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Resolution 2020-057 RESOLUTION NO. 2020- 57 A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF COLLIER COUNTY, FLORIDA APPROVING THE ISSUANCE AND SALE OF REVENUE BONDS IN TWO OR MORE SERIES BY THE COLLIER COUNTY INDUSTRIAL DEVELOPMENT AUTHORITY,AS REQUIRED BY SECTION 147(f) OF THE INTERNAL REVENUE CODE, AS AMENDED; AND PROVIDING FOR OTHER RELATED MATTERS. WHEREAS,the Collier County Industrial Development Authority(the"Authority") is a body corporate and politic of Collier County, Florida ("Collier County") created by Collier County Resolution No. 79-34 duly adopted by the Board of County Commissioners on February 27, 1979 pursuant to Part III of Chapter 159,Florida Statutes, as amended,with the power to issue revenue bonds for the purposes of financing or refinancing the costs of a "project" as defined in Parts II and III of Chapter 159, Florida Statutes, as amended; and WHEREAS, Naples Community Hospital, Inc., and its sole member, NCH Healthcare System, Inc. each a Florida not-for-profit corporation (collectively, the "Borrower"), has requested the Authority to issue its Healthcare Facilities Revenue Bonds (NCH Healthcare System Project), (the "Bonds") in two or more series for the principal purposes of making a loan or loans to the Borrower to finance or reimburse the Borrower for the costs of the Project and to refund the Refunded Bonds (as such terms are defined in the Authority Resolution described below), and to pay certain expenses incurred in connection with the issuance of the Bonds; and WHEREAS, Section 147(f) of the Internal Revenue Code of 1986, as amended(the "Code"), provides that the elected legislative body of the governmental unit which has jurisdiction over the area in which the facility financed or refinanced with the proceeds of tax-exempt bonds is located is to approve the issuance of such bonds after a public hearing; and WHEREAS, the Board of County Commissioners of Collier County, Florida (the "Board") is the elected legislative body of the County; and WHEREAS, the Authority caused a notice (the "Notice") of a public hearing to consider approval of the Bonds and the location and nature of the Project to be published on March 12, 2020 in the Naples Daily News, a newspaper of general circulation in Collier County, a copy of said notice being attached as Exhibit A to the Authority Resolution referred to below: and WHEREAS, the Authority held a special meeting and held a public hearing on March 23, 2020 at which meeting it adopted a Resolution (the "Authority Resolution") containing certain findings and authorizing the issuance of two separate series of the Authority's revenue bonds (the "Series 2020 Bond" and "Series 2021 Bond", respectively, and collectively, the "Bonds") for the purpose of financing (and reimbursing the Borrower for) the costs of the Project (in the case of the Series 2020 Bond) and the refunding of the Refunded Bonds (in the case of the Series 2021 Bond), all as described in the Authority Resolution, in accordance with the provisions of Section 147(f)of the Code,a copy of which Authority Resolution is attached hereto as Exhibit A; and WHEREAS, for the reasons set forth above, it appears to the Board that the approval of the issuance and sale of such Bonds to finance (or reimburse the Borrower for) the costs of the Project and the refunding of the Refunded Bonds, as required by Section 147(f)of the Code is in the best interests of Collier County, NOW, THEREFORE, BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF COLLIER COUNTY, FLORIDA, THAT: SECTION 1. APPROVAL OF ISSUANCE OF THE BONDS. This Board hereby approves the issuance of the Bonds by the Authority for the purposes described in the Notice and in the Authority Resolution pursuant to Section 147(f) of the Code. The Bonds shall be issued in such series, in such aggregate principal amounts (not to exceed $50,000,000 in the case of the Series 2020 Bond and not to exceed $91,000,000 in the case of the Series 2021 Bond), bear interest at such rate or rates, mature in such amount or amounts and be subject to prepayment as are approved by the Authority pursuant to the Authority Resolution and certain Bond Resolutions adopted by the Authority in connection with the authorization for the issuance of the Bonds, without the further approval of this Board. The Bonds shall not constitute a debt, liability or obligation of Collier County, the Board, any officer, agent or employee of Collier County,the State of Florida or any political subdivision thereof, but shall be payable solely from the revenues provided therefor, and neither the faith and credit nor any taxing power of Collier County or the State of Florida or any