O-2014-3525 issuance of private activity tax exempt obligations by Public Finance Authority

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yy O PECK, SHAFFER & WILLIAMS LLP ATTORNEYS AT LAW 65 EAST STATE STREET, SUITE 500 COLUMBUS, OH 43215 January 14, 2014 VIA EMAIL to citymanager@laportetx.gov Corby D. Alexander, City Manager City of LaPorte, Texas 604 West Fairmont Parkway LaPorte, Texas 77571 Re: Educational Media Foundation Dear Mr. Alexander: TEL 614 224 5205 888 900 5205 FAX 614 224 0069 WWW.PECKSHAFFER.COM Diana B. Silveira dsilveira@peckshaffer.com Our firm is acting as. Bond Counsel in connection with the proposed issuance of tax- exempt bonds (the "Bonds") by the Public Finance Authority, a body corporate and politic of the State of Wisconsin (the "Authority"), for the benefit of the Educational Media Foundation, a California nonprofit corporation (the "Borrower"). According to the Borrower, the Borrower's primary educational and cultural benefits include the direct broadcast of educational programs, extensive promotion of cultural and charitable opportunities and sponsorship of and partnership with a wide variety of local and national non-profit groups to advance community improvement. The Authority will loan the proceeds of the Bonds to the Borrower to (a) refinance the cost of acquiring a certain Federal Communications Commission (FCC) license for a radio station, (b) refinance the cost of acquiring certain related equipment and (c) pay certain costs of issuing the Bonds (collectively, the "La Porte Project"). The FCC license is assigned to the City of LaPorte, Texas (the "City"), and the radio antenna relating to the station is located approximately 11.3 miles northwest of Winnie, Texas, off F -M 1410 in Liberty County, Texas. The Borrower operates radio stations in several states and is an organization described in Section 501(c)(3) of the Internal Revenue Code of 1986, as amended (the "Code"), based on its educational mission which it furthers with these stations. The Authority is empowered to issue the Bonds for the La Porte Project pursuant to Section 66.0304 of the Wisconsin Statutes, as amended. Federal tax law plays a large role in tax-exempt financings, including the one required in connection with the La Porte Project. In order to complete this tax-exempt financing and refinance the La Porte Project in the City, the Borrower needs your assistance in meeting the following tax law requirements: ATLANTA CHICAGO CINCINNATI COLUMBUS COVINGTON DENVER