HomeMy WebLinkAboutVeronica Tam & Associates LLC; 2008-12-12;AGREEMENT FOR CONSULTANT SERVICES
(Veronica Tarn & Associates, LLC)
THIS AGREEMENT is made and entered into as of the day of
by and between the CITY OF CARLSBAD, a municipal
corporation, ("City"), and Veronica Tarn & Associates. LLC. a Limited Liability Company.
("Contractor").
RECITALS
City requires the professional services of a consultant that is experienced in preparing an
Assessment of Impediments to Fair Housing. Contractor has the necessary experience in
providing these professional services, has submitted a proposal to City and has affirmed its
willingness and ability to perform such work.
NOW, THEREFORE, in consideration of these recitals and the mutual covenants
contained herein, City and Contractor agree as follows:
1. Scope of Work. City retains Contractor to perform, and Contractor agrees to render,
those services (the "Services") that are defined in Exhibit "A", attached and incorporated by this
reference in accordance with the terms and conditions set forth in this Agreement.
2- Term. This Agreement will be effective for a period of one (1) year from the date first
above written.
3. Compensation. The total fee payable for the Services to be performed will be One
Thousand Nine Hundred Five Dollars Dollars ($1,905). No other compensation for the Services
will be allowed except for items covered by subsequent amendments to this Agreement. City
reserves the right to withhold a ten percent (10%) retention until City has accepted the work
and/or the Services specified in Exhibit "A."
4. Status of Contractor. Contractor will perform the Services as an independent contractor
and in pursuit of Contractor's independent calling, and not as an employee of City. Contractor
will be under the control of City only as to the results to be accomplished.
5. Indemnification. Contractor agrees to indemnify and hold harmless the City and its
officers, officials, employees and volunteers from and against all claims, damages, losses and
expenses including attorneys fees arising out of the performance of the work described herein
caused by any negligence, recklessness, or willful misconduct of the Contractor, any
subcontractor, anyone directly or indirectly employed by any of them or anyone for whose acts
any of them may be liable.
The parties expressly agree that any payment, attorney's fee, costs or expense City incurs or
makes to or on behalf of an injured employee under the City's self-administered workers'
compensation is included as a loss, expense or cost for the purposes of this section, and that
this section will survive the expiration or early termination of this Agreement.
6. Insurance. Contractor will obtain and maintain policies of commercial general liability
insurance, automobile liability insurance, a combined policy of workers' compensation,
City Attorney Approved Version #05.06.08
employers liability insurance, and professional liability insurance from an insurance company
authorized to transact the business of insurance in the State of California which has a current
rating in the Best's Key Rating guide of at least A-:VII OR with a surplus line insurer on the State of
California's List of Eligible Surplus Line Insurers (LESLI) with a rating in the latest Best's Key Rating Guide
of at least "A:X", in an amount of not less than one million dollars ($1,000,000) each, unless
otherwise authorized and approved by the City Attorney or the City Manager. Contractor will
obtain occurrence coverage, excluding Professional Liability, which will be written as claims-
made coverage. The insurance will be in force during the life of this Agreement and will not be
canceled without thirty (30) days prior written notice to the City by certified mail. City will be
named as an additional insured on General liability. Contractor will furnish certificates of
insurance to the Contract Department, with endorsements to City prior to City's execution of this
Agreement.
7. Conflict of Interest. City will evaluate Contractor's duties pursuant to this Agreement to
determine whether disclosure under the Political Reform Act and City's Conflict of Interest Code
is required of Contractor or any of Contractor's employees, agents or subcontractors. Should it
be determined that disclosure is required, Contractor or Contractor's employees, agents, or
subcontractors will complete and file with the City Clerk those schedules specified by City and
contained in the Statement of Economic Interests Form 700.
8. Compliance With Laws. Contractor will comply with all applicable local, state and federal
laws and regulations prohibiting discrimination and harassment and will obtain and maintain a
City of Carlsbad Business License for the term of this Agreement.
9. Termination. City or Contractor may terminate this Agreement at any time after a
discussion, and written notice to the other party. City will pay Contractor's costs for services
delivered up to the time of termination, if the services have been delivered in accordance with
the Agreement.