political subdivision thereof is pledged to the payment of the principal of, premium, if any, and interest on the Bonds. No member of the Board or any officer or employee thereof shall be liable personally on the Bonds by reason of their issuance. This approval shall in no way be deemed to abrogate any regulations of Collier County for any portions of the Project located within the regulatory jurisdiction of Collier County. The Project shall be subject to all such regulations, including,but not limited to,the Collier County Growth Management Plan and all concurrency requirements contained therein and the Collier County Land Development Code. 2 SECTION 2. SEVERABILITY. If any section, paragraph, clause or provision of this Resolution shall be held to be invalid or ineffective for any reason, the remainder of this Resolution shall continue in full force and effect, it being expressly hereby found and declared that the remainder of this Resolution would have been adopted despite the invalidity or ineffectiveness of such section, paragraph, clause or provision. SECTION 3. EFFECTIVE DATE. This Resolution shall take effect immediately upon its adoption, and any provisions of any previous resolutions in conflict with the provisions hereof are hereby superseded. PASSED and Adopted this 24th day of March 2020. ATTEST: COLLIER COUNTY, FLORIDA �Y ,, BY Crystal K. Kir�.2ett C :t, ITS BOARD OF COUNTY ': '' 4 ®,per` COMMISSIONERS rr - By: 66i 2 . 6. . r*.ut,Q L_, /44)1' .Att as tot 0' ` ii eputy Clerk Burt Saunders, Chairman signat1re fl e )`'3 [SEAL] r Approved A to form a r e�glal sufficiency: JeffreyAii Klatzkow, County Attorney i 3 EXHIBIT A COPY OF AUTHORITY RESOLUTION RESOLUTION NO. 2020-03 AN INDUCEMENT RESOLUTION OF THE COLLIER COUNTY INDUSTRIAL DEVELOPMENT AUTHORITY REGARDING THE OFFICIAL ACTION OF THE AUTHORITY WITH RESPECT TO THE PROPOSED ISSUANCE BY THE AUTHORITY OF(A)THE AUTHORITY'S HEALTI!CARE FACILITIES REVENUE BOND, SERIES 2020 (NCH HEALTHCARE SYSTEM PROJECT) IN AN AGGREGATE PRINCIPAL AMOUNT No-r TO EXCEED $50.000.000 FOR TI IL PRINCIPAL PURPOSE OF FUNDING CERTAIN CAPITAL IMPROVEMENTS DESCRIBED HEREIN; AND (B) THE AUTHORITY'S HEALTHCARE FACILITIES REVENUE REFUNDING BOND, SERIES 202 I(NCH HEALTHCARE SYSTEM PROJECT) IN AN AGGREGATE PRINCIPAL AMOUNT NOT TO EXCEED$91,000,000 FOR THE PURPOSE OF REFUNDING TI IE OUTSTANDING COLLIER COUNTY INDUSTRIAI, DEVELOPMENT AUTHORITY HEALTHCARE FACILITIES REVENUE BONDS, SERIES 2011 DESCRIBED HEREIN; AUTHORIZING THE EXECUTION AND DELIVERY OF A PRELIMINARY AGREEMENT BETWEEN THE AUTHORITY AND THE CORPORATION;AND PROVIDING FOR RELATED MATTERS. WHEREAS,Naples Community hospital. Inc.,a Florida not-for-profit corporation,the sole member of which is NCH Healthcare System.Inc..a Florida not-for-profit corporation(collectively. the "Corporation") has applied to the Collier County Industrial Development Authority (the "Authority") to issue (A) the Authority's Healthcare Facilities Revenue Bond, Series 2020 (NCH Healthcare System Project) (or such other designation as the Corporation (defined below) and the Authority deem appropriate)in an aggregate principal amount not to exceed$50,000,000(the"Series 2020 Bond"), for the purpose of making a loan or loans to Naples Community Hospital, Inc., a Florida corporation not for profit. the sole member of which is NCH Healthcare System. Inc. (the "Corporation"), for the purpose of providing funds to (1) finance the costs of certain capital improvements to its healthcare facilities located in Collier County and identified in its master facilities plans including, without limitation, CT Scanner upgrades, second and third floor renovations and equipping and outfitting three new cardiovascular operating suites, a hybrid operating room and general surgical operating room. buildout of the cardiovascular intensive care unit and the expansion, renovation and equipping of its Emergency Department and ancillary facilities all at its Baker Campus located in the City of Naples at 350 7th St. N.,Naples, FL 34110 and certain capital healthcare facilities and equipment improvements including,without limitation. CT Scanner upgrade at its North Naples campus located at 11190 Healthpark Blvd.,Naples,Florida, 34110,and (2) pay certain expenses incurred in connection with the issuance of the Series 2020 Bond (the "Project") and (B) the Authority's forward delivery Healthcare Facilities Revenue Refunding Bond. Series 2021 (NCH Healthcare System Project) (or such other designation as the Corporation and the Authority deem appropriate) in an aggregate principal amount not to exceed EXHIBIT A TO COUNTY RESOLUTION 59 1.000.000 (the " Series 2021 Bond-,and together with the Series 2020 Bond, the-Bonds"), for the purpose of making