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Second, the Court avoided the issue of whether impact fees are permissible under Minnesota law and whether the road unit connection charge was legally permissible as an impact fee, for the reason that the charge lacked an essential impact fee characteristic: that it be proportionate to the need for the public facilities generated by new development. The Court concluded that there was “insufficient evidence” to determine whether the proportionality element was present. Accordingly, we reserve the issue of whether impact fees are authorized under Minnesota law, but reject the city’s contention that the road unit connection charge draws its authorization as such a fee. The Court thus avoided the question of the legality of impact fees in Minnesota by concluding, based on insufficiency of evidence, that the charge did not qualify as an impact fee. Third, the Court rejected the city’s argument that the charge was not an illegal tax, as the court of appeals had held, but rather a legal exercise of the city’s police powers, which include charging fees to cover the costs of regulation. The Court concluded that because the charge went beyond the legitimate police power function of charging fees to recover costs of regulation—clearly the charge was intended to fund the shortfall in road maintenance funding—it was a revenue-raising measure: a tax. Since it was a tax, it “must draw its authorization, if at all, from the city’s powers of taxation.” The Court found no express authorization in the municipal taxing authority granted by the Legislature under Minn. Stat. § 412.251 for a road unit connection charge. Moreover, the Court concluded that the tax enabling legislation’s catch-all provision, allowing cities to impose “other special taxes authorized by law,” failed to provide authority since the Court had concluded for the above-described reasons that the charge was not “‘so authorized by law.’”16 While Country Joe did not decide the issue of the legality of impact fees in Minnesota, it did clarify and confirm that the nature of municipal corporations as limited statutory creations restricts cities to the powers expressly granted by the Legislature under state statute. In particular, cities cannot create financing mechanisms in reliance on inherent or implied powers and in the absence of express statutory authority that sanctions the revenue-raising scheme. SJC Properties v. City of Rochester presents a corollary to these principles, demonstrating that a city cannot legally adopt an impact fee for road improvements and purport to impose the fee through the special assessment procedures of Minn. Stat. Ch. 429. SJC Properties is a judicial appeal of over $1.7 million in special assessments levied by the City of Rochester (Rochester) against 200 acres of contiguous parcels of undeveloped property owned or controlled by developer Frank Kottschade (collectively, SJC property). A regional transportation planning process and Rochester’s creation of a funding mechanism to finance city portions of the transportation improvements provide the backdrop for the special assessments levied against the SJC property. Regional Transportation Planning and the Creation of Transportation Improvement Districts in the City Ten years before Rochester levied the special assessments, a joint council of the city, Olmsted County, and state government issued a study report outlining recommendations for regional transportation improvements along the Trunk Highway (TH) 63 corridor on the south side of Rochester. The study recommended a freeway design for the TH 63 corridor, with uninterrupted mainline traffic flow, controlled access throughout the corridor and local access to TH 63 provided by grade-separated interchanges. The SJC property lies at the southwest corner of TH 63 and 40th Street SW, an intersection that the study recommended for improvement to a grade-separated interchange. The study further recommended that 40th Street SW, a two-lane, low-traffic road, be eventually expanded to four lanes to the west of TH 63—the portion of 40th Street that bounds the SJC property on the north. In 2003, Rochester established a transportation funding task force to provide recommendations for funding future transportation improvements in the city. The task force recommended a variety of funding mechanisms, including seeking approval of a one-half percent sales tax increase from the Legislature, levying special assessments, and establishing transportation improvement districts (TIDs) in the city. Based on these recommendations, the city council adopted by resolution a TID program. Before the city adopted the TID program, the city attorney had advised the city council that TID fees could not be imposed on developers without their consent and must be voluntary, because the TID fees could be deemed to be impact fees for which there was no express authority in Minnesota law. Rochester’s TID program authorized the city to create TIDs for “any geographic area of the city experiencing or anticipating