20594\``j111111111111!//////
OF • C /Rc, 2012035662 Received: 6/13/2012 11:54:21 AM
'�P•' �; �>` Recorded: 06/13/2012 12:00:49 PM Filed &
`'9.', _ �` . n = Recorded in Official Records of Larry Crane.
PULASKI COUNTY CIRCUIT/COUNTY CLERK
Fees $70.00
1 �u,•'•�,`- ORDINANCE NO. 20,594
3 AN ORDI ANCE TO ESTABLISH A SCHEDULE OF SEWER RATES
4 AND CHARGES FOR LITTLE ROCK WASTEWATER, REPEALING
5 ORDINANCE NO. 19,647 DATED NOVEMBER 28, 2006, SECTION 14 OF
6 ORDINANCE NO. 19,895 DATED DECEMBER 21, 2007, AND
7 ORDINANCE NO. 20,311 DATED SEPTEMBER 7, 2010; TO DECLARE
8 AN EMERGENCY, AND FOR OTHER PURPOSES.
9
10 WHEREAS, the authority to operate and maintain Little Rock Wastewater ( "LRW ") is vested in the
11 Little Rock Sanitary Sewer Committee (the "Sewer Committee "), but the authority to establish sewer
12 rates and charges is vested in the Board of Directors of the City of Little Rock, and the Sewer Committee
13 has determined and recommended to the City Board of Directors that the rates and charges herein set
14 forth should be duly adopted by ordinance pursuant to law because the current sewer rates and charges
15 need to be adjusted; and,
16 WHEREAS, the City Board of Directors finds that the rates and charges proposed by the Sewer
17 Committee and established herein are adequate to pay the principal of and the interest on sewer revenue
18 bonds, to make payments into the sewer revenue bonds sinking fund, to provide an adequate depreciation
19 fund, and to provide LRW's estimated cost of operating and maintaining the sewer system, including the
20 cost of improvements and replacements; and,
21 WHEREAS, as a result of the comprehensive rate analysis conducted by Raftelis Financial
22 Consultants, Inc., and the updated System Evaluation Capacity Assurance Plan ( "SECAP ") prepared by
23 RJN Group, Inc., the need for an adjustment of rates and charges was determined, and the Sewer
24 Committee has requested the adoption of rates and charges reflected herein and has stated that the
25 adjustments are necessary to cover the cost of the foregoing items herein, all as more particularly set forth
26 as stated:
27 NOW, THEREFORE, BE IT ORDAINED BY THE BOARD OF DIRECTORS OF THE
28 CITY OF LITTLE ROCK:
29 Section 1. That the following monthly rates are hereby established as the rates to be charged for
30 services furnished by LRW, which rates the City Board of Directors hereby finds and declares to be the
31 reasonable and necessary minimum rates to be charged:
32 (a) The Sewer Committee shall compute separately for each customer (customer being
33 hereby defined as any landowner, lessee, or tenant whose buildings or premises are connected with the
[Page 1 of 121
1 sewer system or otherwise discharge sanitary sewage, water, or other approved wastewater sources, either
2 directly or indirectly into the sewerage system) a monthly bill for each class of customer. All customers
3 of the sewerage system are hereby classified as one of the following:
4 (1) Domestic Customers: Residential users of any structure which is used exclusively as
5 a dwelling. Users of a portion of a structure, which portion is separately metered for water by Central
6 Arkansas Water, or another LRW approved water source, and is used exclusively as a dwelling are also
7 classified as domestic customers. All domestic customers shall utilize a meter size of I inch or less.
8 Domestic customers shall not include the users of hotels, motels, boardinghouses, apartments, nursing
9 homes, hospitals, residence halls, learning institutions, office complexes, wholesale /retail businesses, etc.
10 (2) Non- Domestic Customers: All other users of the sewerage system other than
11 domestic customers classified above.
12 (3) Inside- Outside City Customers: Customers classified above (domestic or non -
13 domestic) are further classified as either inside or outside the city limits of Little Rock, Arkansas, for the
14 purpose of setting rates for service provided by LRW.