a loan or loans to the Corporation for the purpose of providing funds to (I) refund all of the outstanding Collier County Industrial Development Authority I Icalthcare Facilities Revenue Bond Series 2011 (NCI!Healthcare System Project)(the"Refunded Bonds"),the proceeds of which Series 2011 Bonds were used by the Corporation to finance and refinance various healthcare facilities located in Collier County; and (2)pay certain expenses incurred in connection with the issuance of the Series 2021 Bond; and WHEREAS, the Corporation has requested that the Authority loan the proceeds of the Bonds to the Corporation pursuant to Chapter 159. Parts II and Ill, Florida Statutes,or such other provision or provisions of Florida law as the Authority may determine advisable(the"Act")in order to accomplish the foregoing purposes; and WHEREAS, the issuance of the Bonds and the loaning of the proceeds thereof to the Corporation to finance the costs of the Project and refinance the costs of the projects funded with the proceeds of the Refunded Bonds under loan or other financing agreements,and pursuant to the terms thereof which will provide that payments thereunder he at least sufficient to pay the principal of and interest and redemption premium,if any,on such Bonds and such other costs in connection therewith as may be incurred by the Authority, will assist the Corporation and promote the public purposes provided in the Act; and WHEREAS,in order to satisfy certain of the requirements of Section 147(f)of the Internal Revenue Code of 1986,as amended(the"Code"),the Authority did on the date hereof hold a public hearing on the proposed issuance of the Bonds for the purposes herein stated, which date is more than seven(7)days following the first publication of notice of such public hearing in a newspaper of general circulation in Collier County and which public hearing was conducted in a manner that provided a reasonable opportunity for persons with differing views to be heard, both orally and in w-riting.on the issuance of the Bonds and the location and nature of the Project.as more particularly described in the notice of public hearing attached hereto as Exhibit A; and WIIEREAS, it is intended that this Resolution shall constitute official action toward the issuance of the Bonds within the meaning of the applicable United States Treasury Regulations in addition to any other action that may have heretofore been taken by the Corporation; NOW, THEREFORE, BE IT RESOLVED BY THE COLLIER COUNTY INDUSTRIAL DEVELOPMENT AUTHORITY, THAT: SECTION 1. AUTHORITY FOR THIS RESOLUTION. This Resolution is adopted pursuant to the provisions of the Act and other applicable provisions of law. SECTION 2. PRELIMINARY STATEMENT. This Resolution is entered into to permit the Corporation to proceed with financing of the costs of the Project and the refunding of the Refunded Bonds and to provide an expression of intention by the Authority,prior to the issuance of the Bonds,to issue and sell the Bonds and make the proceeds thereof available for such purposes,all in accordance with and subject to the provisions of the Act, the Constitution and other laws of the State of Florida and the laws of the United States of America, including the Code, and this Resolution. but subject in all respects to the terns of the Preliminary Agreement of even date herewith between the Authority and the Corporation. SECTION 3. FINDINGS AND DETERMINATIONS. Upon consideration of the application for financing and the supporting documents presented to the Authority at or prior to the public hearing on March 23.2020 described herein,the testimony of representatives and agents of the Corporation at said hearing, and comments of members of the public either orally or in writing,if any,the Authority has made and does hereby make the following findings and determinations: (1) The Project consists of the acquisition,construction,renovation and equipping of certain capital improvements to the Corporation's health care facilities,said Project being owned and operated or to be owned and operated by the Corporation in its business of providing health care services in the County and the State. (2) The Project alleviates unemployment in the County by creating additional jobs in the County and the State.fosters the economic growth and development and the industrial and business development of the County and State.has the incidental effect of adding to the tax base, and serves other predominantly public purposes as set forth in the Act. It is desirable and will further the public purposes of the Act,and it will most effectively serve the purposes of the Act, for the Corporation to finance and refinance the costs of the Project through the issuance of the