10. Claims and Lawsuits. By signing this Agreement, Contractor agrees it may be subject to
civil penalties for the filing of false claims as set forth in the California False Claims Act,
Government Code sections 12650, et seq.. and Carlsbad Municipal Code Sections 3.32.025, et
seq. Contractor further acknowledges that debarment by another jurisdiction is grounds for the
City of Carlsbad to terminate this Agreement.
11. Venue and Jurisdiction. Contractor agrees and stipulates that the proper venue and
jurisdiction for resolution of any disputes between the parties arising out of this Agreement is the
State Superior Court, San Diego County, California.
12. Assignment. Contractor may assign neither this Agreement nor any part of it, nor any
monies due or to become due under it, without the prior written consent of City.
13. Amendments This Agreement may be amended by mutual consent of City and
Contractor. Any amendment will be in writing, signed by both parties, with a statement of
estimated changes in charges or time schedule.
City Attorney Approved Version #05.06.08
14. Authority. The individuals executing this Agreement and the instruments referenced in it
on behalf of Contractor each represent and warrant that they have the legal power, right and
actual authority to bind Contractor to the terms and conditions of this Agreement.
CONTRACTOR CITY OF CARLSBAD,
corporation of tl/ie/Sta$gj
By:
(sign here)
(print name/title)ATTEST
(sign here)
LO
City Clerk
(print name/title)
Q.
- o Ǥff%f''flS* o ~
•J. 'i;%!ffr'|i-'' >
(e-mail address)
If required by City, proper notarial acknowledgment of execution by contractor must be attached. If a
Corporation. Agreement must be signed by one corporate officer from each of the following two groups.
*Group A.
Chairman,
President, or
Vice-President
*Group B.
Secretary,
Assistant Secretary,
CFO or Assistant Treasurer
Otherwise, the corporation must attach a resolution certified by the secretary or assistant
secretary under corporate seal empowering the officer(s) signing to bind the corporation.
APPROVED AS TO FORM:
RONALD R. BALL, City Attorney
)eputy City Attorney
City Attorney Approved Version #05.06.08
EXHIBIT "A"
SCOPE OF SERVICES
Itemized List of what Contractor will do for City and at what price.
City Attorney Approved Version #05.06.08
ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING | 3-1
Work3* VjT 5 ? -i
SCOPE OF WORK
Our proposed scope of work is consistent with the Fair
Housing Planning Guide prepared by the U.S Department of
Housing and Urban Development (HUD).
Task 1: Evaluation of 2003 Regional Al and Progress
toward Mitigating Impediments Identified
Task 1.1: Review of 2003 Regional Al
Conduct a review of the current Regional Al to identify
conditions and impediments that may no longer be relevant;
and/or may have been partially mitigated; may not have been
adequately addressed; and/or may be of increased concern.
Task 1.2: Review of Other Relevant Documents
Review the housing elements, consolidated plans, action
plans, and CAPERs of all participating jurisdictions to
determine actions and programs as well as accomplishments
with regard to expanding a range of housing choices and
improving equal access to housing.
Specifically, the State Housing Element law has been
amended recently to require jurisdictions to address
constraints to housing for persons with special needs,
including emergency shelters, transitional housing, supportive
housing, single-room occupancy units, and housing for
persons with disabilities:
* SB 520 (Housing for Persons with Disabilities)
» SB 2 (Emergency Shelters)
* AB 2634 (Transitional Housing, Supportive Housing, and
SRO)
We will review the housing elements of all participating
jurisdictions to assess their compliance with these provisions.
Task 1.3: Public and Administrative Policy Survey
We will conduct a Public and Administrative Policy Survey for
participating jurisdictions to assess the potential impediments
to fair housing, including occupancy standards, distance
restrictions for group homes, sensitivity and fair housing
training for staff, multilingual capability of code enforcement
and housing programs staff, accessibility of public facilities
(Section 504 and ADA compliance).
Task 1.4: Review of Fair Housing Services
We will review the scopes of work of the fair housing service
providers in the participating jurisdictions to determine how the
contracted services align with the recommendations of the Al.
We will interview the fair housing service providers (Fair
Housing Council of San Diego, Center for Social Advocacy,
North County Lifeline) to discuss accomplishments in
mitigating the impediments and solicit suggestions regarding
gaps of services and additional needs.
We will also solicit comments from fair housing service
providers regarding the effectiveness of existing fair housing
programs and services and identify where gaps of services
may exist.
