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HomeMy WebLinkAboutO-90-01ORDINANCE NO.: O-90-01 AN ORDINANCE OF THE CITY OF SEBASTIAN, INDIAN RIVER COUNTY, FLORIDA, AMENDING SECTION 2-93 PERTAINING TO THE JURISDICTION OF THE SEBASTIAN CODE ENFORCEMENT BOARD; AMENDING ARTICLE VII OF THE CODE OF ORDINANCES OF THE CITY OF SEBASTIAN PERTAINING TO CONTRACTORS; AMENDING SECTION 7-91 TO PROVIDE FOR ADDITIONAL DEFINITIONS; AMENDING SECTION 7-92 TO PROVIDE PROCEDURES FOR REMOVAL OF MEMBERS OF THE CONSTRUCTION BOARD; AMENDING SECTION 7-92.1 TO PROVIDE FOR INVESTIGATORS TO ASSIST IN THE ENFORCEMENT OF ARTICLE Vii; AMENDING SECTION 7-92.2 PERTAINING TO THE POWER OF THE SEBASTIAN CONSTRUCTION BOARD TO REVIEW VIOLATIONS OF ARTICT~ VII; AMENDING SECTION 7-98 PERTAINING TO PUBLIC ACCESS TO RECORDS; AMENDING SECTION 7-99 PERTAINING TO CERTAIN PROHIBITED ACTIVITIES; AMENDING SECTION 7-100 PERTAINING TO REVOCATION OR SUSPENSION OF CERTIFICATES OF COMPETENCY; AMENDING SECTION 7-101 PERTAINING TO THE APPLICATION OF ARTICr~ VII TO OTHER MUNICIPAL POWERS AND ACTIONS; AMENDING SECTION 7-102 PERTAINING TO EXEMPTIONS FROM ARTICLE VII; AMENDING SECTION 7-103 PERTAINING TO REFERENCES TO THE BUILDING OFFICIAL; PROVIDING FOR EXEMPTIONS; PROVIDING FOR THE REQUIRING OF PAYMENT AND PERFORMANCE BONDS UNDER CERTAIN CIRCUMSTANCES; PROVIDING FOR PENALTIES; PROVIDING FOR APPEALS; PROVIDING THAT THE ORDINANCE IS SUPPI.k~4ENTAL; PROVIDING FOR INCLUSION IN THE CODE OF ORDINANCES OF THE CITY OF SEBASTIAN; PROVIDING A SEVERABILITY CLAUSE; AND PROVIDING AN EFFECTIVE DATE. WHEREAS, the construction industry is a matter substantially affecting the public interest; and, WHEREAS, to protect the health, safety and general welfare of the public, it is necessary to ensure; that individuals and entities engaged in the construction industry are duly qualified and that construction is performed in accordance with the Code of ordinances of the City of Sebastian; and, WHEREAS, existing laws, ordinances and enforcement procedures have not ensured substantial compliance; and, WHEREAS, certain measures can be taken to better regulate the construction industry and enforce the laws and ordinances enacted to protect the public health, safety and general welfare. NOW, THEREFORE, BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF SEBASTIAN, INDIAN RIVER COUNTY, FLORIDA, that: Section 1. Section 2-93 of the Code of Ordinances of the City of Sebastian is hereby amended by amending existing Section 2- 93(a)(16) and by adding Section 2-93(a)(17) to read as follows: "(16) Land Development Code; and, (17) Contractors (Article VII, Chapter 7, Code of Ordinances), or any other provision of the Code of Ordinances as allowable pursuant to Chapter 162 of Florida Statutes, as amended pursuant to Chapter 89-268 of the Laws of Florida, and as such may be amended, and any rules or regulations adopted thereunder." Section 2. Section 7-91 of the Code of Ordinances of the City of Sebastian is hereby amended by adding the following additional definitions to be added in alphabetical order and to revise the definition of "specialty contractors" as set forth in Paragraph 7-91(7) to read as follows: "Application for Permit means any permit application made under the Standard Building Code, Standard Plumbing Code, Standard Mechanical Code, Standard Gas Code, National Electrical Code, Standard Fire Code, or any other building code or technical code contained in or adopted by reference in the Code of Ordinances of the City of Sebastian and the Sebastian Land Development Code, as such have been, or may be, amended, including all documents submitted with any permit application. Department means the Florida Department of Professional Regulation or, where applicable, the Florida Construction Industry Licensing Board. Investigator means an individual authorized by the City Council to enforce the provisions of this Article who has the authority to issue citations and who shall include the Director of Community Development, the building official and code enforcement officers, as well as those individuals authorized by Resolution adopted by the City Council from time to time. Person means an individual, any business or nonbusiness entity, corporation, partnership, joint venture, unincorporated association, trust, estate, club or society. State-Certified means any contractor who possesses a Certificate of Competency issued by the Department and who is allowed to contract in any jurisdiction in the State of Florida without being required to fulfill the competency requirements of the City under this Article. State-Certification means the act of obtaining or holding a Certificate of Competency from the Department as provided in Chapter 489, Florida Statutes (1989) as amended from time to time or any rule or regulation promulgated thereto. Specialty Contractors are those who can qualify with a minimum of two (2) years experience, one-half (1/2) of which must be in a supervisory capacity, who specialize in one or more crafts of the building construction and related contracting trades whose scope is less than those contractors defined above and as limited under the certificate of competency issued by the board to such specialty contractor. The board may further classify