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R2009-148 - 2009-09-14RESOLUTION NO. R2009-148 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PEARLAND, TEXAS, APPROVING A BOND ORDER OF BRAZORIA COUNTY MUNICIPAL UTILITY DISTRICT N0.2 AUTHORIZING THE ISSUANCE OF $6,390,000 UNLIMITED TAX AND REVENUE REFUNDING BONDS, SERIES 2009. WHEREAS, the Brazoria County Municipal Utility District No. 2 (the "District") is located within the extraterritorial jurisdiction and the incorporated limits of the City of Pearland, Texas (the "City"); and WHEREAS, by Resolution No. R 81-2, dated January 26, 1981, the City consented to the creation of the District, and placed certain conditions on the issuance of bonds by the District, including the approval by the City Council of the District's issuance of such bonds; and WHEREAS, the City Council has considered the District's proposed $6,390,000 Unlimited Tax and Revenue Refunding Bonds, Series 2009, and has found it to be acceptable; now, therefore, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF PEARLAND, TEXAS: Section 1. All of the matters and facts set forth in the preamble hereof are true and correct. Section 2. The bond order of the board of directors of Brazoria County Municipal Utility District No. 2, authorizing the issuance of its $6,390,000 Unlimited Tax and Revenue Refunding Bonds, Series 2009, is hereby approved. Section 3. This Resolution shall take effect immediately from and after its passage in accordance with the provisions of the Charter of the City of Pearland and it is accordingly so resolved. RESOLUTION NO. R2009-148 PASSED, APPROVED and ADOPTED this the 14t"day of Sep ber, A. D., 2009. £~.Q TO REID MAYOR ATTEST: Y NG G, C Y S ETAR APPROVED AS TO FORM: 1.~---~ DARRIN M. COKER CITY ATTORNEY ACE ItowNF.0FIMMJAS!NC eK/:7a8119tirt3 Nr►MMARKS THIS MAT:I AST PACE--Ave Isvulkl,nn Primliftn i BOD Ff67748 002.00.00.00 6 E M o PRELIMINARY OFFICIAL STATEMENT DATED SEPTEMBER 9, 2009 22>t This Preliminary Official Statement is subject to completion and amendment and is intended solely for the solicitation ofinitiai bids to o a c purchase the Bonds.Upon the sale of the Bonds,the Official Statement will be completed and delivered to the Underwriters. 7:a o EL THE DELIVERY OF THE BONDS IS SUBJECT TO THE OPINIONS OF BOND COUNSEL AS TO THE VALIDITY OF THE BONDS m m AND OF SPECIAL TAX COUNSEL,TO THE EFFECT THAT INTEREST ON THEBONDS IS EXCLUDABLE FROM GROSS INCOME FOR a7 , FEDERAL INCOME TAXATION,UNDER EXISTING STATUTES,REGULATIONS,PUBLISHED RULINGS AND COURT DECISIONS,AS u w m DESCRIBED UNDER"TAX MATTERS"HEREIN.SEE"LEGAL MATTERS"AND "TAX MATTERS"HEREIN FOR A DISCUSSION OF moo THE OPINIONS OF BOND COUNSEL AND SPECIAL TAX COUNSEL, INCLUDING A DESCRIPTION OFALTERNATIVE AIINIMUM 3 v, TAX CONSEQUENCES FOR CORPORATIONS. m as The District has designated the Bonds as "Qualified Tar-Ereanpt Obligations"for financial institutions. See "TAX MATTERS— o`m 2 Qualified Tar-Ereiupt Obligations"herein, m a'0 NEW ISSUE Standard&Poor's Ratings Services( )..."AAA" o Va v (See 93OND INSURANCE"and "RATINGS"herein) 0 itsE $6,390,000 N N BRAZORIA COUNTY MUNICIPAL UTILITY DISTRICT NO. 2 ,fit a (A Political Subdivision of the State of Texas,located within Brazoria County,Texas) 5 O f°U WATERWORKS AND SEWER SYSTEM COMBINATION E o' si UNLIMITED TAX AND REVENUE REFUNDING BONDS, SERIES 2009 m m ff Dated:October 1,2009 • Due:September 1,as shown below m c Principal of the above-described bonds(the"Bonds")is payable at stated maturity or redemption upon presentation of the N ° Bonds at the principal payment office of the paying agent/registrar,initially,The Bank of New York Mellon Trust Company, N.A.,currently in Dallas,Texas,or any successor paying agent/registrar(the"Paying Agent,""Registrar"or"Paying Agent/ 2I'm Registrar").Interest on the Bonds is payable on March 1,2010(five-month interest payment),and on each September 1 and ~a 2 March 1 thereafter until maturity or prior redemption.The Bonds will be issued as fully registered Bonds in the denomination of E .co ° $0,000 or integral multiples thereof.The Bonds are not subject to optional redemption prior to their scheduled maturities. =E•°c The Bonds will be registered in the name of Cede&Co.,as nominee for The Depository Trust Company,New York,New E m York("DTC"),which will act as securities depository for the Bonds.Beneficial owners of the Bonds will not receive physical n ra 3 certificates representing the Bonds,but will receive a credit balance on the books of the nominees of such beneficial owners.So °•'a1 long as Cede&Co.is the registered owner of the Bonds,the principal of and interest on the Bonds will bepaid bythe Pain oL S P P Paying Agent directly to DTC,which will,in turn,remit such principal and interest to its participants For subsequent disbursement to the ag, beneficial owners of the Bonds as described herein. See"THE BONDS—Book-Entry-Only System." E S.3 The scheduled payment of the principal of and interest on the Bonds when due will be guaranteed under an insurance policy o a° to be issued by concurrently with the delivery of the Bonds by . y F PRINCIPAL AMOUNTS,MATURITIES,INTEREST RATES AND INITIAL REOFFERING RING YIELDS m= Initial Initial m ° Principal Maturity Interest Reoffering Principal Maturity Interest Reoffering •c H o Amount (September t) Rate Yieid(a) Amount (September 1) Role Yield(a) m aa3 re m $105,000 2010 % 95 S965,000 2014 R.L':a 800,000 2011 9E0.000 2015 -0'm Ti 810.000 2012 860,000 2016 ' g L_ 940,000 2013 890,000 2017 o' o (a) Information with respect to the initial reoffering yields of the Bonds has been provided by the Underwriters(hereinafter defined).Initial reoffering yields 0 Cc representing the initial offering price to the public of a substantial amount of the Bonds[breach maturity,which may be changed for subsequent purchasers. o '7 m-mow The proceeds of the Bonds,together with certain lawfully available funds of the District,will be applied to refund certain E�0 outstanding bonds of the District and to pay certain costs incurred in connection with the issuance of the Bonds.See"PLAN OF t€3 FINANCING—Use of Bond Proceeds."The Bonds,when issued,will constitute valid and binding obligations of the District m 2 c and will be payable from the proceeds of an annual ad valorem tax,without legal limitation as to rate or amount,levied against P E all taxable property located within the District,and are further payable from and secured by a pledge of and lien on certain Net E E° Revenues(as defined herein),if any,of the District's waterworks and sewer system(the"System"),to the extent and upon the i:0 N conditions described herein.The System Is not expected to produce sufficient Net Revenues to make significant contributions,if m m:3 any,to future debt service payments.See"THE BONDS—Source of Payment."Neither the State of Texas,Brazoria County, m—_,, Texas,the City of Pearland,Texas,nor any political subdivision other than the District shall be obligated to pay the principal of Nro and interest on the Bonds.Neither the faith and credit nor the taxing power of the State of Texas,Brazoria County,Texas,nor the 7,'a c City of Pearland,Texas, is pledged to the payment of the principal of and interest on the Bonds. o E� The Bonds will be delivered when, as and if issued and accepted by the Underwriters, subject to prior sale and to the m 9'; approval of the Attorney General of Texas; Paul A. .Phi lbin & Assoc., P.C., Houston, Texas, Bond Counsel, and McCall, E rna N Parkhurst&Horton L.L.P.,Dallas,Texas,Special Tax Counsel.Certain legal matters will be passed upon for the Underwriters •• by McCall,Parkhurst&Horton L.L.P.,Dallas,Texas. Delivery of the Bonds is expected on or about October .2009. Ncir RBC CAPITAL MARKETS Ht`o FIRST SOUTHWEST COMPANY TABLE OF CONTENTS Page USE OF INFORMATION IN OPEICIAL STATEMENT 3 SALE AND DISTRIBUTION OF THE BONDS 3 Underwriters 3 Prices and Marketability 3 Securities Laws 4 BOND INSURANCE 4 Bond Insurance Policy 4 RATINGS 4 OFFICIAL STATEMENT SUMMARY 5 INTRODUCTION 12 THE BONDS 12 General 12 Book-Entry-Only System 12 Assignments,Transfers and Exchanges 14 Authorization of the Bonds 14 Source of Payment 14 Redemption Provisions 15 Defeasance 15 Amendments to Bond Order 16 Annexation and Consolidation 16 Legal Ability to Issue Additional Debt 16 Registered Owners'Remedies 17 Bankruptcy Limitation to Registered Owners'Rights 17 Legal Investment and Eligibility to Secure Public Funds in Texas 18 PLAN OF FINANCING 19 Use of Bond Proceeds 19 The Non-Refunded Bonds 20 Escrow Agreement 21 Sources and Uses of Funds 21 INVESTMENT CONSIDERATIONS 22 General 22 Factors Affecting Taxable Values and Tax Payments 22 Maximum Impact on District Tax Rates 22 Tax Collection Limitations 23 Production of Net Revenues 23 Registered Owners'Remedies and Bankruptcy 23 Marketability 24 Future Debt 24 Continuing Compliance with Certain Covenants 24 AERIAL PHOTOGRAPH OF THE DISTRICT 25 PHOTOGRAPHS WITHIN THE DISTRICT 26 PHOTOGRAPHS WITHIN 1'Hh DISTRICT 27 DISTRICT DEBT 28 General 28 Bonded Indebtedness 28 Estimated Direct and Overlapping Debt Statement 29 Debt Service Requirements 30 TAXING PROCEDURES 31 Authority 31 Exempt Property 31 County-Wide Appraisal District 32 Assessment and Levy 32 District and Taxpayer Remedies 33 Collection 33 Rollback 33 District's Rights in the Event of Tax Delinquencies 33 TAX DATA 34 General 34 Maintenance Tax 34' Historical Values and Tax Collection History 35 Tax Rate Calculations 36 Tax Rate Distribution 36 Analysis of Tax Base 37 Principal 2009 Property Owners 37 Estimated Overlapping Taxes 38 THE DISTRICT 38 Authority 38 Description 38 Silverlake Project 39 Management of the District 39 DEVELOPMENT AND HOME CONSTRUCTION 40 Land Development and Home Construction Summary 41 FUTURE DEVELOPMENT 42 THE SYSTEM 42 Regulation 42 Description 43 Waterworks and Sewer System Operating Statement 45 LEGAL MArthRS 46 Legal Opinions 46 No Arbitrage 46 No-Litigation Certificate 47 No Material Adverse Change 47 TAX MATTERS 47 Opinion 47 Federal Income Tax Accounting Treatment of Original Issue Discount 48 Collateral Federal Income Tax Consequences 48 State,Local and Foreign Taxes 49 Qualified Tax-Exempt Obligations 49 VERIFICATION OF ACCURACY OF MATHEMATICAL COMPUTATION 50 SOURCES OF INFORMATION 50 General 50 Experts 50 Certification of Official Statement 50 Official Statement"Deemed Final" 51 CONTINUING DISCLOSURE OF INFORMATION 51 Annual Reports 51 Material Event Notices 51 Availability of Information from NRMSIRs,SID and MSRB 52 Limitations and Amendments 52 Updating of Official Statement 53 APPENDIX A-LOCATION MAP APPENDIX B-ANNUAL FINANCIAL REPORT APPENDIX C-SPECIMEN OF FINANCIAL GUARANTY INSURANCE POLICY 2 USE OF INFORMATION IN OFFICIAL STATEMENT No dealer, broker, salesman or other person has been authorized by the District or the Underwriters to give any information or to make any representations other than those contained in this Official Statement,and,if given or made, such other information or representations must not be relied upon as having been authorized by the District or the Underwriters. This Official Statement does not constitute,and is not authorized by the District for use in connection with,an offer to sell or the solicitation of an offer to buy in any state in which such offer or solicitation is not authorized or in which the person making such offer or solicitation is not qualified to do so or to any person to whom it is unlawful to make such offer or solicitation, All of the summaries of the statutes,resolutions,orders,contracts,audits,engineering and other related reports set forth in this Official Statement are made subject to all of the provisions of such documents. These summaries do not purport to be complete statements of such provisions,and reference is made to such documents,copies of which are available from the District upon payment of the costs for duplication thereof. This Official Statement contains, in part, estimates, assumptions and matters of opinion which are not intended as statements of fact, and no representation is made as to the correctness of such estimates, assumptions or matters of opinion,or as to the likelihood that they will be realized. Any information and expressions of opinion herein contained are subject to change without notice,and neither the delivery of this Official Statement nor any sale made hereunder shall,under any circumstances,create any implication that there has been no change in the condition of the District or other matters described herein since the date hereof. However,the District has agreed to keep this Official Statement currentby amendment or sticker to reflect material changes in the affairs of the District,and to the extent that information actually comes to its attention,the other matters described in this Official Statement,until delivery of the Bonds to the Underwriters of the Bonds,as shown on the cover page hereof The Underwriters(defined below)have provided the following sentence for inclusion in this Official Statement. The Underwriters have reviewed the information in this Official Statement in accordance with, and as part of; their responsibilities to investors under the federal securities laws as applied to the facts and circumstances ofthis transaction, but the Underwriters do not guarantee the accuracy or completeness of such information. SALE AND DISTRIBUTION OF THE;BONDS Underwriters RBC Capital Markets Corporation and First Southwest Company (the"Underwriters")have agreed,pursuant to aBand Purchase Agreement,to purchase the Bonds from the District for$ plus accrued interest from October 1, 2009,to the date of delivery. The obligation of the Underwriters to purchase the Bonds is subject to certain conditions contained in the Bond Purchase Agreement. The Underwriters may offer and sell the Bonds to certain dealers(including dealers depositing Bonds into unit investment trusts)and others at prices lower than public offering price stated on the cover page hereof. The initial offering price maybe changed from time to time by the Underwriters. Prices and Marketability The delivery of the Bonds is conditioned upon the receipt by the District of a certificate executed and delivered by the Underwriters on or before the date of delivery of the Bonds stating the prices at which a substantial amount of the Bonds of each maturity have been sold to the public. For this purpose the term"public"shall not include any person who is a bond house,broker or similar person acting in the capacity of Underwriters or wholesaler. The District has no control over trading of the Bonds after a bona fide offering of the Bonds is made by the Underwriters at the yields specified on the cover page. Information concerning reoffering yields or prices is the responsibility of the Underwriters. 3 The District has no control over the reoffering yields or prices of the Bonds or over trading ofthe Bonds in the secondary market. Moreover,there is no assurance that a secondary market will be made in the Bonds. If there is a secondary market,the difference between the bid and asked prices of the Bonds may be greater than the difference between the bid and asked prices of bonds of comparable maturity and quality issued by more traditional municipal entities,as bonds of such entities are more generally bought,sold or traded in the secondary market. The prices and other terms respecting the offering and sale of the Bonds may be changed from time to time by the Underwriters after the Bonds are released for sale,and the Bonds may be offered and sold at prices other than the initial offering price,including sales to dealers who may sell the Bonds into investment accounts. IN CONNECTION WITH THE OFFERING OF THE BONDS,THE UNDERWRITERS MAY OVER-ALLOT OR EFFECT TRANSACTIONS WHICH STABILIZE OR MAINTAIN THE MARKET PRICE OF 1Hh BONDS AT A LEVEL ABOVE THAT WHICH MIGHT 0 1'HhRWISE PREVAIL IN THE OPEN MARKET. SUCH STABILIZING,IF COMMENCED, MAY BE DISCONTINUED AT ANY TIME. Securities Laws No registration statement relating to the Bonds has been filed with the Securities and Exchange Commission under the Securities Act of 1933,as amended,in reliance upon the exemptions provided thereunder.The Bonds have not been registered or qualified under the Securities Act of Texas in reliance upon various exemptions contained therein,nor have the Bonds been registered or qualified under the securities laws of any other jurisdiction. The District assumes no responsibility for registration or qualification of the Bonds under the securities laws of any other jurisdiction in which the Bonds maybe offered,sold or otherwise transferred.This disclaimer ofresponsibility forregistration or qualification for sale or other disposition of the Bonds shall not be construed as an interpretation of any kind with regard to the availability of any exemption from securities registration or qualification provisions in such other jurisdictions. BOND INSURANCE Bond Insurance Policy Concurrently with the issuance of the Bonds, (" ")will issue its Municipal Bond Insurance Policy for the Bonds(the"Policy"). The Policy guarantees the scheduled payment ofprincipal of and interest on.the Bonds when due as set forth in the form of the Policy included as"APPENDIX C"to this Official Statement. BOND INSURANCE RISK FACTORS In the event of default of the payment of principal or interest with respect to the Bonds when all or some becomes due, any owner of the Bonds shall have a claim under the Policy for such payments. However,in the event of any acceleration of the due date of such principal by reason of mandatory or optional redemption or acceleration resulting from default or otherwise,other than any advancement of maturity pursuant to a mandatory sinking fund payment,the payments are to be made in such amounts and at such times as such payments would have been due had there not been any such acceleration. The Policy does not insure against redemption premium,if any. The payment ofprincipal and interest in connection with mandatory or optional prepayment of the Bonds by the issuer which is recovered by the issuer from the bond owner as a voidable preference under applicable bankruptcy law is covered by the insurance policy,however,such payments will be made by the Insurer at suchtime and in such amounts as would have been due absence such prepayment by the District unless the Insurer chooses to pay such amounts at an earlier date. Undermost circumstances,default of payment of principal and interest does not obligate acceleration of the obligations of the Insurer without appropriate consent. The Insurer may direct and must consent to any remedies and the Insurer's consent may be required in connection with amendments to any applicable bond documents. 4 In the event the Insurer is unable to make payment of principal and interest as such payments become due under the Policy,the Bonds are payable solely from the moneys received pursuant to the applicable bond documents. In the event the Insurer becomes obligated to make payments with respect to the Bonds,no assurance is given that such event will not adversely affect the market price of the Bonds or the marketability(liquidity)for the Bonds. The long-term ratings on the Bonds are dependent in part on the financial strength of the Insurer and its claim paying ability. The Insurer's financial strength and claims paying ability are predicated upon a number of factors which could change over time. No assurance is given that the long-term ratings of the Insurer and of the ratings on the Bonds insured by the Insurer will not be subject to downgrade and such event could adversely affect the market price of the Bonds or the marketability(liquidity)for the Bonds. See"BOND INSURANCE"and"RATINGS"herein. The obligations ofthe Insurer are contractual obligations and in an event of defaultby the Insurer,the remedies available maybe limited by applicable bankruptcy law or state Iaw related to insolvency of insurance companies. Neither the District or Underwriter have made independent investigation into the claims paying ability of the Insurer and no assurance or representation regarding the financial strength or projected financial strength of the Insurer is given. Thus,when making an investment decision,potential investors should carefully consider the ability of the District to pay principal and interest on the Bonds and the claims paying ability of the Insurer, particularly over the life of the investment. See"BOND INSURANCE"herein for further information provided by the Insurer and the Policy,which includes further instructions for obtaining current financial information concerning the Insurer. RATINGS Standard&Poor's Ratings Services("Standard&Poor's")is a division of The McGraw Hill Companies,Inc.,a New York corporation. Standard&Poor's is located at 55 Water Street,New York,New York 10041,telephone number (212)208-8000,and has engaged in providing ratings for corporate bonds since 1923 and municipal bonds since 1940. Long-term debt ratings assigned by Standard.&Poor's reflect its analysis of the overall level of credit risk involved in financings. At present Standard&Poor's assigns long-term debt ratings with symbols "AAA" (the highest rating) through'D"(the lowest rating). The Bonds are expected to receive an initial rating of"AAA"from Standard&Poor's solely in reliance upon its evaluation of the claims paying ability of the Insurer. The underlying credit rating of the District assigned by Standard &Poor's is"A-I-." An explanation of the significance of the foregoing ratings may only be obtained from Standard&Poor's. The foregoing ratings express only the view of Standard&Poor's at the time the ratings are given. Furthermore,a security rating is not a recommendation to buy,sell orhold securities.There is no assurance that the ratings will continue for any given period of time or that they will not be revised downward or withdrawn entirely by Standard&Poor's, if, in its judgment, circumstances so warrant. Any such downward change in or withdrawal of such ratings may have an adverse effect on the market price of the Bonds. The District is not aware of any ratings assigned the Bonds other than the ratings of Standard&Poor's. 5 OFFICIAL STATEMENT SUMMARY The following summary of certain information contained herein is qualified in its entirety by the detailed information and financial statements appearing elsewhere in this Official Statement. The reader should refer particularly to sections that are indicated for more detailed information. THE BONDS The Issuer Brazoria County Municipal Utility District No.2(the"District")is a political subdivision of the State of Texas located in Brazoria County,Texas. See "THE DISTRICT." Description $6,390,000 Waterworks and Sewer System Combination Unlimited Tax and Revenue Refunding Bonds,Series 2009(the"Bonds"),are dated October 1,2009,and mature on September 1 of the years and in the principal amounts indicated on the cover page hereof. Interest on the Bonds is payable on March 1, 2010 (five-month interest payment), and on each September I and March 1 thereafter until maturity or prior redemption. The Bonds are not subject to optional redemption prior to their scheduled maturities. See"THE BONDS." The Bonds will be issued pursuant to a bond order(the "Bond Order") adopted by the Board of Directors of the District. See"THE BONDS-General." The Bonds are being issued under the authority of Chapters 49 and 54 of the Texas Water Code, as amended, and Chapter 1207, Texas Government Code. Book-Entry-Only System The definitive Bonds will be initially registered and delivered only to Cede&Co.,the nominee of DTC,pursuant to the Book-Entry-Only System described herein. Beneficial ownership of the Bonds may be acquired in denominations of$5,000 or integral multiples thereof.No physical delivery of the Bonds will be made to the beneficial owners thereof. Principal of and interest on the Bonds will be payable by the Paying Agent/Registrar to Cede&Co.,which will make distribution of the amounts so paid to the participating members of DTC for subsequentpaymentto the beneficial owners of the Bonds(see"THE BONDS-Book-Entry-Only System"). Source of Payment Principal of and interest on the Bonds are payable from the proceeds of an annual ad valorem tax, without legal limitation as to rate or amount,levied upon all taxable property located within the District, and are further payable from and secured by a pledge of and lien on certain Net Revenues (as defined herein), if any, of the District's waterworks and sewer system (the "System"), to the extent and upon the conditions described herein. The System is not expected to produce sufficient Net Revenues to make significant contributions, if any, to future debt service payments. The Bonds are obligations of the District and are not obligations of Brazoria County,Texas,the State of Texas or any political subdivision other than the District. See"THE BONDS-Source of Payment," "TAX DATA - Tax Rate Calculations," and "INVESTMENT CONSIDERATIONS -Maximum Impact on District Tax Rates". 