HomeMy WebLinkAboutCD Massage Urgency Moratorium ExtensionAgeno Item No: 4. a
Meeting Date: February 17, 2015
SAN RAFAEL CITY COUNCIL AGENDA REPORT
Department: Community Development
Prepared by: Raffi Boloyan, Planning Manager City Manager Approvall/A4644
s/ RB
SUBJECT:
Consideration of an Ordinance of the City Council of the City of San Rafael adopted as an urgency
measure making findings and extending a temporary moratorium on the establishment and
operation of new massage establishments within the City of San Rafael.
RECOMMENDATION:
Accept report and adopt the ordinance to extend the moratorium until December 31, 2015.
BACKGROUND:
At its regular meeting on January 5, 2015, the City Council adopted Ordinance No. 1928, an urgency
ordinance temporarily enacting a moratorium on the establishment and operation of new massage
establishments in any zoning district within the City. The moratorium is in effect for 45 days. A massage
establishment is a business that offers massage therapy in exchange for compensation. By its terms, the
moratorium does not apply to massage establishments that were open and operating with required permits
prior to the adoption of the moratorium.
The moratorium was enacted due to recent changes in State law. Since the enactment of Senate Bill 731
(Massage Therapy Act) in 2008, many communities throughout the state have experienced a significant
increase in massage establishments, as well as difficulty implementing the Massage Therapy Act.
Consequently, the State enacted changes in the law (Assembly Bill 1 147) in 2014 to extend and modify
the Act, which went into effect on January 1, 2015. The amended the Massage Therapy Act, amongst
other changes, once again permits cities to use their land use and zoning powers to regulate massage
establishments differently than other personal or professional services establishments located within their
jurisdictions.
Based on the change in State law, the City determined it was prudent to enact a moratorium to prevent
any new massage establishments opening in San Rafael, while the City studies potential changes to
zoning and land use regulations. The moratorium provides this period of time to allow the issue to be
studied, without enabling new, additional massage establishments that may or may not be allowed if new
FOR CITY CLERK ONLY
File No.: `1- 10 "3
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SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 2
zoning rules are ultimately adopted. The purpose of the moratorium is to allow City planning and legal
staff a measured period of time in which to:
• Conduct a thorough review of the impacts of existing massage establishments in various zoning
districts,
• Understand the extensive state law governing the regulation of this use,
• Review the applicability of the City's existing zoning regulations to the use,
• Evaluate regulatory schemes studied and enacted by many other California cities, and
• Evaluate the need for any additional zoning ordinance amendments.
Therefore, Ordinance No. 1928 was adopted on January 5, 2015 as an urgency ordinance, pursuant to the
authority of Government Code section 65858, is effective for 45 days and is set to expire on February 19,
2015. The Government Code requires that the legislative body must issue a report describing the
measures taken to alleviate the condition which led to the adoption of the ordinance. This report and
ordinance provides the status report and findings. The Government Code also provides that the
moratorium may be extended by the City Council following a noticed public hearing, for an additional
period of time up to 1 year, ten months and fifteen days.
Through separate action, the City also adopted changes to its Massage Ordinance (SRMC 10.90) in
December 2014 modifying certain operating and registration standards and requirements. Also through
separate action, the City is currently considering establishment of fees to cover City staff time for
registering and inspection massage establishments.
ANALYSIS:
Status Report Regarding Moratorium:
Since the enactment of the moratorium on January 5, 2015, staff has the following information to report.
Information on Existing Massage Establishments
Since the adoption of the moratorium, staff has tabulated and mapped all existing (and permitted)
massage establishments within the City of San Rafael. Attachment B -1 illustrates on a map the
locations of all massage establishments within the City, while Attachment B-2, B-3 and B-4
illustrate each of the three types separately. Each map has an index page as the first page and the
subsequent pages are magnifications of the areas which have establishments located. The dot
identifies the location, while the color of the dot indicates how many citations each establishment
has been issued since October 2013.
• Green dots denote establishments that have not received any citations.
• Yellow dots denote massage establishments that have received 1-4 citations
• Red dots denote establishments that have received 5 or more citations
There are three main types of massage establishments, Certified Massage Establishment (with
employees), Certified Massage Establishments - No Employees (Sole Proprietor/Provider) and
Non -Certified Massage Establishments (Operator Permit). Attachment B-1 illustrates all three of
these types of establishments on one map. Attachments B-2 through Attachment B-4 illustrate
each type separately.