Bonds (3) The Project is appropriate to the needs and circumstances of,and will make a significant contribution to. the economic growth of the County; will provide or preserve gainful employment;and will serve a public purpose by advancing the economic prosperity and the health and general welfare of the County,the State and its people in accordance with the Act. (4) Based on the representations made to the Authority through the documentation and testimony furnished by the Corporation and based on other criteria established by the Act, as of the date hereof. the Corporation is financially responsible and fully capable and willing (a) to fulfill its obligations under the Financing Agreement, the Master Indenture, and any other agreements to be made in connection with the issuance of the Bonds, including the obligation to make loan payments or other payments due under the Financing Agreement or the Master indenture in an amount sufficient in the aggregate to pay all of the principal of purchase price,interest and any prepayment or redemption premiums. on the Bonds, in the amounts and at the times required,(b)to operate,repair and maintain at its own expense the Project, and (c) to serve the purposes of the Act and such other responsibilities as may be imposed under such agreements. 3 (5) Based on the representations of the Corporation through the documentation and testimony furnished by the Corporation. the County, the city, and other local agencies have been and will continue to he able to cope satisfactorily with the impact of the Project and have been and will continue to be able to provide,or cause to be provided when needed. the public facilities,including utilities and public services necessary for the operation,repair and maintenance of the Project on account of any increase in population or other circumstances resulting therefrom. (6) Adequate provision is made under the Financing Agreement and the Master Indenture for the operation, repair and maintenance of the Project at the expense of the Corporation. for the payment of the principal of., purchase price,prepayment or redemption premium. if any.and interest on the Bonds when and as the same become due,and payment by the Corporation of all other costs in connection with the financing,refinancing,operation, maintenance and administration of the Project,being paid out of the proceeds of the Bonds or otherwise. (7) The costs of the Project being financed and refinanced with the proceeds of the Bonds constitute "costs" of a "project" within the meaning of the Act. (8) The principal of,prepayment premium.if any,and interest on the Bonds and all other pecuniary obligations of the Authority under the Financing Agreement,or otherwise, in connection with the financing and refinancing of the costs of the Project through the issuance of the Bonds,shall be payable by the Authority solely from the loan payments and other revenues and proceeds received by the Authority under the Financing Agreement and the Master Indenture,or any other agreements relating to the issuance of the Bonds.Neither the faith and credit nor the taxing power of the Authority, the County, the State or of any political subdivision or agency thereof is pledged to the payment of the Bonds or of such other pecuniary obligations of the Authority,and neither the Authority,the County,the State nor any political subdivision or agency thereof shall ever be required or obligated to levy ad valorem taxes on any property within their territorial limits to pay the principal of.purchase price,prepayment premium.if any,or interest on such Bonds or other pecuniary obligations or to pay the same from any funds thereof other than such revenues,receipts and proceeds so pledged,and the Bonds shall not constitute a lien upon any property owned by the Authority. the County or the State or any political subdivision or agency thereof, other than the Authority's interest in Financing Agreement and the property rights,receipts. revenues and proceeds pledged therefor under and as provided in the Financing Agreement and any other agreements securing the Bonds. The Authority has no taxing powers. (9) All requirements precedent to the adoption of this Resolution, of the Constitution and other laws of the State, including the Act, have been complied with. SECTION 4. APPROVAL OF THE FINANCING AND THE REFUNDING. The financing of the costs of the Project (including, without limitation, the reimbursement of any costs incurred by the Corporation prior to the issuance of the Bonds to the extent permitted by the 4 Act and Code)and the refunding of the Refunded Bonds by the Authority through the issuance of the Bonds,pursuant to the Act,will promote the economic development,prosperity,health