of intention to establish a Community Facilities District, to incur bonded indebtedness of $3,500,000 within the proposed Communities Facilities District and setting a public hearing on the proposed district for December 17, 1984. On December 17, 1984, the publ ic hearing was continued until January 21,1985. It is requested that this public hearing be postponed until either February 4 or February 18 in order to provide you adequate time to review the staff information. Mr. Briggs has advised that the public hearing may be continued. POll CY ISSUES A review of the Mello-Roos Community Facilities Act of 1982 and numerous discussions with individuals familiar with the Act and the establishment el"" Oil "HI~~ R'7 '0 " " o o o THE HONORABLE MAYOR AND COMMON COUNCIL January 18, 1985 Page 2 of community facilities districts have helped to identify a number of basic issues which should be considered in making a decision relative to the establishment of a community facilities district. Some of these issues include: o A determination of the advantages to the City of utilizing the Community Facilities District approach as compared to the special assessment approach. The Community Facilities District approach provides a means for spreading the cost of improvements over larger property' holdings capable of absorbing the cost more readily than one developer. The district approach offers a further advantage of providing one funding vehicle for all types of public facilities and for ongoing operation and maintenance of police. fire and recreation services. The special tax provided under the Act offers a means of charging the residents in the district for the increased services which they require. The third advantage is the potential of lower and competitive housing cost as compared to areas where capital improvements and police, fire and recreation services are not funded through the District method. There appears to be a greater advantage to the developer in the use of a Community Facilities District. This is primarily because the District approach does not involve the placement of a lien on the property as does the special assessment approach, and therefore, enables the dev- eloper to obtain more flexible financing. It has also been alleged that lower interest rates can be obtained through the district approach than the special assessment approach. This, however, depends greatly upon the market's assessment of the viability of the project. Under- writers indicated that there is no guarantee that a lower interest rate would be associated with Community Facility District bonds. The Act provides that impact fees or exactions may not be required for facilities provided under the Act. o A basic policy issue is the extent to which the use of a Community Facilities District results in a significant public benefit. One such benefit might be reduced initial housing cost. There is, however, no assurance that the reduction will be passed to the buyer in the form of a lower sales price. Another example of a broad public benefit would involve the construction of public facilities which would serve a wider population such as the bridge. A potential criticism of the use of the Community Facilities District is that it gives a potential competitive advantage to a developer involved in the District which may not have been offered to other developers. Moreover, the estab- lishment of the District could establish a precedent whereby numerous requests might be made to use this technique in other developments. Closely related to the preceding point is the need to determine the viability of the proposed development and its unique characteristics which might set it apart from other developments, and, therefore, warrant the use of a Community Facilities District. Such a determination requires extensive information on the specific type of development proposed, the estimated cost of the units and the extent to which the o '0' I l. rI o C) o THE HONORABLE MAVOR AND COMMON COUNCIL January 18, 1985 page 3 o marketing plan is realistic. Consideration must be given to the feasibility of including in the special tax the cost of police, fire and recreation services and the cost of maintaining the new capital facilities. The proposed Cable Lake District will only provide a special tax to cover the cost of the pUblic improvements. No tax for services is being proposed. The Act states that services provided the District may not supplant existing services but must be in addition to such services. The, City Council could after the District is established initiate proceedings to provide additional authorized facilities or services, change the rate or method of apportionment or propose a new tax and submit the question to the voters. o If a special tax is established to cover the cost of services, the City each year would have to review the special tax needed to be established to support the cost of services for the following year. This would result in considerable uncertainty on the part of the taxpayers in planning for the amount of tax that they would have to pay. It is conceivable that the tax would vary from year to year, and, in some cases, might not even be levied. The taxpayers are further burdened by the fact that the special tax is not integrated into their mortgage payments and, therefore, would be paid over and above such payments. The special tax rate could also change because of a change in development plans. Consideration must be given to the fact that future residents of the District may object to the special tax they have inherited and demand to vote on its continued existence. The Act