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Vk , <br />E <br />PAB allocation but, by tying it to Phase I only, escape safety, health and environmental <br />requirements on Phase 1I. Nearly one year later, on October 27, 2017, the FDFC renewed its <br />agreement to serve as the conduit issuer of the bonds on behalf AAF. <br />In the August 2016 ruling, District Court Judge Cooper found that the $1.75 billion PAB <br />allocation would cost the U.S. Treasury up to $600 million in foregone tax revenue over 10 <br />years. Extrapolating from that conclusion, we can assume that the foregone tax revenue would <br />equal up to approximately one-third of the new $600 million PAB allocation—approximately <br />$200 million over 10 years. <br />Questionable FDFC Practices_ --Then and Now, <br />Public notice of the FDFC's October 27 meeting, during which it approved a bond resolution and <br />related financing documents for the $600 million PAB allocation, was publicly posted 72 hours <br />before the meeting took place. We have now reviewed FDFC's documents and recent exchanges <br />with AAF. These records reveal that AAF officials were in touch with the FDFC staff by email <br />and phone regularly before the public posting. It shows a contempt for opponents to provide so <br />little notice of the proceeding when AAF and FDFC staff were long aware of the hearing. <br />Additionally, we are concerned by the lack of a public hearing required under the Tax Equity and <br />Fiscal Responsibility Act (TEFRA) for the $600 million PAB allocation. In 2015, a TEFRA <br />hearing was held for the issuance of the $1.75 billion PAB request. In 2017, the October 27 <br />FDFC meeting packet indicates that TEFRA approval occurred on August 1, 2017, without a <br />hearing. <br />Upon review of the August 1 TEFRA approval letter, an obvious concern is that the 2017 letter - <br />describes the maximum bond amount as $1.75 billion, not the current $600 million. In addition, <br />the current $600 million PAB allocation is specifically for Phase I of the project, yet the TEFRA <br />letter of August 1 lists two Counties located in Phase II—Brevard County and Orange County. <br />The FDFC needs to explain to the public and OPPAGA if this letter was written in error, or if <br />AAF intends to exploit this ambiguity to use some of the new $600 million allocation for Phase <br />II of the project. <br />These questionable practices are nothing new. During the 2014-2015 FDFC approval process, <br />Indian River County, Martin County, CARE FL and other concerned parties repeatedly raised <br />numerous concerns, including, but not limited to: <br />Multiple Communications Between FDFC Board Members and AAF. Previous <br />public records requests revealed that the FDFC Board Members and FDFC staff engaged <br />in extensive communications with AAF and/or its affiliates. In fact, while Indian River <br />County, Martin County, CARE FL and other opposition voices often got no response to <br />formal correspondence to the FDFC, AAF was having a series of private meals and <br />briefings with the Board Members. For instance: <br />2 <br />/tis�� <br />