ITEM 7-A
Council Mtg: August 7, 1990
TO: Mayor and City Council
FROM: City Staff
SUBJECT: Tenant Participating Conversion (TPC) 108 To Allow The
Conversion of An Eight Unit Apartment Building To
Condominiums at 1518 Yale Street. It Was Determined
That The Planning Commission Did Not Have The Authority
To Act on The Conversion Due To The Presence of One of
The Building's Owners on The Planning Commission.
INTRODUCTION
This report recommends that the City Council approve the proposed
eight unit tenant participating conversion subject to the
findings and conditions contained herein.
BACKGROUND
This application for conversion was originally scheduled for the
June 6, 1990, Planning Commission public hearing. Prior to the
public hearing, it was determined that since an owner of the
building was a member of the Planning Commission, the proposed
conversion should be brought before the City Council for public
hearing. The City Council is therefore required to hear the
subject request, and make the findings and conditions necessary
to approve, conditionally approve or deny the subject conversion.
This is an application for approval of a Tenant-Participating
Conversion (TPC) submitted under the provisions of the Tenant
Ownership Rights Charter Amendment (TORCA) approved by the voters
of the City of Santa Monica in June 1984. As required by the
provisions of TORCA, the public hearing held by the Planning
Commission, or City Council, on the TPC application is held
simultaneously with the hearing on the tentative map for the
conversion.
The subject site contains a two story, eight unit apartment
building constructed in August of 1947. There are 4 two bedroom/
one bathroom units, and 4 one bedroom/one bathroom units. The
building meets parking standards in effect at the time of the its
construction with the provision of 6 parking spaces. The
application for conversion was accepted for filing by the City on
February 2, 1990.
Under a March 23, 1990 opinion issued by the City Attorney, an
apartment building owner who resides in an apartment building of
which they are an owner, cannot be considered a "cosigning
tenant" (a tenant agreeing to the conversion) or an "intending to
purchase" tenant (a tenant who has an intent to purchase their
unit) in a tenant participating conversion filed under the
provisions of TORCA. Owners who are living in their buildings
are therefore precluded from voting for a conversion. The
subject conversion is the first tenant participating conversion
to be reviewed under the aforementioned interpretation, and is
adversely impacted by said interpretation.
Under Charter Section 2001(n), a tenant is defined as "any person
who is an authorized tenant of an owner of a residential rental
building for which a Tenant Participating Conversion Application
has been filed". A cosigning tenant is further defined as "any
tenant agreeing to the conversion by his or her signature on the
Tenant-Participating Conversion Application who has personally
occupied his or her unit continuously for a period of at least
six (6) months prior to the date he or she signs the
Tenant-Participating Conversion Application". Under the City
Attorney's opinion, an owner of residential property could not be
considered a tenant since the owner is not occupying the property
under the terms of a rental housing agreement, and is not an
authorized tenant of the owner. The only exception would be if
an "owner" does not actually hold an ownership interest in the
property, but holds an interest in some other entity, such as a
corporation or partnership, which owns the building. Even under
this situation, the owner must demonstrates a landlord/tenant
relationship with the corporation or partnership.
Under the subject proposal, the owners constitute two of the six
tenants agreeing to the conversion, and two of the four tenants
agreeing to purchase their units. The title report indicates
that Paul Rosenstein, Carol Nolan and Diane Perlov are in fact
owners of the 1518 Yale Street property. Records supplied by the
applicant, however, indicate that rent payments were made to 1518
Yale Street Associates, which in turn made the mortgage payments.
While the 1518 Yale Street Associates is not a formal corporation
or partnership, it would appear that a tenant/landlord
relationship is in existence.
By not allowing the owners of the subject building to act as
"cosigning" tenants or "intending to purchase" tenants, the votes
needed to process a tenant participating conversion are not met.
In processing an application for conversion, the first step is
filing a request for submittal appointment with the Planning
Division. Preliminary research is conducted by staff, and a
formal appointment is scheduled with the applicant. At the
submittal meeting, the application is reviewed for conformance
with the submittal requirements of Article XX, Section 2002. If
all required items are provided, the application is accepted by
the City pursuant to Section 2003. If there is missing
information, the application is not accepted, and an explanation
of what is needed is given by staff.