Task 1.5: Summary of Assessment
Upon completion of the tasks above, we will prepare a written
summary assessment of the progress in mitigating
impediments, identifying areas of deficiency and suggestions
for further enhancement.
Task 2: Community Outreach
Task 2.1: Fair Housing Survey
We will conduct a fair housing survey of the community at
large. This survey will be written in English and Spanish and
will be distributed at community locations and posted on the
Web sites of the County and participating cities. Working with
the Fair Housing Resources Board (FHRB), we will solicit the
participation of service providers to also post the link to the
survey on their Web sites. Each jurisdiction will be provided a
hard copy and a PDF version of the survey in English and
Spanish for distribution at community locations, to service
providers, and for posting on Web sites. Individual cities are
encouraged to translate the survey into other languages as
necessary, as long as the survey questions and format are
consistent with the one provided so that survey responses can
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be efficiently tabulated. Our budget assumes tabulation and
analysis of up to 2,000 responses to the survey. While this is
not a scientific survey in which the survey respondents are
controlled, it offers another opportunity for residents to voice
their concerns.
Task 2.2: Community Meetings
We will conduct at least four community meetings to solicit
input from the general public. We will work with the FHRB to
select centrally located community facilities to conduct the
community meetings (for east, north, south, and central
County areas). We will work with the FHRB to effectively
advertise these meetings to enhance participation and assist
in advertising for these meetings, including direct mailing to
specific groups and coordinating with fair housing councils.
Participating jurisdictions should be encouraged to make
announcements at public hearings and public service
announcements at local cable access. This scope assumes
the jurisdictions and FHRB would be responsible for any direct
advertising or mailing costs.
Aside from residents, potential groups to target for
participation include:
* Real estate associations/realtors
« Apartment owners and managers associations
« Lenders
• Fair housing service providers
• Supportive service providers (e.g., for seniors, families,
disabled persons, immigrant groups)
* Faith-based organizations
Task 2.3: Consultation with Service Providers and
Housing Professionals
We will hold two meetings with key organizations that
represent special interests to obtain information on fair
housing issues, including such groups as disability advocacy
groups, civil rights commissions, faith-based organizations,
and groups representing low- and moderate-income persons,
among others active in the housing arena including realtors,
apartment owners associations, and lending institutions.
An alternative approach is to call the service providers and
referral agencies to 'test such agencies' understanding of fair
housing services available.
Task 2.4: Present Draft of At to FHRB
We will attend one FHRB meeting to present the draft Al. We
will also be available at the meeting to answer questions about
the draft.
Task 3: Fair Housing Testing
We will be responsible for conducting fair housing testing for
the Regional Al. Our scope includes:
« Conducting a total of 40 countywide familial status audits
(paired test format);
• Working with the FHRB in the selection of sites for testing,
using the criteria set forth in the contract;
• Recruiting and training testers in sufficient numbers to
complete the project;
• Conducting training sessions for testers; and
• Preparing a report of findings and recommendations.
In conducting the paired test, we will proceed with the initial
(round one) tests. All of the 40 sites will be tested in the initial
round. We will then review each completed test report with
tester (debrief) and compare and analyze the results to
determine whether a follow-up test is needed. If the results for
specific sites are unclear, a second round of testing will be
conducted for those sites. When the testing phase is
completed, we will produce a report of findings and make
recommendations.
Methodology: Volunteer testers are recruited, screened, and
trained in 4-hour training sessions. The testers for this study
will be trained by Clara Harris, who has many years of
experience in the fair housing field, including training fair
housing testers, conducting fair housing audits, and testing.
The session includes a practice site visit and/or role playing, a
discussion of the history of fair housing law and the
methodology of testing and reinforcement of the qualities
needed in a tester (i.e., objectivity, reliability and
confidentiality).
Planning the Test: The project supervisor locates apartment
vacancies by reviewing newspaper listings as well as the
various rental guide magazines and by monitoring posted
rental signs. A matched pair of testers, one representative of
the variable being tested and the other as a control, is then
assigned to visit the apartment office. Testers are matched in
relation to age, income, dress, and background for all stages
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ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING | 3-3
of the study. The testers are assigned "profiles" or identities,
complete with marital status, occupation, income, and reason
for moving.