• Certified Massage Establishments are those in which the owner(s) of the business is/are
California Massage Therapy Council (CAMTC) certified massage therapist(s)/
practitioners(s). Attachment B-2 illustrates just the locations of these types of
establishments and of the 14 Certified Massage Establishments (with Employees), six
have 5+ violations, four have 1-4 citations and four have 0 citations.
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 3
• Sole Proprietorship/Sole Provider (referred to as Sole Provider throughout the rest of this
report) are those where the business owner is a CAMTC certified practitioner and there
are no other employees. Attachment B-3 illustrates just the locations of these types of
establishments and of the 57 Certified Massage Establishments (Sole Providers), four
have 1-4 citations while the remaining 53 have no citations.
Non -Certified Establishments (Operator Permits) and are those in which the owner of the
business are. not CATMC certified therapist(s) practitioners(s). Attachment B-1 illustrates
just the locations of these types of establishments. Attachment B-4 illustrates just the
locations of these types of establishments and of the 12 Non -Certified Massage
Establishments (Operator Permit), eight have five + violations, one has 1-4 citations and
three have no citations.
2. Input from Massage Operators
Since the adoption of the urgency moratorium in early January, staff has met with the recently re-
established Massage Ordinance Advisory Committee (MOAC) on three separate occasions. The
first two meetings were primarily focused to provide clarity on the proposed massage
establishment fees (separate matter than the moratorium that was reviewed by the Council on
January 19`x' and continued by the Council to allow for additional study). The purpose of the third
meeting was for staff to present the findings and recommendations on the current moratorium to
MOAC as a preview of what will be in this report.
Should the massage moratorium be extended and staff be directed to study the options, staff will,
of course, continue to have continued communications and periodic meetings with MOAC to
present outcomes and solicit feedback.
Options to Study if Moratorium IS Extended
Since the adoption of the urgency ordinance, staff has researched potential zoning/land use
changes that could be considered for study. In the 42 days since the adoption or the moratorium,
it is not feasible for staff to collect and analyze data or study and evaluate options for a complex
issue as this. However, staff has made some progress to develop a menu of potential items that
could be studied should the moratorium be extended. These include:
a. Status Quo - No change to the current zoning regulations or maps, which allow massage
establishments as a permitted use in nearly all commercial and mixed use zoning districts,
although require them to be on a 2"d floor or above or rear ground level in some downtown
zoning districts.
b. Require Use Permit for all Massage Establishments Use permits could be required for
massage establishments in some or all zoning districts to allow the City to evaluate land use
compatibility, hours of operation and concentration/spacing issues. This is not a new tool. At
one time, the City required a Use Permit for all massage establishments.
c. Spacing/Separation requirements for Massage Establishments — Spacing or separation
requirements could be imposed on massage establishments to not locate within a certain
distance of another massage establishment (e.g., 500 foot separation). Recently, the City of
San Gabriel in Southern California adopted an Ordinance establishing spacing requirements,
so this tool is currently being considered and tested.
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 4
d. Modify Zoning district land use tables to limit or prohibit massage establishments in certain
zoning districts — Massage establishments could be limited, or prohibited from certain zoning
districts within the City.
e. Consider exemption from zoning changes for Sole Providers - Any zoning changes could be
coupled with exemptions for sole proprietors/sole providers
f. Combination of options above — Evaluate some combination of the options above.
Please note that at this time, there has not yet been any detailed study or evaluation of any of the zoning
options listed above. The above list is solely a starting point of various options that could be considered
and studied should the moratorium be extended. Even if considered, studying the options does not mean
any changes to zoning are warranted or will be adopted. The Planning Commission and City Council will
ultimately hold public hearing(s) and evaluate the studies to hear from the public and determine if zoning
changes are warranted. The moratorium just provides the City with some time to evaluate the options
without adding more establishments to the current inventory.
In addition, MOAC has requested that the City prepare a longitudinal study, which essentially provides a
chronology of City Code changes and enforcement practices and massage establishment activity since the
2004 amendment to the Massage Ordinance.
