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RES-8884 Policy Guidelines of Public Financing MechanismsRESOLUTION NO. 8884 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ORANGE ESTABLISHING POLICY GUIDELINES REGULATING THE USE OF PUBLIC FINANCING MECHANISMS TO FINANCE PUBLIC FACILITIES. WHEREAS, the City Council of the City of Orange has previously approved requirements for financing public improvements by the use of the Improvement Bond Act of 1915, with the adoption of Resolution No, 6376 on July 9,1985; and WHEREAS, Government Code Section 53312.7 requires that any local agency desiring to initiate proceedings to establish a Cornmunity Facilities District ("CFD") under the Mello-Roos Community Facilities Act of 1982 (the "Act") must first adopt a local policy concerning the use of the Act, setting forth a statement of priority of the kinds of public facilities to be funded through CFDs; requirements for credit quality required for bonds issued by CFDs; procedures and steps to ensure proper notice to property owners of any CFD special tax obligation; criteria for determining the maximum amount of special tax; and standards and assumptions for real property appraisals; and WHEREAS, the City Council desires to adopt the Policy Guidelines Regulating the Use of Public Financing Mechanisms to Finance Public Facilities (the " Policy Guidelines") in the form attached hereto as Exhibit "A" to serve as the City's general guide for evaluating the merits of assisting in the financing of public facilities within the jurisdiction of the City of Orange.WHEREAS, the Policy Guidelines are intended to meet the requirements of Government Code Section 53312,7; and WHEREAS, the Public Financing District Review Committee, chaired by the City Manager, has recommended the approval of the Policy Guidelines.NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Orange, as follows:1. The existing requirements for Council approval of financing of public improvements under the Improvement Bond Act of 1915, as established by Resolution No, 6376, are hereby repealed.2. The Policy Guidelines in the form attached hereto as Exhibit "A" are hereby adopted to serve as the City's general guide for evaluating the merits of assisting in the financing of public facilities within the jurisdiction the City of ADOPTED this ....24.thday of Februarv, 1998. ATTEST: M"'AAAA~J f!car/AA-;;(-Cassandra J, Cathc , City Clerk of the of Orange I hereby certify that the foregoing Resolution was duly and regularly adopted by the City Council of the City of Orange at a regular meeting thereof held on the 24Th day of February , 1998, by the following vote:AYES: COUNCIL MEMBERS: MURPHY. SLATER, COONTZ. SPURGEON,ALVAREZ NOES: COUNCIL MEMBERS: NONE ABSENT: COUNCIL MEMBERS: NONE ABSTAIN: COUNCIL MEMBERS: NONE C/. l/.lAAA~d flM/Ad Cassandra 1. Cath , City Clerk of the City of Orange Filename: 02248#2b RESO NO, 8884 2 DPWE-dr EXHIBIT "A' CITY OF ORANGE POLICY GUIDELINES REGULATING THE USE OF PUBLIC FINANCING MECHANISMS TO FINANCE PUBLIC FACILITIES Municipal Improvement Act of 1913 and Improvement Bond Act of 1915 Landscaping and Lighting Act of 1972 Mello Roos Community Facilities Act of 1982 Benefit Assessment Act of 1982 February, 1998 TABLE OF CONTENTS SECTION PAGE I.Purpose 3 II.Definitions 4 III.Public Financing Mechanisms, Eligible, Public Facilities and Priorities 5 IV. General Policies 8 V. Fee and Charge Schedule I3 VI. Procedures 14 V:L Application Process 15 VIII. Criteria for Appraisals 16 IX. Requirements for Tax Allocation Fonnulas 17 X. Policy on Joint Financing Districts 19 2 CITY OF ORANGE POLICY GUIDELINES REGULATING THE USE OF PUBLIC FINANCING MECHANISMS TO FINANCE PUBLIC IMPROVEMENTS I, PURPOSE This policy document is intended to serve as the City's general guide for evaluating the merits of assisting in the financing of project-related public facilities in ~.a si~ificant ~ benefit has ~ established. These project-related public facilities may be developer or City initiated.The public financing mechanisms subject to this policy document include the: I)Mello Roos Community Facilities Act of 1982, 2) Benefit Assessment Act of 1982,3) Municipal Improvement Act of 1913 and the Improvement Bond Act of 1915, and 4) Landscaping and Lighting Act of 1972.The City will exercise a fiscally conservative approach to the use of public financing assistance in order to maintain the City's good financial standing,minimize any financing risk to the City and to ensure public benefit. The individual and cumulative financial impact of project-related public financing assistance upon the City's credit and any contingent liability will be carefully evaluated. The City's fundamental reason for assisting the financing of project-related public facilities is to ensure that: I) growth within the City occurs in a comprehensive, organized way consistent with the City's General Plan, and 2)that existing City residents don't have to pay for new growth which does not directly benefit them. The purpose of public financing is not intended to provide the development industry with the opportunity to achieve excessive profits at the expense of future residents.It is the City's desire to make these Policy Guidelines available to the community at large so that: I) the City's policies are clearly communicated, 2) the developer can make reasonable and realistic business decisions based upon their understanding of the City's willingness to assist in a public financing program,and 3) the public benefit responsibility is clearly identified.The City shall make the determination as to which public financing mechanism, if any, shall be used to assist in the construction