15 (b) Usage Determination: The amount of sewage discharged to the sewerage system
16 serviced by LRW shall be determined by the quantity of water metered; or other LRW approved
17 sewer /diversion metered system(s) (also herein expressed as usage, flow, volume, or consumption). The
18 sewage usage shall be determined based upon any single or combination of the following which may be
19 applicable to the customer's connection to the sanitary sewerage system; and said usage shall be utilized
20 to compute the portion of the monthly bill known as the volumetric charge:
21 (1) Domestic Customers:
22 A. In the case of domestic customers obtaining water exclusively from
23 Central Arkansas Water, the flow computation shall be based upon the water consumption records of
24 Central Arkansas Water.
25 B. In the case of a domestic customer obtaining water from sources other
26 than Central Arkansas Water, LRW shall determine the amount of water usage obtained by such
27 customers from other sources, and the amount so determined shall be used (together with the amount
28 reflected by Central Arkansas Water's records for such customer, if any) in making the volumetric
29 computation.
30 C. The sewer charge each month will be based on the monthly consumption
31 billed in the months of October, November, December, January, February, and March (Winter Months
32 Period). The Rate shall be calculated based upon the average of three (3) or more winter months having
33 consumption greater than zero. Amounts shall be rounded to the nearest whole number. (In the case of
34 domestic customers who were not on a meter during the previous Winter Month Period, the rates shall be
[Page 2 of 121
1 computed on the actual water usage until such time as an average monthly winter usage can be
2 calculated.) In the case of other domestic customers not on a metered basis, LRW shall establish water
3 consumption based on a comparison of the non - metered users with metered domestic customers.
4 (2) Non - Domestic Customers:
5 A. In the case of non- domestic customers obtaining water exclusively from
6 Central Arkansas Water, the flow computation shall be based upon the water consumption records of
7 Central Arkansas Water.
8 B. Each non - domestic customer from whose property or premises sewage in
9 any quantity is discharged into the sewage system serviced by LRW, but whose water usage is not
10 metered, is hereby required to install a meter, at its source, at the customer's own expense, to measure the
11 quantity of water used, with an appropriate meter to be approved by LRW, and to pay a monthly bill for
12 service based upon the amount of water thus metered.
13 C. In the case of a non - domestic customer obtaining water from sources
14 other than Central Arkansas Water, LRW shall include the volume of water obtained by such customer
15 from other sources, and the amount so determined shall be used (together with the amount reflected by
16 Central Arkansas Water's records for such customer, if any) in making the volumetric charge
17 computation.
18 D. In the case of a single non - domestic customer, whose water usage is
19 measured by multiple meters, the total water usage for all the meters shall be the basis on which the
20 customer's monthly bill is computed and not on the basis of each separate meter source and readings.
21 E. If a non - domestic customer desires to establish eligibility for a sewage
22 service volume based on less than 100% of total monthly water usage, the non - domestic customer may
23 submit a written request to LRW that it be permitted, at the sole expense of the non - domestic customer, to
24 have a meter installed for the purpose of determining the amount of such quantity not reaching the sewer
25 system, provided, however, the meter shall be inspected and approved by LRW prior to being eligible to
26 receive any type of credit or adjustment to the monthly bill. The burden of showing that an appreciable
27 quantity of water usage does not reach the sewer shall be upon the customer; and the customer shall make
28 a determination if it wishes to either (i) install a sewage meter, or (ii) install a diversion meter as outlined
29 below. Both meter types shall comply with the items listed in (iii) below.
30 (i) Install a sewage meter to measure the volume of wastewater
31 actually discharged into the sewage system from the non - domestic customer's premises. In the event a
32 sewage meter is installed, the rate schedule as set forth in this Ordinance shall be applied to either: (a) the
33 volume of sewage entering the sewage system as measured by the meter; or (b) in the event the sewage
34 meter fails, a calculated volume shall be substituted, for up to ninety (90) days, based on the percentage of
(Page 3 of 121
1 metered water usage discharged to the sewage system as determined by the historical comparison of water
2 usage to that of the metered sewage; or
3 (ii) Install a diversion meter. In lieu of a sewage meter, the non -
4 domestic customer may install diversion water meter(s) to measure that portion of water used which is
5 diverted completely away from entering the sewage system. In the event a diversion water meter is
6 installed, the volume of water metered by such meter(s) shall be deducted from the total volume of water
7 usage (master water meter provided by Central Arkansas Water) before the sewer service rate schedule is
8 applied. In the event the diversion meter fails, a calculated volume shall be substituted, for up to ninety
9 (90) days, based on the percentage of metered diverted water usage to the master water meter usage as
10 determined by the historical comparison of the two; and
11 (iii) The following conditions shall also apply to non - domestic
12 customers who desire to establish eligibility for credit related to the use of either a sewer or diversion
13 water meter:
14 • Said meters shall measure flow in units of cubic -feet, and be
15 maintained and routinely calibrated to assure an accuracy of f
16 10 %.