Extension of Moratorium Ordinance:
The Community Development Department and City Attorney's Office staff have already devoted
substantial time to this issue over the past two months; however, the most significant work remains
outstanding. Before staff is prepared to report to the Planning Commission and City Council with results
of any study on zoning options resulting from this moratorium, extensive research, outreach and analysis
will be required to study zoning options.
The extensive work that would be required should the moratorium be extended is not part of the
Community Development Department or City Attorney's Office work plans or objectives for this fiscal
year and would have to be added to the work plan and balanced with the Department's limited staff and
the other goals and projects currently underway. Therefore, should the moratorium be extended, staff
anticipates that it would take around 1.5 2 years to complete this project (which would be past this
current extension date) along with the many other items staff is currently working on.
In addition to the moratorium, the City Council will soon be deciding upon other related and 'un -related
staff work plan items and budgeting for FY 15'16 during the upcoming budget adoption process. One of
the main items that is related to the larger topic of massage establishments is the implementation of the
massage ordinance (registration, inspection and enforcement) that is currently funded through this
September, 2015. For this reason, it is recommended that Council extend the existing moratorium
through the end of this calendar year (December 31, 2015).
Status of Massage Ordinance Registration and Inspection Program:
In June 2013, the City Council assigned the implementation of the Massage Ordinance to the Community
Development Department (from the Police Department). Given that Community Development did not
have the staffing to provide this new service, an outside contractor was hired (CSG Consultants) to create
and implement the Massage Ordinance registration and inspection program.
A summary of the program to date is provided in Attachment C. Since the Code Enforcement Division,
through its contractor, has taken over the implementation of the Massage Ordinance, the City has
performed 644 inspections, observed 516 violations of the ordinance, and issued 201 citations in the
amount of $120,627 ($100,140 of which has been collected). The City has revoked the certificate for one
massage establishment to operate in September 2014 and is currently pursuing the revocation/suspension
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Paim: 5
of one other business' certification (Tokyo Spa). In addition, two other locations been ordered to close
since their certificates had expired and the moratorium has been in place (Tiger Massage and Orchid Spa).
Lastly, the City action and enforcement has resulted in the closure of 5 other massage establishments.
Next Steps:
Should the moratorium be extended, staff would begin to study the current conditions within the City with
the number of existing massage establishments and analyze and develop the 6 options noted above. As
previously noted, this task is not on the current work plan for the Community Development Department,
so it would have to be mixed in with the other tasks that are assigned and scheduled for the Department.
The potential zoning options would be further developed and the advantages and disadvantages of each
option would have to be identified. Staff would present periodic updates at key milestones in this process
to the MOAC group, as well as present updates and solicit feedback from the Planning Commission and
City Council or a Council subcommittee.
Conclusion:
There have been significant changes in State law in recent years, including the restoration of the City's
powers to impose land use regulations on massage establishments under Assembly Bill 1147. Moreover,
the City's zoning ordinance permits the City to foster harmonious and workable relationships among land
uses and reduce or remove negative impacts caused by inappropriate location of uses. Therefore, the City
owes a responsibility to all interested persons, including the operators of existing and proposed massage
establishments, potentially affected surrounding residents and businesses, and the public at large, to
conduct a comprehensive study of current massage establishment land use regulations, and the City's
options for improving the effectiveness of those regulations. The study does not mean zoning changes
would ultimately be an appropriate remedy, but the issue needs to be studied to reach a conclusion
The establishment and operation of new massage establishments within the City, including the relocation
of existing massage establishments to new locations within the City, prior to completion of such a
comprehensive study and possible adoption of new or amended land use regulations governing massage
establishments, creates an immediate threat to public safety, health and welfare, in that such operations
threaten to cause adverse impacts to surrounding residents and businesses, including impacts on or related
to over -concentration, available parking, traffic, noise, outdoor lighting, sanitation, and property values.
As drafted, the extension to the moratorium would continue to not apply to massage establishments which
were already operating in the City (as of January 5, 2015) in compliance with City ordinances (having
valid and current permits and approvals), so long as they maintain their present location. Further, the
moratorium would not prevent the transfer of such a business to a new owner. In addition, if a complete
application had been received by the City for a certificate or permit under the City's massage ordinance
prior to adoption of the urgency ordinance (Jan 5, 2015), the moratorium would not have prevented the
City from processing and approving that application.