of a public facility. The City may confer with the applicant to learn of any unique district requirements, such as facilities serving the regional area or long term development phasing, prior making any final determination. The City prefers to form an Assessment District over a Community Facilities District whenever possible, Where the City forms any district (i.e" Community Facilities District, Assessment District or Landscape & Lighting District), the full cost of the district shall be established and set in place at the time the district is formed, II. DEFINITIONS Unless the context otherwise requires, the terms employed III the following policies shall have the meanings specified below: Bonds" means bonds authorized and issued under any of the public financing mechanisms described herein. City" means the City of Orange. District" means a community facilities district formed under the Mello- Roos Community Facilities Act of 1982 (CFD) or an assessment district formed under theImprover.1ent Bond Act of 1915, the Municipal Improvement Act of 1913 A.D.), the Benefit Assessment Act of 1982 or the Landscape and Lighting Act of 1972 ( LMD).Public Facilities" means improvements authorized to be constructed or acquired under any of the public financing mechanisms described herein.Value" or "Fair Market Value" means the amount of cash or its equivalent which property would bring if exposed for sale in the open market under conditions in which neither buyer nor seller could take advantage of a difficulty or the other and both have knowledge of all of the uses and purposes to which the property is adapted and for which it is capable of being used and of the enforceable restrictions upon uses and purposes,Act" means Mello-Roos Community Facilities Act of 1982 or Improvement Bond Act of 1915 or Municipal Improvement Act of 1913 or the Benefit Assessment Act of 1982 or the Landscape and Lighting Act of HI. PUBLIC FINANCING MECHANISMS AND ELIGffiLE PUBLIC F ACTLlTIES AND PRTORITIES* The public financing mechanisms subject to this policy document include the: 1) Municipal Improvement Act of 1913 and the Improvement Bond Act of 1915 2) Landscaping and Lighting Act of 1972, as described and regulated by the State of California. 3) Mello Roos Community Facilities Act of 1982 4) Benefit Assessment Act of 1982 The general types of facilities currently eligible to be financed are listed as follows for each public financing mechanism: A. Municipal Improvement Act of 1913 and Improvement Bond Act of 1915 I. Arterial Streets 2. Trunk Sewer Mains 3, Master Area Storm Drains 4. Water Transmission Mains 5. Water, Sewer or Drainage Pumping Plants 6. Non-Tract related Street Lighting 7. Traffic Signals and Safety Lighting 8. Grading necessary to accommodate "Backbone" Infrastructure;including Retaining Walls, Drainage Facilities and Stabilization of Land 9. Government Facilities of specific benefit to the district 10. Parks II. Omamental Vegetation Installation B. Landscaping and Lighting Act of 1972 I. The installation or planting of landscaping.2. The installation or construction of statuary, fountains, and other omamental structures and facilities,3, The installation or construction of public lighting facilities,including, but not limited to, traffic signals.4. The installation or construction of any facilities which are appurtenant to any of the foregoing or which are necessary or convenient for the maintenance or servicing thereof, including, but not limited to, grading, clearing, removal of debris, the installation or construction of curbs, gutters, walls, sidewalks, or paving, or water, irrigation, drainage, or electrical facilities.The types of public facilities eligible to be fm.nced shall be governed by the applicable state law,The City will make the fmal determination as to any facility's eligibility for fmancing, 5. The installation of park or recreational improvements, including, but not limited to, all of the following: a. Land preparation, such as grading, leveling, cutting and filling, sod, landscaping, irrigation systems, sidewalks, and drainage. b. Lights, playground equipment, play courts, and public restrooms. 6. The maintenance or servicing, or both, of any of the foregoing. 7. The acquisition of land for park, recreational, or open- space purposes.C. Mello Roos Community Facilities Act of 1982 I. Local park, recreation, parkway open- space facilities 2. Elementary and Secondary School sites and structures 3. Libraries 4. Child Care Facilities 5. Utilities (Public Utilities, including flood and storm drainage)6. Cultural Facilities 7. Police and Fire Protection Services 8. Services with respect to removal or remedial action of hazardous substances.9. In combination with one or more of the foregoing, any of the facilities listed under A. above.10. Statutory development fees can n2t be funded.D. Benefit Assessment Act of 1982 Provides for the financing of ongoing maintenance and operation costs of: 1. Drainage 2. Flood Control 3. Street Lighting 4. Street Improvements PRIORITIES It is the City's view that a comprehensive policy toward mitigating the service impacts of growth is the best way to foster cooperation in allocating available debt capacity.Therefore, it is the City's intent to work closely with local school districts (and any other agency with District creating authority) to ensure that the maximum tax rate " cap" (see section IV. B.) is not exceeded and home owners In order to ensure that public financing is used in a comprehensive, organized way consistent with the City's General Plan and the Policies outlined in Section IV, the aforementioned eligible public facilities are prioritized