indicates that a petition signed by 25% or more of registered voters in the District or owners of 25% or more of the territory within the District can be submitted to the legislative body requesting that the specified public service be reduced or terminated or that any existing special tax be reduced or terminated. Although the legislative body has the discretion not to act on the petition, it must, nevertheless, hold a public hearing on the matter. This would mean that on an annual basis, the City Council could be confronted with citizen requests to reduce or terminate a particular service. The Act does not allow reduction or termination of the tax if it will interfere with the retirement of debt. A decision has to be made as to the rate and method of the tax appor- tionment. Considerable flexibility is available. The tax may be X number of dollars per acre for land in large parcels changing to V dollars per lot when it is subdivided into building lots and changing to Z dollars per dwelling unit, bedroom or square foot of residential dwellings, This approach recognizes the various stages of the develop- ment. The Cable Lake project establishes the tax based on unit size. However, since the developer is a land developer and contemplates selling the developed land to builders, considerable time could elapse before units are actually constructed. Therefore. it might be advisable to base the initial tax rate on the number of dollars per acre for land. o o o ~ 'I J l o o o THE HONORABLE MAYOR AND COMMON COUNCIL January 18, 1985 ' Page 4 o It is proposed that the tax for commercial property shall be at the maximum annual rate of $1,000 per acre per $1,000,000 of annual indebtedness. Consideration should be given to requiring the Community Facilities District property value to bond ratio to be not less than 3 or 4 to 1 after installation of the facilities to be financed. The values could be determined based on an MAl appraisal before and after the installation of the facilities. ,This requirement would provide a security against possible failure of the project in that the land could be sold to meet the debt service requirements. Riverside County requires that District property value to bond ratio be not less than four to one after the installation of the facilities and services to be financed. o A major policy issue relates to the steps that would be taken to provide assurances that all prospective buyers of property within the District receive full disclosure regarding the District's special tax. One approach is to have the initial developer and sUccessor~ to the extent possible, distribute to each potential buyer a separate disclosure report identifying the existence and details of the special tax and foreclosure procedures. In addition, the contractual commitment could be recorded as a lien agreement and, therefore, would appear in any title report on property within the Community Facilities District. The mechanics of such a recording still needs to be verified. 'Although, full disclosure laws require that a buyer be informed of taxes and assessments, experience has shown that buyers often lack knowledge and/or understanding of taxes and assessments. Buyers may be extremely unhappy about the discovery of a special tax and the purpose for which it is being levied. In other cases, a buyer who is financially surprised may be unable to pay the tax. This would place the City in a position of having to foreclose on the property. Since the financial reputation of the City goes along with the name of the City on the bonds sold to finance the Community Facilities District it is important that bond issuance be structured to adequately protect the bondholders and the credit capabilities and credit rating of the City through some combinations of credit enhancement such as bond insurance, foreclosure covenants, special reserve funds or deposits and/or a contractual commitment by the developer and successor to pay the taxes as necessary during at least the fi.rst five years of the bond life. In the Cable Lake case, such enhancements are particularly important since there may be a lag between the time that the initial developer sells the land and development eventually occurs. Many uncertainties associated with the Community Facilities District as a financing plan create a need for a detailed fiscal review. Such a review should evaluate the fiscal risk and impact on City borrowing, economic feasibility, City's obligation on a default and related issues. Proponents of a Community Facilities District should be required to provide a current audited financial statement and other necessary materials o o J." ,., o o o o THE HONORABLE MAYOR AND COMMON COUNCIL January 18, 1985 Page 5 to assist in the fiscal review which preferably should be performed by a financial consultant experienced in such projects. The cost of such a consultant should be paid by the proponent. A decision must be made as to who selects the bond counsel, underwriter, financial consultant, appraiser and other experts required to implement the District. A strong case can be made for selection by the City. Consideration should also be given to requiring the petitioner to pay a fee to compensate the City for all costs incurred in conducting the proceedings. The fee should be paid prior to initiation of the proceedings. The above are some of the important policy issues identified at this point. Responses to the questions in Exhibit "B" will undoubtedly raise other critical policy issues. o ~.: I I m o o o o DEPARTMENTAL EVALUATION OF ESTIMATED IMPACT OF PROPOSED COMMUNITY FACILITIES DISTRICT FIRE DEPARTMENT: The