HomeMy WebLinkAboutItem 1: Ordinance Authorizing Use of Eminent Domain to Acquire Property Near Amazon Creek Headwaters
ECC
UGENE ITY OUNCIL
AIS
GENDA TEM UMMARY
Public Hearing: An Ordinance Authorizing the Institution of Proceedings in Eminent
Domain for the Acquisition by Condemnation of Property for Park and Open Space Land
Near the Amazon Creek Headwaters in South Eugene; and Declaring an Immediate
Effective Date
Meeting Date: May 21, 2007 Agenda Item Number: 1
Department: Public Works Staff Contact: Johnny Medlin
www.eugene-or.gov Contact Telephone Number: [682-4930]
ISSUE STATEMENT
This public hearing is for the City Council to receive testimony in regard to its consideration of an
ordinance authorizing the use of eminent domain on two properties near the Amazon Creek headwaters
in South Eugene. The ordinance is included as Attachment A and includes Exhibit A and B.
A memorandum from the City Attorney describing condemnation procedures and statutory authorization
to acquire property for city parks is included as Attachment B.
Please note: An immediate effective date is requested with this ordinance. An immediate effective
date requires a 2/3 majority or six (6) affirmative votes from the council to enact. Ordinances without
an immediate effective date do not take effect for 30 days.
BACKGROUND
The City Council on April 18, 2007, instructed staff to prepare and take to Public Hearing an ordinance
authorizing the use of eminent domain on two parcels in South Eugene. These parcels have been the topic
of previous discussion under the names of Green property or Green Valley Glen Planned Unit
Development (PUD), and the Beverly property or West Creek PUD, South Park PUD, or Deerbrook PUD.
Current acquisition status on both of these properties is that past purchase offers for a part or all of these
properties have been made and declined. Staff based acquisition of these properties on making purchase
offers at or near current appraised raw land value. The property owner’s view has been that in order to
persuade them to sell, the City would need to pay significantly higher than the currently appraised value
to compensate for the speculative developable value inherent in the properties.
It has been the staff opinion that both of these parcels have the potential for some level of development.
Since the specific level of development possible on these parcels (low or high) is unknown and remains
in dispute, so does any value based on development potential. The recent PUD applications involving
these properties have not been successful. While development may be difficult, the property owners
have indicated they believe they will eventually be able to sufficiently meet PUD criteria, allowing them
a significant level of development.
L:\CMO\2007 Council Agendas\M070521\S0705211.DOC
The specific level of development allowable on these properties is in dispute and the value of these
properties is dependant on what level of development is ultimately allowable. Appraisals have not yet
been performed. Consequently, it is not possible to identify the cost to the City for acquiring these
parcels. Depending on the extent to which the properties are developable, the total fair market value of
these properties likely falls somewhere between $1 million and $14 million. If the council would like to
discuss this valuation issue, doing so in an executive session would be recommended.
A memo from the Planning and Development Department providing information regarding these
properties’ current status of zoning and land use is included as Attachment C. A memo from the Parks
and Open Space Division providing information regarding the “park values” represented by these
properties is included as Attachment D.
RELATED CITY POLICIES
The Parks, Recreation and Open Space (PROS) Comprehensive Plan was adopted by the City
?
Council on February 13, 2006.
The PROS Project and Priority Plan was adopted by the City Council on May 22, 2006.
?
A Parks and Open Space Bond Measure was passed by Eugene voters on November 7, 2006.
?
COUNCIL OPTIONS
a. Take action as scheduled at the June 25 City Council Meeting.
b.Take no action. Allow negotiations to continue while specific property issues are resolved.
c.Direct the City Manager to schedule a work or executive session for additional discussion.
d.Direct staff to provide additional information as specified.
CITY MANAGER’S RECOMMENDATION
None; this is a public hearing only.
SUGGESTED MOTION
None; this is a public hearing only.
ATTACHMENTS
A.Proposed Ordinance (includes Exhibit A and B)
B.Memo dated May 9, 2007, from the City Attorney titled: An Overview of Condemnation Procedures
and Statutory Authorization to Acquire Property for City Parks.
C.Memo dated May 3, 2007, from Planning and Development Department regarding the zoning,
history of land use applications, and conditions of the Green and Beverly properties.
D.Memo dated May 4, 2007, from the Parks and Open Space Division providing information regarding
the “park values” represented by these properties
E.Vicinity map showing location of Deerbrook PUD (Beverly) and Green Valley Glen PUD (Green)
FOR MORE INFORMATION
Staff Contact: Johnny Medlin
Telephone: 682-4930
Staff E-Mail: johnny.r.medlin@ci.eugene.or.us
L:\CMO\2007 Council Agendas\M070521\S0705211.DOC
ATTACHMENT A
ORDINANCE NO. ___________
AN ORDINANCE AUTHORIZING THE INSTITUTION OF
PROCEEDINGS IN EMINENT DOMAIN FOR THE
ACQUISITION BY CONDEMNATION OF PROPERTY
FOR PARK AND OPEN SPACE LAND NEAR THE
AMAZON CREEK HEADWATERS IN SOUTH EUGENE;
AND DECLARING AN IMMEDIATE EFFECTIVE DATE.