6 Other Characteristics The Bonds will be issued in fully registered form in the denomination of$5,000 each, or integral multiples thereof. Use of Proceeds Proceeds of the sale of the Bonds,together with certain funds of the District that are lawfully available for such purpose,will be applied to refund certain of the District's Waterworks and Sewer System Combination Unlimited Tax and Revenue Bonds, Series 1997(the "Series 1997 Bonds"),Waterworks and Sewer System Combination Unlimited Tax and Revenue Refunding Bonds, Series 1998 (the "Series 1998 Refunding Bonds"), Waterworks and Sewer System Combination Unlimited Tax and Revenue Bonds, Series 1999(the "Series 1999 Bonds") and Waterworks and Sewer System Combination Unlimited Tax and Revenue Bonds, Series 2002(the "Series 2002 Bonds") in the aggregate principal amount of $5,980,000. The proceeds will also be used to pay certain costs of issuing the Bonds. The Bonds are being issued to reduce the District's debt service payments, and will result in present value savings in such debt service payments. See "PLAN OF FINANCING" and "DISTRICT DEBT - Debt Service Requirements." Payment Record In addition to the Series 1997 Bonds,Series 1998 Refunding Bonds, Series 1999 Bonds and Series 2002 Bonds, the District has • previously issued Waterworks and Sewer System Combination Unlimited Tax and Revenue Bonds, Series 1985(the "Series 1985 Bonds"),Unlimited Tax Refunding Bonds,Series 1992(the"Series 1992 Refunding Bonds"), Waterworks and Sewer System Combination Unlimited Tax and Revenue Bonds, Series 1995 (the "Series 1995 Bonds"),Waterworks and Sewer System Combination Unlimited Tax and Revenue Refunding Bonds, Series 2003, (the "Series 2003 Refunding Bonds"), and Waterworks and Sewer System Combination Unlimited Tax and Revenue Bonds, Series 2004 (the "Series 2004 Bonds"). The District issued the Series 1992 Refunding Bonds to advance refund and defease certain maturities of the Series 1985 Bonds, issued the Series 1998 Refunding Bonds to advance refund and defease certain maturities of the Series 1992 Refunding Bonds, and issued the Series 2003 Refunding Bonds to advance refund and defease certain maturities of the Series 1995 Bonds. Collective reference is made in this Official Statement to the Series 1985 Bonds, the Series 1992 Refunding Bonds, the Series 1995 Bonds, the Series 1997 Bonds, the Series 1998 Refunding Bonds,the Series 1999 Bonds,the Series 2002 Bonds,the Series 2003 Refunding Bonds and the Series 2004 Bonds as the "Outstanding Bonds." The District has never defaulted in the timely payment of principal of and interest on the Outstanding Bonds. After issuance of the Bonds, the aggregate principal amount of the Outstanding Bonds, less the maturities thereof previously paid by the District and less the Refunded Bonds, will be$5,030,000(the "Remaining Outstanding Bonds"), and the aggregate principal amount of the District's total direct bonded indebtedness, including the Bonds, will be $11,420,000. See "DISTRICT DEBT-Debt Service Requirements." 7 Authorized but Unissued Bonds $2,845,000 in bonds for waterworks, sanit ary sewer,and drainage facilities and for refunding purposes will remain authorized but unissued after issuance of the Bonds. See "THE BONDS-Legal Ability to Issue Additional Debt." Municipal Bond Insurance (" "). See"BOND INSURANCE" Municipal Bond Ratings Standard & Poor's Ratings Services ( ) "AAA" See "BOND INSURANCE"and"RATINGS." Qualified Tax-Exempt Obligations The District will designate the Bonds as "qualified tax-exempt obligations" pursuant to Section 265 (b) of the Internal Revenue Code of 1986,as amended. See"TAX MATTERS-Qualified Tax- Exempt Obligations"herein. Legal and Tax Opinions Paul A. Philbin&Assoc., P.C., Houston,Texas, Bond Counsel; and McCall, Parkhurst&Horton L.L.P., Dallas, Texas, Special Tax Counsel. See"LEGAL MATTERS"and"TAX MATTERS." Verification Agent Grant Thornton LLP, Certified Public Accountants. See "VERIFICATION OF ACCURACY OF MATHEMATICAL COMPUTATION." Authority The rights, powers, privileges, authority and functions of the District are established by Article XVI, Section 59 of the Constitution of the State of Texas and the general laws of the State of Texas pertaining to municipal utility districts, particularly Chapters 49 and 54 of the Texas Water Code, as amended. See "THE DISTRICT-Authority." THE DISTRICT Description Brazoria County Municipal Utility District No. 2, a political subdivision of the State of Texas,was created by the Texas Water Commission,predec essor to the Texas Commission on Environmental Quality(the"TCEQ"or the"Commission"),on July 16, 1981. The District contains approximately 636.6 acres of land, including approximately 23.5 acres annexed by the District in 1998. The District is located approximately 5 miles west of and lies entirely within the extraterritorial jurisdiction of the City of Pearland,Texas. State Highway 288 is located approximately 0.6 miles west of the northwestern boundary of the District and County Road 518 forms the northernmost boundary of the District. The District is located approximately twelve and one-halfmiles south of the central business district of the City of Houston and approximately eleven and one-half miles south of the Texas Medical Center complex. Silverlake Project The District is part of a master-planned,mixed-use land development project which is now known and is being marketed as Sliverlake (formerly known as Southwyck), which includes an aggregate of approximately 2,050 acres of land, approximately 1,000 acres of 8 which were purchased by New Southwyck,L.P.("New Southwyck") in 1994.Amenities within Silverlake include an 18 hole daily fee golf course and club house,pools,playgrounds, soccer fields, baseball fields and a major recreation center consisting of 4 tennis courts, walking paths,community activities and meeting center and a junior Olympic pool. Silverlake includes the approximate 636.6 acres located within the District, approximately 518 acres located in Brazoria County Municipal Utility District No. 1("M.U.D.No. 1"), approximately477 acres located in Brazoria CountyMunicipal Utility District No. 3 ("M.U.D. No. 3"), and approximately 418 of an aggregate approximately 778 acres currently located in Brazoria County Municipal Utility District No.6("M.U.D.No.6"). Land use intended for M.U.D.No.'s 1,2,and 3 is predominantly single-family residential. M.U.D.No. 6 is being developed for residential and commercial use. The development of all of the land located within the District which is available for development is complete. Such development includes an aggregate of 1,114 single-family residential lots on approximately 372.8 acres and 57 townhome lots on approximately 10.0 acres,on all 1,114 of which fully developed single-family lots and 57 townhomc lots residences have been constructed,all of which residences have been sold to home purchasers,plus approximately 10.2 acres that have been developed for commercial purposes on which above- ground improvements including two shopping centers totaling approximately 93,579 square feet of building area have been constructed, and includes the construction of underground water distribution, wastewater collection, and storm sewer facilities and street paving as is enumerated in this Official Statement under the caption'DEVELOPMENT AND HOME CONSTRUCTION-Land Development and Home Construction Summary." In addition to the development of the District,(i)the development of a total of 1,356 single-family residential lots is complete in M.U.D. No. 1, (ii) the development of a total of 1,411 single-family residential lots is complete inM.U.D.No.3,and(iii)the development of 1,308 single-family residential lots is complete in M.U.D.No.6. 11 holes of the Southwyck Golf Course plus an approximate 6,000 square foot clubhouse, and other facilities including a restaurant, men's and women's locker rooms, and a golf cart barn are located within the District,and the balance of the golf course is located within M.U.D.Nos.3 and 6. See"APPENDIX A-LOCATION MAP"and "DEVELOPMENT AND HOME CONSTRUCTION." Authority The rights,powers,privileges,authority and functions of the District are established by Article XVI,Section 59 of the Constitution of the State of Texas and the general Iaws of the State of Texas pertaining to municipal utility districts,particularly Chapters 49 and 54 of the Texas Water Code,as amended. See"TBE DISTRICT-Authority." 9 Development and Home Construction .... The development of all of the land located within the District which is available for development is complete. Such development includes an aggregate of 1,114 single-family residential lots on approximately 372.8 acres and 57 townhome lots on approximately 10.0 acres,on all 1,114 of which fully developed single-family residential lots and 57 townhome lots residences have been constructed, all of which residences have been sold to home purchasers,plus approximately 10.2 acres that have been developed for commercial purposes on which above-ground improvements including two shopping centers totaling approximately 93,579 square feet ofbuilding area have been constructed, and includes the construction of underground water distribution, wastewater collection, and storm sewer facilities and street paving as is enumerated in this Official Statement under the caption'DEVELOPMENT AND HOME CONSTRUCTION-Land Development and Home Construction Summary." 11 holes of the 18 hole Southwyck Golf Course (approximately 134.7 acres),plus an approximate 6,000 square foot clubhouse, and other facilities including a restaurant,men's and women's locker rooms,and a golf cart barn are also located within the District. Approximately 108.9 District acres are contained within street and drainage ditch rights-of- way,various easements,Lake Silverlake,parks and open space or are otherwise not available for future development. • The construction of(i)a regional wastewater treatment facility,(ii) joint water supply facilities, and(iii)joint drainage facilities,all of which facilities the District shares with M.U.D.No.1,M.U.D.No.3 and M.U.D.No.6,is also complete. The District financed its portion of the cost of the acquisition or construction of certain of the aforementioned components of its system(the"System"),and certain other facilities, with portions of the proceeds of the sale of the Outstanding Bonds and will finance additions thereto which are described in this Official Statement under the caption "THE SYSTEM"with portions of the proceeds of the sale of the Bonds. INVESTMENT CONSIDERATIONS THE BONDS ARE SUBJECT TO SPECIAL INVESTMENT CONSIDERATIONS AS SET FORTH IN THIS OFFICIAL STATEMENT. PROSPECTIVE PURCHASERS SHOULD CAREFULLY EXAMINE THE ENTIRE OFFICIAL STATEMENT BEFORE MAKING THEIR INVESTMENT DECISIONS,SPECIALLY THE PORTION OF THE OFFICIAL STATEMENT ENTITLED"INVESTMENT CONSIDERATIONS." • 10 SELECTED FINANCIAL INFORMATION (Unaudited) 2008 Assessed Valuation $319,394,796(a) (As of January 1,2008) See"TAX DATA"and"TAXIING PROCEDURES." 2009 Assessed Valuation $319,928,913(b) (As of January 1,2009) See"TAX DATA"and"TAXING PROCEDURES." Direct Debt Remaining Outstanding Bonds $ 5,030,000(c) The Bonds 6,390,000 Total $ 11,420,000 Estimated Overlapping Debt $ 18.524,782 Direct and Estimated Overlapping Debt $29,944,782 Direct Debt Ratio : as a percentage of 2008 Assessed Valuation($319,394,796) 3.58% : as a percentage of2009 Assessed Valuation($319,928,913) 3.57% Direct and Estimated Overlapping Debt Ratio : as a percentage of 2008 Assessed Valuation($319,394,796) 9.38% : as a percentage of 2009 Assessed Valuation($319,928,913) 9.36% Bond Fund Balance at Delivery of the Bonds $ 1,590,995(d) • General Fund Balance as of July 2,2009 $2,934,818 Average Percentage of Total Tax Collections 1998-2007 99.96% Percentage of Tax Collections 2008 Tax Levy (As of July 31,2009. In process of collection.) 9931% 2009 Tax Rate per$100 of Assessed Valuation Debt Service Tax $0.46 Maintenance Tax .04 Total $0.50(d) Average Annual Debt Service Requirements of the Bonds and the Remaining Outstanding Bonds(2010-2017) $1,645,666 Maximum Annual Debt Service Requirement of the Bonds and the Remaining Outstanding Bonds(2009) $1,661,226 Tax Rate per$100 of Assessed Valuation Required to Pay Average Annual Debt Service Requirements of the Bonds and the Remaining Outstanding Bonds (2010-2017)at 95%Tax Collections Based Upon 2008 Assessed Valuation($319,394,796) $0.55 Based Upon 2009 Assessed Valuation($319,928,913) $0.55 11 Tax Rate per$100 of Assessed Valuation Required to Pay Maximum Annual Debt Service Requirement of the Bonds and the Remaining Outstanding Bonds(2017)at 95%Tax Collections Based Upon 2008 Assessed Valuation($319,394,796) $0.55 Based Upon 2009 Assessed Valuation($319,928,913) $0.55 Total Number of Single-Family Housing Units(1,114)and Townhomes(57) 1,171 (a) As of January 1,2008. All property in the District is valued an the tax rolls by the Brazoria County Appraisal District(the"Appraisal District")at 100%of estimated market value as of January 1 of each year. The District's tax roll is certified by the Brazoria County Appraisal Review Board(the"Appraisal Review Board"). See "TAXING PROCEDURES"and"INVESTMENT CONSIDERATIONS-Factors Affecting Taxable Values and Tax Payments." (b) As of January 1,2009. All property in the District is valued on the tax rolls by the Brazoria County Appraisal District(the"Appraisal District")at 100%of estimated market value as ofJanuary 1 of each year. The District's tax roll is certified by the Brazoria County Appraisal Review Board(the"Appraisal Review Board"). Such sum includes certain values which have not been certified by the Appraisal Review Board,including the value of certain properties which has been proposed by the Appraisal District but protested by the owners thereof to the Appraisal District and the value of certain properties not under protest but not yet certified. The Appraisal District's estimate of the total taxable value of such properties under protest which will be assigned to such properties if the owners' claims are upheld by the Appraisal Review Board is$30,647,483, which sum is included in the amount of$319,928,913. The Appraisal District has proposed the valuation of such protested properties to be$34,052,759. The District is unable to predict the amount of the District's final 2009 Assessed Valuation. Such final 2009 Assessed Valuationwill notbe determined until the valuation of all taxable property located within the District is certified by the Appraisal Review Board for 2009. See "TAXING PROCEDURES" and"INVESTMENT CONSIDERATIONS -Factors Affecting Taxable Values and Tax Payments." (c) Excludes the Refunded Bonds. See "DISTRICT DEBT," and "THE BONDS - Legal Ability to Issue Additional Debt." (d) Neither the Bond Order or Texas lawrequires that any particular amount be maintained in the Bond Fund at any time. Such sum gives effect to the payment by the District of the entirety of its debt service payments due for 2009. See`PLAN OF FINANCING." 12 BRAZORIA COUNTY MUNICIPAL UTILITY DISTRICT NO.2 WATERWORKS AND SEWER SYSTEM COMBINATION UNLIMITED TAX AND REVENUE REFUNDING BONDS SERIES 2009 INTRODUCTION This Official Statement provides certain information with respect to the issuance by Brazoria County Municipal Utility District No.2,Brazoria County,Texas(the"District")of its Waterworks and Sewer System Combination Unlimited Tax and Revenue Refunding Bonds, Series 2009(the "Bonds"). There follow in this Official Statement descriptions of the Bonds,the Plan of Financing,and certain information about the District and its finances. All descriptions of documents contained herein are only summaries and are qualified in their entirety by reference to each such document. Copies of such documents may be obtained from the District upon request and payment of the costs of duplication therefor. Certain capitalized terms used in this Official Statement have the same meanings assigned to such terms in the Bond Order(hereinafter defined),except as otherwise indicated herein. THE BONDS General The following is a description of certain terms and conditions of the Bonds, which description is qualified in its entirety by reference to the resolution of the Board of Directors of the District(the"Board")authorizing the issuance of the Bonds (the "Bond Order"). A copy of the Bond Order may be obtained from the District upon request and payment of the costs of duplication thereof. The Bond Order authorizes the issuance and sale of the Bonds and prescribes the terms, conditions and provisions for the payment of the principal of and interest on the Bonds by the District. The Bond Order also approves and authorizes execution of the Escrow Agreement with the Escrow Agent and the Bond Purchase Agreement with the Underwriters, all as hereinafter defined. The Bonds are dated September 1,2009,and will mature on September 1 of the years and in the principal amounts indicated on the cover page hereof. The Bonds will accrue interest from October 1,2009(or the most recent interest payment date to which interest has been paid or duly provided for)at the stated interest rates indicated on tbe cover page ofthis Official Statement. Interest on the Bonds is payable on March 1,2010(five-month interest payment),and on each March I and September 1 thereafter until maturity or prior redemption. The Bonds will be issued as fully registered bonds in the denomination of$5,000 or any integral multiple thereof. Principal of the Bonds will be payable to the registered holder thereof(the"Registered Owner")at maturity or earlier redemption upon presentation ofBands at the principal payment office of the paying agent/registrar,initially,The Band of New York Mellon Trust Company,N.A., currently in Dallas, Texas, or any successor paying agent/registrar (the "Paying Agent," "Registrar" or "Paying Agent/Registrar"). Interest on the Bonds will be payable by check,dated as of the interest payment date,and mailed by the Registrar to Registered Owners as shown on the records of the Registrar at the close of business on the 15th day of the calendar month next preceding each interest payment date(the"Record Date"),or by other such customary banking arrangements as maybe acceptable to the Registrar and the Registered Owner at the expense and risk of the Registered Owner. Book-Entry-Only System DTC will act as securities depository for the Bonds.The Bonds will be issued as fully-registered securities in the name of Cede&Co.(DTC's partnership nominee)or such other name as may be requested by an authorized representative of DTC.One fully-registered certificate will be issued for the Bonds,in the aggregate principal amount of such issue, and will be deposited with DTC. 13 DTC, the world's largest securities depository, is a limited-purpose trust company organized under the New York Banking Law,a`banking organization"within the meaning of the New York Banking Law,a member of the Federal Reserve System, a"clearing corporation"within the meaning of the New York Uniform Commercial Code, and a "clearing agency"registered pursuant to the provisions of Section 17A of the Securities Exchange Act of 1934. DTC holds and provides asset servicing for over3.5 million issues of U.S.and non-U.S.equity issues,corporate and municipal debt issues,and money market instruments from over 100 countries that DTC's participants("Direct Participants") deposit with DTC. DTC also facilitates the post-trade settlement among Direct Participants of sales and other securities transactions in deposited securities,through electronic computerized book-entry transfers and pledges between Direct Participants' accounts. This eliminates the need for physical movement of securities certificates.Direct Participants include both U.S.and non-U.S.securities brokers and dealers,banks,trust companies,clearing companies,and certain other organizations. DTC is a wholly-owned subsidiary of The Depository Trust&Clearing Corporation("DTCC"). DTCC is the holding company for DTC, National Securities Clearing Corporation and Fixed Income Clearing Corporation,all of which are registered clearing agencies. DTCC is owned by the users of its regulated subsidiaries. Access to the DTC system is also available to others such as both U.S. and non-U.S.securities brokers and dealers, banks,trust companies, and clearing companies that clear through or maintain a custodial relationship with a Direct Participant,either directly or indirectly("Indirect Participants").DTC has Standard&Poor's highest rating:AAA.The DTC Rules applicable to its Direct and Indirect Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtcc.com and www.dtc.oru. Purchases of Bonds under the DTC system must be made by or through Direct Participants,which will receive a credit for the Bonds on DTC's records. The ownership interest of each actual purchaser of each Bond("Beneficial Owner") is in turn to be recorded on the Direct and Indirect Participants'records.Beneficial Owners will not receive written confirmation from DTC of their purchase.Beneficial Owners are,however,expected to receive written confirmations providing details ofthe transaction as well as periodic statements oftheir holdings,fromthe Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the Bonds are to be accomplished by entries made on the books of Direct and Indirect Participants acting on behalf of Beneficial Owners. Beneficial Owners will not receive certificates representing their ownership interests in Bonds,except in the event that use of the book-entry system for the Bonds is discontinued. To facilitate subsequent transfers,all Bonds deposited by Direct Participants with DTC are registered in the name of DTC's partnership nominee,Cede&Co.,or such other name as may be requested by an authorized representative of DTC. The deposit ofBonds with DTC and their registration in the name of Cede&Co.or such other DTC nominee do not effect any change in beneficial ownership. DTC has no knowledge of the actual Beneficial Owners of the Bonds; DTC's records reflect only the identity ofthe Direct Participants to whose accounts suchBonds are credited,which may or may not be the Beneficial Owners. The Direct and Indirect Participants will remain responsible for keeping account of their holdings on behalf of their customers. Conveyance of notices and other communications by DTC to Direct Participants,by Direct Participants to Indirect Participants,and by Direct Participants and IndirectParticipants to Beneficial Owners wlllbe governed by arrangements among them,subject to any statutory or regulatory requirements as maybe in effect from time to time.Beneficial Owners ofBonds may wish to take certain steps to augment the transmission to them ofnotices of significant events with respect to the Bonds,such as redemptions,tenders,defaults,and proposed amendments to the Bond documents. For example, Beneficial Owners of Bonds may wish to ascertain that the nominee holding the Bonds for their benefit has agreed to obtain and transmit notices to Beneficial Owners.In the alternative,Beneficial Owners may wish to provide their names and addresses to the Registrar and request that copies of notices be provided directly to them. Redemption notices shall be sent to DTC. If less than all of the Bonds within an issue are being redeemed,DTC's practice is to determine by lot the amount of the interest of each Direct Participant in such issue to be redeemed. Payments on the Bonds will be made to Cede&Co., or such other nominee as may be requested by an authorized representative of DTC. DTC's practice is to credit Direct Participants' accounts upon DTC's receipt of fiords and corresponding detail information from District or Paying Agent,on payable date in accordance with their respective holdings shown on DTC's records. Payments by Participants to Beneficial Owners will be governed by standing 14 instructions and customary practices,as is the case with securities held for the accounts of customers in bearer form or registered in"street name,"and will be the responsibility of such Participant and not of DTC nor its nominee,Paying Agent,or District,subject to any statutory or regulatory requirements as may be in effect from time to time. Payment to Cede&Co.