below. It is important to note that tne City will not use public financing for normal ''tract'' improvements typically built/installed by the developer, i.e., local streets, sidewalks, etc. Also, the City will not use public financing to fund public services. Accordingly the following types of public facilities shall be given priority: 1" Priority- Facilities needed to serve a community plan area that is currently deficient in off-site infrastructure needed to develop the area as planned; that is:backbone" infrastructure to support already approved community plan areas.2nd Priority- Other public facilities for which there is a clearly demonstrated public benefit.3'd Priority- Other public facilities permitted by the Acts.Reserving the right to make exceptions when circumstances warrant, the City establishes these priorities for use of the Acts in the context of new development (the City is consciously establishing no priority for the use of the Acts in tile case of populated areas and registered-voter elections). IV. GENERAL POLICIES A. The City may allow the financing of public improvements under the provisions of tIlis policy where the public facilities represent, in the City's opinion, a si~ificant ~ benefit not only to the prospective residents of the development, but incidentally to tile entire community. B. The projected ad valorem property taxes, special taxes, and other direct and overlapping debt for tile proposed development project (including projected benefit assessments, levies for authorized but unissued debt and any other anticipated municipal charges which may be included on a property owner's annual tax bill), including the proposed maximum special tax or annual assessment, may not exceed a maximum tax rate of two percent (2.0%) of the anticipated assessed value of ~ach improved parcel ("final use") upon completion of the private and public improvements. Property will be considered in its final use when a final map for single family residential use has been recorded or a final map or parcel map for commercial, industrial, multi-family use has been recorded. The City retains the right to withhold public financing if it determines that such financing is detrimental to its credit rating or to the issuance of other City-planned, land-secured debt.Exceptions may be granted for commercial, industrial and mixed use development projects.NOTE: The total maximum tax rate applies only to public financing debt actually passed along to the " final use" parcel.C. The City will issue assessment and/or community facilities district bonds only if it is assured that the proposed financing is solidly structured and has strong marketability. The value of the property which would be subject to the special tax or assessment lien to pay debt service on tile bonds, after the installation of the improvements to be financed, must exceed by at least three times, the principal amount of bonds to be sold. The value of the real property shall be determined by an M.A.I. appraisal, performed by an appraiser selected by or approved by the City.D. The proposed development project must be consistent with the City's General Plan. Projects shall be at the stage where all criteria of this policy can be adequately assessed. Developments proposed for inclusion in a district shall have already received environmental review and shall have already received legislative approvals such as zoning, master plans or specific plans, tentative maps and development agreements, whichever applies. The City Council may approve a district that includes some lands without legislative approvals if the improvement to be constructed is consistent with the general plan and if the City Council finds the improvement is required in the E. Facilities which are, upon completion, owned, operated or maintained by public agencies shall be considered public facilities. Limited exceptions will be made for certain facilities to be owned, operated or maintained by a public utility company. F. The City shall select and solely direct the work of the bond counsel, underwriter, appraiser, assessment engineer, financial advisor and such other professionals and consultants it deems necessary and appropriate in accordance with City policy. All consultants shall comply with tile regulations of the Fair Political Practices Commission and Section 87100 of the California Government Code. G. Improvements shall be constructed and/or acquired, and bonds shall be issued, in strict accordance with the district enabling legislation. H. The City will consider the apportionment of assessments or special taxes to those properties found to receive special benefits by the assessment engineer or special tax consultant and with limited input from the proponent of the development project. I. The proponents of the district must demonstrate to the satisfaction of the City Council that interim financing or otller means is available to meet all assessment or special tax obligations between the time the district is formed and the payoff of the bonds or their assumption by the purchasers of the final use" parcels within the proposed development. As part of tIlis review, the City Council may also consider any indebtedness presently existing against the properties to be assessed. The district proponents must bring all property tax bills current and agree to keep them current prior to confirmation of the district. 