17
• The readings from the meter shall be taken at least once monthly
18
and shall be provided to LRW in units of 00-ft' (100 cubic - feet).
19
• Cooling towers and boilers used for conditioning the air space of
20
buildings or used by customers of non - domestic facilities for
21
processing shall only be eligible for up to 70% credit when the
22
bleed and /or blow -down wastewaters are connected to the
23
sanitary sewer system.
24
• No refunds, allowances, credits, or reductions from the 100%
25
water use base will be granted to a non - domestic customer for
26
any time period prior to approval of a sewage metering or
27
diverted water metering system.
28
• Should a non - domestic customer fail to report a meter reading to
29
LRW for more than ninety (90) days, the customer shall be
30
removed from the sewer /diversion meter program. The customer
31
may reapply by making written application to LRW for approval.
32
• After receiving approval for a meter installation, and should that
33
metering system later fail, or the customer fail to report monthly
34
readings for ninety (90) days, the non - domestic customer shall
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1 have ninety (90) days to effect repairs or replace the defective
2 meters, and /or resume submittal of monthly meter readings.
3 After ninety (90) days of either occurrence, LRW shall apply
4 100% of the total water metered volume as if it was all
5 discharged to the sewerage system for the purposes of preparing
6 the monthly bill.
7 (3) The following shall apply to both domestic and non - domestic customers:
8 In the case of a customer using water for irrigation or lawn sprinkling purposes,
9 the customer may have an additional service meter installed by Central Arkansas Water to deliver the
10 water in such a way that the water is billed separately without a sewer charge being computed.
11 (c) The following rates shall be effective immediately upon the adoption of this Ordinance
12 (and shall be increased thereafter upon the dates set forth below) and shall be applied to each customer,
13 unless modified by contract recommended by the Sewer Committee and approved by ordinance by the
14 City Board of Directors if the facility provides its own conveyance directing its waste stream to the
15 digester or another specialty treatment process which does not commingle with the influent at the
16 headworks of the Wastewater Treatment Plant, and which does not adversely impact the fair and
17 reasonable rate structure applicable to all customers, as above determined, to arrive at the monthly charge
18 for each customer:
19
(1) Service Availability Charge
A. Inside City - Domestic Customers:
B. Outside City - Domestic Customers
Date of
Adoption of this January 1 January 1
Description Ordinance 2013 2014
Meter Size
[Page 5 of 121
Date of
Adoption of this
January 1
January 1
Description
Ordinance
2013
2014
Meter Size
5/8"
9.24
9.89
10.29
3/4"
11.91
12.74
13.25
1 "
18.01
19.27
20.04
B. Outside City - Domestic Customers
Date of
Adoption of this January 1 January 1
Description Ordinance 2013 2014
Meter Size
[Page 5 of 121
5/8"
13.86
14.84
15.44
3/4"
17.87
19.11
19.88
1"
27.02
28.91
30.06
(2) Operations Volumetric Charge (for all water consumed)
A. Inside City - Domestic Customers:
Date of
Adoption of this January 1 January 1
Description Ordinance 2013 2014
Flow 1.58 1.69 1.76
B. Outside City - Domestic Customers:
Date of
Adoption of this January 1 January 1
Description Ordinance 2013 2014
Flow 2.37 2.54 2.64
Debt Repayment Volumetric Charge (for all water
(3) consumed)
A. Inside City - Domestic Customers:
Date of
Adoption of this January 1 January 1 January 1
Description Ordinance 2013 2014 2016
Flow 1.81 1.81 1.81 2.04
B. Outside City - Domestic Customers:
Date of
Adoption of this January 1 January 1 January 1
Description Ordinance 2013 2014 2016
Flow 2.72 2.72 2.72 3.07
(4) Service Availability Charge
A. Inside City - Non Domestic Customers:
[Page 6 of 121
B. Outside City - Non Domestic Customers:
Date of
Adoption of this
