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of the Internal Revenue Code of 1986, as amended, and to the best of the knowledge and belief of such officer, such expectations are reasonable; (12) Such additional legal opinions, certificates, proceedings, instruments and other documents as the UWerwdters, Disclosure Counsel or Bond Counsel may reasonably request to evidence compliance by the Issuer with legal requirements, the truth and accuracy, as of the time of Closing, of the respective representations of the Issuer herein contained and the due performance or satisfaction by the Issuer at or prior to such time of all agreements or undertakings then required to be satisfied by the Issuer. (13) Evidence that The Chase Manhattan Bank, N.A., New York, New York, has been approved by the Issuer as Paying Agent. (14) A Certificate of the Issuer signed by the Administrator and the Utilities Director stating that (i) the Underwriters can rely on the information in the Official Statement under the headings "THE SYSTEM" and 'SERIES 1996 PROJECT" as a true, reasonable, and accurate summary of the Master Water & Wastewater Plan and (H) the projects being funded with the proceeds of the Series 1996 Bonds are necessary and accomplish the objectives of the Master Water & Sewer Plan. The Certificate will further provide a statement to the effect that: (a) The System is generally in good condition and has been operated and maintained in accordance with standard utility industry practices, and provides good, reliable and cost-effective water and sewer service to the customers of the System; (b) The System is operated in substantial compliance with current Federal, State and Local requirements. All regulatory permits necessary for the operation of a public municipal water and sewer system are current and in good standing; (c) The Project is necessary. The proposed capital improvements are technically sound and conform to proven and industry accepted engineering practice. The Project will provide for water and sewer system improvements and expansion to meet Federal, State and Local regulatory requirements and projected growth -related water demands for a _ year period; (d) The proposed capital improvements are or shall be designed in accordance with accepted engineering standards using proven conventional technology. (e) The City's existing management and professional staff are well qualified and certified to manage, operate, and maintain the System; (f) It is reasonable to assume that all required regulatory permits and/or governmental approvals will be obtained in a timely manner for regulatory compliance and will be obtained prior to construction of the proposed capital improvements and all necessary operating permits will be obtained for the completed capital improvements;