(or such other nominee as maybe requested by an authorized representative of DTC)is the responsibility of the District or Paying Agent. Disbursement of such payments to Direct Participant will be the responsibility ofDTC, and reimbursement of such payments to the Beneficial Owners will be the responsibility of Direct and Indirect Participants. DTC may discontinue providing its services as depository with respect to the Bonds at any time by giving reasonable notice to the District or PayingAgent Under such circumstances,in the event that a successor depository is not obtained, Bond certificates are required to be printed and delivered. The District may decide to discontinue use of the system ofbook-entry transfers through DTC(or a successor securities depository). In that event,Band certificates will be printed and delivered to DTC. The information in this section concerning DTC and DTC's book:entry system has been obtained from sources that the District believes to be reliable,but the District takes no responsibility for the accuracy thereof Assignments,Transfers and Exchanges The Bonds may be transferred, registered and assigned only on the registration books of the Registrar, and such registration and transfer shall be without expense or service charge to the Registered Owner,except for any tax or other governmental charges required to be paid with respect to such registration and transfer in accordance with the terms of the Band Order. A Bond may be assigned by the execution of an assignment form on the Bonds or by other instrument of transfer and assignment acceptable to the Registrar.At any time after the date of delivery of the Bonds to the Initial Purchaser(the"Initial Delivery"),any Bond maybe transferred or exchanged upon its presentment and surrender at the office of the Registrar,duly endorsed for transfer or accompanied by an assignment duly executed by the Registered Owner.To the extent possible,new Bands issued in an exchange or transfer of Bonds willbe delivered to the Registered Owner or assignee of the owner in not more than three(3)business days after the receipt of the request in proper form to transfer,exchange or replace the Bonds.New Bonds registered and delivered in an exchange or transfer shall be in denominations of$5,000 or any integral multiple thereof for any one maturity and for a lice aggregate principal amount as the Bond or Bonds surrendered for exchange or transfer.Neither the District nor the Registrar is required(1) to transfer or exchange any Bond during a period beginning at the opening ofbusiness an a Record Date and ending at the close of business on the next succeeding interest payment date,or(2)to transfer or exchange any Bond selected for redemption in whole or in part within thirty(30)calendar days of the redemption date. In the event the book-entry-only system is discontinued,the District has agreed to replace mutilated,destroyed,lost or stolen Bonds upon surrender of the mutilated Bonds,or receipt of satisfactory evidence of such destruction,loss or theft and receipt by the District and the Registrar of security or indemnity to keep them harmless.The District will require payment of taxes,governmental charges and other expenses in connection with any such replacement. • Authorization of the Bonds At elections held within the District on November 3, 1981, and September 8, 1984, the voters of the District authorized the issuance of an aggregate of$23,400,000 in bonds for waterworks, sanitary sewer, and drainage facilities,and for refunding purposes. The Bonds are issued pursuant to the authority of the Bond Order;Article XVI, Section 59 of the Texas Constitution;Chapters 49 and 54 of the Texas Water Code, as amended; and Chapter 1207, Texas Government Code. See"Legal Ability to Issue Additional Debt"below. Source of Payment The Bonds, when issued, will constitute valid and binding obligations of the District, and the principal thereof and the interest thereon, together with the principal of and interest on the Remaining Outstanding Bonds and such additional tax bonds of the District as may hereafter be issued by the District, if any, are payable from and secured 15 by the proceeds of an annual ad valorem tax, without legal limitation as to rate or amount levied against all taxable property located within the District. The District has the authority to levy an annual ad valorem tax without limit as to rate or amount on all taxable property within the District for each year the Bonds are outstanding. In the Bond Order, the District has covenanted to establish a rate of taxation each year ample and sufficient to provide fluids to pay the interest on the Bonds and to pay the principal when due, full allowance being made for delinquencies and costs of collection. The Bonds are further payable from and secured by a pledge of and lien on certain Net Revenues,if any,of the System. Net Revenues are defined by the Bond Order as all income that is derived from the ownership and operation of the District's System as the same is purchased,constructed or otherwise acquired,which remains after deducting the operation and maintenance expenses of the System,but not including income derived from contracts that is pledged for payment of any special project bonds that may be issued. It is not expected that the Net Revenues will ever be sufficient to contribute significantly,if at all,to debt service payments. See"THE SYSTEM-Waterworks and Sewer System Operating Statement" See"TAXING PROCEDURES"and"TAX DATA-Tax Rate Calculations"for tax adequacy, manner of assessing and collecting taxes,and the remedy to the District in the event oftax delinquencies;and"Registered Owners'Remedies"below for the remedies available to Bondholders in the event of default in the performance of any of the covenants set forth in the Bond Order or in the event of default in the payment of principal of or interest on the Bonds. The Bonds are solely obligations ofBrazoria County Municipal Utility DistrictNo.2 and are not obligations of the State of Texas,Brazoria County,Texas,the City of Pearland,Texas, or any political subdivision or agency other than the District. Redemption Provisions The Bonds are not subject to optional redemption prior to their scheduled maturities. Defeasance The Bond Order provides that the District may discharge its obligations to the Registered Owners of any or all of the Bonds to pay principal,interest and redemption price thereon in any manner permitted bylaw. Under current Texas law, such discharge may be accomplished either(i)by depositing with the Comptroller of Public Accounts of the State of Texas a sum of money equal to the principal of,premium,if any,and all interest to accrue on the Bonds to maturity or redemption or(ii)by depositing with any place of payment(paying agent) of the Bonds or other obligations of the District payable from revenues or from ad valorem taxes or both,or with a bank or commercial trust company named in the proceedings authorizing such discharge,amounts sufficient to provide for the payment and/or redemption of the Bonds;provided that such deposits may be invested and reinvested only in(a) direct noncaIlable obligations of the United States of America,(b)noncallable obligations of an agency or instrumentality of the United States,including obligations that are unconditionally guaranteed or insured by the agency or instrumentality and that, on the date the governing body of the District adopts or approves the proceedings authorizing the issuance of refunding bonds,are rated as to investment quality by a nationally recognized investment rating fnn not less than AAA or its equivalent,and(c) non-callable obligations of a state or an agency or a county,municipality,or other political subdivision of a state that have been refunded and that; on the date the governing body of the District adopts or approves the proceedings authorizing the issuance of refunding bonds,are rated as to investment quality by a nationally recognized investment rating firm not less than AAA or its equivalent,and which mature and/or bear interest payable at such times and in such amounts as will be sufficient to provide for the scheduled payment and/or redemption of the Bonds. Upon such deposit as described above,such Bonds shall no longer be regarded as outstanding or unpaid. After firm banking and financial arrangements for the discharge and final payment or redemption of the Bonds have been made as described above,all rights of the District to initiate proceedings to call the Bonds for redemption or take any other action amending the terms of the Bonds are extinguished;provided,however,that the right to call the Bonds for redemption is not extinguished if the District: (i)in the proceedings providing for the firm banking and financial arrangements, expressly reserves the right to call the Bonds for redemption;(ii)gives notice of the reservation of that rightto the owners of the Bonds immediately following the making of the firm banking and financial arrangements; and(in)directs that notice of the reservation be included in any redemption notices that it authorizes. 16 There is no assurance that the current law will not be changed in the future in a manner which would permit investments other than those described above to be made with amounts deposited to defease the Bonds.Because the Bond Order does not contractually limit such investments,Registered Owners may be deemed to have consented to defeasance with such other investments,notwithstanding the fact that such investments may not be of the same investment quality as those currently permitted under Texas law. Amendments to Bond Order The District may,without the consent of or notice to any Registered Owners of the Bonds,amend,change or modify the Band Order as maybe required(a)by the provisions thereof,(b)for the purpose of curing any ambiguity,inconsistency, or formal defect or omission therein,or(c)in connection with any other change which is not to the prejudice of the Registered Owners of the Bonds. Except for such amendments,changes,or modifications,the District shall not amend, change or modify the Bond Order in any manner without the consent of the Registered Owners of the Bonds. Annexation and Consolidation The District lies within the extraterritorial jurisdiction of the City ofPearland,Texas(the"City").Under Texas statutes, the District may be annexed in whole,but not in part,by the City without the District's consent,in which case the City must dissolve the District and assume the assets,functions and obligations of the District, including the Bonds,the Remaining Outstanding Bonds,and any other bonded indebtedness of the District existing at the time of annexation. The District and the City ofPearland are currently negotiating the terms of a strategic partnership agreement("SPA"). When any bonds or other obligations of the District payable in whole or inpart from ad valorem taxes have been assumed by the City,the City is required to levy and cause to be collected,upon all taxable property within the City, taxes sufficient to pay principal of and interest on any such bonds or obligations as they become due and payable. The City may issue refunding bonds in its own name to refund any bonds or obligations so assumed. Until such time as the SPA is executed by the District and the City,the District cannot represent any specific element of such SPA,or that it will become effective at all. Therefore,no representation is made that the City will ever abolish the District and assume its debt,nor that the City would be able to pay such debt service obligations Wit were to annex the District. The District has the right to consolidate with other districts and,in connection therewith,to provide for the consolidation of its System with the water and sewer systems of the district or districts with which it is consolidating.No representation is made that the District will ever consolidate its System with another district or consolidate its System with other systems. Legal Ability to Issue Additional Debt The District has reserved the right in the Bond Order to issue additional bonds. Following the issuance of the Bonds, and the refunding of the Refunded Bonds,the District will have the right to issue$2,845,000 in bonds for waterworks, sanitary sewer,and drainage facilities,and for refunding purposes,as approved by the District's voters at elections held on November 3,1981 and September 8,1984. The District has the right to issue the aforementioned bonds without the necessity of further voter authorization. Except for such refunding bonds,before issuing any additional bonds for waterworks,sanitary sewer,and drainage facilities, the District would have to obtain approval of the Texas Commission on Environmental Quality(the"TCEQ"),for the issuance of such bonds and the projects to be financed thereby. The District has the right to issue such additional tax bonds,revenue bonds,or combination tax and revenue bonds as maybe hereafter approved by the voters of the District. The District also has the right to issue revenue notes,bond anticipation notes and tax anticipation notes without the necessity of voter approval. In addition,the District has the right to enter into contracts and to pledge its taxing power to secure any payments the District is required to make under such a contract,provided the provisions of the contract are approved by the voters of the District. The District further has the right to issue refunding bonds,in addition to the refunding bonds described above,with additional voter approval. The Bond Order places no limitation on the amount of additional bonds which maybe issued by the District 17 According to the District's Engineer,the District with the proceeds ofthe Outstanding Bonds has financed all ofthe water supply and distribution,wastewater collection and treatment,and storm drainage facilities that are necessary to serve the entirety ofthe District. Therefore,the District does not presently foresee the need to issue additional taxbonds to finance additions to the System, although the District cannot represent that the need for such future issuance might not materialize. See"THE BONDS-Legal Ability to Issue Additional Debt" Registered Owners'Remedies The Band Order contains a covenant that while any part of the Bonds is outstanding,there shall be assessed,levied,and collected an annual ad valorem tax, without limit as to rate or amount, on all taxable property within the District, sufficient to pay principal of and interest on the Bonds when due and to pay the expenses necessary in collecting taxes. Texas law and the Bond Order provide that in the event that the District defaults in the payment of the principal of or interest on any of the Bonds when due,fails to make payments required by the Bond Order into the Bond Fund,or defaults in the observance orperformance of any of the covenants,conditions,or obligations set forth in the Bond Order, any Registered Owner shall be entitled at any time to a writ of mandamus from a court of competent jurisdiction compelling and requiring the Board of Directors of the District to observe and perform any covenant,obligation, or condition prescribed by the Bond Order. Such right is in addition to all other rights the Registered Owners may be provided by the laws of the State of Texas. Except for mandamus,the Bond Order does not specifically provide for remedies to a Registered Owner in the event of a District default,nor does itprovide for the appointment of a trustee to protect and enforce the interests of the Registered Owners. There is no acceleration of maturity of the Bonds in the event of default. Consequently, the remedy of mandamus is a remedy which may have to be relied upon from year to year by the Registered Owners. Although the Registered Owners could obtain a judgment against the District,such judgment could not be enforced by direct levy and execution against the District's property.Further,the Registered Owners cannot themselves foreclose onpropertywithin the District or sell property within the District in order to pay the principal of and interest on the Bonds. The enforceability of the rights and remedies of the Registered Owners may be further limited by federal bankruptcy laws, reorganization,or other similar laws of general application affecting the rights of creditors ofpolitical subdivisions such as the District. See`Bankruptcy Limitation to Registered Owners'Rights"below. Bankruptcy Limitation to Registered Owners'Rights The enforceability of the rights and remedies of the Registered Owners may be limited by laws relating to bankruptcy, reorganization or other similar laws of general application affecting the rights of creditors ofpolitical subdivisions such as the District. Subject to the requirements of Texas law,the District may voluntarily proceed under Chapter 9 of the Federal Bankruptcy Code,11 U.S.C.§§901-946,if the District(1)is generally authorized to file for federalbanlauptcy protection by State law,(2)is insolvent or unable to meet its debts as they mature,(3)desires to effect a plan to adjust such debts,and(4)has either obtained the agreement of or negotiated in good faith with its creditors or is unable to negotiate with its creditors because negotiation is impracticable. Under recent Texas legislation, a municipal utility district, such as the District,must obtain the approval of the TWC prior to filing for bankruptcy. Such legislation requires that the TWC investigate the financial condition of the District and authorize the District to proceed only if the District has fully exercised its rights and powers under Texas law and remains unable to meet its debts and other obligations as they mature. lithe District decides in the future to proceed voluntarily under the Federal Bankruptcy Code,the District would develop and file a plan for the adjustment of its debts,and the Bankruptcy Court would confirm the District's plan if(1)the plan complies with the applicable provisions of the Federal Bankruptcy Code,(2)all payments to be made in connection with the plan are fully disclosed and reasonable,(3)the District is not prohibited by law from taking any action necessary to carry out the plan,(4)administrative expenses are paid in full,and(5)the plan is in the best interests of creditors and is feasible. The rights and remedies of the Registered Owners would be adjusted in accordance with the confirmed plan of adjustment of the District's debt. See"INVESTMENT CONSIDERATIONS." The District may not be placed into bankruptcy involuntarily. 18 Legal Investment and Eligibility to Secure Public Funds in Texas The following is quoted from Section 49.186 of the Texas Water Code,and is applicable to the District "(a) All bonds,notes,and other obligations issued by a district shall be legal and authorized investments for all banks,trust companies,building and loan associations,savings and loan associations,insurance companies of all kinds and types,fiduciaries,and trustees, and for all interest and sinking funds and other public funds of the state, and all agencies,subdivisions,and instrumentalities of the state,including all counties,cities,towns,villages,school districts, and all other kinds and types of districts,public agencies,and bodies politic. "(b) A district's bonds,notes,and other obligations are eligible and lawful security for all deposits ofpublic funds of the state,and all agencies,subdivisions,and instrumentalities of the state,including all counties,cities,towns,villages, school districts,and all other kinds and types of districts,public agencies,and bodies politic,to the extent of the market value of the bonds,notes,and other obligations when accompanied by any unmatured interest coupons attached to them." The Public Funds Collateral Act(Chapter 2257, Texas Government Code) also provides that bonds of the District (including the Bonds)are eligible as collateral for public funds. No representation is made that the Bonds will be suitable for or acceptable to financial or public entities for investment or collateral purposes. No representation is made concerning other laws,rules,regulations or investment criteria which apply to or which might be utilized by any of such persons or entities to limit the acceptability or suitability of the Bonds for any of the foregoing purposes. Prospective purchasers are urged to carefully evaluate the investment quality of the Bonds as to the suitability or acceptability of the Bonds for investment or collateral purposes. PLAN OF FINANCING Use of Bond Proceeds Proceeds of the sale of the Bonds,together with certain funds of the District that are lawfully available for such purpose, will be applied to refund certain of the District's Waterworks and Sewer System Combination Unlimited Tax and Revenue Bonds,Series 1997(the"Series 1997 Bonds"),Waterworks and Sewer System Combination Unlimited Tax and Revenue Refunding Bonds, Series 1998 (the"Series 1998 Refunding Bonds") , Waterworks and Sewer System Combination Unlimited Tax and Revenue Bonds, Series 1999 (the "Series 1999 Bonds") and Waterworks and Sewer System Combination Unlimited Tax and Revenue Bonds, Series 2002 (the "Series 2002 Bonds") in the aggregate principal amount of$5,980,000. The proceeds will also be used to pay certain costs of issuing the Bonds. The Bonds are being issued to reduce the District's debt service payments, and will result in present value savings in such debt service payments. See "DISTRICT DEBT-Debt Service Requirements." The principal amounts and maturity dates of the Series 1997 Bonds,Series 1998 Refunding Bonds,Series 1999 Bonds and the Series 2002 Bonds to be advance refunded (collectively, the"Refunded Bonds"), are set forth below. Refunded Series Refunded Series Refunded Series Refunded Series Maturing 1997 Bonds 1998 Refunding Bonds 1999 Bonds 2002 Bonds September 1 Principal Amount Principal Amount Principal Amount Principal Amount 2011 S200,000 S340,000 $155,000 2012 205,000 355,000 165,000 2013 215,000 375,000 I70,000 120,000 2014 230,000. 