and welfare of the citizens of Collier County,will promote the general economic structure of Collier County,and will thereby serve the public purposes of the Act and is hereby preliminarily approved, subject, however, in all respects to the Corporation meeting the conditions set forth in the Preliminary Agreement to the sole satisfaction of the Authority. SECTION 5. AUTHORIZATION OF THE BONDS. There is hereby authorized to be issued and the Authority hereby determines to issue the Bonds, if so requested by the Corporation and subject in all respects to the conditions set forth in the Preliminary Agreement,in two separate series (the "Series 2020 Bond" and "Series 2021 Bond"), in an aggregate principal amount not to exceed$50,000,000 with respect to the Series 2020 Bond or$91,000,000 with respect to the Series 2021 Bond. The rate of interest payable on the Bonds shall not exceed the maximum rate permitted by law. SECTION 6. GENERAL AUTHORIZATION. The Chairman, the Vice-Chairman, and the other officers of the Authority are hereby further authorized to proceed, upon execution of the Preliminary Agreement,with the undertakings provided for therein on the part of the Authority and are further authorized to take such steps and actions as may be required or necessary in order to cause the Authority to issue the Bonds,including presenting this Resolution to the Board of County Commissioners of Collier County and requesting approval of such Board pursuant to Section 147(f)of the Code;subject in all respects to the terms and conditions set forth in the Preliminary Agreement authorized hereby. SECTION 7. OFFICIAL ACTION. This resolution is an official action of the Authority toward the issuance of the Bonds, as contemplated in the Preliminary Agreement, in accordance with the purposes of the laws of the State of Florida,the Code and the applicable United States Treasury Regulations. SECTION 8. LIMITED OBLIGATIONS. The Bonds and the interest thereon shall not constitute an indebtedness or pledge of the general credit or taxing power of Collier County, the State of Florida or any political subdivision or agency thereof but shall be payable solely from the revenues pledged therefor pursuant to a loan agreement or other financing agreement entered into between the Authority and the Corporation prior to or contemporaneously with the issuance of the Bonds. The Authority has no taxing power. SECTION 9. LIMITED APPROVAL. The approval given herein shall not be construed as an approval or endorsement of approval of any necessary rezoning applications nor for any other regulatory permits relating to the Project and the Authority shall not be construed by reason of its adoption of this resolution to have waived any right of Collier County or estopping Collier County from asserting any rights or responsibilities it may have in that regard. 5 SECTION 10. EFFECTIVE DATE. This Resolution shall take effect immediately. ADOPTED this 23rd day of March,2020. COLLIER COUNTY INDUSTRIAL DEVELOPMENT AUTHORITY (SEAL) Is! Dr. Robert R. Jones, Chairman ATTEST: /s/ Barbara M. Rosenberg, Secretary 6 EXHIBIT A TO RESOLUTION AFFIDAVIT OF PUBLICATION OF NOTICE OF PUBLIC HEARING t\aplrti Tail; D. PARI OF THE USA tODAY NE TWORK Published Daily Naples, FL 34110 WATSON SLOANE 100 S ASHLEY DR,STE 600 NOTICE OF SPECIAL MEETING AND PUBLIC HEARING TAMPA,FL 33602 Notifsr Is hereby given that the Collier County industrial Devel• opinent Authority(the'Authority") will conduct a special meet mq and public hearing on March 23, 7020 at 9:D0 a.m., 5133 Castello Drive,Suite 2,Naples, Florida 34103 for the purposes of Affidavit of Publication P)rl'(eiviny public comments and hearing discussion concerning the proposed issuance of(A) the Authority's Healthcare Fatal- STATE atdeSTATE OF WISCONSIN ties Revenue Frond, Series 1020(NCH Healthcare System Project) COUNTY OF BROWN Mr pooh oilier desigiution as the Corporation (defined below ) and the Authority deem appropriate) in ail aggro ale principal amount not to exceed 550,000.000 (the ' Series 2070 Bored') , Before the undersigned they serve as the authority, for the purpose of making a loan or loans to Naples Community Before appearedHospital, Inc.,a Florida(orperralion riot for profit, the sole mern- personally y said legal clerk who on oath says that her of which is NCH Healthcare System, Inc.