The subject application for conversion was submitted for staff
review and accepted for filing on February 2, 1990. No objection
letters were received by the City during the 25 day objection
period. The application for subdivision was accepted as complete
on April 2, 1990. Section 2004(a) states that a Tenant
Participating Conversion Application, along with any required
subdivision map or tentative parcel map, shall be denied if the
Tenant Participating Conversion Application fails to the meet the
requirements of Article [XX], was the result of fraud,
misrepresentation, or threat of similar coercion, or fails to
meet the requirements of the Subdivision Map Act of the State of
California. Through staff's acceptance of the tenant
participating conversion application and tentative tract map, the
grounds for denial of the subject application would be if there
were any allegations of fraud, misrepresentation, ect., or if it
is determined that the requisite number of votes were not
obtained.
The applicant argues that since the tentative tract map is a
vesting tract map, then the application for conversion should be
reviewed under the Charter amendment as it was interpreted prior
to the City Attorney's opinion.
Until the March 23, 1990 memorandum from the City Attorney was
issued, the City had processed and approved a number of
conversion projects in which resident owners were considered as
"cosigning tenants" and "intending to purchase" tenants.
Research by the applicant's attorney indicates that there have
been 27 projects where owners have been considered as tenants,
all of which have been accepted by the City, approved by the
Planning Commission and with various documents relating to the
conversions reviewed and approved by the City Attorney's office.
Given this precedent, and the applicant's reliance on it, it
would seem to be unfair to apply the new interpretation to
project's submitted prior to City Attorney's March 23, 1990,
memorandum. One other project, a three unit conversion, would be
affected.
Staff is prepared to enforce the recent City Attorney
interpretation of the definition of "tenant" on all applications
submitted after March 23, 1990. The owner/signatory issue aside,
The City Council, may, however, deny this application ONLY upon a
specific finding that the proposed conversion fails to meet the
requirements of Article XX of the City Charter (TORCA) or the
State Subdivision Map Act or is the result of fraud,
misrepresentation, or threat or similar coercion. The conversion
meets the requirements of Article XX as they were interpreted at
the time of application submittal, and as such should be
approved. This recommendation is at variance with the City
Attorney's opinion and recommendation on this matter. Should
the Council wish to apply the City Attorney's opinion to this and
the other affected project, staff will prepare appropriate
findings for denial based upon the Council action.
With the application of the previous interpretation regarding the
owner/tenant issue, staff finds no basis for denial of this
application and therefore recommends approval with the findings
and conditions set forth below. If the City Council, however,
determines that in this particular situation owners should not be
considered tenants, the application must be denied based on the
applicant's failure to obtain the required number of votes
agreeing to the conversion and intending to purchase. If this is
the case, staff will return to the City Council at a later date
with negative findings.
As the Council knows, it approved revised Charter language for
voter consideration which would specifically address the issue of
owner/tenant eligibility to sign as a co-signing and intending to
purchase tenant. It seems clear that the intent of the Council
is to allow projects such as this one to move forward.
Summary Information
Number of Total Units 8
Units with Cosigning Tenants 6 (75% of total units)
Units with Tenants Signing 4 (50% of total units)
Intent to Purchase
Units with Senior or
Disabled Tenants 2 senior citizens
Estimate of Conversion Tax $43,300.00 on sale of
all units
Owner(s) Carol Nolan, Diane Per-
lov and Paul Rosenstein
Last Hearing Date
per Sub. Map Act June 6, 1990 w/ ext. of
time granted by
applicant.
Building Qualification: The subject building is a Qualifying
Building per Sec. 2001 (l) of Article XX of the City Charter, as
declared by the applicant and confirmed by the City Planning Di-
vision, the Building and Safety Division and the Rent Control
Administration office.
Objections: No objections to this Tenant-Participating Conver-
sion were filed with the City within the 25 day objection period
following notification to all building tenants of the Tenant-
Participating Conversion Application, nor were any objections
received prior to the time of distribution of this report to
Planning Commissioners.
Additional Information: Additional information may be found in
the attached portions of the Tenant-Participating Conversion Ap-
plication and Tentative Map Application.
BUDGET/FINANCIAL IMPACT
The recommendation presented in this report does not have an
immediate budget or fiscal impact. As each unit is sold a
conversion tax per Section 2008 of Article XX is due in an amount
equal to twelve times the monthly maximum allowable rent for that
unit. These taxes will be used to assist low and moderate income
households to purchase or improve their units subject to
affordable repayment per Section 2009 of Article XX.