department has indicated that the Cable Lakes Project will not have a major impact on the Fire Department. Fire Station #5 at 1640 Kendall Drive will provide initial fire and medical aid response within the prescribed response time. The Chief indicated that any increase of 560 dwelling units and 1,500 population will affect the overall response of the Fire Department but will not require additional fire stations, equip- ment or personnel. PUBLIC SERVICES DEPARTMENT: The department was unable to estimate the maintenance cost until information is obtained on the miles of street proposed in the development as well as other improvements such as street trees, sewer, etc. The Director estimated the service cost per mile for street sweeping to be $13.00. PUBLIC WORKS DEPARTMENT: The department raised questions on the length, height and type of the proposed storm drain improvement. The cost is ' based on standards set forth by the County Flood Control District. There was concern that costs may have been underestimated as the flooding potential is extensive in the area, and inadequate drainage will cause future maintenance problems. An additional improvement identified by the Director is a bridge that crosses over Cable Creek, replacing the present 2-lane wooden bridge with a 4-lane reinforced concrete box. Based on the estimated travel trips generated by the proposed residential and commercial development, the cost is $85,000 (26% of the total estimated cost of $327,000). No plan for street lights is proposed. PARKSh RECREATION & COMMUNITY SERVICES DEPARTMENT: The department pointed out t at park services are now being designed for the Al Guhin Park which is approximately 1/4 to 1/2 mile away from the Cable Lakes Development project. It was suggested that any reference to park services within the development should not deter from the ongoing development of the Al Guhin Park. The Director recommended that park construction fees should still apply to the Cable Lakes Development Project as their proposal does not address the various park and recreation services which their residents will eventually demand. A clarification of the term "Park Landscape" was requested. It was not clear to whether the terms refer to parkways or a full service park. Questions were also raised as to the number of 'tennis courts and whether or not they were lighted. Information on the kinds of recreation buildings being proposed was requested. The department was unable to determine the maintenance and operation cost because the type of park and recreation services were not clearly defined. - . o o o ",. u o POLICE DEPARTMENT: The department recommended three additional sworn officers and one marked police unit in order to effectively address the increased population density proposed in the plan. The Chief recommended the manpower distribution to be two (2) uniformed officers to Field Operations and one (1) investigator to Investigations to provide support services. The cost breakdown is as follows: A. Patrolman $24,024 + $9,609 (bene's) x 2 = $ B. Investigator, $32,388 + $12,955 (bene's) x 1= C. Ancillary Equipment, $773 x 3 officers = D. Fully equipped marked police unit = TOTAL JM/md 67,266 45,343 2,319 13,500 --------- --------- $ 128,428 o Il"." Jl o o o EXHIBIT "A" CHRONOLOGY OF PROPOSED COMMUNITY FACILITIES DISTRICT July, 1984 7-13-84 9- 13-84 10-2-84 11-5-84 11-8-84 Cable Lake Associates submitted to the Planning Department the proposal to change the zoning classification from MHP Mobile Home Park to PRD-7U Planned Residential Development (Change of Zone No. 84-14), subdivide approximately 20 acres of land into 120 residential lots (Tentative Tract No. 12756), and develop 120 single family units ranging from 800-1,200 square feet in size on substandard lots of approximately 4,000 square feet (Conditional Use Permit No. 84-37). The Environmental Review Committee, during their preliminary review, directed the developer to explore the possibility of providing a second dedicated means of access, as required under SBMC Chapter 18.40.160. This requirement cannot be waived by the Commission or the Mayor and Common Council since the property is located inside the high fire hazard area. By memo dated January 4, 1985, Fire Chief Newcombe reaffirmed the necessity of the designation as experience has shown that wildland fires are a threat to this area. The Environmental Review Committee determined that a focused EIR is required, because the developer's proposed second means of access did not meet the intent of the ordinance, whereas the applicant was proposing one dedicated and one undedicated means of access, essentially meeting at the same point for in- gress and egress. The Developer's engineer, J. E. Bonadiman, appealed the deter- mination of the Environmental Review Committee to the Planning Commission. The Planning Commission upheld the determination of the Environ- mental Review Committee. J. E. Bonadiman appealed the determination of the Planning Commission to the Mayor and Council. Adopted Resolution of Intention (84-463) to establish a Community Facilities District (CFD). Adopted Resolution of Intention (84-464) to incur bonded in- debtedness of $3,500,000 within the proposed Community Facil- ities District (CDF). Established public hearing on the proposed CFD on December 17, 1984. The Mayor and Council reversed the decision of the Planning Commission and the Environmental Review Committee, and in- 1. Minimum square footage is 1,000 2. Minimum single-family residential lot is 7200 square feet. o I H..I' " o o o CHRONOLOGY OF PROPOSED COMMUNITY FACILITIES DISTRICT Page 2 12-17-84 12-18-84 