390,000 175,000 135,000 2015 595,000 235,000 135,000 2016 635,000 235,000 2017 675.000 240.000 $2,755,000 $1,460,000 S1,375,000 $390,000 Redemption Date: 10/ /2009 10/ /2009 10/ /2009 10/ /2009 Aggregate Principal Amount of Refunded Bonds: $5,980,000 19 The Non-Refunded Bonds(Remaining Outstanding Bonds) In addition to the Series 1997 Bonds, Series 1998 Refunding Bonds, Series 1999 Bonds and Series 2002 Bonds, the District has previously issued Waterworks and Sewer System Combination Unlimited Tax and Revenue Bonds, Series 1985(the"Series 1985 Bonds"),Unlimited Tax Refunding Bonds, Series 1992(the "Series 1992 Refunding Bonds"), Waterworks and Sewer System Combination Unlimited Tax and Revenue Bonds,Series 1995(the"Series 1995 Bonds"), Waterworks and Sewer System Combination Unlimited Tax and Revenue Refunding Bonds, Series 2003, (the"Series 2003 Refunding Bonds"),and Waterworks and Sewer System Combination Unlimited Tax and Revenue Bonds,Series 2004(the "Series 2004 Bonds"). The District issued the Series 1992 Refunding Bonds to advance refund and defease certain maturities of the Series 1985 Bonds, issued the Series 1998 Refunding Bonds to advance refund and defease certain maturities of the Series 1992 Refunding Bonds,and issued the Series 2003 Refunding Bonds to advance refund and defease certain maturities of the Series 1995 Bonds. Collective reference is made in this Official Statement to the Series 1985 Bonds,the Series 1992 Refunding Bonds,the Series 1995 Bonds, the Series 1997 Bonds, the Series 1998 Refunding Bonds,the Series 1999 Bonds,the Series 2002 Bonds,the Series 2003 Refunding Bonds and the Series 2004 Bonds as the"Outstanding Bonds." The District has never defaulted in the timely payment of principal of and interest on the Outstanding Bonds. After issuance of the Bonds, the aggregate principal amount of the Outstanding Bonds,less the maturities thereof previously paid by the District and less the Refunded Bonds,will be$5,030,000(the"Remaining Outstanding Bonds"),and the aggregate principal amount of the District's total direct bonded indebtedness, including the Bonds, will be$11,420,000. See "DISTRICT DEBT-Debt Service Requirements." The principal amounts and maturity dates of the Remaining Outstanding Bonds are as follows. Series 1998 Maturity Series 1997 Bonds Refunding Bonds Series 1999 Bonds September 1 Principal Amount Principal Amount Principal Amount 2010 $185,000 $325,000 $ 155,000 $185,000 $325,000 $155,000 Series 2003 Maturity Series 2002 Bonds Refunding Bonds Series 2004 Bonds September 1 Principal Amount Principal Amount Principal Amount 2010 $105,000 $245,000 $140,000 2011 110,000 255,000 145,000 2012 115,000 270,000 155,000 2013 290,000 165,000 2014 300,000 175,000 2015 320,000 185,000 2016 145,000 340,000 195,000 2017 145.000 360.000 205.000 $620,000 $2,380,000 $1,365,000 Total principal amount of Remaining Outstanding Bonds $5,030,000 20 Sources and Uses of Funds The proceeds from the sale of the Bonds will be applied as follows: SOURCES OF FUNDS: Principal Amount of Bonds Plus: Premium District Contribution Accrued Interest Less: Original Issue Discount Total Sources of Funds USES OF FUNDS: Escrow Fund Deposit Accrued Interest to Bond Fund Expenses: Underwriters Discount Municipal Bond Insurance Premium and Other Issuance Expenses Total Uses of Funds INVESTMENT CONSIDERATIONS General The Bonds,which are obligations of the District and not of the State of Texas,Brazoria County,Texas,or any political subdivision other than the District,are secured by a continuing,direct,annual ad valorem tax,without legal limitation as to rate or amount,on all taxable property located within the District,and are further payable from and secured by a pledge of and lien on certain Net Revenues (as defined herein), if any, of the District's waterworks and sewer system(the "System"),to the extent and upon the conditions described herein. The System is not expected to produce sufficient Net Revenues to make significant contributions, if any,to future debt service payments. See"THE BONDS -Source of Payment." The ultimate security for payment of the principal of and interest on the Bonds depends upon the ability of the District to(i)collect from the property owners within the District taxes Ievied against all taxable property located within the District,or,in the event taxes are not collected and foreclosure proceedings are institutedby the District,upon the value of the taxable property with respect to taxes levied by the District and by other taxing authorities,and(ii)generate Net Revenues from the operation of the District's System. The District makes no representations that over the life of the Bonds the property within the District will maintain a value sufficient to justify continued payment of taxes by the property owners,or that any Net Revenues will be generated. The potential increase in taxable valuation of District property will be primarily as a result of increases in the value of existing homes,which is directly related to the economics of the residential housing industry,not only due to general economic conditions,but also due to the particular factors discussed below. Maximum Impact on District Tax Rates The value of the Iand and improvements currently located within the District will be a major determinant of the ability of the District to collect,and the willingness of District property owners to pay,ad valorem taxes levied by the District. The 2008 Assessed Valuation of property within the District is$319,394,796. (See"TAX DATA"). After issuance of the Bonds, the Maximum Annual Debt Service Requirement on the Bonds and the Remaining Outstanding Bonds will be $1,661,226(2017)and the Average Annual Debt Service Requirements will be$1,645,666(2010 through 2017,inclusive). Assuming no increase to or decrease fromtlie 2008 Assessed Valuation,and no use of other legally available Districtfunds, a tax rate of$0.55 per$100 of Assessed Valuation at a 95%collection rate would be necessary to pay the Maximum Annual Debt Service Requirement and the Average Annual Debt Service Requirements. The 2009 Assessed Valuation of propertywithin the District is$319,928,913. Assuming no increase to or decrease from the 2009 Assessed Valuation, 21 and no use of other legally available District funds,a tax rate of$0.55 per$100 of Assessed Valuation at a 95%collection rate would be necessary to pay the Maximum Annual Debt Service Requirement and the Average Annual Debt Service Requirements. The District levied a debt service tax in 2009 of$0.46 per$100 of Assessed Valuation,plus a maintenance tax of$0.04 per$100 of Assessed Valuation,for a total 2009 District tax rate of$0.50 per$100 of Assessed Valuation.As the above information illustrates,the 2009 debt service tax rate of$0.46 per$100 of Assessed Valuation is not sufficient to pay the Average Annual Debt Service Requirements on the Bonds and the Remaining Outstanding Bonds,assuming the District's tax base at the level of the 2008 Assessed Valuation or the 2009 Assessed Valuation,and assuming no use of other legally available District funds,95%tax collections and the issuance of no additional bonds by the District. The District's Bond Fund balance is estimated to be$1,157,818 upon delivery of the Bonds. Although neither Texas law nor the Bond Order requires that any specific amount be retained in the Bond Fund at any time,the District has in the past applied earnings from the investment ofmonies held in the Bond Fund to meet the debt service requirements of the Remaining Outstanding Bonds (see"APPENDIX B-ANNUAL FINANCIAL REPORT"). In addition,the District had,at July 31,2009,total annual tax collections averaging 99.96%for the years 1998 through 2007,and had collected 99.31%of its 2008 tax levy,which was in the process of collection,as of that date. Therefore,the District anticipates being able to pay the Average Annual and Maximum Annual Debt Service Requirements of the Bonds and the Remaining Outstanding Bonds without increasing its debt service levy above the level of the 2009 debt service levy of$0.46 per$100 ofAssessed Valuation. See"TAXING PROCEDURES"and"TAX DATA-Tax Rate Calculations." Tax Collection Limitations The District's ability to make debt service payments may be adversely affected by its inability to collect ad valorem taxes. Under Texas law,the levy of ad valorem taxes by the District constitutes a lien in favor of the District on a parity with the liens of all other state and Iocal taxing authorities on the property against which taxes are levied,and such lien maybe enforced by foreclosure. The District's ability to collect ad valorem taxes through such foreclosure may be impaired by the amount of taxes owed to other taxing units,a bankruptcy court's stay of tax collection procedures against a taxpayer, and market conditions limiting the proceeds from a foreclosure sale of taxable property. The District's lien on taxable property within the District for taxes levied against such property can be foreclosed only in a judicial proceeding. See "TAXING PROCEDURES-District's Rights in the Event of Tax Delinquencies." Production of Net Revenues The Net Revenues,if any,to be derived from the operation of the System are entirely dependent upon sales of water and sewer services to current and future residents and users of the System and related operating expenses. The District does not expect that the operation of the System will produce net operating revenue sufficient to make a significant contribution, if any,to the District's debt service requirements. The District's General Fund balance(audited)as of December 31,2008, was$2,913,286(audited),and as of July 2,2009,was$2,934,818(unaudited). See"THE SYSTEM-Waterworks and Sewer System Operating Statement" Registered Owners'Remedies and Bankruptcy In the event of default in the payment of principal of or interest on the Bonds,the Registered Owners have a right to seek a writ of mandamus requiring the District to levy adequate taxes each year to make such payments. Except for mandamus, the Bond Order does not provide for remedies to protect and enforce the interests of the Registered Owners. There is no acceleration of maturity of the Bonds in the event of default and,consequently,the remedy of mandamus may have to be relied upon from year to year. Although the Registered Owners could obtain a judgment against the District,such a judgment could not be enforced by a direct levy and execution against the District's property. Further,the Registered Owners cannot themselves foreclose on property within the District or sell property of the District in order to pay the principal of and interest on the Bonds. Since there is no trust indenture or trustee,the Registered Owners would have to initiate and finance the legal process to enforce their remedies. The enforceability of the rights and remedies of the Registered Owners further may be limited by laws relating to bankruptcy,reorganization or other similar laws of general 22 application affecting the rights of creditors ofpolitical subdivisions such as the District. In this regard,should the District file a petition for protection from creditors under federal bankruptcy laws,a suit seeking the remedy of mandamus would be automatically stayed and could not be pursued unless authorized by a federal bankruptcy judge. See"THE BONDS -Bankruptcy Limitation to Registered Owners'Rights." Marketability The District has no understanding(other thou the initial reoffering yields)with the Underwriter regarding the reoffering yields or prices of the Bonds and has no control over the trading of the Bonds in the secondary market. There is no assurance that a secondary market wiII be made for the Bonds. If there is a secondary market,the difference between the bid and asked price of the Bonds may be greater than the bid and asked spread of other bonds generally bought,sold or traded in the secondary market. See"SALE AND DISTRIBUTION OF THE BONDS." Future Debt The District has reserved in the Bond Order the right to issue the remaining$2,845,000 in bonds authorized but unissued for waterworks,sanitary sewer and drainage facilities, and for refunding purposes, and such additional bonds as may hereafter be approved by both the Board of Directors and voters of the District. The District also has reserved the right to issue certain other additional bonds,special project bonds,and other obligations described in the Bond Order. All of the remaining bonds authorized for waterworks,sanitary sewer and drainage facilities,and for refunding purposes,which have heretofore been authorized by voters of the District may be issued by the District from time to time as needed. If additional bonds are issued in the future andproperty values have not increased proportionately,such issuance may increase gross debt/property valuation ratios and thereby adversely affect the investment quality or security of the Bonds and the Remaining Outstanding Bonds. According to the District's Engineer,the District with the proceeds of the Outstanding Bonds has financed all of the water supply and distribution,wastewater collection and treatment, and storm drainage facilities that are necessary to serve the entirety of the District. Therefore,the District does not presently foresee the need to issue additional taxbonds to finance additions to the System,although-the District cannot represent that the need for such future issuance might not materialize. See"THE BONDS-Legal Ability to Issue Additional Debt,""DEVELOPMENT AND HOME CONSTRUCTION"and"nib SYSTEM." Continuing Compliance with Certain Covenants The Bond Order contains covenants by the District intended to preserve the exclusion from gross income of interest on the Bonds. Failure by the District to comply with such covenants on a continuous basis prior to maturity of the Bonds could result in interest on the Bonds becoming taxable retroactively to the date of original issuance. See"TAX MATTERS." 23 AERIAL PHOTOGRAPH OF THE DISTRICT (taken August,2009) 24 PHOTOGRAPHS WITHIN THE DISTRICT (taken August,2009) • 25 PHOTOGRAPHS WITHIN THE DISTRICT (taken August,2009) 26 DISTRICT DEBT General The following tables and calculations relate to the Bonds and the Remaining Outstanding Bonds. After issuance of the Bonds, the aggregate principal amount of the Outstanding Bonds, less the Refunded Bonds, will be $5,030,000 (the "Remaining Outstanding Bonds"),and the District's total bonded indebtedness,including the Bonds,will be$11,420,000. The District is empowered to incur debt to be paid from revenues raised by taxation against all taxable property located within the District,and various other political subdivisions of government which overlap all or a portion of the District are empowered to incur debt to be paid from revenues raised or to be raised by taxation against all or a portion of the property within the District. Bonded Indebtedness 2008 Assessed Valuation $319,394,796(a) (As of January 1,2008) See"TAX DATA"and"TAXING PROCEDURES." 2009 Assessed Valuation $319,928,913(b) (As of January 1,2009) See"TAX DATA"and"TAXING PROCEDURES." Direct Debt: Remaining Outstanding Bonds $ 5,030,000(c) The Bonds 6,390,000 Total $ 11,420,000 Estimated Overlapping Debt $ 18,524,782 Direct and Estimated Overlapping Debt $29,944,782 Direct Debt Ratio : as a percentage of 2008 Assessed Valuation($319,394,796) 3.58% : as a percentage of 2009 Assessed Valuation($319,928,913) 3.57% Direct and Estimated Overlapping Debt Ratio : as a percentage of 2008 Assessed Valuation($319,394,796) 9.38°%o : as a percentage of 2009 Assessed Valuation($319,928,913) 9.36% Bond Fund Balance at Delivery of the Bonds $ 1,590,995(d) General Fund Balance as of July 2,2009 $ 2,934,818 (a) As of January 1,2008. All property in the District is valued on the tax rolls by the Brazoria County Appraisal District(the"Appraisal District")at 100%of estimated market value as of January 1 of each year. The District's tax roll is certified by the Brazoria County Appraisal Review Board (the "Appraisal Review Board"). See 'TAXING PROCEDURES"and"INVESTMENT CONSIDERATIONS-Factors Affecting Taxable Values and Tax Payments." (b) As of January 1,2009. All property in the District is valued on the tax rolls by the Brazoria County Appraisal District(the"Appraisal District")at 100%of estimated market value as of January 1 of each year. The District's tax roll is certified by the Brazoria County Appraisal Review Board(the"Appraisal Review Board"). Such sum includes certain values which have not been certified by the Appraisal Review Board, including the value of certain properties which has been proposed by the Appraisal District but protested by the owners thereof to the 27 Appraisal District and the value of certain properties not under protest but not yet certified. The Appraisal District's estimate of the total taxable value of such properties under protest which will be assigned to such properties if the owners'claims are upheld by the Appraisal Review Board is$30,647,483,which total is included in the amount of$319,928,913. The Appraisal District has proposed the valuation of such protested properties to be$34,052,759. The District is unable to predict the amount of the District's final 2009 Assessed Valuation. Such final 2009 Assessed Valuation will not be determined until the valuation of all taxable property located within the District is certified by the Appraisal Review Board for 2009. See"TAXING PROCEDURES"and "INVESTMENT CONSIDERATIONS-Factors Affecting Taxable Values and Tax Payments." (c) Excludes the Refunded Bonds. See "THE BONDS-Legal Ability to Issue Additional Debt." (d) Neither the Bond Order or Texas law requires that any particular amount be maintained in the Bond Fund at any time. Such sum gives effect to the payment by the District of the entirety of its debt service payments due for 2009. See"PLAN OF FINANCING." 28 Estimated Direct and Overlapping Debt Statement The following statement indicates the direct and estimated overlapping debt of the District. The table includes the estimated amount of indebtedness of governmental entities overlapping the District,defined as outstanding bonds payable from ad valorem taxes,and the estimated percentages and amounts of such indebtedness attributable to property located within the District This information is based upon data secured from the individual jurisdictions and/or the Texas Municipal Reports published by the Municipal Advisory Council of Texas. The calculations by which the statement was derived were made in part by comparing the reported assessed valuation of the property in the overlapping taxing jurisdictions with the Assessed Valuation ofproperty within the District No effect has been given to the tax burden levied by any applicable taxing jurisdiction for maintenance and operational or other purposes. Outstanding Debt Overlapping Taxing Jurisdiction As of June 1,2009 Percent Amount Brazoria County $53,845,000 1.53022% $ 823,948 PearIand Independent School 336,315,890 5.26316 17,700.834 • TOTAL ESTIMATED OVERLAPPING DEBT $18,524,782 TOTAL DIRECT DEBT(the Bonds and the Remaining Outstanding Bonds)* 11.420.000 TOTAL DIRECT AND ESTIMATED OVERLAPPING DEBT S29,944.782 Ratio of Total Direct and Estimated Overlapping Debt to: 2008 Assessed Valuation($319,394,796) 9.38% 2009 Assessed Valuation($319,928,913) 9.36% * See"Bonded Indebtedness"above. Under Texas law ad valorem taxes levied by each taxing authority other than the District create a lien which is on a parity with the lien in favor of the District on all taxable property within the District. In addition to the ad valorem taxes required to retire the foregoing direct and overlapping debt,the various taxing authorities mentioned above also are authorized by Texas law to assess,Ievy and collect ad valorem taxes for operation,maintenance,administration and/or general revenue purposes. Certain of the jurisdictions have in the past levied such taxes. The District has the power to assess,levy and collect ad valorem taxes for operation and maintenance purposes in an amount not to exceed$0.20 per$100 of Assessed Valuation,and such taxes have been authorized by the duly qualified voters of the District The District levied a total tax of$0.50 per$100 of Assessed Valuation in 2009,consisting of debt service and maintenance tax components of$0.46 and $0.04 per$100 of Assessed Valuation,respectively. See"TAX DATA-Maintenance Tax"and"Tax Rate Distribution." 29 Debt Service Requirements The following schedule sets forth the debt service requirements on the Outstanding Bonds, less the debt service requirements on the Refunded Bonds,plus the principal and estimated interest requirements of the Bonds. Less: Debt Current Service on Total Year Ending Total Debt Refunded Plus:—The Bonds— New Debt December 31 Service Bonds Principal Interest* Service 2009 $1,661,226 $1,661,226 2010 1,669,111 306,488 $ 120,000 $ 144,464 1,627,088 2011 1,668,511 1,001,488 805,000 156,158 1,628,181 2012 1,674,194 996,373 810,000 144,888 1,632,709 2013 1,686,005 1,114,086 945,000 130,713 1,647,631 2014 1,693,590 1,119,436 970,000 109,923 1,654,076 2015 1,692,248 1,107,269 985,000 84,703 1,654,681 2016 1,700,714 961,625 865,000 56,630 1,660,719 2017 1.702.381 961.950 890.000 29.815 1,660.246 $15,147,980 $7,568,715 $6,390,000 $857,294 $14,826,557 Average Annual Requirements-Subsequent to Refunding(2010-2017) $1,645,666 Maximum Annual Requirement -Subsequent to Refunding(2009) $1,661,226 *Interest is estimated at various rates for the maturities of the Bonds. See"TAX DATA-TaxRate Calculations"and"INVESTMENT CONSIDERATIONS-Maximumlmpact on District Tax Rates"for a discussion of the District's projected tax rates and the effect of the Bonds thereon. TAXING PROCEDURES Authority The Board is authorized to levy an annual ad valorem tax,without legal limitation as to rate and amount,on all taxable property within the District in sufficient amount to pay the principal of and interest on the Bonds and the Remaining Outstanding Bonds and any additional bonds payable from taxes which the District may hereafter issue,and to pay the expenses of assessing and collecting such taxes. The District agrees in the Bond Order to levy such a tax from year to year as described more fully above under the caption"THE BONDS-Source of Payment." The Board is also authorized to levy and collect annual ad valorem taxes for the administration and maintenance of the District and the System and for the payment of certain contractual obligations if such taxes are authorized by vote of the District's electors at an election. The District's electors have authorized the levy of such a maintenance tax in the maximum amount of$0.20 per$100 of assessed valuation. See"TAX DATA-Maintenance Tax." Exempt Property Except for certain exemptions provided by Texas law, all real property and tangible personal property and certain categories of intangible personal property with a tax situs in the District are subject to taxation by the District;however, no effort is expected to be made by the Brazoria County Appraisal District("BCAD"orthe"Appraisal District")described below to assess taxes against tangible or intangible personal property not devoted to commercial or industrial use.Principal categories of exempt real property include: property owned by the State of Texas or its political subdivisions,if the property is used for public purposes;property exempt from ad valorem taxation by federal law;nonprofit cemeteries;and 30 certainproperty owned by qualified charitable,religious,veterans,fraternal,or educational organizations.Partially exempt to the extent of$5,000 to$12,000 of assessed value,depending on the disability rating of the veteran,is property owned by a disabled veteran or by the spouse or certain children of a deceased disabled veteran or a veteran who died while on active duty. Also partially exempt,if approved by the Board or at an election called by the Board upon petition of at least 20%of the number of the qualified voters who voted in the District's preceding election, are residence homesteads of certain persons who are disabled or at least 65 years old to the extent of$3,000 of appraised value or such higher amount as the Board or the District's voters may approve. The District's tax assessor is authorized by statute to disregard exemptions for the disabled and elderly if granting the exemption would impair the District's obligation to pay tax- supported debt incurred prior to adoption of the exemption by the District. The District's 2009 tax roll contains disabled veterans'exemptions aggregating$103,000 in assessed valuation,and over 65 or