The City Council of the City of Eugene finds that:
A.
The City Council has authority under provisions of the City Charter and
applicable state law to institute proceedings in eminent domain for the acquisition by
condemnation of private property within and without its corporate limits for the public purpose
of public parks, preservation of land for open space, and expansion of the Ridgeline Trail system.
B.
Acquisition of land in the south Eugene area for parks, preservation of open space
and expansion of the Ridgeline Trail system has long been a priority of the City and the affected
neighborhood organization.
C.
The importance of preservation of land for parks and open space has also been
reflected in the passage by the electors of the City of Parks and Open Space bonds in 1998 and
2006.
D.
The policies and goals of the City and the directive of the electors in approving
the 1998 and 2006 Parks and Open Space bonds can best be met by acquisition of the 26 acre
parcel of real property located south of West Amazon Drive’s terminus and the 39 acre parcel of
real property located between Dillard Road and Nectar Way, which are more particularly
described on Exhibits A and B hereto.
E.
The public good realized from the acquisition far outweighs any damage which
the property owners might sustain, particularly in light of the Citys obligation to provide just
=
compensation to the affected property owners.
Now, therefore,
THE CITY OF EUGENE DOES ORDAIN AS FOLLOWS:
Section 1.
Based upon the above findings, which are incorporated herein and adopted,
the City Council of the City of Eugene does hereby find, declare, and determine it necessary to
acquire certain ownership interests to the parcels of real property located south of West Amazon
Drive’s terminus and between Dillard Road and Nectar Way, and more particularly described on
Ordinance - 1
Exhibits A and B attached hereto and incorporated herein by reference in order to acquire land
necessary for parks, preservation of open space, and expansion of the Ridgeline Trail system.
Section 2.
The City Council does hereby direct that the City Manager or the Managers
=
designee shall undertake negotiations with affected property owners to acquire the described
property interests. No less than 40 days prior to filing any action for condemnation of those
property interests described in Section 1, the City Manager or designee shall make a written offer
or offers to pay the owners of the property or persons having an interest therein a stated amount
of compensation for the property interests and for any compensable damages to the remaining
property, if any. If the written offer is not accepted within the time specified in the offer, the
City Manager or designee shall institute proceedings in eminent domain for the condemnation of
the real property interests described in Section 1.
Section 3.
The City Council does hereby declare that the acquisition of the fee title to the
real property described on Exhibits A and B hereto is for a public purpose, is necessary for the
public welfare, is the most compatible with the greatest public good and the least private injury,
and is authorized under the laws of the State of Oregon and the Charter, Ordinances and policies
of the City of Eugene.
Section 4.
The City Council further declares that the real property interests described in
Section 1 shall be used by the City of Eugene for public purposes at the earliest possible date
and, in any event, no later than ten years from the date this Ordinance is adopted by the City
Council and approved by the Mayor.
Section 5.
In order to serve the important public purpose of securing park land in a
timely manner, it is necessary for this ordinance to have immediate effect. This Ordinance shall
become effective upon its passage by the City Council and approval by the Mayor, retention by
the Mayor for more than ten days, or readoption over a Mayoral veto by two-thirds of all
members of the City Council.
Passed by the City Council this Approved by the Mayor this
____ day of ___________, 2007 ____ day of _________, 2007
_______________________________ ________________________________
City Recorder Mayor
Ordinance - 2
ATTACHMENT B
CITY OF EUGENE
INTER-DEPARTMENTAL MEMORANDUM
CITY ATTORNEY – CIVIL DEPARTMENT
To: Mayor and City Council Date: May 11, 2007
Subject: Overview of Condemnation Procedures
Statutory Authorization to Acquire Property for City Parks
and
Below is a summary of the Oregon condemnation process and the statutory authority for
acquiring property specifically for city parks.
Basic Steps in a Condemnation Action
? Identify property needed for public project
? Survey property to obtain legal description of property
? Perform title search to identify all interests in property
? Perform environmental testing on property
? Adopt ordinance authorizing condemnation and describing need and purpose
? Appraise the property
? Appraisal review
? Negotiate with the property owner
? Make written offer to property owner and provide appraisal
? File condemnation action
? Quick take (optional)
? Trial
? Just compensation award
? Provide relocation assistance
The Power of Eminent Domain
The power of eminent domain is the power inherent in a sovereign state to take property
within its jurisdiction for a public use or benefit. The state has delegated the power of eminent
domain to different entities including local governments and urban renewal districts.