and define specialty contractors in such rules and regulations it promulgates in accordance with this Chapter. All specialty contractors must receive a passing grade of at least seventy-five (75) on the examination for their trade which is administered by Block & Associates. Provided, however, that the following types of specialty contractors shall be exempt from the testing requirements of this section:land clearing and grading, insulation, floor covering, garage door installation, cabinet installation, landscaping, aluminum non-structural, water pump, pressure cleaning and mildew control, roofing limited, sign painting, vacuum systems, and fences." Section 3. Section 7-92 of the Code of ordinances of the City of Sebastian is hereby amended by adding Section 7-92(g) to read as follows: "(g) Removal_of Board Member. The City Council shall have the power to remove any member of the board for any reason provided by the laws of the State of Florida. In addition, the 4 city Council shall have the power to remove any member of the board if that member fails to attend three (3) consecutive meetings without having been excused by the Chairperson, or upon the written recommendation to remove a member which is submitted by the board to the City Council which a majority of the board votes in favor of submitting to the City Council which sets forth specific reasons indicating that the member is not fulfilling his or her duties as a member of the board. Such written recommendation shall indicate the votes of the board members with respect to the written recommendation." Section 4. Section 7-92.1 of the Code of Ordinances of the City of Sebastian is hereby amended by amending existing Section 7- 92.1(b) to read as follows: "(b) Clerk. The building official shall appoint a City employee to be the board clerk. The clerk shall record all meetings of the board and shall prepare minutes of each meeting, which state all motions, the vote of each member upon each question or motion, and a statement as to any member who is absent or failed to vote. summary or outline form, deliberations of the board. The minutes of the board may be in a but shall accurately reflect the The clerk shall perform such other functions assigned to the clerk by the board." Section 5. Section 7-92.1 of the Code of Ordinances of the City of Sebastian is hereby amended by adding Section 7-92.1(d) to read 5 as follows: "(d) Investiqators. Investigators under the direction of the Director of Community Development or his designee are hereby charged with the enforcement responsibilities of this Article. An investigator is authorized to issue citations in accordance with Section 7-104 for any violation under this Article when, based upon personal investigation, the investigator has reasonable probable grounds to believe that a violation under any provision of this Article has occurred. Investigators shall not have the power of physical arrest nor shall they be authorized pursuant to this Article to bear arms. Nothing herein contained shall be construed to authorize or permit any investigator to perform any function or duty of a law enforcement officer other than as specified herein. An investigator may also issue any person a Notice of Hearing in lieu of a citation whereby the alleged violator would then appear before the board in accordance with Section 7-92.2(e)." Section 6. Section 7-92.2 of the Code of Ordinances of the City of Sebastian is hereby amended by amending existing Section 7- 92.2(e) to read as follows: "(e) Review of Violations of this Article. On the Motion of the board, on a Notice of Hearing issued by an investigator or on the verified written complaint of any person, the board may review the actions of any person, including a contractor that has been issued a Certificate of Competency by the board pursuant to 6 this Article or a state-certified contractor, who has violated any provision of this Article. The board may hold due process hearings and thereafter take appropriate disciplinary action as authorized pursuant to this Article if the person, including a state-certified contractor or a contractor holding a Certificate of competency from the board pursuant to this Article and including an entity qualified by a contractor who is state- certified or holds a Certificate of Competency from the board pursuant to this Article, is found to be in violation of one or more of the acts or omissions constituting a prohibited activity pursuant to Section 7-99 or constituting cause for disciplinary action pursuant to Section 7-100 to the extent not reserved to the Department to the exclusion of the board." Section 7. Section 7-98(a) of the Code of Ordinances of the City of Sebastian is hereby amended in its entirety to read as follows: "(a) Ail information provided to the board by any applicant for certification shall be a public record except to the extent exempted from the provisions of requiring public access to public records under the laws of the State of Florida. Any applicants for a certificate of competency shall be informed that their application, examination, examination scores and other financial records which are received by the city shall become a public record." Section 8. Section 7-99 of the Code of