disabledpersons'exemptions aggregating $3,060,000. TheBoard may exempt up to 20%ofthe market value of residential homesteads from ad valorem taxation. Such exemption would be in addition to any other applicable exemptions provided by law. However,if ad valorem taxes have previously been pledged for the payment of debt and the cessation of the levy would impair the obligation of the contract by which the debt was created,then the Board may continue to Ievy and collect taxes against the exempt value of the homesteads until the debt is discharged. To date the Board has not voted to exempt any percentage of the market value of residential homesteads from ad valorem taxation,but no representation may be made that the Board will not determine to grant such exemption in the future. Brazoria County may designate all or part of the area within the District as a reinvestment zone,and the City,Brazoria County,or the Pearland Independent School District,may thereafter enter into tax abatement agreements with owners of real property within the zone. The tax abatement agreements may exempt from ad valorem taxation by the applicable taxing jurisdiction, and by the District, for a period of up to 15 years, all or any part of any increase in the assessed valuation of property covered by the agreement over its assessed valuation in the year in which the agreement is executed, on the condition that the property owner make specified improvements or repairs to the property in conformity with a comprehensive plan. None of the area within the District has been designated as a reinvestment zone to date. County-Wide Appraisal District The Texas Property Tax Code(the"Property Tax Code")establishes an appraisal district and an appraisal review board in each county of the State of Texas. The appraisal district is governed by a board of directors elected by the governing bodies of cities,towns,school districts and,if entitled to vote,the conservation and reclamation districts that participate in the appraisal district and of the county. The District is entitled to vote upon and participate in the selection of members of the board of directors of the BCAD. The board of directors selects a chief appraiser to manage the appraisal office of the appraisal district. All taxing units within Brazoria County,including the District,are included in the BCAD. BCAD is responsible for appraising property within the District,subject to reviewbythe Brazoria CountyAppraisal Review Board (the"Appraisal Review Board"). The appraisal roll as approved by the Appraisal Review Board must be used by the District in establishing its tax rolls and tax rate. The valuation and assessment of taxable property within the District is governed by the Property Tax Code. Under current Texas law, the District is responsible for the levy and collection of its taxes and will continue to be so responsible unless the Board of Directors of the District,or the qualified voters of the District or of Brazoria County at an election held for such purpose,determines to transfer such functions to the BCAD or another taxing unit. Assessment and Levy Generally,all taxable property in the District(other than any qualifying agricultural and timberland)must be appraised at 100%of market value as of January 1 of each tax year,subject to review and approval by the Appraisal Review Board. Under the Property Tax Code,however,houses held for sale by a developer or builder which remain unoccupied,are not leased or rented and produce no income,are required to be assessed at the price for which they would sell as a unit to a purchaser who would continue the owner's business. Implementation of this amendment could reduce the assessed value of builder inventory within the District. See"TAX DATA-Principal 2009 Property Owners"below. The Property Tax 31 Code requires each appraisal district to implement a plan providing for reappraisal of all real property in the appraisal district at least once every three years. It is not known what frequency of reappraisal will be utilized by the BCAD or whether reappraisals will be conducted on a zone or county-wide basis. The Property Tax Code permits land designated for agricultural use or timberland to be appraised at its value based on the land's capacity to produce agricultural or timber products rather than at its fair market value. Provisions of the Property Tax Code are complex and are not fully summarized here. Landowners wishing to avail themselves of the agricultural use designation must apply for the designation,and the appraiser is required by the Property Tax Code to act on each claimant's right to the designation individually. If a claimant receives the designation and later loses it by changing the use of the property or selling it to an unqualified owner,the District can collect taxes based on the new use,including for three years for agricultural use and for five years for agricultural land and timberland,prior to the loss of the designation. The chief appraiser must give written notice on May 15,or as soon thereafter as practicable to each owner if the appraised value of his property is greater than it was in the preceding year,if the appraised value of the property is greater than the value rendered by the property owner,or if the property was not on the appraisal roll in the preceding year. In addition, the chief appraiser must give written notice to each property owner whose property was reappraised in the current year or if ownership of the property changed during the preceding year. The appraisal reviewboard has the ultimate responsibility for determining the value of all taxable property within the District;however,any owner who has timely filed notice with the appraisal review board may appeal the final determination by the appraisal review board by filing suit in Texas district court. Prior to such appeal and prior to the delinquency date,however,the owner must pay the tax due on the amount of value of the property involved that is not in dispute or the amount of tax paid in the prior year,whichever is greater,or the amount of tax due under the order from which the appeal is taken. In the event of such suit,the value of the property is determined by the court; or a jury if requested by any party. Additionally,the District is entitled to challenge certain matters before the appraisal review board,including the level of appraisals of a certain category of property,the exclusion of property from the appraisal records, or the grant in whole or in part of a partial exemption. The District may not, however,protest a valuation of individual property. By September 1 of each year,or as soon thereafter as practicable,the rate of taxation is set by the Board based upon the assessed valuation of property within the District as of the preceding January 1 and the amount required to be raised for debt service,maintenance purposes and authorized contractual obligations. District and Taxpayer Remedies Under certain circumstances,taxpayers and taxing units,including the District,may appeal orders ofthe Appraisal Review Board by filing a petition for review in Texas state district court within forty-five(45)days after notice is received that a final order has been entered. In such event,the property value in question may be determined by the court,or by a jury, if requested by any party. Additionally,taxing units may bring suit against the Appraisal District to compel compliance with the Property Tax Code. The Property Tax Code establishes a procedure for notice to property owners ofreappraisals reflecting increased property values,appraisals that are higher than renditions and appraisals of property not previously on an appraisal roll. Collection The District is responsible for the collection of its taxes,unless it elects to transfer such functions to another governmental entity. Taxes are due on receipt of the tax bill and become delinquent after January 31 of the following year. The date of the delinquency maybe postponed if the tax bills are mailed after September 30(if the Board has authorized discounts for early payment)or otherwise after January 10, So long as the Board has not transferred responsibility for collection of the taxes to another taxing unit or the Appraisal District,the Board may permit payment without penalty or interest of the final tax installment by July 1,if one-half of taxes assessed for the current year are paid prior to December 1. The Board may approve a 3%discount for taxes paid in October,2%for November and 1%for December. Delinquent taxes are subject to a 6%penalty for the first month of delinquency, 1%for each month thereafter to July 1 and 12%total if any taxes are unpaid on July 1. Delinquent taxes also accrue interest at the rate of 1%per month during the period they remain outstanding. In addition,the Board may impose a further penalty not to exceed 20%on all taxes unpaid on July 1 which is used to defray the cost of engaging an attorney for collection of delinquent taxes. 32 Rollback of Operation and Maintenance Tax Rate The qualified voters of the District have the right to petition for a rollback of the District's operation and maintenance tax rate only ifthe total District tax bill on the average residence homestead increases by more than eight percent. If a rollback election's called and passes,the rollback tax rate is the District's current year's debt service and contract tax rates plus 1.08 times the District's previous year's operation and maintenance tax rate. Thus,the District's debt service and contract tax rates cannot be changed by a rollback election. District's Rights in the Event of Tax Delinquencies Taxes levied by the District are a personal obligation of the person who owns or acquires the property on January 1 of the year for which the tax is imposed. On.January 1 of each year,a tax lien attaches to property to secure the payment of all taxes,penalties,and interest ultimately imposed for the year upon the property. The District's tax lien is on a parity with the tax liens of the other state and local jurisdictions levying taxes on property within the District. Whether a lien of the United States is on a parity with or takes priority over a tax lien of the District is determined by applicable federal law. In the absence of such federal Iaw,the District's tax lien takes priority over a lien of the United States. In the event a taxpayer falls to make timely payment of taxes due the District,the District may file suit at any time after taxes become delinquent to foreclose its lien securing payment of the tax,to enforce personal liability for the tax,or both. In filing a suit to foreclose a tax lien on real property,the District must join other taxing units that have claims for delinquent taxes against all or part of the same property. Collection of delinquent taxes may also be adversely affected by the amount of taxes owed to other federal,state and local taxing jurisdictions,by the effects of market conditions on the foreclosure sales price,by the taxpayer's right to redeem the property(a taxpayermay redeemproperty within six(6)months for commercial property and two(2)years for residential and all other types of property after the purchaser's deed issued at the foreclosure sale is filed in the county records), or by bankruptcy proceedings which restrain or stay the collection of a taxpayer's debts. Federal bankruptcy Iaw provides that an automatic stay of actions by creditors and other entities,including governmental units,goes into effect with the filing of any petition in bankruptcy. The automatic stay prevents governmental units from foreclosing on property and prevents liens for post-petition taxes from attaching to property and obtaining secured creditor status unless,in either case,an order lifting the stay is obtained from the bankruptcy court. In many cases post-petition taxes are paid as an arlminictrative expense of the estate in bankruptcy or by order of the bankruptcy court. TAX DATA General All taxable property within the District is subject to the assessment,levy and collection by the District of a continuing, direct,annual ad valorem tax,without legal limitation as to rate or amount,sufficient to pay principal of and interest on the Remaining Outstanding Bonds,the Bonds and any future tax-supported bonds which may be issued from time to time as authorized. Taxes are levied by the District each year against the District's assessed valuation at January 1 of that year. Taxes become due October 1 of such year,or when billed,and become delinquent after January 31 of the following year. The Board covenants in the Bond Order to assess and Ievy, for each year that all or any part of the Bonds remain outstanding and unpaid,a tax ample and sufficient(with any net revenue)to produce funds to pay the principal of and interest on the Bonds when due. The actual rate of such tax will be determined from year to year as a function of the District's tax base,its debt service requirements and available funds. Maintenance Tax The Board of Directors of the District has the statutory authority to levy and collect an annual ad valorem tax for maintenance of the District's improvements,if such maintenance tax is authorized by a vote ofthe District's electorate. On November 3,1981,the District voters authorized the levy of such a maintenance tax in an amount not to exceed$0.20 per $100 of Assessed Valuation. Such tax is in addition to taxes which the District is authorized to levy for paying principal of and interest on the Bonds,the Remaining Outstanding Bonds and any tax supported bonds which maybe issued in the future. The District has levied a maintenance tax in 2009 of$0.04 per$100 of Assessed Valuation and in prior years in varying amounts as indicated below under the caption"Tax Rate Distribution." 33 Historical Values and Tax Collection History The following statement of tax collections sets forth, in condensed form, the historical Assessed Valuation and tax collections of the District. Such summary has been prepared for inclusion herein based upon information obtained from District records. Reference is made to such records,including the District's annual audited financial statements,for more complete information. Collections Assessed Tax Adjusted Current& Year Ending Tax Year Valuation Rate(a) Levy Prior Years(b) 9/30 1998 $127,638,472 $0.9480 $1,210,012.71 100.00% 1999 1999 148,627,208 0.8700 1,293,056.71 100.00 2000 2000 170,326,897 0.7800 1,328,549.80 100.00 2001 2001 199,486,977 0.7400 1,476,203.63 99.99 2002 2002 238,209,950 0.7400 1,762,753.63 100.00 2003 2003 290,956,191 0.6700 1,949,406.48 .100.00 2004 2004 308,401,000 0.5500 1,695,714.06 99.98 2005 2005 313,083,942 0.4800 1,502,567.85 99.94 2006 2006 320,068,656 0.4500 1,440,513.99 99,85 2007 2007 325,872,267 . 0.5100 1,662,302.89 99.86 2008 2008 319,394,796 0.5000 1,597,073.88 99.31(c) 2009 2009 319,928,913(d) 0.5000 1,599,644.57 (d) 2010 (a) Per$100 of Assessed Valuation. (b) Such percentages reflect cumulative total collections for each year from the time each respective annual tax was levied through July31,2009. The amount of tax collected for each levy on a current basis(by September 30 of the year following each respective levy)is not reflected in this statement. (c) As of July 31,2009. In process of collection. (d) Such sum includes certain values which have not been certified by the Appraisal Review B oard,including the value of certain properties which has been proposed by the Appraisal District but protested by the owners thereof to the Appraisal District The Appraisal District's estimate ofthe total taxable value ofsuchproperties under protest which will be assigned to such properties if the owners'claims are upheld by the Appraisal Review Board is$30,647,483, included in the amount of$319,928,913. The Appraisal District has proposed the valuation of such protested properties to be$34,052,759. The District is unable to predict the amount of the District 's final 2009 Assessed Valuation:Such final 2009 Assessed Valuation will not be determined until the valuation of all taxable property located within the District is certified by the Appraisal Review Board for 2009. (e) Levied September 9,2009. 34 Tax Rate Calculations The tax rate calculations setforthbelow are presented to indicate the tax rates per$100 ofAssessed Valuation which would be required to meet certain debt service requirements if no growth in the District occurs beyond the 2009 Assessed Valuation. The calculations also assume collection of 95%of taxes levied,no use of other legally available District funds on hand,and the sale of no additional bonds by the District. As outlined above under the caption"Historical Values and Tax Collection History,"the District has collected an average total annual percentage of its property taxes of 99.96%for the period 1998 through 2007,while 2008 taxes were 99.31%collected as of July 31,2009. • Average Annual Debt Service Requirements(2010-2017) $1,645,666 Tax Rate of$0.55 on the 2008 Assessed Valuation($319,394,796)produces $1,668,838 Tax Rate of$0.55 on the 2009 Assessed Valuation($319,928,913)produces $1,671,269 Maximum Debt Service Requirement(2017) $1,661,226 Tax Rate of$0.55 on the 2008 Assessed Valuation($319,394,796)produces $1,668,838 Tax Rate of$0.55 on the 2009 Assessed Valuation($319,928,913)produces $1,671,629 The District Ievied a debt service tax in 2009 of$0.46 per$100 of Assessed Valuation,plus a maintenance tax of$0.04 per$100 of Assessed Valuation. As the above table indicates,the 2009 debt service tax rate will not be sufficient to pay the average annual debt service requirements on the Bonds and the Remaining Outstanding Bonds assuming the District's tax base at the level of 2008 Assessed Valuation or the 2009 Assessed Valuation,and assuming no use of other legally available District funds,95%tax collections and the issuance of no additional bonds by the District. The District's Bond Fund balance is estimated to be$1,157,818 upon delivery of the Bonds. Although neither Texas law nor the Bond Order requires that any specific amount be retained in the Bond Fund at any time,the District has in the past applied earnings from the investment of monies held in the BondFund to meet the debt service requirements ofthe Remaining Outstanding Bonds (see"APPENDIX B-ANNUAL FINANCIAL REPORT"). In addition,the District bad,at July 31,2009,total annual tax collections averaging 99.96%for the years 1998 through 2007,and had collected 99.31%of its 2008 tax levy,which was in the process of collection,as of that date. Therefore,the District anticipates being able to pay the Average Annual and Maximum Annual Debt Service Requirements of the Bonds and the Remaining Outstanding Bonds without increasing its debt service levy above the level of the 2009 debt service levy of$0.46 per$100 ofAssessed Valuation. See"TAXIING PROCEDURES"and"INVESTMENT CONSIDERATIONS-Factors Affecting Taxable Values and Tax Payments." Tax Rate Distribution 2009 2008 2007 2006 2005 Debt Service $0.46 $0.46 $0.49 $0.43 $0.46 Maintenance 0.04 0.04 0.02 0.02 0.02 Total $0.50 $0.50 $0.51 $0.45 $0.48 35 Analysis of Tax Base The following table illustrates the composition of property located within the District during the past six years. Assessed Valuation Property Valuation 2009 % 2008 % 2007 % Land $ 47,771,200 14.93% $ 53,672,670 16.80% $ 53,083,450 16.29% Improvements 246,164,807 76.94 269,748,956 84.46 276,369,112 84.81 Personal Property 5,334,490 1.67 6,302,920 1.97 6,578,730 2.02 Exemptions (9,989,067) (3.12) (10,329,750) (3.23) (10,159,025) (3.12) Not Certified 30,647,483 9.58 0 0 0 Total Valuations $319,928,913* 100.00% $319,394,796 100.00% $325,872,267 100.00% Assessed Valuation Property Valuation 2006 % 2005 % 2004 % Land $53,054,970 16.58% $ 53,048,870 16.94% $48,560,870 15.75% Improvements 269,094,986 84,07 262,089,990 83.71 260,479,690 84.46 Personal Property 6,315,720 1.97 6,122,390 1.96 5,092,480 1.65 • Exemptions (8,397,020) (2.62) (8,177,308) (2.61) (5,732,040) (1.86) Total $320,068,656 100,00% $313,083,942 100.00% $308,401,000 100.00% * Such sum includes certain values which have not been certified by the Appraisal Review B oard,including the value of certain properties which has been proposed by the Appraisal District but protested by the owners thereof to the Appraisal District.The Appraisal District's estimate ofthe total taxable value ofsuchpropertiesunderprotestwhich will be assigned to suchproperties if the owners'claims are upheld by the Appraisal Review Board is$30,647,483, included in the amount of$319,928,913. The Appraisal District has proposed the valuation of such protested properties to be$34,052,759. The District is unable to predict the amount of the District 's final 2009 Assessed Valuation. Such final 2009 Assessed Valuation will not be determined until the valuation of all taxable property located within the District is certified by the Appraisal Review Board for 2009. Principal 2009 Property Owners Based upon information supplied by the District's Tax Assessor/Collector,the following table lists principal District taxpayers,type ofproperty owned by such taxpayers,and the Assessed Valuation of such property as of January 1,2009. The information reflects the composition ofthe Appraisal District's record ofproperty ownership as of January 1,2009. %of 2009 2009 Assessed Property Owner Property Description Property Value Valuation Plalca Stiverlake,LLC Commercial $5,356,050 1.68% Silverlake Plaza,LLC Commercial 2,624,470 0.80 Roth Pearland LLC Commercial 1,688,360 0.53 Akshipra Investments,Inc. Commercial 1,143,110 0.36 . WSG Southwyck IV,LP Commercial 957,830 0.30 Jubilee Brown Lot and Home 764,810 0.24 . • Centerpoint Energy Inc. Utilities 753,970 0.23 AEI Income&Growth Fund XXII LP Lot and Home 749,350 0.23 Horace&Alexa St.Julian Lot and Home 711,000 0.22 June Jackson&Horace St.Julian Lot and Home 705.740 0.22 $15,354,690 4.81% 36 Estimated Overlapping Taxes Property located within the District is subject to taxation by several taxing authorities in addition to the District. Set forth below is a compilation of all 2008 taxes levied upon property located within the District and the 2009 tax rate of the District. Under Texas law, ad valorem taxes levied by each taxing authority other than the District entitled to levy taxes against property located within the District create a lien which is on a parity with the tax lien of the District. In addition to the ad valorem taxes required to make the debt service payments on bonded debt of the District and of such other jurisdictions(see"DISTRICT DEBT-Estimated Direct and Overlapping Debt Statement"), certain taxing jurisdictions are authorized by Texas law to assess, levy and collect ad valorem taxes for operation, maintenance, administrative and/or general revenue purposes. 