January 1
January 1
Description
Ordinance
2013
2014
Meter Size
5/8"
9.24
9.89
10.29
3/4"
11.91
12.74
13.25
1 "
18.01
19.27
20.04
1.5"
31.79
34.02
35.38
2"
49.34
52.79
54.90
3"
90.17
96.48
100.34
4"
148.67
159.08
165.44
6"
294.86
315.50
328.12
B. Outside City - Non Domestic Customers:
A. Inside City - Non Domestic Customers:
Date of
Adoption of this January 1 January 1
Description Ordinance 2013 2014
Flow 1.85 2.29 2.75
B. Outside City - Non Domestic Customers:
[Page 7 of 121
Date of
Adoption of this
January 1
January 1
Description
Ordinance
2013
2014
Meter Size
5/8"
13.86
14.84
15.44
3/4"
17.87
19.11
19.88
1"
27.02
28.91
30.06
1.5"
47.69
51.03
53.07
2"
74.01
79.19
82.35
3"
135.26
144.72
150.51
4"
223.01
238.62
248.16
6"
442.29
473.25
492.18
(5)
Operations Volumetric Charge (for
all water consumed)
A. Inside City - Non Domestic Customers:
Date of
Adoption of this January 1 January 1
Description Ordinance 2013 2014
Flow 1.85 2.29 2.75
B. Outside City - Non Domestic Customers:
[Page 7 of 121
1
2
3
4
61
Date of
Adoption of this January 1 January 1
Description Ordinance 2013 2014
Flow 2.78 3.44 4.13
Debt Repayment Volumetric Charge (for all water
(6) consumed)
A. Inside City - Non Domestic Customers:
Date of
Adoption of this January 1 January 1 January 1
Description Ordinance 2013 2014 2016
Flow 2.12 2.12 2.12 2.40
B. Outside City - Non Domestic Customers:
Date of
Adoption of this January 1 January 1 January 1
Description Ordinance 2013 2014 2016
Flow 3.19 3.19 3.19 3.61
(7) Unit Extra Strength Surcharges (Inside and Outside City)
(6) Billing Charge: Customers whose usage requires rendering a bill shall pay a
service charge as determined by LRW's Annual Consolidated Fee Schedule which shall be duly adopted
by the Sewer Committee.
[Page 8 of 121
Date of
Cost Rate
Adoption of
Based on Units
this
January 1
January 1
Description
of
Ordinance
2013
2014
Unit Extra
Strength
Surcharges*
TSS > 600 mg /L
pounds
0.16
0.16
0.16
O &G > 50 mg/L
pounds
0.17
0.18
0.19
COD > 960
mg/L
pounds
0.17
0.18
0.19
(6) Billing Charge: Customers whose usage requires rendering a bill shall pay a
service charge as determined by LRW's Annual Consolidated Fee Schedule which shall be duly adopted
by the Sewer Committee.
[Page 8 of 121
1
2 (7) Delinquent Accounts: All accounts for sewer service not paid within thirty (30)
3 days of the billing date shall bear interest at the maximum rate permitted by law until paid in full.
4 (8) Wastewater Rate Subsidy Program: A customer may qualify for payment of
5 sewer rates payable according to the Wastewater Rate Subsidy Program by submitting a written
6 application, as provided by the City of Little Rock Department of Public Works, Solid Waste Division for
7 the Solid Waste Fee Increase Subsidy Program, and if approved by LRW, such customer will pay the
8 minimum service availability charge for the size water meter located at the customer's residence.
9 Section 2. The following rates for extra strength charges (or surcharge) are also established
10 as rates which the City Board of Directors further find and declare to be reasonable and minimum rates to
11 be charged.
12 (a) Applicability of Payment of Surcharge: The discharge of wastewaters having an
13 excessive chemical oxygen demand (COD), total suspended solids (TSS), or oil and grease (O &G)
14 constitute an added expense in the operation and maintenance of LRW's treatment facilities and should be
15 accompanied by payment of an extra strength surcharge to compensate for this added expense.
16 (1) Any non- domestic customer who demonstrates the ability, in any single month,
17 to discharge 4,000 pounds per month of COD, or more, shall receive a monthly bill for surcharge for all
18 applicable parameters. The applicability determination shall be on the following basis:
19 COD, Ibs /month = ((flow, gallons per month) 11, 000, 000) (8.34) (COD, mg1L *)
20 (2) *COD, mg/L shall be measured on the total sample basis and shall not receive
21 any deduction for the typical background domestic wastewater characteristic.