Ordinances of the City of Sebastian is hereby amended in its entirety to read as follows: "Sec. 7-99. Prohibited activities. (a) It is unlawful for any person to engage in the business or act in the capacity of a contractor without being a state- certified contractor holding a state-certification or being in lawful possession of a Certificate of competency issued by the board pursuant to this Article. (b) It is unlawful for any person who possesses a current Certificate of Competency issued by the board pursuant to this Article or a state-certification issued by the Department to contract with or utilize the services of another person engaging in the business or acting in the capacity of a contractor where such other person does not hold a state-certification or a Certificate of Competency for engaging in the type of contracting business that such other person operates in the corporate limits of the City. This prohibition shall be enforceable even if the unlicensed contractor does not have an office in the City, so long as the unlicensed contractor performs or contracts to perform the services of a contractor in the corporate limits of the City for the person holding a state-certification or a Certificate of Authority issued by the board pursuant to this Article. (c) It is unlawful for a person required to possess, but not possessing, a current Certificate of Competency issued by the board pursuant to this Article or a state-certification issued by the Department to advertise to the public in a newspaper, magazine, handbill, flyer, airwave transmission or telephone directory, or by issuance of a card or other communication or other advertising medium, that he is a contractor or is qualified to act in business as a contractor, pursuant to a Certificate of Competency issued by the board pursuant to this Article or a state-certification issued by the Department. (d) It is unlawful for a contractor who possesses a Certificate of Competency issued by the board pursuant to this Article or a state-certification issued by the Department to fail to include his Certificate of Competency Number or state- certification or registration number in any publication which is primarily circulated, displayed, distributed or marketed within the City which advertisement identifies a contractor or entity offering services regulated by Chapter 489 of Florida Statutes, as amended from time to time, or by this Article, unless the advertisement included the Certificate of Competency Number or state-certification or registration number issued to that contractor. Nothing in this Section shall be construed as requiring that the publisher not publish any advertisement which does not include a Certificate of Competency Number or a state- certification or registration number, nor determine or investigate whether a Certificate of Competency Number or a state-certification or registration number is required, whether the license number given is accurate, nor determine or investigate whether the person whom the advertisement is published is state-certified or holds a Certificate of Competency issued by the board pursuant to this Article." Section 9. Section 7-100 of the Code of Ordinances of the city of Sebastian is hereby amended in its entirety to read as follows: "Sec. 7-100. Causes for Disciplinary Action. The following acts constitute cause for disciplinary action: (1) Willful or deliberate disregard or violation of the applicable building codes of the city; (2) Aiding or abetting a person who is not a state- certified contractor or a contractor who possesses a Certificate of Competency issued by the board pursuant to this Article VII to evade any provision of this Article. Utilizing or contracting with an unlicensed contractor or subcontractor is prima facia evidence of engaging in such an act; (3) Knowingly combining or conspiring with an uncertified person with intent to evade the provisions of this Article. When a person holding a Certificate of Competency issued by the board pursuant to this Article or a state-certification allows his certificate or state-certification to be used by one or more companies without having any active participation in the operations, management or control of such companies, this act shall constitute prima facie evidence of an intent to evade the provisions of this Article; (4) Acting in the capacity of a contractor under any Certificate of Competency issued by the board pursuant to this Article or any state-certification issued by the Department, 10 except in the name of the certificate holder as set forth on the issued Certificate of Competency or the state-certification or in accordance with the personnel of the certificate holder as set forth in the application for the certificate or state- certification, or as later changed as provided in this Article or pursuant to Chapter 489 of Florida Statutes, as amended from time to time or any rule or regulation promulgated pursuant thereto; (5) Diversion of funds or property received for the completion of a specified construction project or operation or as a result of the diversion the contractor is or will be unable to fill the terms of his obligation or contract; (6) Failure in any material respect to comply with the provisions of