1-21-85 1-22-85 NOTE: structed staff to prepare statements of overridfng effect. (To be scheduled for February 4, 1985 Councfl Agenda for approval). Council continued Public Hearing to January 21, 1985. Change of Zone 84-14 was scheduled before the Planning Com- mission, but was continued to January 22, 1985 in order to receive an opinion from the City Attorney's office relative to the issue of density bonuses. The Commission felt that the zone change to 7 units per acre is already dense enough for the area, and want to preclude density bonuses (State requfres automatic approval) be granted to future home builders if providing affordable housing by meeting certain criterfa. Request to continue Publfc Hearing by Cfty Administrator to February 18, 1985 (or earl fer). Change of Zone No. 84-14 fs scheduled on the Planning Commission's agenda. Planning staff has recommended approval, because it is fn conformity to the General Plan. Tentative Tract No. 12756 and C.U.P. No. 84-37 will not be considered at the Plannfng Commission's January 22, 1985 meeting. It will be scheduled on February 5, 1985 at the next regular meeting. o I ~ t I ; , I j; o o EXHIBIT "B" o MELLO-ROOS GENERAL QUESTIONS o What are the specific advantages and disadvantages to the City of utilizing the Mello-Roos Conmunity Facilities Act of 1982 vs. the special assessement and/or other approaches to developer financing of public improvements. Are the special assessment proceedings more time-consuming and cumbersome than those for community facilities districts. What specific benefits should the City require, such as substantial reduced housing cost, prior to agreeing to the use of a Community Facilities District to assist a private developer to enhance the value of vacant land? How can the specific benefits be quantified and guaranteed? Is there double taxation if City services such as Police, Fire and Recreation are included in the special tax levy? What criteria should be used in determining whether services should be included along with capital improvements in a Community Facilities District? Is there evidence that the interest rate on Community Facilities District bonds is lower than that of special assessment bonds? What credit enhancements should the City use to minimize exposure to liability in case of default of the Community Facilities bonds? Will bond insurance be provided? Doesn't the special provision in the Act providing for early foreclosure put the City in the unenviable position of foreclosing on homeowners in the District much earlier than normally would be the case? Approximately 7 years are now required to collect delinquencies under the normal procedures for the collection of delinquent property taxes. Early foreclosures in the District could be considered as unequal treatment for homeowners. The Mountain View School District has a provision to initiate foreclosure proceedings within 90 days. Will the City want to initiate special foreclosure procedures for the protection of bond holders? o o o o o o o o What kinds of disclosure guarantees will the City obtain to be sure that every current and future homeowner 'would be fully apprised of the current potential assessments,and any special foreclosure proceedings in effect? What guarantee is there that future homeowners will read the various recording notices that might be employed? o 11l.L... H_ o o o o What has been the experience in recording notice of this special tax on each parcel of property on which such tax is levied?' Will it appear on a title search? Should a bond reserve be established and how large should it be? Must the legislative body adopt a resolution of intention to establish the District within 40 days after receipt of a petition or can it reject it until further study is done? Why shouldn't the initial tax be based on the number of dollars per acre for land in large parcels or the number of dollars per lot when sub-divided rather than the number of dollars per dwelling unit, bedroom or square foot of residential dwelling being proposed. Doesn't a tax on the land assure payment of the special tax during the period while the land is being developed? How long will the validation proceedings in Superior Court take? Who bears the cost? Will it and should it be reimbursed through the bond sale? Are not unpopulated areas given a competitive edge for development under the Mello-Roos Community Facilities District concept. What assurance is there that the savings initiated by the use of the Act would be passed on to the eventual purchaser of the developed property within the City? Shouldn't the developer be required to identify when construction of the units will begin to coincide with the bond sale? What criteria should be used to determine the extent to which a proposed development represents a significant public benefit to the community at large? What is the extent of the fiscal risk to the City in terms of impact on City borrowing, economic feasibility, City obligations on a default and the City's ability to sell issues in the competing bond market? Will the developer pay a fee to the City for all costs incurred in conducting the proceedings relating to the establishment of the Communities Facilities District? When should the fee be paid? What is the estimated cost of conducting the proceedings? What is involved in the foreclosure proceedings if a special tax is not paid? Who handles the proceedings? How soon are they initiated and how long do they take to complete? As the developer or successors begin to market units, will comparable sales data showing prices of homes within the 'District and similar homes in