22 (b) If applicable in Section 2(a) surcharge will be determined as follows:
23 (1) Excessive strength is hereby defined as COD in excess of 960 mg/L, TSS
24 in excess of 600 mg/L, and O &G in excess of 50 mg/L, as determined in accordance with test
25 methods approved under 40 C.F.R. Part 136. The surcharge costs shall be based upon the pounds of
26 pollutant discharged in excess, and the following shall also apply:
27 COD, lbs /month = ((flow, gallons per month)/ 1,000,000) (8.34)(COD, mg/L — 960 mg/L)
28 TSS, lbs /month = ((flow, gallons per month)/ 1,000,000) (8.34)(TSS, mg/L — 600 mg/L)
29 O &G, ibs /month = ((flow, gallons per month)/ 1,000,000) (8.34)(0 &G, mg/L — 50 mg/L)
30 (2) The surcharge shall be computed separately for COD, TSS, and O &G on the total
31 discharge, unless the usage determination has been adjusted as provided for under Section 1(b)(2)E.
32 (c) Determination of Surcharge Strengths: LRW will perform analyses at minimum of once
33 per calendar year to determine the strength of sewage discharged by non - domestic customers, whose
[Page 9 of 121
1 wastes are subject to surcharge, and who have demonstrated the ability to exceed the pounds of COD
2 specified in Section 2(a). For those non - domestic customers, the following shall also apply:
3 (1) If a non- domestic customer disagrees with the analytical value determination
4 made by LRW, the customer may, at its sole expense, employ an independent laboratory, acceptable to
5 LRW, to conduct sampling and analysis of its sewage discharge. The time period and location for the
6 collection of the samples shall be designated by LRW. LRW and the independent laboratory shall both
7 preside over the collection of the samples and shall equally divide the final composite sample so that
8 duplicate analyses may be made. In the case of the O &G, two (2) separate and distinct samples shall be
9 collected and both analyzed.
10 (2) The results of the analyses of the sewage sample made by both LRW and the
11 independent laboratory will be averaged. The average of the results of these analyses shall be used to
12 determine the actual extra strength surcharges.
13 (d) Reevaluation Period: If any non- domestic customer improves the quality of its sewage
14 discharged, upon written request by the customer, LRW shall reevaluate the strength of the sewage
15 discharge over a period of no more than one (1) -year. If after the one (I) -year evaluation period, the
16 monitoring data reveals the customer did not, in any one single data point, exceed the amount of 4,000
17 pounds per month of COD, then LRW shall remove the customer from the extra strength surcharge
18 program the first billing cycle following the conclusion of the one (I) -year evaluation period. The
19 customer shall pay LRW for any additional monitoring data requested by the customer over and above the
20 routine monitoring normally performed by LRW. The additional monitoring charge shall consist of all
21 costs for personnel, material, and equipment used to collect and analyze samples from the customer's
22 discharge of sewage. The exact charge shall be based on actual costs and shall be determined by LRW.
23 (e) Performance of Analyses: All analyses shall be performed in accordance with the
24 provisions as specified in City of Little Rock Ordinance 19,895, or its successor ordinance. All
25 surcharges shall be calculated based on 100% of metered water use, except as otherwise provided in
26 Section I (b)(2)E. of this ordinance.
27 Section 3. Adjustments: Any customer who feels its monthly bill is unjust and inequitable may
28 make written application to LRW requesting a review of this charge. Said written request shall, when
29 necessary, show the actual or estimated average flow and /or strength of the customer's wastewater in
30 comparison with the values upon which the charge is based, including how the measurements or estimates
31 were made. Review of the request shall be made by LRW. If substantiated, the charges for that customer
32 shall be recomputed based on the revised flow and /or strength data, and the new charges shall be
33 applicable to the next billing cycle /period. The following shall apply to any adjustments made:
[Page 10 of 121
1 (a) Subject to Section 3(b), LRW shall adjust a customer's account and issue a corrected bill
2 if it determines that it has over - billed or under - billed the customer for sewer because of-
3 (1) Central Arkansas Water meter's failure to meet the accuracy standards of the
4 American National Standards Institute or the American Water Works Association, as applicable (subject
5 to verification by LRW with Central Arkansas Water);
6 (2) The application of an incorrect sewer rate to the customer's account;
7 (3) An erroneous meter reading or the reading of a meter other than that through
8 which the customer actually received service; or
9 (4) The failure of Central Arkansas Water to include the sewer service in the
10 customer's billing account.