this Article; (7) Failure to maintain insurance coverage as set by the board; (8) Failure to provide proof of workmen's compensation insurance to the building official or his designees upon demand for same; (9) Falsification of application or testimony given before the board; (10) Abandonment of a construction project in which the contractor is engaged or under contract as a contractor. A project is to be considered abandoned if the contractor terminates said project without notification to the prospective owner or current owner for at least thirty (30) days without just cause, such as acts of God causing construction delay; 11 (il) Cheating on the examination required by this Article; (12) Giving or offering to give directly or indirectly any City employee, council member, the Mayor or board member anything of value, monetary or otherwise, with intent to influence such employee or board member in the discharge of his or her duties under the provisions of this Article; (13) Attempting or threatening to coerce or coercing through physical act, injury or damage to the Mayor, or to any council member, board member, City employee or any family member or property of any board member or City employee, with intent to influence such board member or employee in the discharge of his or her duties under the provisions of this Article; or, (14) The filing of a Petition in Bankruptcy, either voluntarily or involuntarily, the making of an assignment for the benefit of creditors or the appointment of a receiver for a contractor or an entity which is qualified to engage in the business of a contractor by the holder of a Certificate of Competency issued by the board or a state-certification issued by the Department. Provided, however, that such act shall only empower the board to take such action as allowable under the laws of the State of Florida or the United State of America, or to the extent otherwise allowable pursuant to this Article VII." Section 10. Section 7-102 of the Code of Ordinances of the City of Sebastian is hereby amended in its entirety to read as follows: "Sec. 7-102. Exemptions. The exemptions provided by Section 12 489.103 of Florida Statutes (1989), as amended or supplemented from time to time, shall also constitute exemptions from the provisions of this Article VII." Section 11. Section 7-103 is hereby amended to read as follows: "(a) The provisions of this Article VII shall be deemed supplemental to, and not in conflict with or in preemption of, the provisions of Article V of Chapter 2 of the Code of Ordinances conCerning the Sebastian Code Enforcement Board. To the extent provided in Article V of Chapter 2 of the Code of Ordinances, the Sebastian Code Enforcement Board shall have concurrent jurisdiction over the enforcement of any of the provisions of this Article VII." Section 12. Section 7-104 of the Code of Ordinances of the City of Sebastian is hereby reserved for future use. Section 13. Section 7-105 of the Code of Ordinances of the City of Sebastian is hereby created to read as follows: "Sec. 7-105. Payment and Performance Bonds. (a) The board is authorized to require a contractor who holds a Certificate of Competency issued by the board pursuant to this Article, including a corporation or other entity which the certificate holder has qualified, obtain a payment and performance bond as a prerequisite to being able to obtain a building permit or other development order from the City if, 13 after an evidentiary hearing thereon which provides due process to the adversely affected parties, the board finds that the contractor or the entity which such contractor has qualified presents a substantial risk of not being able or willing to fully complete a job or project for which a building permit or other development order is requested or needed to authorize the job or project. Evidence on which such a finding of the need for such a bond or bonds may be based shall consist of any one or more of the following findings of fact: (1) A Claim of Lien in excess of $2,000.00 has been filed in connection with the real property the contractor or entity which the contractor has qualified is working on, whereby the Claim of Lien avers that the contractor or entity has not made proper payment to the lienor, and the Claim of Lien has not been released or satisfied within sixty (60) days of the filing of same with the Clerk of the Circuit Court; (2) The contractor or entity which the contractor has qualified has a judgment for money damages entered by a court of competent jurisdiction against such contractor or entity and the judgment is reasonably related to the type of work for which the requested building permit or other development order relates, and the judgment has not been released or otherwise satisfied; (3) The contractor or entity which the contractor has qualified has failed to substantially complete performance of any other contract for work of the type that is the subject of the requested building permit or other development order and the 14 failure to substantially complete performance of the contract is reasonably within the control of the contractor or the entity which the contractor has qualified; (4) Any officer, director, shareholder, partner, joint venturer, trustee or