1. A fiscal feasibility report shall be required if forty percent (40%) or more of the land witllin a district is substantially undeveloped. The report shall be prepared by or at the direction of the City. All costs for preparing this report shall be borne by the applicant/developer. An estimate of the report cost will be made prior to initiating the study and the applicant/developer shall deposit the full estimated cost prior to starting the report and shall pay any additional costs as and when required. K. All statements and materials related to the sale of Special Assessment or Community Facilities District Bonds shall emphasize and state tIlat neither the faith, credit nor tile taxing power of the City is pledged to security or repayment of tile Bonds. The sole source of revenues to repay such bonds shall be tile special taxes, annual assessments or funds derived from foreclosure proceedings. 1. As a part of the structuring of the financing for the district, an adequate reserve fund shall be funded from the proceeds of each series of bonds to cover any potential defaults. The amount of the reserve fund shall be determined by the City with the advice of the financial advisor and shall 9 equal the lesser of ten percent (10%) of the original principal amount of the bonds, maximum annual debt service or one hundred twenty-five percent 125%) ofaverage annual debt service.M. Additional credit enhancement in the form of a Letter of Credit will be required on projects if anyone property owner will be responsible for payment of 20% or more of tile total annual special tax or special assessment to be levied. The Letter of Credit is to have a term of one year, subject to annual renewal and to be in the amount equivalent to the gross debt service on tile bonds allocable to the person's property for tile current fiscal year and the succeeding fiscal year. The amount of tile letter of credit will be proportionally reduced as the property owner sells portions of his or her property and will terminate when tIleir property holding has an annual special tax or special assessment liability below 20%. New property owners responsible for 20% or more of the total annual special tax or assessment will be required to provide a substitute Letter of Credit under the same terms and conditions as described herein.N. It is the policy of the City Council in approving basic legislative authorization for developments such as master plans for planned communities, to give such approvals as a part odhe City's on- going planning processes. That is, tile City reserves the right to modify the approvals in the future as they determine the public interest may require. Such approvals when given are subject to a condition that the construction of any part of a development does not vest any rights to complete other portions of the development. Construction of public improvements pursuant to a Community Facilities District or assessment district on undeveloped land shall not vest any rights to future legislative approvals for the property to be assessed or to any particular level, type or intensity of use. Proponents of a district shall include an acknowledgment of this policy as a part of their petition and shall expressly waive on their behalf and on behalf of their successors and assigns any cause of action based on the case of Furv v.County of Sacramento which might be applicable to the properties to be taxed or assessed.O. The principal purpose for the City Council's approval of district financing in regard to Arterial Highway construction is to extend or complete the City's circulation systems. The City Council in that regard will not favor a proposed district which contemplates tile construction of a portion of an arterial street without extending it in a logical way to connect to the City' s or an adjacent jurisdiction's existing circulation system. The City may require tIlat proponents of a district presenting a petition expand the area to be included within a proposed district as may be necessary to complete such circulation links.P. (I) District proponents shall be responsible for compliance with all applicable federal and state statutory disclosure requirements in transactions with purchasers of properties within the district. District proponents shall provide full disclosure to all prospective, and actual, buyers of witllin the District) of the District's assessment/special tax levy. The District proponent shall submit a full disclosure program for the City's approval prior to the sale of the project's first lot. In advertising the price of the housing tile advertised amount shall include a statement tIlat the property is subject to assessments and/or special tax levies. NOTE: Regarding Mello-Roos Districts, the City Council may require proponents of tile district to discharge the district bonds applicable to tIleir property prior to tile sale of individual lots, or the City Council may approve a pass through of the bond obligation to a prospective purchaser. The City Council will make tIlis determination at tIleir sole discretion based upon public benefit.2) District proponents shall also assist the City in complying with Rule l5c2-l2 promulgated by the Securities and Exchange Commission by cooperation in initial and continuing disclosure as appropriate.Q. The City Council adopts the requirements of Section 53345.8 of the Mello-Roos Community Facilities Act of 1982 as sufficient minimum standards for the credit quality of any bonds issued pursuant to that Act.R. The City in its discretion may require, and may employ a consultant for the purpose of conducting a market absorption study. The study, if required,shall include an estimate of the total number of units, land uses and rate of absorption, and will be used as a basis for verification that sufficient revenues can be generated, and to determine if the financing of the infrastructure and public facilities is appropriate given tile