The standard test is arranged as follows: The tester
(representing the variable being tested) makes an
appointment for a specified time, or simply drops in if it is
determined that the office will be open and appointments are
not necessary. The control tester follows within an hour,
making an appointment only if the other tester has made one.
At the Site - Ask and Observe: Each tester asks standard
prearranged questions and is trained with certain responses,
so that the two visits are essentially identical in all ways
except the variable being tested. Each tester is instructed to
inquire about one- or two-bedroom apartments that are within
a certain price range and available within a certain time frame.
In this way, the chance that different information may be
obtained due to a particular request or characteristic of the
tester (for example, a request to be near the pool or on the
first floor) is eliminated. Testers are instructed to closely
follow the assignment so that they each make the same
request.
Testers are trained to ask about and observe a number of
items that are things any renter would need to know such as
the following: Is there an apartment available and when will it
be ready? Is some preparation necessary, such as cleaning
and painting, or is the apartment ready to be occupied? The
tester notes which apartments she or he was shown, or
whether a model was shown. Is the tester offered an
application and invited to place a deposit? What are the rental
terms, amount of security deposit, and credit check fees (costs
that together are often referred to as "move-in costs")? Are
there any moving incentives offered such as rent reductions or
deposit rebates after move-in. What types of leases are
available (e.g., month-to-month, six month, or one year)?
Testers also observe other persons around the complex and
in the office to note the race of tenants, applicants, and
employees, and the presence of children. Testers are asked
to report on how they were greeted, the mechanics of the
interview, whether they were asked about "good credit," or if
there was any discussion of ability to pay.
The items listed above are all important to the comparison
since slight variations in any of the items can make renting an
apartment more attractive to a prospective tenant. For
example, a 1-year lease protects the tenant from rent
increases and provides more stability. Also, it is helpful in
analyzing the test results to know the apparent demographics
of the complex.
Analysis of Each Visit: Immediately upon leaving the testing
site, testers fill out their reports, which consist of a narrative
and a four-page questionnaire. These reports are then
returned to the project supervisor and compared for
differences. The testers, therefore, are unaware of any
difference in results. The comparisons are not revealed to
them at any point. Even in instances where one of the testers
is told that there are no apartments available and/or is treated
discourteously, the inference cannot automatically be made
that discrimination has taken place. In a fair housing
assessment, the important tool is the comparison of the
experience to that of the other tester. Not all complex
managers are professional. There may be cases where both
testers are treated rudely.
If, however, on repeated visits a pattern emerges of different
treatment to the tester (representing the testing variable), the
comparisons afford a powerful piece of evidence that the
rental agent would have difficulty explaining. An example is if
different apartments are shown to the testers, or the ones
shown to the tester (representing the testing variable) are
inferior in some way. Is the control tester shown an apartment
that is freshly painted and ready for occupancy, while the
tester (representing the testing variable) is shown a
comparable apartment in price and size but which needs
painted and cleaned? The comparison needs to be analyzed
carefully to see if a picture emerges that the tester
(representing the testing variable) had been discouraged from
applying.
Then, if such a picture emerges, is this an indication of
discrimination, or was the agent simply having a bad day and
not being thorough and professional with each client who
came through the door that day? When discrimination is
suspected, a pattern needs to be established through
repeated visits in order to rule out such factors as possible
explanations.
Once the comparison of the test reports is done, retests are
scheduled. A new set of testers is assigned to visit those
apartment complexes in which a difference was observed.
In conclusion, the design of an assessment ensures a high
degree of objectivity and eliminates alternative explanations,
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ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING | 3-4
(aside from the variable being tested) for observed differences
in information and treatment.
Task 4: Regional Al Update
Task 4.1: Community Profile
The current Regional Al was prepared in 2003 with 2000
Census data. We do not recommend updating the Census
data with American Community Survey data, which contains
large margins of errors. To the extent feasible, we will update
the Community Profile with current data such as:
* 2008 Department of Finance population and housing
estimates
* 2008 Employment Development Department employment
and wage data
2007 Home Mortgage Disclosure Act (HMDA) data on
lending activities
* Current market data for rental rates, home prices, and
foreclosure activities
SAN DAG projections
* Inventory of licensed community care facilities from State
Department of Social Services
* Comprehensive Housing Affordability Strategy (CHAS)
data and updated income data by block group created by
HUD
» Consolidated plans and general plans (including 2005-
2010 housing elements) for participating jurisdictions
Based on statistics, empirical data, research and consultation,
we will evaluate the following background information:
a) Demographic Profile to include the number and
proportion of persons in the participating jurisdictions by
race/ethnicity, age, disability, and familial status. This
section will use an Index of Dissimilarity to measure
housing segregation among ethnic groups and this will be
evaluated. Much of this data will depend on 2000 Census
and therefore no update is available. However, we will
correlate these demographic characteristics with current
and/or changing patterns of fair housing concerns.