Governments exercise the power of eminent domain through condemnation proceedings.
Article I, section 18, of the Oregon Constitution requires “just compensation” for the taking of
private property for public use. ORS chapter 35 provides the procedures for condemnation
actions and the process for determining just compensation.
Mayor and City Council May 11, 2007 Page 2
Survey and Testing
The condemner may conduct surveys or other testing of the property prior to filing a
condemnation action to determine the appropriateness of the property for the project.
ORS 35.220. The land owner must receive notice and must consent to the entry upon the
property, unless the condemner receives a court order allowing the entry after consent is refused.
ORS 35.220.
Resolution or Ordinance
Prior to initiating a condemnation action, the condemner must issue a resolution or
ordinance declaring the necessity of the property for a project which the condemner has the
authority to carry out. ORS 35.235.
Appraisal
Prior to submitting a written offer to the property owner, the condemner must have the
property appraised, unless it determines that just compensation is less than $20,000.
ORS 35.346(2). The condemner must give the property owner 15 days notice prior to any
appraisal inspection. ORS 35.346(3).
Negotiations
The condemner must attempt to agree with the property owner on the appropriate amount
of compensation prior to filing a condemnation proceeding. ORS 35.235(1).
Written Offer
At least 40 days before filing a condemnation complaint, the condemner must make a
written offer to the property owner to purchase the property, or an interest in the property
required for the project. ORS 35.346(1). The written offer must be accompanied by the written
appraisal the condemner is relying on in making the offer, unless the value is less than $20,000.
ORS 35.346(2).
Action
If the condemner and property owner cannot agree, then the condemner may file a
condemnation action in circuit court. ORS 35.245(1). If the amount offered by the condemner is
$20,000 or less, then the property owner may elect to have the compensation value determined
by court-sponsored binding arbitration. ORS 35.346(6). If the value offered by the condemner
is between $20,000 and $50,000, then the property owner may elect to have compensation
determined by court-sponsored non-binding arbitration. ORS 35.346(6). Most of the time,
property owners choose to have the amount of just compensation determined by a jury.
Mayor and City Council May 11, 2007 Page 3
Immediate Possession
If a condemner believes possession of the property is necessary prior to the completion of
the condemnation proceedings, it may give notice to the property owner of its intent to take
immediate possession. ORS 35.352(1). If the owner does not object within 10 days of service of
the notice of immediate possession, the condemner may deposit the amount it alleges as just
compensation with the court and obtain an order granting it possession of the property.
ORS 35.352(3). If the owner files a timely objection, the court will hold a hearing on the
owner’s objections. ORS 35.352(5). The only objections allowed at this stage of the proceeding
are (1) whether the condemnation is legal and (2) whether the condemner has acted in bad faith,
engaged in fraud, or engaged in an abuse of discretion. ORS 35.352(4). If immediate possession
is granted, the property owner may withdraw the funds from the court without waiving any
arguments regarding valuation. ORS 35.285.
Attorney Fees
The property owner can recover attorney fees and reasonable expenses (e.g., expert
witnesses) if the amount of the just compensation awarded at trial exceeds the initial offer made
by the condemner. ORS 35.346(7), as modified by Measure 39. The property owner is also
entitled to attorney fees and reasonable expenses if the condemner abandons the condemnation
action or if the court finds that the first written offer was not a good faith offer based on what the
condemner reasonably believed just compensation to be. ORS 35.335(1); ORS 35.346(7).
Appeal
Either party may appeal, but an appeal will not prevent the condemner from taking
possession of the property. ORS 35.355.
Repurchase Rights
Under certain circumstances, a property owner may have a right to repurchase the
property from the condemner if the condemner fails to use the property for the public use for
which it was condemned. ORS 35.385.
Relocation Assistance
Relocation assistance is governed by ORS 35.500 - .530 which incorporates certain
requirements of federal law in 42 USC §§ 4651-4652. If the project is receiving federal financial
assistance, federal law controls the provision of relocation assistance. ORS 35.530. When a
person or business is displaced through condemnation, the condemner must provide certain
relocation assistance and relocation payments to the displaced person or business. ORS 35.510.
Unless an emergency exists, a person or business cannot be required to move from the
condemned property without first receiving notice at least 90 days prior to the date by which the
move is required. ORS 35.505(2). A requirement to move must also be preceded by notice of
Mayor and City Council May 11, 2007 Page 4
the costs and allowances to which the person may be entitled. ORS 35.505(2). In cases of urban
renewal, governments shall make reasonable efforts to those displaced by the project to relocate
those persons within the urban renewal area. ORS 35.505(1).