projected level and pace of development. In tile case of a phased development, land value appraisal should include the developed land value assuming the infrastructure to be included in the current financing is completed. However, land values for remaining future phases of the development should not assume future infrastructure is completed. The study will also be provided to tile appraiser for use in the appraisal process.S. All costs incurred by the City prior to formation of the district, including but not limited to consultant costs (e.g., legal counsel, engineer firms, appraisers,special tax consultants, market absorption consultants, financial advisors),City staff and administrative costs and related expenses, cost of providing notices, printing and publication costs, and all expenses directly or indirectly relating to these items, shall be reimbursed to the City by the applicant/developer prior to formation. Reimbursement shall be facilitated by advance deposit increments in accordance with a required funding and reimbursement agreement between the City and the applicant/ developer. The deposit must be in place before any work is initiated by consultants on City staff.In the event that the district is not formed due to City disapproval or due to applicant/developer abandonment, or the district is formed and bonds are not issued for any reason, the City will refund to applicant/ developer remaining unexpended and unobligated portion of advance deposits posted with tile City, subject to City's prior and full reimbursement of all its direct and indirect costs. The City shall be entitled to pay any refund to the applicant/developer listed on the application form, irrespective of any changes in tile ownership or composition of applicant/developer. T. The City, in conjunction with its financial advisors, shall determine whether the aggregate cost of public improvements and permitted indirect costs, allowable under statute, shall equal an amount which renders formation of a district, both economically cost-effective and efficient. The size of the bond issue, as determined by the City and its consultants, shall meet industry standards with respect to marketability. The minimum size of a Community Facilities District bond issue shall be approximately $3.0 - $3.5 M. 12 V. FEE SCHEDULE The district proponent shall be subject to the following fee as applied in the following manner: DISTRICT APPLICATION FEE In addition to the deposit required pursuant to Section IV Paragrath R, with the filing of the application to form a district the proponent shall pay a District Application m in an amount determined as follows: Jotal District Bond Amount District Application Fee Less than $10,000,000 Greater than $10,000,000 5,000.00 10,000.00 13 VI. PROCEDURES A. It is the intention of the City Council that proponents of a district have an early opportunity to have the proposal reviewed by City staff for compliance with this policy. To facilitate staff review, each proposal shall be reviewed by the ~ Financinl1 District Review Committee. The Committee shall consist of members appointed by the City Manager. The City Attorney will act as legal counsel and the City Manager shall "chair" the Committee or their designees. The Committee shall meet with proponents of a district to review a proposed district to determine whether or not the requirements of this policy have been satisfied. Committee review shall take place prior to the submittal ofROI to City Council and after the deposit and application fee have been submitted. Whenever any such project is presented to the Council it shall be accompanied by a report containing the findings and recommendation ofthe Committee made in regard to such project. B. Upon review of the proposed district and after considering the report of the Committee, the City Council shall determine whether or not to approve proceeding with the formation of the district. It is the policy of the City Council to limit projects to the criteria set forth in this policy. The City Council reserves to itself the authority to approve or disapprove any proposed improvement district based upon the evidence received at hearings held by the City Council. Any exceptions to the criteria of this policy will be approved only upon an express finding by the City Council that the project is so affected with a public interest that the City should assist in providing financing for the improvement in order to satisfy a public need. If the City Council approves proceeding with the formation of the district, City staff and the proponents shall proceed to do that in accordance with state law and the requirements of this policy. C. Where there are multiple proponents of a proposed district they shall designate a spokesman authorized to act for the proponents in their dealing with the City. The spokesman shall be responsible for collecting any fees for deposit with the City, providing any necessary information to the City, and for communicating as necessary back to the proponents. 