b) Income Profile to include income distribution of residents;
evaluation of income differences and poverty levels
between race and special needs populations; concentration
of low-income population by block groups. Updated
income data by Census block group and CHAS data will be
used.
c) Employment and Transportation Profile to map
locations of major employment centers that potentially offer
jobs to minorities and persons with disabilities at the lower
income levels of the wage scale. The Consultant will also
evaluate the relationship between public transportation, job
centers, and lower income housing locations.
d) Housing Profile to examine the implications of geography,
diverse populations, and income discrepancies in the
participating jurisdictions. Include discussion of the
housing profile including the following variables: household
size and overcrowding; housing type, tenure and vacancy;
age of housing (and related lead-based paint concerns);
ownership and rental housing costs; and housing
affordability. Relationships between these housing
characteristics and fair housing concerns will be included.
e) Mapping of Planning Data will be done using geographic
information system (CIS) to evaluate geographic
relationships among the demographic, income,
employment and transportation, and housing variables to
identify potential impediments to fair housing choice. To
the extent feasible, information will be provided at the
jurisdiction-level and aggregated by San Diego City Council
District and County Supervisor District, as appropriate.
Types of maps to be included, but may vary depending on
data availability and relevancy of specific issues, are:
1 Location of housing for seniors and disabled (e.g., Section
202 and 811 projects)
2. Location of public and assisted housing (e.g., public
housing, HUD-funded projects, and others as information is
available)
3. Location of licensed residential care facilities (e.g., group
homes, elderly residential care facilities, housing for the
mentally ill)
4 Concentrations of Section 8 assistance (if available from
the local housing authorities)
5 Geographic concentrations of families with children (no
change from 2000 Census)
6. Main transit routes in relation to employment centers, lower
income, and special needs populations, and assisted
housing projects
7. Low- and moderate-income areas
8 Areas of racial/ethnic concentration (no change from 2000
Census)
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Task 4.2: Current Fair Housing Profile
We will evaluate the current fair housing profile in San Diego
County, including the following:
a) Assessment of current public and private fair housing
program/activities to identify and describe existing
programs, services, and activities that assist in the
provision of fair housing. This will involve interviewing staff,
fair housing councils, and appropriate local non-profits and
community groups (see results of Task 1.4 and Task 2.3).
b) Identify and describe fair housing practices and procedures
of real estate associations and apartment owners
associations. This will include a description of common
practices of and fair housing issues involving real estate
associations, agents, property managers, and landlords
including advertising and reasonable accommodations and
modifications. Issues such as blockbusting, steering, "all
adult," one-language advertising, inaccessible design,
underwriting, PICO scoring, and unfair lease terms will be
discussed.
c) Contact and interview fair housing service providers in San
Diego County, local nonprofit housing organizations,
housing advocacy groups, and the local HUD office to
obtain information on the nature and extent of fair housing
complaints, violations, or suits against the jurisdictions.
Also included are:
1. Research of the prevalence of fair housing
discrimination suit(s) filed by the Department of
Justice, State Department of Fair Employment and
Housing, and other agencies.
2. Identification of the nature and extent of hate crimes in
all participating jurisdictions.
3. Discussion of other fair housing issues such as the
impact of "NIMBYism" on housing choice.
Task 4.3: Lending and Insurance Practices
In light of the current lending market crisis, the discussions on
lending and insurance practices in the current Regional Al will
be completed updated. Specifically, we will:
a) Evaluate the lending patterns in the County using a variety
of sources, including but not limited to, CRA rating and
documentation available as a result of the HMDA. We will
evaluate the following:
1 Foreclosure activities by jurisdiction and other
characteristics as available
2. Disposition of conventional home purchase, home
improvement, and home refinancing loan applications
by race and income of applicants
3. Disposition of government-backed home purchase and
home improvement loan applications by race and
income of applicants
4. Lending in low- and moderate-income areas
5. Lending in minority concentration areas
6 Top lenders and their performance in lending to
minority and low- and moderate-income applications
and lending in general in minority concentration and
low- and moderate-income areas
b) Conduct research on the literature, data, and legislation
available to discuss the predatory lending issues. This will
also include a discussion of the level of subprime lending in
the County using the HMDA data and HDD's report on
subprime lending. However, no original research will be
conducted to investigate predatory lending due to
complexity of the issues and the general lack of data.
c) Provide a general discussion on insurance practices based
on literature review, interviews, and fair housing survey.