employee of a business entity that is seeking the building permit or other development order was an officer, director, shareholder, partner, joint venturer, trustee or employee of another business entity at a time when the other entity violated any of the provisions of Subsections (1), (2) or (3) of this Section 7-105; (5) For any other violation provided for in this Section 7-105 if the violation could reasonably render the contractor or the entity which the contractor has qualified a substantial risk of not being able to willing to fully complete the job or project for which the building permit or other development order is required. (b) The amount of the payment and performance bond shall be set by the board and may be in an amount equal to the contract price, if any, or the full estimated cost to complete the job or project for which the building permit or Other development order pertains. (c) The requirement to obtain a payment and performance bond or bonds may also be one of the conditions prescribed in Paragraph 7-105(a)(4), if such bond or bonds are reasonably related to the type of violation found by the board to have occurred. The board shall determine who shall be the beneficiary 15 of any such bond or bonds. The authority to require a bond or bonds shall not be imposed, however, if the contractor or the entity which the contractor has qualified is certified in the specific trade by the Department or other state agency, and if such state-certification prohibits the imposition of a payment and performance bond as a matter of law under applicable state statutes. The burden of establishing that a state law preempts the imposition of a bond or bonds shall be upon the contractor or the entity which the contractor has qualified." Section 14. Section 7-106 of the Code of Ordinances of the City of Sebastian is hereby created to read as follows: "Sec. 7-106. Penalties; appeals. (a) In addition to the penalties that may be imposed, and other remedies that may be available to the City, which are provided for elsewhere in this Section 7-106, any person who violates any provisions of Section 7-99 or commits any of the acts constituting cause for disciplinary action as set forth in Section 7-100 shall be guilty of a violation of the provisions of this Article VII, and upon conviction thereof, shall be subject to the penalties of Section 1-10. (b) in addition to the penalties and other remedies that may be imposed elsewhere in this Section 7-106, the board may issue a cease and desist order to prohibit any person from engaging in the business of contracting who does not hold the required state-certification or local Certificate of Competency 16 for any work being performed by that person or his/her/its employees or agents under this Article VII. (c) If a state-certified contractor or a contractor possessing a Certificate of Competency issued by the board pursuant to this Article VII is found by the board, after a due process hearing, to be guilty of fraud or a willful building code violation in the city, or if the board possesses proof that such contractor, through a due hearing process, has been found guilty in another city or county within the twelve-month period of fraud or a willful building code violation, and the board finds, after providing notice to the contractor, that such fraud or violation would have been fraud or a violation of a building code of the City if committed in the City, then the board may, in addition to the penalties that may be imposed, and other remedies that may be available to the City, which are provided for elsewhere in this Section 7-106, deny the issuance of a building permit to such contractor or issue a building permit with specific conditions which the board determines to be necessary to protect the public health, safety and general welfare. The board shall provide notification of, and information concerning, any denial of a building permit pursuant to this provision to the Department within fifteen (15) days after the board decides to deny such building permit. (d) In addition to the penalties that may be imposed, and other remedies that may be available to the City, which are provided for elsewhere in this Section 7-106, the board may 17 impose an administrative fine in an amount not to exceed ($500.00), which shall be recoverable by the board only in an action at law. (e) In addition to the penalties that may be imposed, and other remedies that may be available to the City, which are provided for elsewhere in this Section 7-106, the board is authorized to take the following disciplinary actions against the holder of a Certificate of Competency issued by the board pursuant to this Article VII, where such holder has been found to violate Section 7-99 or has engaged in any of the acts or omissions which constitute cause for disciplinary action pursuant to Section 7-100: (1) Suspend the Certificate of Competency issued by the board pursuant to this Article during the period fixed by the board, but the board may permit the certificate holder to complete any contracts then uncompleted; (2) Revoke the Certificate of Competency previously issued by the board pursuant to this Article; or (3) Place the certificate holder on probation for a period fixed