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<br />agency as listed on the license, on each side of the <br />vehicle and on the trunk or rear of the vehicle. <br /> <br />2. The display of the name prescribed in this rule <br />shall be in letters and figures in sharp contrast to the <br />background, and be of such size, shape and color as to <br />be readily legible during both daylight and night time <br />hours from a distance of 50 feet while the vehicle is not <br />in motion, and such display shall be kept and maintained <br />in such a manner as to remain so legible. <br /> <br />3. within 30 days after the effective date of this <br />rule, all existing detective or security agencies which <br />use vehicles equipped with either a spotlight or lightbar <br />shall identify the vehicles as required by this rule. <br /> <br />Public notice of the proposed repeal of the Detective and <br />Security Agency Administrative Rules adopted on December 23, 1985, <br />including subsequent amendments, and the adoption of this Detective <br />or Security Agency Administrative Rule R-3.285 was given by <br />publication thereof in the Register Guard, a newspaper of general <br />circulation within the city on April 5 and April 9, 1990, with an <br />opportunity for comment thereon provided. <br /> <br />Fourteen written comments were received in response thereto. <br />Of those comments, one expressed support for the proposed Rules in <br />their entirety and the other thirteen contained objections to or <br />comments on: (1) the increase in license and certification fees; <br />(2) the lack of distinction between investigative agencies and <br />security agencies; (3) the requirement to name the City as an <br />additional insured on required insurance policies; and (4) a <br />request that the City implement stricter requirements for the <br />criminal background checks now being conducted. <br /> <br />In response to these comments, I specifically find: <br /> <br />1. The fee increases were proposed in an effort to meet the <br />Council's goal of a 100% cost recovery for business licenses, and <br />were based on a formula developed during the City's user fee study <br />in 1988. It presently costs the City $145 per agent to review and <br />monitor certifications. The proposed application fee of $25 and <br />certification fee of $75 for an unarmed agent would therefore <br />recover only 69% of the city's cost. However, given the concerns <br />expressed that the increased fee for this particular category would <br />limit the number of individuals willing or able to apply for such <br />employment, I have reduced the certification fee for an unarmed <br />agent from $75 to $50, with the application fee remaining the same. <br />Armed agent application and certification fees will be adopted as <br />proposed, as will the agency application and license fees, <br />resulting in an overall program cost recovery of approximately 78%. <br />In addition, the City Council will be asked to approve amendments <br />to Chapter 3 of the Code to change the certification terms from the <br />current five years for unarmed agents and two years for armed <br /> <br />Administrative Rule R-3.285 - 8 <br />