2008 Tax Rate Per$100 of Taxing Jurisdictions Assessed Valuation The District $0.500000* Brazoria County 0.390000 Pearland Independent School District 1.419400 Brazoria County Drainage District No, 4 0.143845 Estimated Total Tax Rate $2.453245 * The District has levied a tax of$0.50 per$100 of Assessed Valuation for 2009, consisting of debt service and maintenance tax components of$0.46 and$0.04 per$100 of Assessed Valuation, respectively. THE DISTRICT Authority The District is a municipal utility district created pursuant to an order of the Texas Water Commission(the"TWC"), now the Texas Commission on Environmental Quality(the "TCEQ"), dated July 16, 1981,and is authorized under Article XVI, Section 59 of the Texas Constitution. The creation of the District was confirmed at an election held within the District on November 3, 1981 by a vote of 4 "For" to 0 "Against." The rights, powers, privileges, authority,and functions of the District are established by the general laws of the State of Texas pertaining to municipal utility districts,particularly Chapters 49 and 54,Texas Water Code,as amended. In addition,the District is subject to the continuing supervision of the TCEQ. The principal functions of the District are to finance,construct,own,and operate waterworks, wastewater, and drainage facilities and to provide such facilities and services to the customers of the District. The District,if approved by the voters within the District,the TCEQ,and other governmental entities having jurisdiction,may establish,operate, and maintain a fire department,independently or with one or more other conservation and reclamation districts,and provide such facilities and services to the customers of the District. Under certain circumstances the District also is authorized to construct,develop and maintain park and recreational facilities and to construct roads. See "DEVELOPMENT AND HOME CONSTRUCTION." The District is subject to the continuing supervision of the TCEQ in certain matters. Description The District contains approximately 636.6 acres of land,including approximately 23.5 acres annexed by the District in 1998. The District is located approximately 5 miles west of and lies entirely within the extraterritorial jurisdiction of the City of Pearland,Texas. State Highway 288 is Iocated approximately 0.6 miles west of the northwestern boundary of the District and County Road 518 forms the northernmost boundary of the District. The District is located approximately twelve and one-half miles south of the central business district of the City of Houston and approximately eleven and one-half miles north of the Texas Medical Center complex. 37 Silverlake Project The District is part of a master-planned,mixed-use land development project which is now known and is being marketed as Silverlake (formerly known as Southwyck), which includes an aggregate of approximately 2,050 acres of land, approximately 1,000 acres of which were purchased by New Southwyck,L.P.("New Southwyck")in 1994. Amenities within Silverlake include an 18 hole daily fee golf course and club house,pools,playgrounds,soccer fields,baseball fields and a majorrecreation center consisting of 4 tennis courts,walking paths,community activities and meeting center and a junior Olympic pool. Silverlake includes the approximate 636.6 acres Iocated within the District,approximately 518 acres located inBrazoriaCountyMunicipal Utility DistrictNo.1("M.U.D.No.1"),approximately 477 acres located in Brazoria County Municipal Utility District No. 3 ("M.U.D. No. 3"), and approximately 418 of an aggregate approximately 778 acres currently located in Brazoria County Municipal Utility District No.6("M.U.D.No.6"). Land use intended for M.U.D.No.'s 1,2,and 3 is predominantly single-family residential. M.U.D.No.6 is being developed for residential and commercial use. The development of all of the land located within the District which is available for development is complete. Such developmentincludes an aggregate of 1,114 single-familyresidential lots on approximately 372.8 acres and 57 townhome lots on approximately 10.0 acres, on all 1,114 of which fully developed single-family lots and 57 townhome lots residences have been constructed,all of which residences have been sold to home purchasers,plus approximately 10.2 acres that have been developed for commercial purposes on which above-ground improvements including two shopping centers totaling approximately 93,579 square feet of building area have been constructed,and includes the construction of underground water distribution,wastewater collection,and storm sewer facilities and street paving as is enumerated in this Official Statement under the caption"DEVELOPMENT AND HOME CONSTRUCTION-Land Development and Home Construction Summary." In addition to the development of the District,(i)the development of a total of 1,356 single-family residential lots is complete in M.U.D.No. 1,(ii)the development of a total of 1,411 single-family residential lots is complete in M.U.D. No.3,and(iii)the development of 1,308 single-family residential Iots is complete in M.U.D.No. 6. 11 holes of the Southwyck Golf Course plus an approximate 6,000 square foot clubhouse,and other facilities including a restaurant, men's and women's locker rooms,and a golf cart barn are located within the District,and the balance of the golf course is located within M.U.D.Nos.3 and 6. See"APPEND]X A-LOCATION MAP"and`DEVELOPMENT AND HOME CONSTRUCTION." Management of the District The District is governed by the Board of Directors,consisting of five directors. The Board of Directors has control over and management supervision of all affairs of the District. Directors serve four-year staggered terms,and elections are held within the District in May in even numbered years. The current members and officers of the Board,along with their respective terms of office,are listed below. Directors Scarry and Linzer currently reside within the District. The other Directors own separate parcels of land located within the District that are subject to separate non-recourse promissory notes. Name Title Term Expires Mav Sandy Gingles President 2004 Gerry Lowry Vice President 2006 Kevin Wilson Secretary 2006 Bernie Scarry Deputy Secretary 2006 Larry Linzer Director 2004 38 The District does not have a general manager but has contracted for services,or employs directly,as follows: Bookkeeper-The District's bookkeeper is McLennan&Associates,L.P.,which serves as bookkeeper for 100 utility districts. Tax Assessor/Collector-The District has engaged Thomas W.Lee,RTA and Assessments of the Southwest,Inc., Friendswood,Texas,as the District's Tax Assessor/Collector.According to Mr.Lee,he presently serves 138 taxing units as tax assessor/collector. The Tax Assessor/Collector applies the District's tax Ievy to tax rolls prepared by the Brazoria County Appraisal District and bills and collects such levy. Consulting Engineers-The District has employed the firm of Jones&Carter,Inc.,Houston,Texas,as Consulting Engineer on a contract basis to provide engineering services to the District. District Operator-SWWC Services,Inc.is the general operator of the District's System. According to SWWC Services,Inc.,it is currently employed as operator for 275 utility districts including the District. Auditor-The District has employed McCall Gibson Swedlund Barfoot PLLC,Certified Public Accountants,to audit its financial statements for the year ending December 31,2008. A copy ofthe District's audit for the fiscal year ended December 31,2008,is included as"APPENDIX B"to this Official Statement. Counsel-The District employs Paul A.Philbin&Assoc.,P.C.,Houston,Texas,as general counsel and as Bond Counsel in connection with the issuance of the Bonds. Payment to Bond Counsel by the District is contingent on the issuance,sale and delivery of the Bonds. See`LEGAL MATTERS." Special Tax Counsel-McCall,Parkhurst&Horton,L.L.P.,Dallas,Texas,serves as Special Tax Counsel to the District in connection with the issuance ofthe Bonds. The fees to be paid Special Tax Counsel for services rendered in connection with the issuance of the Bonds is contingent on the issuance,sale and delivery of the Bonds. Financial Advisor-The District has engaged Rathmann&Associates,L.P.,as financial advisor(the"Financial Advisor")to the District. The fees payable to the Financial Advisor for services rendered in connection with the issuance of the Bonds are contingent upon the issuance,sale and delivery of the Bonds. DEVELOPMENT AND HOME CONSTRUCTION The development of all of the land located within the District which is available for development is complete. Such developmentincludes an aggregate of 1,114 single-familyresidential lots on approximately 372.8 acres and 57 townhome Iots on approximately 10.0 acres,on all 1,114 of which fully developed single-family residential lots and 57 townhome lots residences have been constructed,all of which residences have been sold to home purchasers,plus approximately 10.2 acres that have been developed for commercial purposes on which above-ground improvements including two shopping centers totaling approximately 93,579 square feet of building area have been constructed,and includes the construction of underground water distribution,wastewater collection,and storm sewer facilities and street paving as is enumerated in this Official Statement under the caption"DEVELOPMENT AND HOME CONSTRUCTION-Land Development andHome Construction Summary." 11 holes of the 18 hole Southwyck Golf Course(approximately 134.7 acres),plus an approximate 6,000 square foot clubhouse,and other facilities including a restaurant,men's and women's locker rooms,and a golf cartbam are also located withinthe District. Approximately 108.9 District acres are contained within street and drainage ditchrigbts-of-way,various easements,Lake Silverlake,parks and open space or are otherwise not available for future development. The construction of(i)a regional wastewater treatment facility,(ii)joint water supply facilities,and(iii)joint drainage facilities,all of which facilities the District shares with M.U.D.No.1,M.U.D.No.3 and M.U.D.No.6,is also complete. The District financed its portion of the cost of the acquisition or construction of certain of the aforementioned components of its system(the"System"),and certain other facilities,with portions of the proceeds of the sale of the Outstanding Bonds and will finance additions thereto which are described in this Official Statement under the caption "THE SYSTEM"with portions of the proceeds of the sale of the Bonds. 39 Land Development and Home Construction Summary The residential lot development and home construction activity which has been undertaken within the District as of September 1,2009,is illustrated below.Underground water distribution,wastewater collection and storm sewer facilities and street paving have been constructed to serve the entirety of the developable land located within the District,and wastewater treatment capacity and water supply capacity have been allocated to provide service to all of such land. Such underground facilities and wastewater treatment and water supply capacity have been financed by the District with the proceeds of the sale of the Outstanding Bonds as is described in this Official Statement. Lots Homes Under Under Construction Completed Subdivision Developed Acres Development Acres Sold Unsold Sold Unsold Totals Southwyck Section 4 142 35.8 0 0 142 0 142 Section 5 53 37.9 0 0 53 0 53 Section 9, Phase 1 57 15.6 0 0 57 0 57 Phase 2 68 19.0 0 0 68 0 68 Parkeside at Silverlake Section 1 90 24.1 0 0 90 0 90 The Gardens at Silverlake Section 1 82 22.7 0 0 82 0 82 Lakepointe at Silverlake Section 1 81 27.3 0 0 81 0 81 Section 2 59 20.1 0 0 59 0 59 Meadowview at Silverlake Section 1 76 22.5 0 0 76 0 76 Section 2 16 6.3 0 0 16 0 16 Cambridge Cove at Stiverlake Section 1 79 35.5 0 0 79 0 79 Section 2 21 7.3 0 0 21 0 21 Waterbury Estates at Stiverlake Section 1 45 19.0 0 0 45 0 45 Section 2 34 13.8 0 0 34 0 34 Section 3 32 8.5 0 0 32 0 32 Springbrook at Silverlake Section 1 93 28.8 0 0 93 0 93 Section 2 86 28.6 0 0 86 0 86 Townhome Tract 57 10.0 0 0 0 0 57 0 57 Totals 1,171 382.8 0 0 0 0 1,171 0 1,171 40 According to the District's Engineer,the District,with the proceeds of the Outstanding Bonds has financed all of the water supply and distribution,wastewater collection and treatment,and storm drainage facilities that are necessary to serve the entirety of the District. Therefore,the District does not presently foresee the need to issue additional tax bonds to finance additions to the System,although the District cannot represent that the need for such future issuance might not materialize. See`°11L-th BONDS-Legal Ability to Issue Additional Debt" THE SYSTEM Regulation The water,wastewater and storm drainage facilities serving land within the District(the"System")have been designed in conformance with accepted engineering practices and the requirements of certain governmental agencies having regulatory or supervisory jurisdiction over the construction and operation of such facilities including,among others,the City ofPearland,Brazoria County,Brazoria Drainage District No.4 and the TCEQ. Operation of the System is subject to regulation by,among others,the United States Environmental Protection Agency and the TCEQ. In many cases,regulations promulgated by these agencies have become effective only recently and are subject to further development and revision. According to the District's Engineer, the total number of equivalent residential connections projected for the District at the full development of its approximate 636.6 acres is 1,328 with a total estimated population of 3,916. A description of portions of the System follows,and is based upon information supplied by the District's Engineer. Description As described above under the caption"DEVELOPMENT AND HOME CONSTRUCTION,"portions of the proceeds of the sale of the Outstanding Bonds were used to finance the construction or acquisition of water supply and distribution, wastewater collection and treatment,and storm drainage facilities to serve the entirety of the developable land that is located within the District. According to the District's Engineer,the District,with the proceeds of the Outstanding Bonds 'has financed all of the water supply and distribution,wastewater collection and treatment,and storm drainage facilities that are necessary to serve the entirety of the District. Therefore,the District does not presently foresee the need to issue additional tax bonds to finance additions to the System,although the District cannot represent that the need for such future issuance might not materialize. See"THE BONDS-Legal Ability to Issue Additional Debt" -Storm Drainage- Storm water drainage for the District is accomplished by a joint drainage improvement and storm sewer system financed with proceeds of the sale of the Outstanding Bonds. Such improvements,which also serve M.U.D.No 1,M.U.D.No. 3,and M.U.D.No.6 include(i)the excavation of the detentionportion ofLake Silverlake,Phase 1 located in the District to serve as an onsite detention lake, including approximately 160,000 cubic yards of excavation, and related appurtenances;(ii)a detention pond system which includes approximately 3,317 linear feet of 54-inch diameter storm sewer pipe,a drop structure,a control weir,a lake outran structure,approximately 11,200 feet of linear detention pond, and a bridge at County Road 89;and(iii)the reclamation of Mary's Creek which includes approximately 8,590 linear feet of improvements to the existing channel of Mary's Creek downstream of FM 1128. See"100-Year FIood Plain" below. -Water Supply- The District has entered into a Restated P ermanent Water Supply Contract(the"Agreement")dated September 1,1999, as amended by a FirstAmendment to the Agreement dated December 3,2001,with the adjoining M.U.D.No.1,M.U.D. No.3 andM.U.D.No.6 whichprovides,among other things,for the joint ownership of a water supply well and treatment plant(the"Water Plant No. 1"). The District financed its pro rata share of the cost of the facility with a portion of the proceeds of the Outstanding Bonds. Water PlantNo.1 consists of a 1,000 gallons-per-minute(g.p.m.")water well with auxiliary power supply,a 500,000 gallon storage tank,30,000 gallons ofhydropneumatic tank capacity,a total of 2,750 41 • g.p.m. of booster pump capacity, a 450 g.p.m.remote water well and related appurtenances. Under the terms of the Agreement,the District is entitled to 24%of the water supply capacity in the Water Plant and bears 24%of the costs, including construction costs,related thereto. The District entered into a Facilities Proration Agreement dated February 24, 1995, with M.U.D.No. 1,M.U.D.No. 3, and M.U.D.No. 6 which provides, among other things, for the joint ownership of the District's second water supply well and treatment plant("Water Plant No.2"). The District financed its pra rata share of the cost of Phases 1,2 and 3 of Water Plant No.2 with a portion of the proceeds of the sale of the Outstanding Bonds. Water Plant No.2 consists of a 1,250 g.p.m.water well with auxiliary power, an 1,800 g.p.m. remote water well, two (2) 300,000 gallon and one (1) 600,000 gallon ground storage tanks, 30,000 gallons of hydropneumatic tank capacity,a total of 7,000 g.p.m.of booster pump capacity and related appurtenances. Under the terms of the agreement,the District is entitled to 23%of the water supply capacity of the plant and bears 23%of the costs,including construction costs related thereto. The District has entered into a Facilities Proration Agreement with • M.U.D.No.1,M.U.D.No.3,and M.U.D.No.6 which provides,among other things,for the joint ownership of Water PIant No.3 ("Water Plant No.3"). The District financed its pro rata share of the cost of the Phases 1 and 2 of Water Plant No.3 with a portion of the proceeds of the sale of the Outstanding Bonds. Water PlantNo.3 consists of a 2,100 g.p.m.well,two(2) 620,000 gallon ground storage tanks,booster pumps totaling 6,250 g.p.m.of capacity and related appurtenances. Under the terms of the agreement,the District bears 12.8%of the costs,including construction costs related thereto,and is entitled to 12.8%of the water supply capacity of Water Plant No.3 upon completion of Phase 2. The District has entered into a Facilities Proration Agreement with M.U.D.No. 1,M.U.D.No.3, and M.U.D.No.6 which provides,among other things,for the joint ownership of a 700,000 gallon elevated storage tank. The District financed its pro rata share of the cost of the facilities with a portion ofthe proceeds of the sale of the Outstanding Bonds. Under the terms of the agreement,the District is entitled to 19.0%of the capacity of the tank upon its completion and bears 19.0%of the costs,including construction costs related thereto. According to the District's Engineer,the District's pro rata share of the capacity in the water plants and aforementioned related facilities is sufficient to provide service to all of the connections that are programmed for the District upon its full development. -Wastewater Treatment- The District has entered into a Facilities Proration Agreement dated April 29, 1993,restated pursuant to the`Restated Regional Wastewater Treatment Facilities Agreement" dated September 1, 1999, and amended by the "Facilities Proration Agreement"dated February 24,2000,with M.U.D.No.1,M.U.D.No.3 and M.U.D.No.6 which provides, among other things,for the joint ownership of a regional wastewater treatment facility. The plant currently consists of 2,400,000 gallons per day("g.p.d.")average daily flow capacity. The District financed its pro rata share of the cost of the facility with a portion of the proceeds of the sale of the Outstanding Bonds. Under the terms of the Agreement,the District is entitled to 16.7%of the wastewater treatment capacity in the plant and bears 16.7%of the costs,including construction costs related thereto.According to the District's Engineer,the District's 16.7%pro rata share of the capacity in the plant is sufficient to provide service to all of the connections that are programmed for the District upon its full development. -100-Year Flood Plain- According to the District's Engineer,the Federal EmergencyManagement Agency FloodHazardBoundaryMap currently in effect which covers the land located in the District indicates thatno portion ofthe District except the channel of Mary's Creek is located within the 100-year flood plain of any water course. 42 Waterworks and Sewer System Operating Statement The following statement summarizes the operating history of the District's waterworks and sewer system for the fiscal ' years ended December 31,2004,through 2008,and the six-month period ended June 30,2009. The summary has been condensed from information contained in the District's audited financial statements for the fiscal years ended December 31,2004,through 2008,to which reference is made for more complete and further information and from an unaudited compilation of information supplied by the District's Bookkeeper in the case of the information covering the six-month period ended June 30, 2009. The derivation of Net Revenues which follows excludes depreciation expenses. See "APPENDIX C-FINANCIAL STATEMENTS OF THE DISTRICT." Fiscal Year Ended December 31 Six-Month Period Ended June 30,2009* 2008 2007 2006 2005 2004 GENERAL FUND REVENUES: Property Taxes $126,181 $65,516 $64,240 $62,235 $62,281 $58,430 Water Service 166,849 389,503 348,315 407,592 444,983 383,472 , . Wastewater Service 155,942 306,015 307,323 301,717 303,741 290,944 Penalty and Interest 6,654 9,657 9,351 13,455 10,450 9,778 Tap Connection and • Inspection Fees 7,055 63,655 Investment Revenues 13,979 80,375 130,042 125,007 74,607 28,470 Miscellaneous Revenues 22,185 23,534 29,025 12.887 13.279 11.737 TOTAL REVENUES $498,845 $874,600 $888,296 $922,893 $909,341 $846,486 EXPENDITURES: Professional Fees $72,342 $92,651 $64,916 $72,024 $71,308 $49,000 Contracted Services 117,489 228,694 226,811 210,643 195,734 171,193 Purchased Water Service 103,616 159,312 103,922 109,073 91,911 88,715 Purchased Wastewater Service 64,913 173,516 132,273 127,955 113,142 89,127 Utilities 2,660 4,652 4,668 4,647 3,981 3,097 Repairs and Maintenance 111,951 178,339 187,453 111,589 151,382 105,936 Other 41,788 54,756 43,751 48,099 33,036 55,844 Capital Outlay 28.051 38.696 TOTAL EXPENDI- TURES $514.759 $891,920 $763,794 $684,030 $688,545 $601,608 EXCESS REVENUES OVER(UNDER) EXPENDITURES S(15,914) $(17,320) $124,502 $238,863 5157.765 $219,169 * Unaudited. The District's General Fund balance(audited) as of December 31, 2008,was$2,913,286(audited), and as of July 2, 2009, was$2,934,818(unaudited). 