by the board, but not in excess of three (3) years. (f) In addition to the penalties that may be imposed and other remedies that may be available to the city, which are provided for elsewhere in this Section 7-106, the board shall be empowered to refuse to issue building permits or to issue building permits containing specific conditions to protect the public health, safety and general welfare to a contractor who is 18 state-certified or who holds a Certificate of Competency issued by the board pursuant to this Article VII who has commi~e'd' multiple violations of this Article VII when such contractor has been disciplined for each of them by the board and when each disciplinary action has involved revocation or suspension of the state-certification by the Department or has involved revocation or suspension of the Certificate of Competency issued by the board pursuant to this Article VII, the imposition of an administrative fine of at least $1,000.00 or probation. Furthermore, the board shall be empowered to issue permits with specific conditions designed to protect the public health, safety and general welfare to a state-certified contractor or a contractor who holds a Certificate of Competency issued by the board pursuant to this Article VII who, within the previous twelve months, has had final action taken against him by the Department, or by the board when the board has reported such disciplinary action against the contractor to the Department where the contractor has engaged in the business or acted in the capacity of a contractor without a license. (g) In addition to the penalties that may be imposed, and other remedies that may be available to the city, which are provided for elsewhere in this Section 7-106, the board shall be empowered to restrain any violation of this Article VII by filing the appropriate action in a court of competent jurisdiction for injunctive relief. (h) Any aggrieved party, including the board, may appeal a 19 final administrative Order of the board to the Circuit Court for Indian River County, Florida. Such an appeal shall not be an appeal de novo but shall be limited to appellate review of the record created before the board. An appeal shall be filed within thirty (30) days of the execution of the Order to be appealed." Section 15. Section 7-107 of the Code of Ordinances of the City of Sebastian is hereby created to read as follows: "Sec. 7-107. Savings Clause. It is the intent of the City that the provisions of Article VII of Chapter 7 of the Code of Ordinances be construed as being consistent with the inherent municipal powers of the City and supplemental to, and consistent with, the provisions of Chapter 489 of Florida Statutes (1989), as amended from time to time. However, it is the intent of the City to reserve the power to regulate state-certified contractors to the extent not inconsistent with the laws of the State of Florida, as amended from time to time." Section 16. ORDINANCE SUPPLEMENTAL. The provisions of this Ordinance are supplemental, in addition to, and not in derogation of, all existing ordinances effective in the City of Sebastian, Indian River County, Florida. Section 17. CODIFICATION. It is the intention of the City Council of the City of Sebastian, Indian River County, Florida, and it is hereby provided that the provisions of this Ordinance shall become and be made a part of the Code of Ordinances of the City of Sebastian, Florida; that the sections of this Ordinance 20 m~ be renumbered or relettered to accomplish such intention; ~ad. the word "Ordinance" may be changed to "Section", "Article" or other appropriate designations. Section 18. SEVERABILITY. In the event a court of competent jurisdiction shall hold or determine that any part of this Ordinance is invalid or unconstitutional, the remainder'of the Ordinance shall not be affected and it shall be presumed that the City Council of the city of Sebastian did not intend to enact such invalid or unconstitutional provision. It shall further be assumed that the City Council would have enacted the remainder of this Ordinance without said invalid and unconstitutional provision, thereby causing said remainder to remain in full force and effect. Section 19. EFFECTIVE DATE. This Ordinance shall become effective immediately upon its adoption. The foregoing Ordinance was moved for adoption by Councilman _~O ~'r /'~0 Co~-~U~ The motion was seconded by Councilman L~oW~ .... ~o~/~UAnd, upon being put to a vote, the vote was as follows: Mayor W. E. Conyers Vice Mayor Frank Oberbeck Councilman Robert L. McCollum Councilman Lloyd Rondeau Councilman Lonnie Powell The Mayor thereupon declared this Ordinance duly passed and adopted this ~h~day of ...... /~-~C /~ , 1990. 21 CITY OF SEBASTIAN, FLORIDA W. E. Co ayor ATTE~S? Ka~hryn/~. O'Halloran, CMC/AAE City Cl~rk I HEREBY CERTIFY that notice of public hearing on this Ordinance was published in the Vero Beach Press Journal as .required by State Statute, that one public hearing was held on -this Ordinance at 7:00 p.m. on the ~ day of~. ~ct~ , 1990, .a-nd that following said public hearing this ordinance was passed by the City Council. ~a~nryn~. 6" Ha~il°~n, CMC/AAE City Clerk Approve~as~ to Form and content: Chaf°z~s lan Nash, City Attorney 22