"The Internal Revenue Service August 3 issued guidance that will allow state and local tax exempt bond issuers to allocate the full amount of their volume cap to an entire draw-down loan or commercial paper program on the date they issue the bonds, as long as all the draws are made within three years, practitioners told BNA."
In this article, "IRS Guidance Allows Allocation of Volume Cap to Entire Financing," published in BNA Daily Tax Report on August 4, 2011, Mintz Levin attorney Jeremy Spector is quoted detailing the volume cap relief for issuers.