Staff is proposing to extend the moratorium for a period of 10 months and 15 days, thus through
December 31, 2015 to allow Staff to: 1) study and identify any potential impacts of the number of
existing massage establishments 2) study and research the options for alternative land use regulations; and
3) if warranted, draft any recommended new or amended land use regulations governing massage
establishments for consideration by the City Council. Should the work not be completed in that
timeframe, the moratorium could be extended for another 1 year period, following a noticed public
hearing and status report and adoption of an Ordinance.
PUBLIC OUTREACH AND NOTICING:
As noted above, staff has met with the MOAC committee on three occasions during this 45 moratorium
period. In addition, staff has had numerous phone calls and email communication with the members of the
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 6
MOAC to answer questions. The final MOAC meeting was noticed to all owners and operators of
massage establishments as well as other interested parties.
Notice of this hearing to consider the extension of the moratorium was provided by a notice in the Marin
IJ on Thursday February 5, 2015 (Attachment D) and mailing of public hearing notice to all massage
establishments and other interested parties, on Monday, February 9, 2015.
Staff has received a few letters from massage operators, expressing concern with the moratorium and
requesting it not be extended. All correspondence received as of the reproduction of this report are
included in this staff report. Letters received after the reproduction of the report will be forwarded to the
Council under separate cover.
FISCAL IMPACT:
There will be no direct fiscal impact of the Council's adoption of the attached moratorium extension,
other than the significant commitment of City staff time to the study and implementation of applicable
law.
OPTIONS:
The City Council has the following options:
1. Adopt the urgency ordinance as proposed to extend the moratorium through December 31, 2015
2. Adopt the urgency ordinance with a modified expiration date.
3. Do not adopt the urgency ordinance, and direct staff to return to the Council with other options
for addressing the issues raised by massage establishments.
4. Do not adopt the urgency ordinance and allow the moratorium to expire with no further work by
staff.
ACTION REQUIRED:
1. Accept status report.
2. Adopt ordinance by at least a four-fifths (4/5) vote.
ATTACHMENTS:
Page #
(Stamped)
A. Ordinance 7
B. Maps of current massage establishments within the City of San Rafael
B-1 All Massage Establishments 13
B-2 Certified Massage Establishments 22
B-3 Certified Massage Establishments (Sole Provider) 31
B-4 Non -Certified Massage Establishment (Operator Permit) 40
C. Status Report on Massage Inspection Program 49
D. Proof of Publication of Public Hearing Notice 51
E. Public Comments 52
ORDINANCE NO. 1929
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SAN
RAFAEL ADOPTED AS AN URGENCY MEASURE MAKING FINDINGS
AND FURTHER EXTENDING A TEMPORARY MORATORIUM ON
THE ESTABLISHMENT AND OPERATION OF NEW MASSAGE
ESTABLISHMENTS WITHIN THE CITY OF SAN RAFAEL
THE CITY COUNCIL OF THE CITY OF SAN RAFAEL, DOES ORDAIN AS
FOLLOWS:
WHEREAS, the City Council has broad discretion pursuant to Article III, Sections 16
and 59 of the City Charter; California Constitution Article XI, Section 5; and the general law of
the state, including but not limited to the California Planning and Zoning Law (Gov. Code
§§65000 et seq.), to legislate for public purposes and for the general welfare, including but not
limited to matters of public health and safety; and
WHEREAS, since the 1970's, California Government Code section 51030 has
authorized California cities and counties to adopt ordinances to regulate the business of massage
through a licensing process, and pursuant to such authority, the City of San Rafael historically
has imposed various regulations on massage and/or bodywork offices or establishments
(hereafter "massage establishments") operating within the City. Those regulations are currently
codified as Chapter 10.90 of the San Rafael Municipal Code entitled "Massage Therapy"; and
WHEREAS, the City regulates the permitted uses of real property within the City
pursuant to the provisions of its zoning ordinance, codified in San Rafael Municipal Code Title
14 ("the Zoning Ordinance"), and pursuant to such authority the City has for many years also
regulated the uses of real property within the City for the operation of massage establishments;
and
WHEREAS, in 2008, the State Legislature adopted Senate Bill 731, the Massage
Therapy Act, establishing a new statutory scheme for a voluntary certification program for
massage professionals that would entitle them to rely on a uniform statewide set of occupational
regulations and that would, for massage establishments where all the massage practitioners are so
certified, prohibit cities from imposing special zoning and land use requirements not applicable