(the•Corporation'), he/she serves as Legal Clerk of the Naples Daily News, a for the purpose of providing funds to(1) finance the costs of certain capital improvements to its healthcare facilities located daily newspaper published al Naples, in Collier County, in Collier County and identified in its master facilities plans in. Florida; distributed in Collier and Lee counties of Florida; eluding), without limitation, CT Scanner upgrades, second and curd floor renovations and equrppmy and outfitting three new that the attached copy of the advertising was published in cardrovaseular operating suites, a hybrid operating room and general surgica� operating room, buildout of the cardiovascular said newspaper on dates listed. Affiant further says that the intensive care unit and the expansion, renovation and equip, said Naples Daily News is a newspaper published al ping of its Emergency Department and ancillary facilities all at Naples, in said Collier County, Florida, and that the said its Raker Campus locates) m the City of Naples at 350 7th St,N, Naples, FL 34110 and certain capital healthcare facilities and newspaper has heretofore been continuously published in equipment improvements rncludiny, without limitation, CT said Scanner ul+yrade at its North Naples campus located at 11190 Healthpark Blvd, Naples, Florida, 341 l0,and (7)pay certain ex- Collier County, Florida; distributed in Collier and Lee penses mooned in connection with the issuance of the Street counties of Florida, each day and has been entered as 1010 Bond and(B)the Authority's forward delivery Healthcare Facilities Convertible Revenue Refunding Bond, Series 2021 second class mail matter at the post office in Naples, in INCH Healthcare System Protect) (or such other designation as said Collier County, Florida, for a period of one year next the Corpor,rhon and the Authority deem appropriate) on an ag- gregate principal amount not to exceed 591,000,000 (the'Ser- preceding the first publication of the attached copy of les 2011 Bond", and together with the Series 2020 Bnnd, the and affiant further says that he has neither "Bonds'), for the purpose of making a loan or loans to the Cor- advertisement; potatum for the purpose of providing funds to(I)refund all of paid nor promised any person, or corporation any discount, the outstanding Collier County Industrial Development Authori rebate, commission or relund for the purpose of securing Iv Healthcare Facilities Revenue florid Series 2011 (NCH Healthcare System Protect), the proceeds of which Series 1011 this advertisement for publication in the said newspaper. Bonds were used by the Corporation to finance and refinance various healthcare Wadies located in Collier County; and (1) pay tertont expenses incurred in connection with the issuance of Published:03/12/2020 the Series 2021 Bond, (ii)adopting a Bond Resolution in wormer- tion with the foregoing and(iii)conducting such other matters ---" "$- as may come before the Authority at such meeting. The Bonds will be payable solely from the revenues derived by the Authority 'row a loan agreement or other financing docu, monis between the Authority and the Corporation. Neither the Subscribed and sworn to before on March 12,2020: Bunds our ore interest thereon shall he an indebtedness of,or a pledge of, the taxing power or any other revenues of Collier County, the State of Florida,or any political subdivision or agen- rythereof. Copies of she application for financing are available for mpec- r,, tun and copying ,11 the office of the Authority set forth below. All interested persons are invited to submit written comments Notary,State of WI.Courtly of Brown or attend the hearing, either personally or through their repre• sentalrve, ane will be given an op oortunity to express their __ _ views concerning the protect or the financing. Anyone desiring In make written commen:s in advance of the hearingmaysend Ii All/i I Intal- ( r'II 1 - Nil y I'irl such comments to. Culler County Industrial Development Authority ✓tato nit srl,5 ur s r: 5133 Castello Drive,Suite2 Nap-es,Florida 34103 SHOULD ANY PERSON DECIDE TO APPEAL ANY DECISION MADE By '-rE AUTHORITY WlrH RESPECT 10 ANY MATTER CON51D• FRED AT SUCH HEARING, SUCH PERSON WILL NEED A RECORD My commission expires August 6 2021 OF THE PROCEEDINGS AND, FOR THAT PURPOSE. SUCH PERSON MAY NEED TO ENSURE THAT A VERBATIM RECORD OF THE PROCEEDINGS IS MADE, WHICH RECORD INCLUDES THE TESTI. MONY AND EVIDENCE UPON WHICH THE APPEAL 15 TO SE Publication Cost:$574.00 BASED Ad No:0004103619 ii`accordance with the Americans with Disabilities Act. persons un•d rig a special accommodation to participate In this hearing Customer No:8136903025 slwuld cortacl Donald A I'rikwurth, General Counsel, at 1239) 404.1475 no later than live(5)days prior to the hearing. PO 1$: TEFRA Notice this notice 1 givers pursuant to Sen tun 147(f) 01 the Internal Revenue Cooe,as amended R of Affirtavitsi COLLIER routioY MfuSrv!A1.DEVELOPMENT AUTHORITY /s!Uonala A Pickworth This is not an invoice Assistant Secretary and Centra'Counsel Mann I2,2020 Nu 41036'4 EXHIBIT A TO AUTHORITY RESOLUTION