DALLAS -- For the Dallas Independent School district, managing a $2 billion drop in the tax base may be the easy part of budget-writing this year.

The tough part will be living with the so-called Robin Hood school finance law. The wealth-sharing plan could cost the district $47 million in state aid this year, triggering teacher layoffs and other spending cuts and forcing an estimated 17% tax increase to balance the $544 million budget.

"We're going through some drastic reductions in personnel at this point," said Marvin Edwards, superintendent of the nation's last metropolitan district with a triple-A rating. "I think that this year is rating. "I think that this year is probably the worst that it will ever be. It has to go up from here."

Dallas is hardly alone. Investment bankers say that many of the state's 1,054 schools are facing pressures on their ability to balance budgets and plan capital programs under a new school finance law -- known as Senate Bill 351 -- that caps maximum tax rates and forces property-rich districts to share $400 million in tax wealth with poor schools.

But the Dallas schools are undergoing in microcosm the backlash that some of the state's better-known credits face under a law written by court order and meant to correct years of inequitable funding among Texas schools.

As it faces its first school year under a plan that critics call draconian, Mr. Edwards says the district must juggle more than $400 million in capital needs while riding out the loss of state aid and a drop in the tax base that -- along with a new property tax cap -- will hamper the district in addressing its needs.

Just last week a commission recommended that the district ask voters to approve a record $275 million bond program, the district's first referendum since 1985.

The district believes it can sell a bond program to voters by structuring the debt so that it will not cause an increase in the debt service tax -- now about 9.35 cents per $100 of assessed valuation.

"We feel at this point that a new-money issue can be structured without any pain to taxpayers," said Jerry Robinson, senior vice president and manager of public finance at NCNB Capital Markets Inc. in Dallas, the district's financial adviser. "We believe it is possible."

To do that, the district expects to have to restructure an undertermined amount of its outstanding debt, a move that has become common this year with Texas schools trying to free up debt or tax rate capacity they may need later.

In fact, Texas schools refunded $528.7 million in debt so far in 1991 as part of a recofd $1.78 billion of issuance this year. That level is twice the total for all of last year, according to Securities Data Co./Bond Buyer.

"We've seen some refundings done to free up capacity," said Chris Evangel, a vice president at Moody's Investors Service, which rates nearly 800 school credits in Texas. "They are extending debt life, in some cases out to 30 years from 20 years."

Texas schools are also using short-term debt at record levels. While exact numbers are not available, investment bankers estimated that at least $200 million in tax and revenue anticipation note sales had been completed this year. A dozen issues totaling $74 million were on the August calendar alone.

"We've seen more cash flow borrowing than in the past," said Mr. Evangel. "It seems like it's a trend."

While short-term borrowing is expected to persist, experts say the future for long-term bond sales is less certain because of the continuing legal fight.

"We are going to have a fairly long period of time where there is going to be uncertainty over S.B. 351," said Cliff Youngblood, a bond lawyer with Vinson & Elkins in Houston. "I expect, as everyone else does, that there will be more decisions to come in this $(school finance$) case."

Last month, Travis County District Judge Scott McCown upheld the constitutionally of the new school finance law, but already the case has been appealed to the Texas Supreme Court. Justices have twice struck down school funding laws in the seven-year-old court fight.

"The growth will continue and the need for facilities continues," said Mel Schonhorst, first vice president at Rauscher Pierce Refsnes Inc. of Dallas, the leading underwriter of school bonds in Texas this year. "We have several other clients that will be selling later this year."

In fact, his firm had about a dozen closing last week alone. So far, they have underwritten 39 issues totaling $481.8 million in 1991.

For Mr. Schonhorst and others, there is little doubt that the so-called Robin Hood plan will affect the way that administrators write their budgets and plan bond programs in future years.

Approved by lawmakers in April, the new law creates a two-tier funding system by establishing countywide education districts empowered to collect a state-set tax of 72 cents per $100 of assessed valuation next year. That property tax would rise to $1 in 1994.

The money collected would be redistributed on an equalized basis to schools within the district. At the same time, each district could levy up to 50 cents per $100 of assessed valuation to pay for new debt service, build facilities, or pay for programs.

Because the relationship between paying for school operations and funding new debt will have to come from a limited tax, Mr. Schonhorst said that districts will have to do more careful long-range planning.

"Those that don't," he warned, "will only pay the price later."

But for a district such as Dallas, the risks may be even greater. After surviving two energy recessions and a collapse of real estate values in the 1980s, outsiders believe the district's triple-A rating from Moody's may be jeopardized by the new school finance law.

Dallas has been assigned the top rating since 1973 and is the last major metropolitan school district to still have a triple-A. Standard & Poor's Corp. rates the district AA-plus.

However, Mr. Edwards said the district intends to continue to balance its budget and maintain operations that have sustained its triple-A. He added, "We're hoping it will remain intact."

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