43 r LEGAL MATTERS Legal Opinions The District will furnish the Underwriters a transcript of certain certified proceedings had incident to the authorization and issuance of the Bonds. Such transcript will include a certified copy of the approving opinion ofthe Attorney General of Texas,as recorded in the Bond Register of the Comptroller of Public Accounts of the State of Texas,to the effect that the Bonds are valid and binding obligations of the District. The District also will furnish the approving legal opinion of Paul A.Philbin&Assoc.,P.C.,Houston,Texas,Bond Counsel("Bond Counsel"),to the effect that,based upon an examination of such transcript,the Bonds are valid and binding obligations of the District under the Constitution and laws of the State of Texas. The legal opinion of Bond Counsel will further state that the Bonds,including principal of and interest thereon,are payable from ad valorem taxes,without legal limit as to rate or amount,upon all taxable property located within the District,and are further payable from and secured by a pledge of and lien on the Net Revenues,if any, of the System. The District will also furnish the approving legal opinion of McCall,Parkhurst&Horton L.L.P,Dallas, Texas,Special Tax Counsel to the District("Special Tax Counsel"),to the effect that interest on the Bonds is excludable from gross income of the owners thereof for federal income tax purposes under existing statues,regulations,published rulings and court decisions as described under the caption which follows entitled"TAX MATTERS." The opinions of Bond Counsel and Special Tax Counsel will be printed on the Bonds. Based upon the matters stated in such opinion, Bond Counsel's opinion will also state that,as a result of the deposit of the Escrowed Obligations pursuant to the Escrow Agreement, firm banking and financial arrangements will have been made for the payment of the Refunded Bonds pursuant to the Escrow Agreement and that,therefore,such Refunded Bonds will be deemed to be fully paid and no longer outstanding except for the purpose of being paid from the funds provided therefor in such Escrow Agreement In its capacity as Bond Counsel,Paul A.Philbin&Assoc.,P.C.has reviewed the information appearing in this Official Statement under the captions "THE BONDS," `PLAN OF FINANCING - Escrow Agreement," "TAXING PROCEDURES," "THE DISTRICT-Authority," and- "Management of the District- Legal Counsel," "LEGAL MATTERS" (except the information therein relating to the opinion of Special Tax Counsel and the information appearing under the caption"No Arbitrage"),and"CONTINUING DISCLOSURE OF INFORMATION,"to determine whether such information fairly summarizes the procedures,law and documents referred to therein. In its capacity as Special Tax Counsel, McCall, Parkhurst&Horton L.L.P.,has reviewed the information appearing in this Official Statement under the captions "THE DISTRICT - Management of the District - Special Tax Counsel," "LEGAL MATTERS-Legal Opinions"(but only insofar as such caption relates to the opinion of Special Tax Counsel)and"TAX MATTERS"to determine whether such information fairly summarizes the procedures,law and documents referred to therein. Bond Counsel and Special Tax Counsel have not,however,independently verified any of the other factual information contained in this Official Statement nor have they conducted an investigation of the affairs of the District for the purpose of passing upon the accuracy or completeness of this Official Statement. No person is entitled to rely upon such parties'limited participation as an assumption of responsibility for,or an expression of opinion of any kind with regard to the accuracy or completeness of any of the information contained herein. The legal fees to be paid Bond Counsel and Special Tax Counsel for services rendered in connection with the issuance of the Bonds are based on a percentage of the Bonds actually issued, sold and delivered and, therefore, such fees are contingent on the sale and delivery of the Bonds. Bond Counsel acts as general counsel for the District on matters other than the issuance ofbonds. Certain legal matters will be passed upon for the Underwriters by McCall,Parkhurst&Horton L.L.P.,Dallas,Texas, as Underwriters'Counsel. No Arbitrage The District will certify on the date the Bonds are delivered and paid for that based upon all facts and estimates now known or reasonably expected to be in existence,the District reasonably expects that the proceeds of the Bonds will not be used in a manner that would cause the Bonds,or any portion of the Bonds,to be"arbitrage bonds"under Section 148 of the Internal Revenue Code of 1986, as amended(the"Code"), and the regulations prescribed from time to time thereunder. Furthermore,all officers,employees and agents of the District have been authorized and directed to provide certifications offacts and estimates that are material to the reasonable expectations of the District as ofthe date the Bonds are delivered and paid for. In particular,all or any officers of the District have been authorized to certify to the facts, 44 circumstances and reasonable expectations of the District an the date the Bonds are delivered and paid for regarding the amount and use of the proceeds of the Bonds. Moreover,the District will covenant in the Bond Order that it will make such use of the proceeds of the Bonds,regulate investments of proceeds of the Bonds and take such other and further actions and follow such procedures, including without limitation, calculation of the yield on the Bonds, as may be required so that the Bonds will not become"arbitrage bonds"under the Code and the regulations prescribed from time to time thereunder. • No-Litigation Certificate The District will furnish to the Underwriters a certificate,dated as of the date of delivery of the Bonds,executed by both the President and Secretary of the Board,to the effect that no litigation of any nature has been filed or is then pending or threatened,either in state or federal courts,contesting or attacking the Bonds;restraining or enjoining the issuance, execution or delivery of the Bonds;affecting the provisions made for the payment of or security for the Bonds;in any manner questioning the authority or proceedings for the issuance,execution,or delivery of the Bonds;or affecting the validity of the Bonds. No Material Adverse Change The obligations of the Underwriters to take and pay for the Bonds,and of the District to deliver the Bonds,are subject to the condition that,up to the time of delivery of and receipt of payment for the Bonds,there shall have been no material adverse change in the condition(financial or otherwise)of the District from that set forth or contemplated in the Official Statement,as it may have been supplemented or amended,through the date of sale. TAX MATTERS Opinion On the date of initial delivery of the Bonds,McCall,Parkhurst&Horton L.L.P.,Dallas,Texas,Special Tax Counsel, will render its opinion that,in accordance with statutes,regulations,published rulings and court decisions existing on the date thereof("Existing Law")interest on the Bonds(1)will be excludable from the gross income, as defined in section 61 of the Code, of the owners thereof for federal income tax purposes;and(2) will not be included in the alternative minimum taxable income of individuals under section 57(a)(5)of the Code or,except as described below, corporations.Except as stated above,Special Tax Counsel will express no opinion as to any other federal,state or local tax consequences of the purchase,ownership or disposition of the Bonds. In rendering its opinion,Special Tax Counsel will rely upon(a)the opinion of Paul A.Philbin&Assoc.,P.C.,Bond Counsel,that the Bonds are valid and binding obligations of the District payable from the proceeds of a generally- applicable ad valorem tax,(b)the District's federal tax certificate and the verification reportprepared by Grant Thornton LLP, Certified Public Accountants and(c) covenants of the District with respect to arbitrage,the application of the proceeds to be received from the issuance and sale of the Bonds and certain other matter. Failure by the District to observe the aforementioned representations or covenants, could cause the interest on the Bonds to become taxable retroactively to the date of issuance. The Code and the regulations promulgated thereunder contain a number ofrequirements that must be satisfied subsequent to the issuance of the Bands in order for interest on the Bonds to be,and to remain,excludable from gross income for federal income tax purposes.Failure to comply with such requirements may cause interest on the Bonds to be included in gross income retroactively to the date of issuance of the Bonds.The opinion of Special Tax Counsel is conditioned on compliance by the District with such requirements, and Special Tax Counsel has not been retained to monitor compliance with these requirements subsequent to the issuance of the Bonds. Special Tax Counsel's opinion represents its legal judgement based upon its review of Existing Law and the reliance on the aforementioned information,representations and covenants.Special Tax Counsel's opinion is not a guarantee of a result. Existing Law is subject to change by the Congress and to subsequent judicial and administrative interpretation 45 • by the courts and the Department of the Treasury. There can be no assurance that Existing Law or the interpretation thereof will not be changed in a manner which would adversely affect the tax treatment of the purchase,ownership or disposition of the Bonds. A ruling was not sought from the Internal Revenue Service by the Issuer with respect to the Bonds or the property financed orrefinanced with proceeds of the Bands.No assurances can be given as to whether or not the Internal Revenue • Service will commence an audit of the Bonds, or as to whether the Internal Revenue Service would agree with the opinion of Special Tax Counsel. If an audit is commenced,under current procedures the Internal Revenue Service is likely to treat the District as the taxpayer and the Bondholders may have no right to participate in such procedure. No additional interest will be paid upon any determination of taxability. Federal Income Tax Accounting Treatment of Original Issue Discount The initial public offering price to be paid for the Bonds,as stated on the cover of the Official Statement,may be less than the principal amount thereof(the"Original Issue DiscountBonds"). As such,the difference between(i)the amount payable at the maturity of each Original Issue Discount Bond, and(ii)the initial offering price to the public of such Original Issue Discount Bond constitutes original issue discount with respect to such Original Issue Discount Bond in the hands of any owner who has purchased such Original Issue DiscountBond in the initial public offering of the Bonds. • Under Existing Law,such an owner is entitled to exclude from gross income(as defined in section 61 of the Code)an amount of income with respect to such Original Issue Discount Bond equal to that portion ofthe amount of such original issue discount allocable to the period for which such Original Issue DiscountBond continues to be owned by such owner. For a discussion of certain collateral federal tax consequences,see discussion set forth below. In the event of the redemption,sale or other taxable disposition of such Original Issue Discount Bond prior to stated maturity,however,the amount realized by such owner in excess of the basis of such Original Issue Discount Bond in the hands of such owner(adjusted upward by the portion of the original issue discount allocable to the period for which such Original Issue Discount Bond was held by such initial owner)is includable in gross income. Under Existing Law,the original issue discount on each Original Issue Discount Band is accrued daily to the stated maturity thereof(in amounts calculated as described below for each six-month period ending on the date before the semiannual anniversary dates of the date of the Bonds and ratably within each such six-month period)and the accrued amount is added to an initial owner's basis for such Original Issue DiscountBond forpurposes of determining the amount of gain or loss recognized by such owner upon the redemption,sale or other disposition thereof. The amount to be added to basis for each accrual period is equal to(a)the sum ofthe issue price and the amount of original issue discount accrued in prior periods multiplied by the yield to stated maturity(determined on the basis of compounding at the close of each accrual period and properly adjusted for the length of the accrual period)less(b)the amounts payable as current interest during such accrual period on such Original Issue Discount Bond. The federal income tax consequences of the purchase,ownership,redemption,sale or other disposition of Original Issue Discount Bonds which are notpurchased in the initial offering at the initial offering price may be determined according to rules which differ from those described above. All owners of Original Issue DiscountBonds should consult their own tax advisors withrespect to the determination for federal,state and local income tax purposes of the treatment of interest accrued upon redemption,sale or other disposition of such Original Issue Discount Bonds and with respect to the federal, state, local and foreign tax consequences of the purchase, ownership, redemption, sale or other disposition of such Original Issue Discount Bonds. Collateral Federal Income Tax Consequences The following discussion is a summary of certain collateral federal income tax consequences resulting fromthe purchase, ownership or disposition ofthe Bonds. This discussion is based on existing statutes,regulations,published rulings and court decisions,all of which are subject to change or modification,retroactively. 46 The following discussion is applicable to investors,other than those who are subject to special provisions of the Code, such as financial institutions,property and casualty insurance companies,life insurance companies,individual recipients of Social Security or Railroad Retirement benefits,individuals allowed an earned income credit,certain S corporations with accumulated earnings and profits and excess passive investment income,foreign corporations subject to the branch profits tax, taxpayers who may be deemed to have incurred or continued indebtedness to purchase tax-exempt obligations. • THE DISCUSSION CONTAINED HEREIN MAY NOT BE EXHAUSTIVE. INVESTORS,INCLUDING THOSE WHO ARE SUBJECT TO SPECIAL PROVISIONS OF THE CODE, SHOULD CONSULT THEIR OWN TAX ADVISORS AS TO THE TAX TREATMENT WHICH MAY BE ANTICIPATED TO RESULT FROM THE PURCHASE,OWNERSHIP AND DISPOSITION OF TAX-EXEMPT OBLIGATIONS BEFORE DETERMINING WHETHER TO PURCHASE THE BONDS. Interest on the Bonds will be includable as an adjustment for"adjusted current earnings" to calculate the alternative minimum tax imposed on corporations by section 55 of the Code. Section 55 of the Code imposes a tax equal to 20 percent for corporations,or 26 percent for noncorporate taxpayers(28 percent for taxable income exceeding$175,000), of the taxpayer's"alternative minimum taxable income,"if the amount of such alternative minimum tax is greater than the taxpayer's regular income tax for the taxable year. Under section 6012 of the Code,holders of tax-exempt obligations,such as the Bonds,may be required to disclose interest received or accrued during each taxable year on their returns of federal income taxation. Section 1276 of the Code provides for ordinary income tax treatment of gain recognized upon the disposition of a tax- exempt obligation,such as the Bonds,if such obligation was acquired at a"market discount"and if the fixed maturity of such obligation is equal to,or exceeds,one year from the date of issue. Such treatment applies to"market discount bonds"to the extent such gain does not exceed the accrued market discount of such bonds;although for this purpose, a de minimiq amount of market discount is ignored. A"market discount bond"is one which is acquired by the holder at a purchase price which is less than the stated redemption price at maturity or,in the case of a bond issued at an original issue discount,the"revised issue price"(i.e.,the issue price plus accrued original issue discount). The"accrued market discount"is the amount whichbears the same ratio to the market discount as the number of days during which the holder holds the obligation bears to the number of days between the acquisition date and the final maturity date. State,Local and Foreign Taxes Investors should consult their own tax advisors concerning the tax implications of the purchase,ownership or disposition of the Bonds under applicable state or local laws. Foreign investors should also consult their own tax advisors regarding the tax consequences unique to investors who are not United States persons. Qualified Tax-Exempt Obligations for Financial Institutions Section 265(a)of the Code provides,in pertinent part,that interest paid or incurred by a taxpayer,including a"financial institution,"on indebtedness incurred or continued to purchase or carry tax-exempt obligations is not deductible by such taxpayer in determining taxable income. Section 265(b)of the Code provides an exception to the disallowance of such deduction for any interest expense paid or incurred on indebtedness of a taxpayer which is a"financial institution" allocable to tax-exempt obligations,other than"specified private activity bonds,"which are designated by a"qualified small issuer"as"qualified tax-exempt obligations." A"qualified small issuer"is any governmental issuer(together with any subordinate issuers) who issues no more than$10,000,000 of tax-exempt obligations during the calendar year. Section 265(b)(5)of the Code defines the term"financial institution"as referring to any corporation described in section 585(a)(2)of the Code,or any person accepting deposits from the public in the ordinary course of such person's trade or business which is subject to federal or state supervision as a financial institution. 47 The District expects to designate the Bonds as"qualified tax-exempt obligations"within the meaning of section 265(b) of the Code. In furtherance of that designation,the District will covenant to take such action which would assure,or to refrain from such action which would adversely affect,the treatment ofthe Bonds as"qualified tax-exempt obligations." Potential purchasers should be aware that if the issue price to the public exceeds $10,000,000, there is a reasonable basis to conclude that the payment of a de minimis amount of premium in excess of$10,000,000 is disregarded, however,the Internal Revenue Service could take a contrary view.Were the Internal Revenue Service to conclude that the amount of such premium is not disregarded,then such obligations might fail to satisfy the$10,000,000 limitation and the obligations would not be"qualified tax-exempt obligations." VERIFICATION OF ACCURACY OF MATHEMATICAL COMPUTATION The arithmetical computations of the adequacy of the amounts deposited with the paying agent for the Refimded Bonds and certain available funds(if any)to pay,when due,the principal or redemption price of and interest on the Refunded Bonds,was verified by Grant Thornton LLP, Certified Public Accountants. The computations were independently verified by Grant Thornton LLP based upon assumptions andJinformation supplied on behalf of the District. SOURCES OF INFORMATION General The information contained in this Official Statement has been obtained primarily from the District's records,the Brazoria County Appraisal District and other sources believed to be reliable; however, no representation is made as to the accuracy or completeness ofthe information contained herein,except as describedbelow under"Certification of Official Statement." The summaries of the statutes,resolutions and engineering and other related reports set forth herein are included subject to all of the provisions of such documents. These summaries do not purport to be complete statements of such provisions and reference is made to such documents for further information. Experts The information contained in this Official Statement relating to engineering,to the description of the System generally and,in particular,the engineering information included in the section captioned"THE SYSTEM"has been provided by Jones&Carter,Inc.Houston,Texas. Such information has been included herein in reliance upon the authority of said firm as an expert in the field of civil engineering. The information contained in this Official Statement relating to assessed valuations of property generally and, in particular,that information concerning principal taxpayers,tax collection rates and valuations contained in the sections captioned"TAX DATA"and"DISTRICT DEBT"has been provided by the Brazoria County Appraisal District and Thomas W.Lee. The District has included certain information herein in reliance upon Mr.Lee's authority as an expert in the field of tax assessing and real property appraisal. The District's audited financial statements for the year ended December 31,2008,were prepared by McCall Gibson Swedlund Barfoot PLLC,Certified Public Accountants,and have been included herein as"APPENDIX B." McCall, Gibson Swedlund Barfoot PLLC, Certified Public Accountants, has consented to the publication of such financial statements in this Official Statement. A copy of the Management Letter from the District's auditor to the District's Board of Directors relating to the District's financial reporting under Statement of Auditing Standards No. 112,including the District's response thereto,is included in"APPENDIX B." 48 Certification of Official Statement At the time of payment for and delivery of the Bonds,the District will furnish the Underwriter a certificate,executed by the President and Secretary of the Board,acting in their official capacities,to the effect that to the best of their knowledge and belief: (a)the information,descriptions and statements of or pertaining to the District contained in this Official Statement,on the date thereof and on the date of delivery were and are true and correct in all material respects; (b) ' insofar as the District and its affairs,including its financial affairs,are concerned,this Official Statement did not and does not contain an untrue statement of a material fact or omit to state a material fact required to be stated herein or necessary to make the statements herein,in the light of the circumstances under which they were made,not misleading and(c) insofar as the descriptions and statements,including financial data contained in this Official Statement,of or pertaining to entities other than the District and their activities are concerned,such statements and data have been obtained from sources which the District believes to be reliable and that the District has no reason to believe that they are untrue in any material respect or omit to state any material fact necessary to make the statements herein, in the light of the circumstances under which they were made,not misleading;however,the District has made no independent investigation as to the accuracy or completeness of the information derived from sources other than the District. Official Statement"Deemed Final" For purposes of compliance with Rule t5c(2)-12 of the Securities and Exchange Commission,this document,as the same maybe supplemented or corrected by the District from time to time,maybe treated as an Official Statement with respect to the Bonds described herein "deemed final"by the District as of the date hereof(or of any such supplement or correction)except for the omission of certain information referred to in the succeeding paragraph. The Official Statement,when further supplemented by adding information specifying the interest rates and certain other information relating to the Bonds,shall constitute a"FINAL OFFICIAL STATEMENT'of the District with respect to the Bonds,as that term is defined in Rule 15c(2)-12. CONTINUING DISCLOSURE OF INFORMATION In the Bond Order,the District has made the following agreement for the benefit of the holders and beneficial owners of the Bonds. The District is required to observe the agreement for so long as it remains obligated to advance funds to pay the Bonds. Under the agreement,the District will be obligated to provide certain updated financial information and operating data annually,and timely notice of specified material.events,to certain information vendors. This information will be available to securities brokers and others who purchase the information from the information vendors. Annual Reports The District will provide certain updated financial information and operating data to certain information vendors annually. The information to be updated includes all quantitative financial information and operating data with respect to the District of the general type included in this Official Statement under the headings"DISTRICT DEBT"and"TAX DATA"and in"APPENDIX B"(the Audit). The District will update and provide this information within six months after the end of each fiscal year ending in or after 2009. The District will provide the updated information to the Municipal Securities Rulemaking Board(the"MSRB")or any successor to its functions as a repository through its • Electronic Municipal Market Access("EMMA")system. The District may provide updated information in full text or may incorporate by reference certain other publicly available documents,as permitted by SEC Rule 15c2-I2. The updated information will include audited financial statements,if the District's audit is completed by the required time. If audited financial statements are not available by the required time,the District will provide unaudited financial statements within the required time,and audited financial statements when the audit report becomes available. Any such financial statements will be prepared in accordance with the accounting principles described in the Bond Resolution or such other accounting principles as the District may be required to employ from time to time pursuant to state law or regulation. 