to other personal and professional services; and
WHEREAS, since 2010, the City has been regulating massage professionals and
massage establishments in compliance with the Massage Therapy Act; and
WHEREAS, the State Legislature recently adopted and the Governor signed Assembly
Bill 1147, which became effective on January 1, 2015 and amended the Massage Therapy Act to
once again permit cities to use their land use powers to regulate massage establishments
differently than other personal or professional services establishments located within their
jurisdictions; and
WHEREAS, the City regularly receives complaints from members of the public about
the growth in the number of massage establishments within the City, including complaints of
their over -concentration and adverse impacts in the Downtown area; and
WHEREAS, pursuant to Government Code section 65858, in order to protect the public
health, safety or welfare, the City Council may, by an affirmative vote of at least four-fifths (4/5)
of its members, and without following the procedures otherwise required prior to the adoption or
amendment of a zoning ordinance, adopt an interim urgency ordinance to prohibit uses that may
be in conflict with a contemplated general plan or zoning proposal that the City is studying or
intends to study within a reasonable time; and
WHEREAS, due to the significant changes in State law in recent years and the restored
powers of the City to impose land use regulations on massage establishments under Assembly
Bill 1147, the City Council finds that it is timely and important for City staff to undertake a
comprehensive study of current massage establishment regulations, and the City's options for
improving the effectiveness of those regulations; and
WHEREAS, the establishment and operation of new massage establishments within the
City prior to completion of such a study and possible adoption of new or amended land use
regulations governing massage establishments, creates a current and immediate threat to the
public safety, health, and welfare, in that such operations threaten to cause adverse impacts to
surrounding residents and businesses, including impacts on or related to over -concentration,
available parking, traffic, noise, outdoor lighting, sanitation, and property values; and
WHEREAS, for the reasons stated above, on January 5, 2015 the San Rafael City
Council adopted Ordinance No. 1928, a 45 -day moratorium on the establishment of new
massage establishments within the City. The purpose of the moratorium is to allow the City
Staff to undertake a comprehensive study to: (1) determine the number and location of existing
massage establishments within the City; (2) review and analyze the provisions of the Zoning
Ordinance and other laws and regulations applicable to massage establishments; (3) study and
research options for alternative land use regulations; and (4) draft any recommended new or
amended land use regulations governing massage establishments for consideration by the City
Council; and
WHEREAS, the City Council finds that additional time is required for City staff to
thoroughly study the issues related to regulation of massage establishments; to draft any
appropriate amendments to the City's Municipal Code for consideration by the City Council, and
that therefore the temporary moratorium adopted in Ordinance No. 1928 should be extended; and
WHEREAS, as required pursuant to Government Code section 65858, the City Council
has received and accepted a report from City staff on the measures taken to address the
conditions which led to the adoption of Ordinance No. 1928; and
WHEREAS, the City Council hereby finds that it can be seen with certainty that there is
no possibility that the extension of the temporary moratorium ordinance may have a significant
effect on the environment, since this ordinance does not authorize construction or installation of
any facilities and, in fact, imposes greater restrictions on such construction and installation in
order to protect the public health, safety and general welfare. This ordinance is therefore exempt
from the environmental review requirements of the California Environmental Quality Act
(CEQA) pursuant to Section 15061(b)(3) of Title 14 of the California Code of Regulations.
NOW, THEREFORE, the City Council of the City of San Rafael does hereby ordain as
follows:
DIVISION 1. -- FINDINGS.
Pursuant to the provisions of Government code section 65858, the City Council of the
City of San Rafael hereby finds as follows:
1. The above recitals are true and correct and are incorporated herein by reference.
2. Based on the recitals above, the City Council hereby finds and determines that the
establishment or commencement of operation of massage establishments within the City prior to
the City completing a study of the existing and potential impacts and regulation of such use
would pose a current and immediate threat to the public peace, health, safety, and welfare, and
that a temporary moratorium on the establishment of such uses is therefore necessary.