the area served by facilities financed through conventional means be provided to the City along with an estimate of what sales prices would have been if conventional financing was used? o o o o o o o o o o o o o o HI.I.;-_ I." o o o o When should an authorized agency seriously consider the use of Mello Roos? When the plans for the development are in an advanced stage or when it is still a speculative package? Who will administer the special tax? How much staff time will be required? What are the estimated administrative costs? What is the potential marketability of the bonds? What interest rates can be anticipated? What do the rating houses and underwriters look for in evaluating such bonds? Will the issuance of such bonds have a significant impact on the area's overlapping debt? If a tax for services is not implemented at the time of the formation of the District, can it be added later? Is a 2/3 vote required to implement the tax? Should permit, appraisal, engineering, attorney, financial consultant fees, etc. be financed under the bond issue and special tax? While this type of financing is legal, it is not encouraged by some jurisdictions such as Oceanside which requires that the fee be paid by the developer. Doesn't the financing of sUch fees and charges in a Communities Facilities District present an unfair competitive advantage over other developers whose property is not suited to a Community Facilities District approach? Can the City Council after a public hearing terminate or reduce the special tax for services without a popular vote? What administrative service charge will the County Tax Collector charge and will it be computed into the special tax? Can annual City administrative costs associated with the special tax be included in the tax? What mechanisms can be used to prevent the final cost of constructing facilities from exceeding its estimates? o o o o o o o Lel'"IL '0' o o o CABLE LAKE SPECIFIC QUESTIONS 1. What is the marketability of the homes in the proposed area? Has a copy of the market survey been submitted? What is the economic feasibility of the project? 2. How would the effects of environmental factors such as fire, wind and flood affect the cost of developing homes in the area? 3. Why shouldn't the cost of expenses incurred in the fonmation of a, District such as attorney, engineer, appraisal, financial consultant and other fees be reimbursed by the developer rather than financed over the life of the bonds? Is it good management to finance these costs over such a long period? 4. In view of the fact that the City's Housing Element indicates that it has more than its share of affordable housing, is the current plan for 120 affordable homes the appropriate kind of development for the City which should be assisted by a Community Facilities District? 5. How many miles of streets, sewers, curbs, gutter, etc. will be inclu- ded in the project and will they be dedicated in phases? Who will assume the maintenance cost prior to dedication? What will be the impact of a requirement to provide a secondary access to the project if it involves other property owners currently outside of the proposed Community Facilities District? 6. What is the appraised value of the land before and after the public facilities are installed? Will the developer be willing to incur the costs of such appraisals? 7. Is the levy based upon the square footage of homes the best approach? Should consideration be given to establishing an initial rate based upon the number of acres or the number of lots when subdivided? 8. Has the developer supplied a current audited financial statement? 9. What guarantee can the developer provide that the homes in the de- velopment would be priced lower than comparable homes in other areas of the City? 10. What is meant by "park landscape" to be provided as part of the im- provement plan? Does this mean parkways or full service parks? How many tennis courts are being provided and are they lighted? What kinds of recreation buildings are proposed? 11. What are the specific proposed Cable Creek Channel improvements and their estimated cost? Illll' Jr '0. o o o CABLE LAKE SPECIFIC QUESTIONS - Continued Page 2 12. How final are the development plans? Is the proposed development realistic and what are the possibilities of it being changed? How many of each type of unit are being proposed? Are full development plans available? 13. Have proposed financing agreements been submitted and reviewed? 14. What potential litigation could be initiated before, during and after the formation of the District and what would be its potential effect on the City? 15. How firm are the estimated improvement costs? Is the estimate of $2,642,000 still valid? 16. When will construction of the improvements commence? What is the estimated build out schedule? 17. When will construction of the residential and commercial units conmence? 18. Has a fee been paid to cover the cost of conducting the proceedings? 19. Are the developers and builders willing to make a contractual commit- ment to pay taxes during the first four or five years of the bond 1 i fe? 20. Will the costs of the sewer capacity rights be included in the bond issue? Have the costs been incurred? Is it a good practice to in- clude costs already incurred in a bond issue? 21. What equity are the developers putting into the project? 22. Has any property been sold? 23. What is the likelihood of a change in the proposed development or in the allocation of unit types from those currently being proposed? If changes occur, how would the bond payoff be affected? 