11 (b) No billing adjustment shall be made, and no back credit or refund shall be issued, with
12 respect to sewer services provided.
13 (1) More than twelve (12) months before the date the error or inaccuracy is
14 discovered if the error or inaccuracy caused the customer to be over - billed;
15 (2) More than twelve (12) months before the date the error or inaccuracy is
16 discovered if the error or inaccuracy caused the customer to be under - billed, or, in the case of a domestic
17 customer, more than six (6) months before the date the error or inaccuracy is discovered;
18 (3) To any customer other than the customer currently receiving sewer service at the
19 service address to which the adjustment pertains; or
20 (4) Under an account that has become an inactive account and for which a final bill
21 was issued more than ninety (90) days before the error or inaccuracy was discovered.
22 (c) For an adjustment due to an inaccurate meter, LRW may estimate the customer's utility
23 consumption using prior consumption history, comparisons to similarly situated customers under similar
24 weather conditions, readings from a replacement meter, or such other methods and information that it
25 reasonably deems appropriate. In the case of the application of an incorrect rate, LRW shall base the
26 adjustment on the correct rate.
27 (d) In the event an adjustment is made for Central Arkansas Water's utility service, the sewer
28 charges will be adjusted by LRW for the same period.
29 (e) If a customer is liable for a balance under an inactive account, LRW may transfer that
30 balance to any of the customer's active accounts. The time limitations in Section 3(b) shall not apply to a
31 transfer made under this subsection.
32 (f) If LRW makes a determination on its own that an adjustment is needed to a customer's
33 bill, notwithstanding the above provisions, LRW may make that adjustment.
[Page 11 of 121
1 Section 4. All bills for sewer service shall be rendered monthly. Under the provision of Ark. Code
2 Ann § 14- 235 -223, if any sewer charge is not paid within thirty (30) days after same is due, there shall be
3 a 10% penalty on the amount due, for which suit may be brought to collect all sums due, together with a
4 reasonable attorney's fee.
5 Section 5. Each user of the sewer system shall be notified, at least annually by publication having
6 circulation in Pulaski County, Arkansas, in conjunction with a regular bill, of the rate and the portion of
7 the user charges which are attributable to waste water treatment services, in compliance with 40 C.F.R.
8 §35.929 -2(f).
9 Section 6. Severability: In the event any title, section, paragraph, item, sentence, clause, phrase, or
10 word of this ordinance is declared or adjudged to be invalid or unconstitutional, such declaration or
11 adjudication shall not affect the remaining portions of this ordinance, which remain in full force and
12 effect as if the portion so declared or adjudged invalid or unconstitutional is not a part of this ordinance.
13 Section 7. Repealer: All resolutions and ordinances and parts thereof in conflict with this
14 Ordinance, including City of Little Rock Ordinance No. 19,647 (approved November 28, 2006), Section
15 14 of City of Little Rock Ordinance No. 19,895 (approved December 21, 2007), and Ordinance No.
16 20,311 approved September 7, 2010, are repealed at the effective date of this ordinance, as provided in
17 Section 8 herein.
18 Section 8. Emergency Clause: The Board of Directors of the City of Little Rock has determined
19 that inadequate sewer rates and charges will endanger the proper operation, maintenance, and continued
20 improvement of the wastewater collection and treatment facilities of the City which are necessary in order
21 to prevent a hazard to the public health, safety, and welfare of the inhabitants of the City; and, therefore,
22 an emergency is declared to exist, and this ordinance shall take effect immediately upon adoption; and,
23 until that date, Ordinance No. 19,647 approved November 28, 2006, Section 14 of Ordinance No. 19,895
24 approved December 21, 2007, and Ordinance No. 20,311 approved September 7, 2010, shall remain in
25 full force and effect.
26 PASSED: June 12, 2012
27 ATTEST:
28
29
30 4WS ty Clerk 31 O LEGAL FORM:
32
33
34 Thomas M. Carpenter, City ttor ley
35 H
APPROVED:
Mark Stodola, Mayor
IPage 12 of 121