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purposes under Section 103(a) of the Internal Revenue Code of 1986, as amended, and applicable regulations thereunder (the "Code'), based in part on a certificate to be obtained from the Borrower; and the Bonds will not be issued unless the Issuer has received a satisfactory opinion of bond counsel regarding the fact that the interest on such Bonds will be excluded from gross income at the time of the delivery of the Bonds. E. The Project constitutes "educational facilities," and a "project" within the meaning and contemplation of the Act, is appropriate to the needs and circumstances of, and shall make a significant contribution to the economic growth of Indian River County, Florida, shall provide or preserve gainful employment and shall serve a public purpose by advancing the economic prosperity and the general welfare of the State of Florida and its people and by improving living conditions within the State of Florida. F. Indian River County, Florida, will be able to cope satisfactorily with the impact of the Project and will be able to provide, or cause to be provided when needed, the public facilities, including utilities and public services, that will be necessary for the construction, operation, repair and maintenance of the Project and on account of any increases in population or other circumstances resulting therefrom. G. The availability of financing by means of industrial development revenue bonds was and is an important inducement to the Borrower to proceed with the acquisition, construction and equipping of the Project and the refinancing thereof. H. Adequate provision has been made in the documents attached hereto for a loan by the Issuer to the Borrower (the "Loan"), to finance the acquisition, construction and equipping of the Project and the refinancing thereof and thereafter for the operation, repair and maintenance of the Project at the expense of the Borrower and for the repayment by the Borrower of the Loan in installments sufficient to pay the principal of and the interest on the Bonds and all costs and expenses relating thereto in the amounts and at the times required. I. The Borrower and First Union National Bank (the "Bank"), which will issue the Letter of Credit, as that term is hereinafter defined, are financially responsible based on the criteria established by the Act, the Borrower is fully capable and willing to fulfill its obligations under the Loan Agreement (the "Agreement") between the Borrower and the Issuer, including the obligation to repay the Loan in installments in the amounts and at the times required, the obligation to operate, repair and maintain the Project at the Borrower's own expense and such other obligations and responsibilities as are imposed under the Agreement. The payments to be made by the Borrower to the Issuer and the other security provided by the Agreement, the Trust Agreement and the Letter of Credit, 3