RECOMMENDATION
A Tenant-Participating Conversion, along with any required
tentative map, may only be denied if it fails to meet the
requirements of Article XX of the City Charter, is the result of
fraud, misrepresentation, or threat or similar coercion, or
fails to meet any mandatory requirement of the Subdivision Map
Act.
In that this application meets the requirements of Article XX and
all mandatory requirements of the State Subdivision Map Act, it
is respectfully recommended that Tenant-Participating Conversion
108 and vesting tentative tract map 49372 be approved with the
following findings and conditions:
Tenant-Participating Conversion Findings
1. This Tenant-Participating Conversion Application meets the
requirements of Article XX of the City Charter of the City
of Santa Monica along with all mandatory requirements of
the Subdivision Map Act of the State of California.
[reference Sec. 2004 (a), Article XX]
2. The Tenant-Participating Conversion Application has been
deemed complete and accepted for filing. At the time of
filing it met the requirements of Section 2002 of Article
XX of the City Charter for a complete application. The
subject application:
(a) Identifies the building, its owner and its tenants and
contains a declaration that such building is a Qualify-
ing Building, the specific details of which are incor-
porated into these findings by reference.
(b) Sets forth, for each tenant occupied unit, the follow-
ing sales information, which is incorporated into these
findings by reference:
1) The maximum sales price for each unit.
2) The minimum down payment for each unit.
3) If seller financing is offered, the
minimum amount to be financed, the maximum
rate of interest and the minimum term of the
loan offered by the seller.
(c) Sets forth, for each unit, the following common area,
maintenance and budget information, which is incorporated
into these findings by reference:
1) The plan for the assignment and use of all
parking spaces.
2) The plan for the use of all common area
facilities.
3) The occupancy and management plans and
policies.
4) A list of all repairs and alterations, if
any, which will be performed before the close
of the first escrow.
5) The plan for allocating costs and expenses
for the building.
6) A prepared monthly maintenance budget
based upon actual maintenance expenses for at
least the preceding two years plus a reserve
fund which states the monthly maintenance
assessment for each unit.
7) The procedures for the allocation and use
of such reserve funds.
(d) Contains a declaration with the following information:
1) That there has been a building inspection report
of the accessible portions of the entire build-
ing, including but not limited to, the roof,
walls, floors, heating, air conditioning, plumb-
ing, electrical systems or components of a simi-
lar or comparable nature, and recreational
facilities of the building prepared by a Building
Inspection Service or similar agency within the
preceding three (3) months.
2) That, for each tenant occupied unit, a written
statement setting forth any substantial defects
or malfunctions identified in the building in-
spection report regarding the unit and the common
areas has been delivered to the unit or a tenant
occupying the unit.
3) That, for each tenant occupied unit, a copy of
the complete building inspection report has been
delivered to the unit or a tenant occupying the
unit.
(e) Sets forth the form of tenant ownership for which the
application is submitted--Condominium.
(f) Is signed by cosigning tenants occupying 75% (not
less than two-thirds) of all the residential units
in the building. (If there is more than one tenant
in a unit, the signature of only one tenant is
required.)
(g) Identifies the cosigning tenants and the units occu-
pied by such tenants and lists all other tenants
known to the owner in the building and the units
they occupy.
(h) Contains a declaration that the signature of each
cosigning tenant was obtained only after the deliv-
ery, in writing, to such tenant of the information
required in subsections (a) (b) (c) (d) and (e) of
this Section.
(i) Contains a declaration that all lawful notices have
been given of the application for conversion.
(j) Has attached to the application Statements of Tenant
Intent to Purchase, signed by Intending to Purchase
Tenants occupying 50% (not less than fifty percent)
of the total number of residential units in the
building. (If there is more than one tenant in a
unit, the signature of only one tenant is required.)
(k) That, for each tenant occupied unit, a Tenant Intent
to Purchase has been delivered to the unit or a
tenant occupying the unit.
3. The following procedures have been followed in the pro-
cessing of this Tenant-Participating Conversion
Application:
(a) A Tenant-Participating Conversion Application was
accepted for filing by the City and meets the
requirements of Section 2002 of Article XX of the
City Charter.