14 VII. APPLICATION PROCESS Early communication with the City is encouraged to assist applicants in evaluating the feasibility of available financing programs and to discuss program procedures: A. PREAPPLICATION CONFERENCE: Applicant meets with City staff to discuss the proposed project and application procedures. B. APPLICATION SUBMISSION: Applicant submits an initial application for review by City staff. Applicant pays the District Application Fee (See Section V, Fee and Charge Schedule) C. PROJECT REVIEW: Public Financing District Review Committee shall meet to discuss initial application, including any issues raised and further information that might be required. If necessary, applicant submits revised application. D. APPLICATION PROCESSING: Upon City determination that application is complete, staff prepares a staff report which forwards the request for district formation and project financing and staff recommendation to the City Council. E. CITY COUNCIL CONSIDERATION: The City Council makes any necessary findings and grants or denies the application, selects consultants if approval is granted) and either approves contracts or directs staff to negotiate contracts. F. PROJECT INITIATION: Staff submits consultant contracts, reimbursement agreements and other similar items for City Council consideration. G. PROJECT IMPLEMENTATION: Applicant, staff and consultants meet to determine preliminary project schedule and begin work necessary to initiate district formation. 15 VIII. CRITERIA FOR APPRAISALS The Appraisal Standards for Land Secured Financing published by the California Debt Advisory Commission and dated May, 1994, are adopted as the appraisal standards for the City of Orange with the following modifications: 1. The independent review appraiser is an option, and not a requirement if the District has a lien to value ratio of 4: 1 or greater or if the bond amount is under 10,000,000. 2. The Comparable Sales method may be used whenever there is sufficient data available. 3. The appraiser should assume the presence of the public infrastructure to be financed with the bonds. 4. The special tax lien need not be computed as the present value of the future tax payments if there is a pre-payment mechanism or other more appropriate measure.5. In the Discounted Cash flow analysis, the appraiser is to take care that the inclusion of "developer profit" as a cost, and the setting of the discount rate to include a "risk premium" for equity investors, does not amount to a " double-counting" for the developer. IX. REQUIREMENTS FOR TAX ALLOCATION FORMlJLAS The proposed amount and apportionment of the special tax shall comply with the following criteria: 1. The special tax formula shall be structured to produce sufficient annual special tax revenue to pay: a) Annual debt service, and b) Reasonable annual administrative expenses and the cost of any services and "pay as you go" programs funded by the CFD special tax. 2. A backup special tax to protect against changes in densities or product type will be required. 3. The rate and method of apportionment should not provide for an annual increase in the maximum special tax for residential properties to exceed two percent (2%) annually. 4. The total projected annual special tax revenues, less estimated annual administrative expenses, must exceed the projected annual gross debt service on the bonds by at least ten percent (10%). 5. All property within the CFD to be benefited shall bear its appropriate share of the special tax liability. The special tax formula shall be structured to closely link the tax paid by a property owner with the actual benefit that the property owner receives from the improvement. The formula shall not create an unequal tax allocation that would result in the early home buyers in a development project paying a disproportionate share of the infrastructure costs of the project in relation to the benefit that they receive - indirectly subsidizing the developers. Also, the special tax formula shall not allow early low payments and later increased substantially. 6. The special tax shall be allocated and apportioned on the basis of reasonableness to all categories and classes of property receiving specific benefit within the CFD.7. A method to prepay or completely payoff the special tax after District formation shall be required absent demonstrated impracticality.8. The projected ad valorem property tax and other direct and overlapping debt for the proposed CFD (including estimated CFD charges, projected benefit assessments, levies for authorized but unissued debt and any other anticipated municipal charges which may be included on a property owner' s annual tax bill), including the proposed maximum special tax,shall not exceed two percent (2%) of the anticipated sales price to the ultimate home buyer. Any deviations from the foregoing will not be permitted unless specifically approved by the Council.17 9. The special tax formula shall be such that once the total tax need is known, and the status of all properties within the financing district relative to that formula are known, the special tax on each parcel is determined purely by the application of the formula. 18 X. POLICY ON JOINT FINANCING DISTRICTS The City may enter into a Joint Powers Authority or may enter into a joint financing agreement or a utility agreement (pursuant to Section 10110 of the Street & Highways Code) with regard to proposed districts, if the district is in substantial compliance with the City's public financing policies as contained herein. After staff review, all such requests shall be brought before the City Council and will be reviewed in a similar manner as are City initiated districts. The City recognizes that the Mello-Roos Community Facilities Act of 1982 may be the only method available to school districts to mitigate the impact of new development, new school facilities may be given first priority in any joint- use of the Mello-Roos Act by the City and any school district. In appropriate cases, the City may defer to any school district in the use of the Mello-Roos Act, but only to the extent of mitigating the impact of new development ( as distinct form solving current school district problems), and only to the extent such mitigation is not provided by statutory developer fees andstate funds. N :