Task 4.4: Public Policies
In this task, we will analyze public policies and regulations for
participating jurisdictions:
a) Design a questionnaire to be sent to all participating
jurisdictions to explore the jurisdictions' efforts and status in
complying with fair housing laws (see Task 1.3).
b) Document each jurisdiction's compliance with the State
Housing Element law. The current housing element cycle
is for July 1, 2005 through June 30, 2010 (see Task 1.2).
c) Evaluate each jurisdiction's general plan, land use element
in relation to the provision of housing choices.
d) Interview participating jurisdictions for standards and
procedures adopted by each jurisdiction in terms of building
codes, health and safety codes, occupancy codes, and
reasonable accommodation procedures and determine
their effect on access to housing.
e) Map and discuss the location of assisted housing
developments to determine if a concentration exists.
Included in the discussion are land use controls and sites
availability relating to potential location of affordable
housing. Housing developers/affordable housing
developers will be interviewed to discuss barriers to
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ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING 3.6
receiving approval on affordable housing projects,
particularly those for the protected classes (see Task
4.1[e]).
Assess the provision of government services to all areas
within the jurisdiction. This will be done by including a
question on the Fair Housing Survey regarding the
equitable provision of government services and, to the
extent feasible (assuming that target area boundaries are
available in electronic or easy-to-use formats for mapping
purposes), the Consultant will map the location of parks
and community facilities, neighborhood revitalization areas,
and redevelopment project areas to identify targeted areas
for improvements. This information will be compared
against the areas of minority and low- and moderate-
-income concentrations (see Task 4.1[e]). —
Task 4.6: Executive Summary
An executive summary of the complete analysis will be
provided.
Task 5: Deliverables
We will prepare the following documents:
* Administrative Staff Review Draft Al -19 reproducible
copies, 10 bound copies, and electronic version of
document in PDF format
- Each participating jurisdiction - one reproducible copy
and electronic version
FHRB members not from participating jurisdictions -
10 bound copies total
9)Discuss any policies causing displacement and regarding
selection of commissions and task forces with the ability to
"influence housing decisions.
h) Review and discuss the Public Housing Agency Plans
(PHAPs) for policies regarding tenant selection, de-
concentrationr-delivery-of-servicesTiTiaintenancerand——
accessibility:" " ""
i) Other public policies and practices may be reviewed and
discussed as they relate to fair housing choice.
Task 4.5: Conclusion and Recommendations
We will identify appropriate plans of action to overcome or
prevent the effects of the identified impediments in the
Regional Al. The San Diego region is comprised of 18 cities
and a large unincorporated county.
* Revise plans of action from the 2005-2010 Al to address
the identified impediments found in the current Al. All the
reevaluated impediments must be addressed so as to
monitor the region's efforts to affirmatively further fair
housing.
» Establish milestones/schedules of performance for actions
to be to taken.
* Establish methods to measure results of the action plan on
an annual basis from 2010 through 2015.
* The fair housing strategic plan should address all
recommendations, either by incorporating
recommendations from the 2005-2010 Al, providing
modified versions of those recommendations, or by
identifying reasons why the specific actions should be
excluded from the 2010-2015 Al.
Public Review Draft Al -19 reproducible copies, 48 bound
copies, and electronic version of document in PDF format
=£ach.participating jurisdiction-—ooe-reproducible^opy,
two bound copies, and electronic version
FHRB members not from participating. ftirisriiflinns -
10 bound copies total
Final Al -19 reproducible copies, 86 bound copies, and
electronic version of document in PDF format
Each participating jurisdiction - one reproducible copy,
four bound copies, and electronic version
FHRB members not from participating jurisdictions -
10 bound copies total
EDAW INC DESIGN, PLANNING AND ENVIRONMENTS WORLDWIDE