(b) The Tenant-Participating Conversion Application was
filed by the owner on February 2, 1990, not less
than forty (40) days prior to the filing of the ap-
plication for the tentative subdivision/parcel map
on March 26, 1990.
(c) Within five (5) days of the filing of the Tenant-
Participating Conversion Application, the City sent
notice to every tenant in the building stating that
a Tenant-Participating Conversion Application had
been filed and that any objections thereto may be
filed with the City within twenty-five (25) days
from the date of the notice.
(d) Upon the filing of the application for the required
tentative subdivision/parcel map, the Tenant-
Participating Conversion Application and required
map were scheduled for hearing and processed in ac-
cordance with the procedures for the processing of
subdivision maps.
Tentative Map Findings
1. The proposed subdivision, together with its provisions for
its design and improvements, is consistent with the ap-
plicable general and specific plans as adopted by the City
of Santa Monica. [Reference California Government Code
Sec. 66473.5 and Santa Monica Municipal Code Sec. 9362
(a)]
2. The owner(s) and each tenant on the subject property
received copies of this staff report and recommendation at
least three days prior to this public hearing.
3. Notification of this hearing has been in conformance with
Section 9360 of the Santa Monica Municipal Code.
4. Each of the tenants of the proposed condominium project
has received, pursuant to Government Code Section 66452.9,
written notification of intention to convert at least 60
days prior to the filing of the tentative map pursuant to
Section 66452. Each such tenant, and each person applying
for the rental of a unit in such residential real proper-
ty, has, or will have, received all applicable notices and
rights now or hereafter required by the Subdivision Map
Act. Each tenant has received or will receive 10 days
written notification that an application for a public re-
port will be, or has been, submitted to the Department of
Real Estate, and that such report will be available on
request. The written notices to tenants shall be deemed
satisfied if such notices comply with the legal require-
ments for service by mail.
5. Each of the tenants of the proposed condominium project
has been, or will be, given written notification within 10
days of approval of a final map for the proposed
conversion.
6. Each of the tenants of the proposed condominium project
has been, or will be, given 180 days written notice of
intention to convert prior to any termination of tenancy
due to the conversion or proposed conversion. This will
not alter or abridge the rights or obligations of the
parties in performance of their covenants, including, but
not limited by Sections 1941, 1941.1, and 1941.2 of the
Civil Code, and set forth herein as conditions of
approval.
7. Each of the tenants of the proposed condominium project
has been, or will be, given notice of an exclusive right
to contract for the purchase of his or her respective unit
upon the same terms and conditions that such unit will be
initially offered to the general public or terms more
favorable to the tenant. The right will run for a period
of not less than 90 days from the date of issuance of the
subdivision public report pursuant to Section 11018.2 of
the Business and Professions Code, unless the tenant gives
prior written notice of his or her intention not to exer-
cise the right. This will not alter or abridge the rights
or obligations of the parties set forth herein as condi-
tions of approval.
8. This project has been found to be categorically exempt
from the California Environmental Quality Act of 1970 and
state and local guidelines adopted thereunder.
Note: Individual findings required for approval of non-Tenant-
Participating Conversions specified in Santa Monica Municipal
Code Sec. 9122F either are inconsistent with or redundant with
the requirements of Article XX and therefore are not applicable
to or necessary for approval of Tenant-Participating Conversions.
Conditions
1. The owner shall agree to each condition imposed in connec-
tion with the approval of a Tenant-Participating Conver-
sion Application. Written consent shall be filed prior to
the approval of the required final parcel/subdivision map
and shall be in a form approved by the City Attorney. The
filing of such written consent shall constitute an agree-
ment, with the City of Santa Monica and each Participating
Tenant, binding upon the owner and any successors in
interest, to comply with each and every condition imposed
in connection with approval of this Tenant-Participating
Conversion Application. The City and any Participating
Tenant shall have the right to specific enforcement of
this Agreement in addition to any other remedies provided
by law.
2. The owner shall offer and continue to offer the exclusive
right to purchase each rental unit in the building to the
Participating Tenant thereof upon the terms set forth in
the application, without change, for a period of not less
than two (2) years from the date of final approval by the
California Department of Real Estate or the date the first
unit in the building is offered for sale, if no approval
by the California Department of Real Estate is required.
At the beginning of the second year, the Tenant Sale Price
may be adjusted according to any change reflected in the
Price Index [as defined in Section 2001(j) of Article XX
of the City Charter] occurring during the proceeding year.
