Resolution Number 01-7-3-2RESOLUTION NO 01-7-3-2
A RESOLUTION AND RATE ORDER OF THE CITY COUNCIL OF THE
CITY OF SAN JUAN CAPISTRANO APPROVING A POSSESSORY
INTEREST TAX REFUND PLAN OF COX COMMUNICATIONS, INC., OR
A SUBSIDIARY THEREOF ("COX").
The City Council of the City of San Juan Capistrano finds:
WHEREAS, Cox Communications, Inc., or a subsidiary thereof ("Cox"), has been
granted a franchise to own and operate a cable telephone system in the City of San
Juan Capistrano (the "City").
A. The City is authorized to regulate Basic Service rates in accordance with
the Regulations established by the Federal Communications Commission (the
"Commission").
B. In or about 1990, the Assessor of the County of Orange (the "Assessor")
significantly increased the valuation of Cox's possessory interest in public rights-of-way.
This increase in possessory interest value, which simply constituted a component of
Cox's overall real property located within the County of Orange (the "County"), resulted
in significantly higher property tax assessments and actual property taxes due to the
County from Cox. Although the Assessor's increase in the valuation of the possessory
interest did not result in the imposition of a new tax, said increase did result in a material
increase in property taxes payable and said increase will generally be referred to herein
as the "Possessory Interest Tax" ("PIT").
C. Cox filed assessment appeals with the Orange County Assessment
Appeals Board (the "AAB") for all relevant years. Cox further joined a consortium of
other Orange County cable operators (the "Consortium") to pool expertise, experience
and resources in collectively prosecuting assessment appeals before the AAB and
related litigation.
D. In or about 1990, Cox adopted a policy to "pass-through" as a line
itemization a pro rata share of the PIT upon subscribers' monthly bills, which practice
continued until 1996 (the "Pass -Through Period").
E. The City has joined together with other South Orange County franchising
authorities (the "Franchising Authorities") in reviewing Cox's annual Commission rate
forms. The Franchising Authorities have consistently hired the same rate consultant,
Jay Smith of Public Knowledge, Inc. ("PKI"), to prepare a global report to the legislative
bodies of each of the Franchising Authorities analyzing Cox's request for rate
modifications and make recommendations regarding appropriate regulatory action upon
those requests.
F. The Rate Regulations of the Commission allow the externalization (or
pass-through) of possessory interest taxes if certain valuation criteria are satisfied.
1
Although the appropriate regulatory treatment of the PIT is unclear, and to great extent
relates to the methodology of assessment utilized by the Assessor at the time, a facial
reading of the Commission Regulations suggests that pass-through treatment of the PIT
may have been appropriate.
G. During each of the annual rate reviews between 1994 and 1996, the City
questioned (1) the appropriateness of the PIT pass-through; (2) the amount of the PIT
pass-through; and (3) the nature and extent of the potential refund obligation.
H. Based upon numerous discussions between PKI and Cox, or its
predecessor -in -interest, regarding these subject matters, a general understanding was
reached between Cox and PKI whereby the City would take no immediate action upon
the PIT pass-through but would rather defer resolution of this issue until Cox and the
County had resolved the PIT issue by way of either litigation or settlement, and actual
refunds were paid to Cox.
I. The County entered into a "Framework for Resolution" agreement with
Cox on November 7, 1995 (the "Settlement') which, resulted in the payment of refunds
from the County to Cox between July 1, 1996 through December 31, 1998. Pursuant to
this Settlement, Cox was paid some, but not all, of the PIT plus interest (the 'Refunded
Taxes").
J. The Franchising Authorities, including the City, appointed the City of San
Juan Capistrano ("San Juan Capistrano") to act as the lead agency in relation to the
review and negotiation of a tentative refund plan and selected James Widner,
Administrative Services Manager of San Juan Capistrano, and William M. Marticorena
of Rutan & Tucker, LLP, Special Counsel, to act as the negotiating team (the
"Negotiating Team").
K. After many months of negotiations, the Negotiating Team has reached a
proposed settlement and tentative agreement (the 'Tentative Agreement") in relation to
the Refunded Taxes with Cox which Tentative Agreement is attached to this Resolution
as Exhibit A and incorporated herein by this reference.
L. The Negotiating Team has prepared a "Final Report to the City Councils of
the City of Dana Point, Laguna Beach, Laguna Hills, Laguna Niguel, Lake Forest,
Rancho Santa Margarita, San Clemente and San Juan Capistrano, Relating To The
Possessory Interest Tax Refund Plan of Cox Communications, Inc." (the "Final Report")
dated April 11, 2001, a copy of which is attached hereto as Exhibit B and incorporated
herein by this reference.
M. The Final Report constitutes the recommendations of the Negotiating
Team to the City Councils of all of the Franchising Authorities relating to a final
resolution and settlement of the PIT refund dispute and the approval of a final refund
plan pursuant to the rate regulation and consumer protection authority of the City.
_ N. This matter is being placed before the City Council pursuant to its
authority to regulate Basic Service Tier rates and related equipment charges pursuant
to the provisions of the Cable Television Consumer Protection and Competition Act of
1992, as amended (the "1992 Cable Act") as well as the implementing rate regulations
of the Commission (47 C.F.R. §§ 76.900, et seg.). Upon approval of this resolution, the
annual reviews undertaken by the City of the rate regulation forms filed by Cox and its
predecessor -in -interest to the City between 1994 and 1996 are hereby deemed final
and concluded.
The City Council of the City of San Juan Capistrano hereby resolves as follows
Section 1. The Refund Plan attached to this Resolution as Exhibit A is hereby
approved and Cox is hereby directed and authorized to implement said Refund Plan.
Section 2. Cox shall, within ninety (90) days from the issuance of this Rate Order,
document its compliance with the conditions included herein including the provision of a
written accounting to the City of Cox's implementation of the Refund Plan.
PASSED, APPROVED, AND ADOPTED THIS 3RD day of July, 2001
WYAT"ART, MAYO
ATTEST:
R. MONAHAN, CITY CLERK
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss.
CITY OF SAN JUAN CAPISTRANO )
I, MARGARET R. MONAHAN, appointed City Clerk of the City of San Juan Capistrano,
do hereby certify that the foregoing Resolution No. 01.7-3-2 was duly adopted by the
City Council of the City of San Juan Capistrano at a regular meeting thereof, held the
3rd day of July 2001, by the following vote:
AYES: COUNCIL MEMBERS:
NOES COUNCIL MEMBERS:
ABSENT: COUNCIL MEMBERS:
Bathgate, Greiner, Gelff, Swerdlin and Mayor
Hart
None
None
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