49 The District's fiscal year end is currently December 31. Accordingly,it must provide updated information by June 30 in each year,unless the District changes its fiscal year. If the District changes its fiscal year,it will notify the MSRB of the change. Material Event Notices The District will also provide timely notices of certain events to EMMA and any SID. The District will provide notice of any of the following events with respect to the Bonds,if such event is material to a decision to purchase or sell Bonds: (1)principal and interest payment delinquencies; (2)non-payment related defaults; (3)unscheduled draws on debt service reserves reflecting financial difficulties; (4)unscheduled draws on credit enhancements reflecting financial difficulties;(5)substitution of credit or liquidity providers,or their failure to perform;(6)adverse tax opinions or events affecting the tax-exempt status of the Bonds; (7) modifications to rights of holders of the Bonds; (8) Bond calls; (9)defeasances;(10)release,substitution,or sale ofproperty securing repayment of the Bonds;and(11)rating changes. Neither the Bonds nor the Bond Resolution makes any provision for debt service reserves or liquidity enhancement. In addition,the District will provide timely notice of any failure by the District to provide information,data,or financial statements in accordance with its agreement described above under"Annual Reports." Availability of Information The District has agreed to provide the foregoing information only to the MSRB. Investors will be able to access,without charge from the MSRB,continuing disclosure information filed with the MSRB at www.emma:msrb.org. Limitations and Amendments The District has agreed to update information and to provide notices of material events only as described above. The District has not agreed to provide other information that may be relevant or material to a complete presentation of its financial results of operations,condition or prospects or agreed to update any information that is provided,except as described above. The District makes no representation or warranty concerning such information or concerning its usefulness to a decision to invest in or sell Bonds at any future date. The District disclaims any contractual or tort liability for damages resulting in whale or in part from any breach of its continuing disclosure agreement,or from any statement made pursuant to its agreement,although holders and beneficial owners ofB onds may seek a writ of mandamus to compel the District to comply with its agreement. The District may amend its continuing disclosure agreement from time to time to adapt to changed circumstances that arise from a change in legal requirements,a change in law,or a change in the identity,nature,status,or type of operations of the District,but only if the agreement,as amended,would have permitted an underwriter to purchase or sell Bonds in the offering described herein in compliance with Rule 15c2-12, taking into account any amendments and interpretations of the Rule to the date of such amendment,as well as such changed circumstances,and either the holders of a majority in aggregate principal amount of the outstanding Bonds consent to the amendment or any person unaffiliated with the District(such as nationally recognized bond counsel) determines that the amendment will not materially impair the interests of the beneficial owners of the Bonds. The District may also amend or repeal the agreement if the SEC amends or repeals the applicable provisions of such rule or a court of final jurisdiction determines that such provisions are invalid, but in either case only to the extent that its right to do so would not prevent the Underwriter from lawfully purchasing the Bonds in the offering described herein. If the District so amends the agreement,it has agreed to include with any financial information or operating data next provided in accordance with its agreement described above under "Annual Reports" an explanation, in narrative form, of the reasons for the amendment and of the impact of any change in the type of financial information and operating data so provided. Compliance with Prior Undertakings The District is in compliance with all continuing disclosure agreements made by it in accordance with the SEC Rule 15c2-12 in the last five years.. 50 Updating of Official Statement If,subsequent to the date of the Official Statement,the District learns,or is notified by the Underwriter,of any adverse event which causes the Official Statement to be materially misleading,and unless the Underwriter elects to terminate its obligation to purchase the Bonds, the District will promptly prepare and supply to the Underwriter an appropriate amendment or supplement to the Official Statement satisfactory to the Underwriter; provided, however, that the obligation of the District to so amend or supplement the Official Statement will terminate when the District delivers the Bonds to the Underwriter, unless the Underwriter notifies the District on or before such date that less than all of the Bonds have been sold to ultimate customers, in which case the District's obligations hereunder will extend for an additional period of time(but not more than 90 days after the date the District delivers the Bonds)until all of the bonds have been sold to ultimate customers. • This Official Statement is duly approved by the Board ofDirectors of the District as ofthe date specified on the firstpage hereof. /s/ Sandy tingles President,Board of Directors Brazoria County Municipal Utility District No.2 ATTEST: /s/ Kevin Wilson Secretary,Board of Directors Brazoria County Municipal Utility District No.2 • 51 APPENDIX A LOCATION MAP APPENDIX B BRAZORIA COUNTY MUNICIPAL UTILITY DISTRICT NO.2 BRAZORIA COUNTY,TEXAS ANNUAL FINANCIAL REPORT DECEMBER 31,2008 • APPENDIX B BRAZORIA COUNTY MUNICIPAL UTILITY DISTRICT NO.3 BRAZORIA COUNTY,TEXAS ANNUAL FINANCIAL REPORT DECEMBER 31,2008 APPENDIX C SPECIMEN OF FINANCIAL GUARANTY INSURANCE POLICY Brazoria County Municipal Utility District No.2 Refunding Effects Current Refunding of Selected Series 1997,1998,1999 and 2002 Bonds("A"Insured/BQ Sca Less:Debt Service Plus:Series 2009 Refunding Bonds Year Ending Current Total on Refunded Current Interest Bonds Capital Post Rfndg Post Rfndg 12/31 Debt Service Bonds(1) Principal Interest Appr Bonds Debt Service Savings 2009 1,661,226 1,661,226 2010 1,669,111 306,488 120,000 144,464 1,627,088 42,023 2011 1,668,511 1,001,488 805,000 156,158 1,628,181 40,330 2012 1,674,194 996,373 810,000 144,888 1,632,709 41,485 2013 1,686,005 1,114,086 945,000 130,713 1,647,631 38,374 2014 1,693,590 1,119,436 970,000 109,923 1,654,076 39,514 2015 1,692,248 1,107,269 985,000 84,703 1,654,681 37,566 2016 1,700,714 961,625 865,000 56,630 1,660,719 39,995 2017 1,702,381 961,950 890,000 29,815 1,660,246 42,135 Totals $15,147,980 $7,568,715 $6,390,000 $857,294 $14,826,557 $321,422 (1)-This column only reflects debt payments scheduled after the closing date of 10/01/2009. BRAZORIA_MUD02:RUN2009REF AGG2009OLD AGG2009REF NEW2009REF Prepared by:Rathmann&Associates-Houston,Texas 08/24/2009 @ 15:50 v9.03--Run"D" Page-1 Brazoria County Municipal Utility District No.2 Sources &Uses Report Current Refunding of Selected Series 1997,1998,1999 and 2002 Bonds("A"Insured/BQ Sca Sources of Funds: Principal Amount of Current Interest Bonds(CIBs) 6,390,000.00 Total SOURCES of Funds $6,390,000.00 Uses of Funds: Initial Cash Deposit to Escrow 6,017,460.58 Bond Insurance 72,472.92 Issuance Expenses: ($298,395.00) Underwriter's Discount 79,875.00 Rating Agency 11,000.00 Bond Counsel 63,900.00 Accountant/CPA 9,000.00 Printing 9,500.00 Trustee 1,600.00 Financial Advisor 108,630.00 Special Tax Counsel 2,500.00 Underwriter's Counsel 6,000.00 Attorney General's Fee 6,390.00 • Rounding Amount 1,671.50 Total USES of Funds $6,390,000.00 Miscellaneous Bond Issuance Information: Delivery Date: 10/01/2009 Principal Amount of Bonds Being Refunded 5,980,000.00 Principal Amount of the Refunding Bonds 6,390,000.00 Proceeds of'The(new)Bonds" 6,390,000.00_ Rate/Yield on the Refunded Bonds 5.43357962% "All Costs Included"TIC on the New Issue is 4.05265810% Federal Arbitrage Yield on the New Issue is 2.97401229% Yield on Escrow - Total Debt Service Savings 321,421.96 • Present Value Savings @ 4.05265810% 277,259.91 Total Debt Service Savings as a Percent of Total Debt Service of Refunded Bonds 4.24671836% Present Value Savings as a Percent of Principal Amount of Bonds Being Refunded 4.63645343% BRAZORIA MUD02:RUN2009REF NEW2009REF AGG2009REF Prepared by:Rathmann&Associates-Houston,Texas 08/24/2009 @ 15:50 v9.03--Run"D" Page-2 Brazoria County Municipal Utility District No.2 Current Refunding of Selected Series 1997,1998,1999 and 2002 Bonds("A"Insured/BQ Sca Dated Date=10/01/2009 Series 2009 Refunding Bonds Delivery Date=10/01/2009 Term Bond Bond Coupon Interest Total Fiscal Year Dates Maturities Redemptions Proceeds Rate Yield Price Amount Debt Service Debt Service ' 03/01/2010 - - - - - - 65,665.63 65,665.63 - 09/01/2010 - 120,000.00 120,000.00 1.200 1.200000 100.000000 78,798.75 198,798.75 264,464.38 03/01/2011 - - - - - - 78,078.75 78,078.75 - 09/01/2011 - 805,000.00 805,000.00 1.400 1.400000 100.000000 78,078.75 883,078.75 961,157.50 03/01/2012 - - - - - - 72,443.75 72,443.75 - 09/01/2012 - 810,000.00 810,000.00 1.750 1.750000 100.000000 72,443.75 882,443.75 954,887.50 03/01/2013 - - - - - - 65,356.25 65,356.25 - 09/01/2013 - 945,000.00 945,000.00 2.200 2.200000 100.000000 65,356.25 1,010,356.25 1,075,712.50 03/01/2014 - - - - - - 54,961.25 54,961.25 - 09/01/2014 - 970,000.00 970,000.00 2.600 2.600000 100.000000 54,961.25 1,024,961.25 1,079,922.50 03/01/2015 - - - - - - 42,351.25 42,351.25 - 09/01/2015 - 985,000.00 985,000.00 2.850 2.850000 100.000000 42,351.25 1,027,351.25 1,069,702.50 03/01/2016 - - - - - - 28,315.00 28,315.00 - 09/01/2016 - 865,000.00 865,000.00 3.100 3.100000 100.000000 28,315.00 893,315.00 921,630.00 03/01/2017 - - - - - - 14,907.50 14,907.50 - 09/01/2017 - 890,000.00 890,000.00 3.350 3.350000 100.000000 14,907.50 904,907.50 919,815.00 Total - 6,390,000.00 6,390,000.00 857,291.88 7,247,291.88 7,247,291.88 Acc Int - - - - - - Grand Ttls - 6,390,000.00 6,390,000.00 857,291.88 7,247,291.88 7,247,291.88 TIC(Incl.all expenses)....4.05265810% Average Coupon 2.73523771% Net Eff.Int.Rate(Texas Vemon's)= 2.735238%(with Adjstmnt of$0.00). TIC(Arbitrage TIC) 2.97401229% Average Life(yrs)... 4.90 IRS Form 8038-G NIC =2.735238%(with Adjstmnt of$0.00). Bond Years 31,342.50 WAM(yrs) 4.904930 NIC= 2.735238%(with Adjstmnt of$0.00). BRAZORIA MUD02:NEW2009REF Prepared by:Rathmann&Associates-Houston,Texas 08/24/2009 @ 15:50 v9.03--Run"D" Page-3 Brazoria County Municipal Utility District No.2 Refunding Analysis Savings Report Current Refunding of Selected Series 1997,1998,1999 and 2002 Bonds("A"Insured/BQ Sca Maturing Proceeds @ Interest Total Escrowed FY Begins Cumulative PV of Savings Dates Amount issue Date Coupon Yield Amount Debt Service Debt 01/01 Savings 4.05265810% Savings 2009 2010 120,000 120,000.00 1.200 1.200000 144,464.38 264,464.38 306,487.52 42,023.14 42,023.14 42,216.23 2011 805,000 805,000.00 1.400 1.400000 156,157.50 961,157.50 1,001,487.52 40,330.02 82,353.16 38,755.27 2012 810,000 810,000.00 1.750 1.750000 144,887.50 954,887.50 996,372.52 41,485.02 123,838.18 38,043.67 2013 945,000 945,000.00 2.200 2.200000 130,712.50 1,075,712.50 1,114,086.26 38,373.76 162,211.94 33,688.58 • 2014 970,000 970,000.00 2.600 2.600000 109,922.50 1,079,922.50 1,119,436.26 39,513.76 201,725.70 33,101.15 2015 985,000 985,000.00 2.850 2.850000 84,702.50 1,069,702.50 1,107,268.76 37,566.26 239,291.96 30,088.03 2016 865,000 865,000.00 3.100 3.100000 56,630.00 921,630.00 961,625.00 39,995.00 279,286.96 30,571.67 2017 890,000 890,000.00 3.350 3.350000 29,815.00 919,815.00 961,950.00 42,135.00 321,421.96 30,795.31 $6,390,000 $6,390,000.00 $857,291.88 $7,247,291.88 $7,568,713.84 $321,421.96 $277,259.91 ' Acc/nt Grnd Total $6,390,000 $6,390,000.00 $857,291.88 $7,247,291.88 $7,568,713.84 $321,421.96 $277,259.91 BRAZORIA MUD02:RUN2009REF NEW2009REF AGG2009REF Prepared by:Rathmann 8 Associates-Houston,Texas 08/24/2009 @ 15:50 v9.03--Run"D" Page-4 Brazoria County Municipal Utility District No.2 Issuance Expenses for NEW2009REF Current Refunding of Selected Series 1997,1998,1999 and 2002 Bonds("A"Insured/BQ Sca Expenses for NEW2009REF Expense Raises Exp has no Expense Title Type Units Arb Yield Affect Total on Arb Yield Underwriter's Discount V 12.500000 0.00 79,875.00 79,875.00 Rating Agency F 11,000.00 0.00 11,000.00 11,000.00 Bond Counsel V 10.000000 0.00 63,900.00 63,900.00 Accountant/CPA F 9,000.00 0.00 9,000.00 9,000.00 Printing F 9,500.00 0.00 9,500.00 9,500.00 Trustee F 1,600.00 0.00 1,600.00 1,600.00 Bond Insurance D 10.000000 72,472.92 0.00 72,472.92 Miscellaneous F 0.00 0.00 0.00 0.00 Financial Advisor V 17.000000 0.00 108,630.00 108,630.00 Special Tax Counsel F 2,500.00 0.00 2,500.00 2,500.00 Underwriter's Counsel F 6,000.00 0.00 6,000.00 6,000.00 Attorney General's Fee V 1.000000 0.00 6,390.00 6,390.00 Totals $72,472.92 $298,395.00 $370,867.92 Type: F-Fixed Expense V-Variable Expense Based on Issue Size D-Variable Expense Based on Total Debt Service E-Variable Expense Based on Total Debt Service Less Accrued Interest R-Variable Expense Based on Reserve Fund Requirement BRAZORIA_MUD02:.EXP2009REF Prepared by:Rathmann&Associates-Houston,Texas 08/24/2009 @ 15:50 v9.03--Run"D" Page-5 Brazoria County Municipal Utility District No.2 Escrow Sufficiency&Balance Report Current Refunding of Selected Series 1997,1998,1999 and 2002 Bonds("A"Insured/BQ Sca Escrow Settlement Date Is 10/01/2009 Proceeds from Less Amts to Plus Maturing Adjusted Proceeds from Original be Invested Amts Invested Proceeds from Present Value 'Other' Old D/S Escrow Escrow Dates ResEscted in 0%SLGs in 0%SLGs Rstrct'd Esc @ 0.00000000% Investments Requirement New Balance Old Balance 10/01/2009 0.00 0.00 0.00 0.00 0.00 0.00 0.00 6,017,460.58 6,017,460.58 10/15/2009 0.00 0.00 0.00 0.00 0.00 0.00 6,017,459.58 1.00 1.00 Totals $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $6,017,459.58 Cost of SLG Securities $0.00 Escrow Arbitrage YLD after Reinvestment in 0%SLGs=0.00000000% Cost of'Other'Restricted Investments $0.00 Escrow Starting Balance $6,017,460.58 Total Escrow Cost... $6,017,460.58 SLG Rates Were Taken From SLG Table Dated 07/30/2009 BRAZORIA_MUD02:RUN2009REFAGG2009REF Prepared by:Rathmann 8 Associates-Houston,Texas 08/24/2009 @ 15:50 v9.03—Run"D" Page-6 Brazoria County Municipal Utility District No.2 Aggregation Spreadsheet Report Current Refunding of Selected Series 1997,1998,1999 and 2002 Bonds("A"Insured/BQ Sca Data are Principal Amounts Bonds to Refund in 2009 Data are to Maturity FY 01/01 Dates Totals OLD1997R OLD1998R OLD1999R OLD2002R 2009 0.00 2010 0.00 2011 695,000.00 200,000.00 340,000.00 155,000.00 2012 725,000.00 205,000.00 355,000.00 165,000.00 2013 880,000.00 215,000.00 375,000.00 170,000.00 120,000.00 2014 930,000.00 230,000.00 390,000.00 175,000.00 135,000.00 2015 965,000.00 595,000.00 235,000.00 135,000.00 2016 870,000.00 635,000.00 235,000.00 2017 915,000.00 675,000.00 240,000.00 Totals $5,980,000.00 $2755,000.00 $1,460,000.00 $1,375,000.00 $390,000.00 Component Face Amt -----Title----- From To OLD1997R $2,755,000.00 Series 1997 Bonds to Refund OLD1998R $1,460,000.00 Series 1998 Refunding Bonds to Refund OLD1999R $1,375,000.00 Series 1999 Bonds to Refund OLD2002R $390,000.00 Series 2002 New Money Bonds to Refund • • • BRAZORIA_MUD02:AGG2009REF Prepared by:Rathmann&Associates-Houston,Texas 08/24/2009 @ 15:50 v9.03--Run"D" Page-7 Brazoria County Municipal Utility District No.2 Current Refunding of Selected Series 1997,1998,1999 and 2002 Bonds("A"Insured/BQ Sca Dated Date=12/01/1996 Series 1997 Bonds to Refund Delivery Date=06/30/1997 _• Term Bond Bond Coupon Interest Total Fiscal Year Debt Service Dates Maturities Redemptions Proceeds Rate Yield Price Amount Debt Service Debt Service to Call 03/01/2009 - - - - - - 71,715.63 71,715.63 - 71,715.63 09/01/2009 - - - - - 100.000000 71,715.63 71,715.63 - 71,715.63 10/15/2009 - - - - - - - - 143,431.26 2,772,530.49 03/01/2010 - - - - - - 71,715.63 71,715.63 - - 09/01/2010 - - - - 100.000000 71,715.63 71,715.63 143,431.26 - 03/01/2011 - - - - - - 71,715.63 71,715.63 - - 09/01/2011 - 200,000.00 * 200,000.00 5.375 5.375000 100.000000 71,715.63 271,715.63 343,431.26 - 03/01/2012 - - - - - - 66,340.63 66,340.63 - - 09/01/2012 - 205,000.00 * 202,890.55 5.400 5.500000 98.971000 66,340.63 271,340.63 337,681.26 - . 03/01/2013 - - - - - - 60,805.63 60,805.63 - - 09/01/2013 - 215,000.00 * 213,843.30 5.500 5.550000 99.462000 60,805.63 275,805.63 336,611.26 - 03/01/2014 - - - - - - 54,893.13 54,893.13 - - 09/01/2014 - 230,000.00 * 223,688.80 5.350 5.600000 97.256000 54,893.13 284,893.13 339,786.26 - 03/01/2015 - - - - - - 48,740.63 48,740.63 - - 09/01/2015 - 595,000.00 * 576,507.40 5.375 5.650000 96.892000 48,740.63 643,740.63 692,481.26 - 03/01/2016 - - - - - - 32,750.00 32,750.00 - - 09/01/2016 - 635,000.00 * 583,514.20 5.000 5.700000 91.892000 32,750.00 667,750.00 700,500.00 - 03/01/2017 - - - - - - 16,875.00 16,875.00 - - 09/01/2017 - 675,000.00 " 614,965.50 5.000 5.750000 91.106000 16,875.00 691,875.00 708,750.00 - Total - 2,755,000.00 2,615,409.75 991,103.82 3,746,103.82 3,746,103.82 2,915,961.75 Acc Int - - - -226,701.06 -226,701.06 - - Grand Ttls - 2,755,000.00 2,615,409.75 764,402.76 3,519,402.76 3,746,103.82 2,915,961.75 "-Bonds callable... 10/15/2009@100.000 TIC(Incl.all expenses)....5.61888459% Average Coupon 5.19106677% Net Eff.Int.Rate(Texas Vemon's)= 5.448038%(with Adjstmnt of$0.00). TIC(Arbitrage TIC) 5.61888459% Average Life(yrs)... 19.72 IRS Form 8038-G NIC =5.780651%(with Adjstmnt of$0.00). Bond Years 54,321.25 WAM(yrs) 18.075156 NIC= 5.448038%(with Adjstmnt of$0.00). BRAZORIA_MUD02:OLD1997R Prepared by:Rathmann&Associates-Houston,Texas 08/24/2009 @ 15:50 v9.03--Run"D" Page-8 Brazoria County Municipal Utility District No. 2 Current Refunding of Selected Series 1997,1998,1999 and 2002 Bonds("A"Insured/BQ Sca Dated Date=05/01/1998 Series 1998 Refunding Bonds to Refund Delivery Date=05/14/1998 _; Term Bond Bond Coupon Interest Total Fiscal Year Debt Service Dates Maturities Redemptions Proceeds Rate Yield Price Amount Debt Service Debt Service to Call 03/01/2009 - - - - - - 35,665.63 35,665.63 - 35,665.63 09/01/2009 - - - 4.650 4.700000 99.559000 35,665.63 35,665.63 - 35,665.63 10/15/2009 - - - - - - - - 71,331.26 1,468,718.26 03/01/2010 - - - - - - 35,665.63 35,665.63 - - 09/01/2010 - - * - 4.700 4.770000 99.347000 35,665.63 35,665.63 71,331.26 - 03/01/2011 - - - - - - 35,665.63 35,665.63 - - 09/01/2011 - 340,000.00 * 337,327.60 4.750 4.830000 99.214000 35,665.63 375,665.63 411,331.26 - 03/01/2012 - - - - - - 27,590.63 27,590.63 - - 09/01/2012 - 355,000.00 * 353,345.70 4.875 4.920000 99.534000 27,590.63 382,590.63 410,181.26 - 03/01/2013 - - - - - - 18,937.50 18,937.50 - - 09/01/2013 - 375,000.00 ' 372,180.00 4.900 4.970000 99.248000 18,937.50 393,937.50 412,875.00 - 03/01/2014 - - - - - - 9,750.00 9,750.00 - - 09/01/2014 - 390,000.00 * 387,819.90 5.000 5.050000 99.441000 9,750.00 399,750.00 409,500.00 - Total - 1,460,000.00 1,450,673.20 326,550.04 1,786,550.04 1,786,550.04 1,540,049.52 Acc Int - - - -2,575.85 -2,575.85 - - • Grand Ttls - 1,460,000.00 1,450,673.20 323,974.19 1,783,974.19 1,786,550.04 1,540,049.52 *-Bonds callable... 10/15/2009@100.000 TIC(Incl.all expenses)....4.95191135% Average Coupon 4.89217196% Net Eff.Int.Rate(Texas Vernon's)= 4.935070%(with Adjstmnt of$0.00). TIC(Arbitrage TIC) 4.95191135% Average Life(yrs)... 14.89 IRS Form 8038-G NIC =4.966759%(with Adjstmnt of$0.00). Bond Years 21,741.67 WAM(yrs) 14.855923 NIC= 4.935070%(with Adjstmnt of$0.00). BRAZORIA_MUD02:OLD1998R Prepared by:Rathmann&Associates-Houston,Texas 08/24/2009 @ 15:50 v9.03--Run"D" • Page-9 Brazoria County Municipal Utility District No.2 Current Refunding of Selected Series 1997,1998,1999 and 2002 Bonds("A"Insured/BQ Sca Dated Date=11/01/1999 Series 1999 Bonds to Refund Delivery Date=11/30/1999 Term Bond Bond Coupon Interest Total Fiscal Year Debt Service Dates Maturities Redemptions Proceeds Rate Yield Price Amount Debt Service Debt Service to Call 03/01/2009 - - - - - 37,575.00 37,575.00 - 37,575.00 09/01/2009 - - - 5.200 5.200000 100.000000 37,575.00 37,575.00 - 37,575.00 ' 10/15/2009 - - - - - - - - 75,150.00 1,384,185.00 03/01/2010 - - - - - - 37,575.00 37,575.00 - - 09/01/2010 - - 5.200 5.250000 99.584000 37,575.00 37,575.00 75,150.00 - , 03/01/2011 - - - - - - 37,575.00 37,575.00 - - 09/01/2011 - 155,000.00 * 154,316.45 5.300 5.350000 99.559000 37,575.00 192,575.00 230,150.00 - 03/01/2012 - - - - - - 33,467.50 33,467.50 - - 09/01/2012 - 165,000.00 * 164,232.75 5.400 5.450000 99.535000 33,467.50 198,467.50 231,935.00 - ' 03/01/2013 - - - - - - 29,012.50 29,012.50 - - 09/01/2013 - 170,000.00 * 170,000.00 5.500 5.500000 100.000000 29,012.50 199,012.50 228,025.00 - 03/01/2014 - - - - - - 24,337.50 24,337.50 - - 09/01/2014 - 175,000.00 * 174,109.25 5.500 5.550000 99.491000 24,337.50 199,337.50 223,675.00 - 03/01/2015 - - - - - - 19,525.00 19,525.00 - - 09/01/2015 - 235,000.00 * 232,537.20 5.500 5.600000 98.952000 19,525.00 254,525.00 274,050.00 - 03/01/2016 - - - - - - 13,062.50 13,062.50 - - 09/01/2016 - 235,000.00 * 231,190.65 5.500 5.650000 98.379000 13,062.50 248,062.50 261,125.00 - 03/01/2017 - - - - - - 6,600.00 6,600.00 - - 09/01/2017 - 240,000.00 * 234,660.00 5.500 5.700000 97.775000 6,600.00 246,600.00 253,200.00 - Total - 1,375,000.00 1,361,046.30 477,460.00 1,852,460.00 1,852,460.00 1,459,335.00 Acc Int - - - -6,053.75 -6,053.75 - - Grand Ttls - 1,375,000.00 1,361,046.30 471,406.25 1,846,406.25 1,852,460.00 1,459,335.00 *-Bonds callable... 10/15/2009@100.000 TIC(Incl.all expenses)....5.56634768% Average Coupon 5.47225796% Net Eff.Int.Rate(Texas Vernon's)= 5.539163%(with Adjstmnt of$0.00). TIC(Arbitrage TIC) 5.56634768% Average Life(yrs)... 15.17 IRS Form 8038-G MC =5.601218%(with Adjstmnt of$0.00). Bond Years 20,855.83 WAM(yrs) 15.074210 NIC= 5.539163%(with Adjstmnt of$0.00). BRAZORIA_MUD02:OLD1999R Prepared by:Rathmann&Associates-Houston,Texas 08/24/2009 @ 15:50 v9.03--Run"D" Page-10 Brazoria County Municipal Utility District No.2 Current Refunding of Selected Series 1997,1998,1999 and 2002 Bonds("A"Insured I BQ Sca Dated Date=03/01/2002 Series 2002 New Money Bonds to Refund Delivery Date=03/07/2002 Term Bond Bond Coupon Interest Total Fiscal Year Debt Service Dates Maturities Redemptions Proceeds Rate Yield Price Amount Debt Service Debt Service to Call 03/01/2009 - - - - - - 8,287.50 8,287.50 - 8,287.50 09/01/2009 - - - 4.250 4.100000 100.957000 8,287.50 8,287.50 - 8,287.50 10/15/2009 - - - - - - - - 16,575.00 392,025.83 , 03/01/2010 - - - - - - 8,287.50 8,287.50 - - 09/01/2010 - - - 4.250 4.250000 100.000000 8,287.50 8,287.50 16,575.00 - 03/01/2011 - - - - - - 8,287.50 8,287.50 - - 09/01/2011 - - * - 4.250 4.300000 99.613000 8,287.50 8,287.50 16,575.00 - 03/01/2012 - - - - - - 8,287.50 8,287.50 - _ 09/01/2012 - - 4.250 4.450000 98.338000 8,287.50 8,287.50 16,575.00 - 03/01/2013 - - - - - - 8,287.50 8,287.50 - _ 09/01/2013 - 120,000.00 * 116,805.60 4.250 4.550000 97.338000 8,287.50 128,287.50 136,575.00 - 03/01/2014 - - - - - - 5,737.50 5,737.50 - - 09/01/2014 - 135,000.00 * 129,928.05 4.250 4.650000 96.243000 5,737.50 140,737.50 146,475.00 - 03/01/2015 - -_ - - - - 2,868.75 2,868.75 - _ 09/01/2015 - 135,000.00 * 128,981.70 4.250 4.700000 95.542000 2,868.75 137,868.75 140,737.50 - Total - 390,000.00 375,715.35 100,087.50 490,087.50 490,087.50 408,600.83 Acc Int - - - -276.25 -276.25 - - Grand Ttls - 390,000.00 375,715.35 99,811.25 489,811.25 490,087.50 408,600.83 *-Bonds callable... 10/15/2009@100.000 TIC(Incl.all expenses)....4.63919757% Average Coupon 4.25000000% Net Eff.Int.Rate(Texas Vernon's)= 4.542120%(with Adjstmnt of$0.00). TIC(Arbitrage TIC) 4.63919757% Average Life(yrs)... 12.54 IRS Form 8038-G NIC =4.717495%(with Adjstmnt of$0.00). Bond Years 4,890.00 WAM(yrs) 12.515741 NIC= 4.542120%(with Adjstmnt of$0.00). BRAZORIA_MUD02:OLD2002R Prepared by:Rathmann&Associates-Houston, Texas 08/24/2009 @ 15:50 v9.03—Run"D" Page-11