Upon the written acceptance of the offer by the Par-
ticipating Tenant at any time within the two year period,
escrow shall open within thirty (30) days from the written
acceptance by the Participating Tenant. Unless otherwise
agreed by the parties, the period of the escrow shall not
exceed sixty (60) days.
3. No Participating Tenant shall at any time after the ap-
proval of this Tenant-Participating Conversion Application
be evicted for the purpose of occupancy by the owner, oc-
cupancy by any relative of the owner, or for demolition of
the unit. In the event the Participating Tenant does not
exercise his or her right to purchase within the time
period set forth, the owner may transfer the unit without
any price restriction to the Participating Tenant or any
other person. However, in the event such transfer is to
someone other than the Participating Tenant, the transfer
shall be expressly made subject to the rights of the Par-
ticipating Tenant to continue to occupy the unit as pro-
vided for in Article XX of the City Charter. The provi-
sions of California Government Code Section 7060 et seq.
("The Ellis Act") shall not be used to evict any non-
purchasing Participating Tenant.
4. Each unit shall at all times remain subject to all terms
and conditions of Article XVIII of the City Charter, ex-
cept Section 1803 (t), before, during and after any
Tenant-Participating Conversion. If any unit is rented,
the maximum allowable rent for each unit shall be no
greater than the maximum allowable rent allowed under Ar-
ticle XVIII of the City Charter.
5. Prior to the approval of the required final parcel/
subdivision map for the Tenant-Participating Conversion,
each participating tenant shall be informed in writing, in
a form approved by the City, of his or her rights under
Article XX of the City Charter.
6. All non-purchasing Participating Tenants who are senior
citizens or disabled on the date of filing the Tenant-
Participating Conversion Application and who personally
occupied a rental unit in this qualifying building con-
tinuously for at least six (6) months immediately preced-
ing the date of the filing of this Tenant-Participating
Conversion Application shall have a right without time
limitations to occupy their units subject to the provi-
sions of Article XVIII of the City Charter and shall be
given the non-assignable right to continue to personally
reside in their unit as long as they choose to do so sub-
ject only to just cause evictions provided that the evic-
tion is not for the purpose of occupancy by the owner,
occupancy by any relative of the owner, or for demolition
of the unit. In addition, should the maximum allowable
rent provision of Article XVIII of the City Charter no
longer apply, the rent for each such unit may be adjusted
annually to allow an increase of no more than the increase
in the Price Index [as defined in Section 2001(j) of Arti-
cle XX of the City Charter] plus a reasonable pro rata
share of capital replacements for the buildings's common
areas or agreed to capital improvements for the unit.
Within sixty (60) days after the approval of this Tenant-
Participating Conversion Application, any senior citizen
Participating Tenant who is entitled to the protections of
this provision may designate in writing the name of one
person who is entitled to continue living in the rental
unit under the same terms as the senior citizen if the
senior citizen predeceases him or her and if the person
designated is residing in the unit at the time of the
death of the senior citizen. The person designated by the
senior citizen must be a lawful occupant of the unit, at
least fifty-five (55) years of age on the date of the
filing of this Tenant-Participating Conversion
Application.
All other non-purchasing Participating Tenants who per-
sonally occupied a rental unit in this qualifying building
continuously for at least six (6) months immediately pre-
ceding the date of filing of this Tenant-Participating
Conversion Application shall have a right without time
limitations to occupy their units subject to the provi-
sions of Article XVIII of the City Charter and shall be
given the nonassignable right to continue to personally
reside in their unit subject only to just cause eviction
for a period of five (5) years from the date the first
unit is offered for sale. No eviction shall be allowed
during this time period except for just cause provided the
eviction is not for the purpose of occupancy by the owner,
occupancy by any relative of the owner, or demolition of
the unit. In addition, during this time period, should
the maximum allowable rent provisions of Article XVIII of
the City Charter no longer apply, the rent for each unit
may be adjusted annually to allow an increase of no more
than the increase in the Price Index [as defined in Sec-
tion 2001(j) of Article XX of the City Charter] plus a
reasonable pro rata share of capital improvements for the
building's common areas or agreed to capital improvements
for the unit.
All rights under this condition shall expire upon the ter-
mination of the landlord-tenant relationship between the
owner and the participating tenant entitled to the
protections of this condition.