24. How was the special tax for commercial properties of $1.000 per acre per $1,000,000 of annual indebtedness determined? 25. What is the estimated term of the bonds? 26. What is the estimated ultimate market value of the project? IlU.U U '0' o (j ~' ,:) CABLE LAKE SPECIFIC QUESTIONS - Continued Page 3 27. How will the bond proceeds be distributed (developer, bond fund, bond reserve fund, etc.)? 28. Why was the special tax formula for the residential units related to the total debt rather than a maximum annual rate per "x" dollars of annual debt service? 29. The proposed residential homes are aimed at first-time or low-income home buyers who have limited income. Since the special levy will not be considered as part of the total financing, it would require suffi- cient prior notice and foreknowledge of the additional tax so as to minimize future foreclosure and complaints from citizens. Again, procedures for disclosure have to be discussed and assured by the owner? 30. A secondary access is required for the proposed development since it is located within a "High Fire Hazard Zone". The proposed road requires a right-of-way through the County Flood Control District. There is no indication that such an easement has been obtained. There is no indi- cation that an alternate route for the secondary access can be provided. 31. If the change of zone is not successful, will the development of mobile home lots be able to generate sufficient tax to payoff the bond? The City wants to have a reasonable assu.rance that the proposed development is realistic. Otherwise, the next owner (home builder) will be stuck with a piece of land with a heavy debt. ..... . QITY OF SAN BERQARDINO a.. MEMORANDUrO To Mayor and Conmon Council Supplemental Information Regarding Community Facilities District Proposal From John Matzer, Jr. City Administrator February 7, 1985 Subject Date Approvsd M~ , Date The following supplemental information is presented to assist you in your review of the proposed Cable Lake Community Facilities District. This information supplements the information provided in the January 18, 1985 memorandum to you and completes the 'staff analysis. The following information is included: 1. A copy of general questions and answers relating to the Mello-Roos Community Facilities Act prepared by Mr. Timothy Sabo's Office (Exhibit A). This information provides considerable insight into the implications of establishing a District. 2. A,list of suggested sample pOlicies relatin~ to the formation of Community Facilities Districts. (Exhibit B). 3. A copy of specific questions presented to the Cable Lake developer and information prepared by the developer in response to the ques- tions. (Exhibit C). 4. A copy of a Community Facilities District proposal memorandum, dated January 18, 1985. (Exhibit D). RECOr+1ENDATION Before you elect to proceed with the formation of a 'Community Facilities Dis- trict, it is recommended that you consider the adoption of general policy guidelines to be followed by proponents requesting the formation of a Commu- nity Facilities District. The guidelines would indicate the City's position regarding crucial ,aspects of the Community Facilities District process. Con- sideration should be given to adopting such guidelines prior to the hOlding of the public hearing for the Cable Lakes project that has been postponed to February 18, 1985. Exhibit B provides some examples of sample policies which could be adopted. These policies are by no means meant to be all encompassing or complete. They were prepared on the basis of the policy issues raised in the December 18, 1984, memorandum (Exhibit D) and as a result of the responses to questions relating to the Mello-Roos Facility Act and the specific Cable Lakes Project (Exhibit A & C). A review of the attached information will no doubt generate a need for other policies. CITY Oil TH.:M~ 11.11_; d I "0 o o o Mayor and Common Council February 7. 1985 Page 2 The Cable Lakes developer has indicated that although they have not responded to all of the questions related to the project. they will provide all infor- mation required by the City after the formation of the Community Facilities District and prior to the actual sale of the bonds. They are encouraging the City to create the District and then proceed to work out the necessary details. Caution is recommended in adopting this approach since it is felt that once the City has established the District. it will be very difficult to abort the effort. Basic policy issues should be resolved prior to any agreement to establish the District. The analysis of the Mello-Roos Community Facilities Act indicates that it is only advantageous to the City to employ the Act when there appears to be no other viable alternative for financing the construction and installation of public improvements and/or providing a source for funding various services within a newly developed area. In Exhibit A, Mr. Sabo states lilt would be advantageous to the City to work with a developer in the early stages of pro- ject implementation and formulation so that alternative financing devices can be arranged and adequately explored so that neither the City nor a developer confront a situation where the development and planning 'goals of the City are compromised merely for the sake of expediency and the accommodation of a par- ticular developer. II Mr. Alex Bowie. the attorney representing Cable Lake, has indicated the developer's willingness to use other financing devices such as an assessment district. The staff and Mr. Sabo are available to meet with you to discuss the attached information and to provide any additional information you may require. JM/djn