3. This ordinance is necessary as an urgency measure to preserve the public peace,
health or safety.
DIVISION 2. -- EXTENSION OF MORATORIUM.
1. The temporary moratorium adopted by City of San Rafael Ordinance No. 1928 is
hereby extended to and including December 31, 2015.
2. During the term of this temporary moratorium, no new massage establishment, as
defined in section 14.03.030 of the Zoning Ordinance, including but not limited to massage
establishments operated as home occupations, shall be opened and/or operated in any zoning
district within the City. Provided however, that if a massage establishment was doing business at
a location within the City in compliance with the applicable provisions of the current Zoning
Ordinance and San Rafael Municipal Code Chapter 10.90 prior to adoption of Ordinance No.
1928, the moratorium shall not prevent that business from continuing to operate at that location,
or prohibit transfer of the ownership of the business at that location, or prohibit a sole
proprietorship from moving to a new location; and shall not prevent the City from approving the
establishment and operation of a massage establishment for which a completed application was
submitted under San Rafael Municipal Code Chapter 10.90 prior to the adoption of Ordinance
No. 1928.
3. City staff is directed to continue its comprehensive study to: (1) determine the
number and location of existing massage establishments within the City; (2) review and analyze
the provisions of the Zoning Ordinance and other ,laws and regulations applicable to massage
3
establishments; (3) study and research options for alternative land use regulations; and (4) draft
any recommended new or amended land use regulations governing massage establishments for
consideration by the City Council.
4. Violations of this temporary moratorium may be charged as infractions or
misdemeanors as set forth in Section 1.16.060 of the San Rafael Municipal Code, may be the
subject of administrative citations or administrative orders as set forth in Chapters 1.44 or 1.46 of
the San Rafael Municipal Code, or may be deemed a public nuisance and may be enforced by an
action for injunction or civil penalties as provided in Section 1.42.020, or by any other remedy
authorized by law.
5. The San Rafael City Manager is hereby authorized to direct all City Departments,
including the Code Enforcement Division of the Community Development Department, Police
Department and the City Attorney to facilitate compliance with the purpose and intent of this
temporary moratorium using the enforcement powers described in the preceding paragraph.
111►+I N tilk"WM
Pursuant to the pertinent provisions of Government Code section 65858, this interim
urgency ordinance shall expire and shall be of no further force and effect after December 31,
2015; provided however, that after notice and public hearing, the City Council may, upon an
affirmative vote of at least four-fifths of its members, extend this Ordinance No. 1928 as
provided in section 65858, for an additional period of time not to exceed a total extension period
of twenty-two (22) months and fifteen (15) days.
DIVISION 4.
If any section, subsection, sentence, clause or phrase of this ordinance is, for any reason,
held to be invalid, such decision shall not affect the validity of the remaining portions of this
ordinance. The City Council hereby declares that it would have adopted the ordinance and each
section, subsection, sentence, clause or phrase thereof, irrespective of the fact that any one or
more sections, subsections, sentences, clauses, or phrases are declared invalid.
DIVISION 5.
This ordinance is hereby declared to be an urgency measure and shall become effective
immediately upon adoption by an affirmative vote of at least four-fifths (4/5) of the members of
the City Council pursuant to Government Code section 65858. The City Clerk is directed to
publish forthwith a copy of this Ordinance, together with the names of those Councilmembers
voting for or against same, in a newspaper of general circulation published and circulated in the
City of San Rafael, County of Marin, State of California.
�-i
GARY 0. PHILLIPS, Mayor
4
ATTEST:
e_- • 44r rR—C
ESTHER C. BEIRNE, City Clerk
I, ESTHER C. BEIRNE, City Clerk of the City of San Rafael, certify that the foregoing
Ordinance was passed by the City Council of the City of San Rafael, California, by a vote of at
least four-fifths (4/5) of the members thereof, at a regular meeting held on Tuesday, the 17th day
of February, 2015, by the following vote, to wit:
AYES: Councilmembers: Bushey, Gamblin, McCullough & Mayor Phillips
NOES: Councilmembers: Colin
ABSENT: Councilmembers: None
6
"'� . r- en . 4 -to?" '
ESTHER C. BEIRNE, City Clerk
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