For purposes of this condition, "just cause" means one of
the reasons set forth in subdivisions (a) through (g) of
Section 1806 of the City Charter.
7. The requirements of these conditions shall be set forth in
the Declaration of Covenants, Conditions, and Restric-
tions, or equivalent document, and shall specifically name
the Participating Tenants in each unit entitled to the
benefits and protections of Article XX of the City
Charter. The City Attorney shall review and approve for
compliance with Article XX the Covenants, Conditions, and
Restrictions, or equivalent documents, prior to the ap-
proval of the required final parcel/subdivision map. To
the extent applicable, the requirements of Article XX
shall be made a part of the rental agreement with the Par-
ticipating Tenants.
8. The owner shall pay the Tenant-Participating Conversion
Tax in the manner required by Section 2008 of Article XX
of the City Charter.
The Tenant-Participating Conversion Tax shall be paid by
the owner to the City Treasurer on each Tenant-
Participating Conversion unit in an amount equal to twelve
(12) times the monthly maximum allowable rent for the unit
at the time the tax is due and payable. If there is no
monthly maximum allowable rent, the tax shall be computed
on the basis of the monthly fair rental value of the unit.
The Tenant-Participating Conversion Tax shall be due and
payable at the time of approval of the required final
parcel/subdivision map. Payment of the tax may be de-
ferred until sale of the unit by the owner executing a
lien in the form approved by the City. Upon payment of
the tax, or upon a determination that a unit is exempt
from the tax in accordance with subdivision (d) of Section
2008 a release of lien shall be filed by the City with
respect to each unit for which the tax has been paid or
which has been determined to be exempt from the tax.
9. The Declaration of Covenants, Conditions, and Restric-
tions, or equivalent document, shall contain a non-
discrimination clause in substantially the following form:
"No unit owner shall execute or file for record any in-
strument which imposes a restriction upon the sale, leas-
ing or occupancy of his or her unit on the basis of sex,
race, color, religion, sexual orientation, ancestry, na-
tional origin, age, pregnancy, marital status, family
composition, or the potential or actual occupancy of minor
children. The association shall not discriminate on the
basis of sex, race, color, religion, sexual orientation,
ancestry, national origin, age, pregnancy, marital status,
family composition, or the potential or actual occupancy
of minor children."
10. Approval of the Tenant-Participating Conversion Applica-
tion shall expire if the required final parcel/subdivision
map is not approved within the time period set forth in
Condition 11.
11. The tentative parcel/subdivision map shall expire 24
months after approval, except as provided in the provi-
sions of California Government Code Section 66452.6 and
Sections 9380-9382 of the Santa Monica Municipal Code.
During this time period, the final map shall be presented
to the City of Santa Monica for approval. If the tenta-
tive map is a vesting tentative map pursuant to California
Government Code Section 66474.2, the provisions of Santa
Monica Municipal Code Section 9325 also shall apply.
12. The applicant shall comply with all requirements set forth
in Government code Section 66427.1, including notification
of tenants regarding application for a public report to
the Department of Real Estate and notification of tenants
regarding approval of a final map for the conversion.
13. The developer/applicant shall provide the Engineering De-
partment of the City of Santa Monica with one Dizal Cloth
print reproduction and microfilm of each sheet of the
final map after recordation.
14. The effective date of this action shall be ten (10) calen-
dar days from the date of Planning Commission determina-
tion or, if appealed per Section 9366 (SMMC), at such time
as a final determination is made by the City Council.
15. For information purposes, the following persons are iden-
tified in the application as participating tenants:
Elizabeth paganelli, Diane Perlov, William Bracken and
Michelle Fine, Carmen Vasquez, Carol Nolan and Paul
Rosenstein, and Marcie Adelsohn.
ATTACHMENTS: A. Summary Cover Sheet
B. Unit/Tenant Info.
C. Seller Financing Info.
D. Parking Plan
E. Summary CC+R's
F. Tenant Notice
G. Correspondence (if any)
H. Radius Map
I. Tract/Parcel Map
Prepared by: Larry Miner, Associate Planner
D. Kenyon Webster, Principal Planner
Paul Berlant, Director of Planning
Community and Economic Development Department
NOTE: The attachments are not available on PEN, but may be
obtained from the City Clerk's office.