Authority to Acquire Property for City Parks
Oregon statutes provide specific authority for cities with populations over 5,000 to
acquire property for parks.
When city authorities pass an ordinance to do so, cities may acquire through the exercise
of their eminent domain powers property within or outside city boundaries for public parks.
ORS 226.320(1).
Cities may acquire more property than they currently need for park lands. ORS 226.330.
When it is determined that property in excess of that needed for parks has been acquired, the
excess property may be sold with such restrictions as are needed to assure protection of the
public parks, their environs, and “preservation of the view and appearance, light, air, health or
usefulness” of the park property. ORS 226.350.
The condemnation procedures applicable to acquisition of park property are the same
procedures used for condemnations in general. ORS 226.380.
HARRANG LONG GARY RUDNICK P.C. –
CITY ATTORNEYS
/s/ Jeffery J. Matthews
Jeffery J. Matthews
JJM:kdp
ATTACHMENT C
Planning & Development
Planning
City of Eugene
th
99 West 10 Avenue
M
Eugene, Oregon 97401
EMORANDUM
(541) 682-5377
(541) 682-5572 FAX
www.eugene-or.gov
Date:
May 3, 2007
To:
Johnny Medlin, Parks and Open Space Division Manager
From:
Alissa Hansen, Senior Planner Eugene Planning Division
Subject:
Green Property (Tax lot 101 of Assessor’s Map 18-03-20-00)
Beverly Property (Tax lots 101, 200, 300, and 302 of Assessor’s Map 18-03-20-21)
This memorandum provides responses to your questions regarding the zoning and history of these
properties.
1. What is the current zoning of these properties? Are they included in our buildable lands
inventory?
Both properties are zoned R-1 Low Density Residential with /PD Planned Unit Development and /WR
Water Resources Conservation overlays. Both properties are designated for low density residential use in
the Metro Plan and are included in the documented supply of “buildable land” that is available for
residential development as inventoried in the acknowledged 1999 Residential Lands Study.
Both proprieties were designated low density residential in the Eugene-Springfield Metropolitan Area
1990 General Plan (1972). In 1978 the Green property was annexed into the City of Eugene and was
concurrently rezoned from RA Outer Residential District and AGT Agricultural Grazing and Timber-
Raising District to R-1/PD (City file AZ 77-7). The Beverly property was annexed to the City of Eugene
in 1979 with a concurrent rezoning from AGT Agricultural Grazing and Timber-Raising District to R-
1/PD (City file AZ 79-8). The /WR Water Resources Conservation overlay was applied to both
properties on January 1, 2006, due to the presence of Goal 5 inventoried streams (City file Z 05-8).
2. What is the history of land use applications on these properties?
The Green property was granted tentative planned unit development (PUD) approval in 1979, at which
time it was part of a larger tax lot and under different ownership. The approval expired before final
approval was obtained. In 2005, Joe Green submitted a tentative PUD to create a 113-lot single-family
residential subdivision with a private street system and common open space areas on 40 acres. This
proposal, known as Green Valley Glen PUD (City File PDT 05-6), was denied by the Eugene Hearings
Official on the basis of a procedural issue, on lack of sufficient geotechnical evidence and on the lack of
sufficient evidence regarding emergency response. The applicant appealed the Hearings Official’s
decision to the Planning Commission in February 2007, who voted to reverse the Hearings Official’s
findings regarding the procedural and the emergency response issues. The Planning Commission voted to
uphold the Hearings Official’s findings regarding the lack of sufficient geotechnical evidence, concluding
1
that soil borings were necessary to determine the feasibility of the proposed development. Prior to the
signing of a final order on the denial by the Planning Commission, the applicant withdrew the application.
Since then, the applicant has obtained the necessary erosion and NPDES permits to enter the property to
conduct further soil tests.
Three separate PUD applications have been submitted for the Beverly property. The first, known as West
Creek PUD (City file PD 98-12), was a request for 21 residential lots, and only applied to Tax Lot 300 of
the subject property. The application was withdrawn the day of the public hearing, and did not receive a
favorable staff recommendation. The applicant then submitted property line adjustments (City files LA
99-46 and 99-47) in conjunction with the City’s acquisition of a portion (approximately 13 acres) of Tax
Lot 101 of the subject property.
South Park PUD (PD 00-2) was a proposal for tentative planned unit development of a 57-lot single-
family residential subdivision. The Eugene Hearings Official denied this application due to lack of
compliance with several tentative PUD criteria, including compliance with the South Hills Study, tree
preservation and natural feature protection. On appeal, the Planning Commission upheld the Hearings
Official’s denial of the application.
The most recent PUD application for the Beverly property, known as Deerbrook PUD (City files PDT 06-
2) was a proposal for 91 dwellings on 26.5 acres. Following the release of the staff report recommending
denial on the basis of a number of tentative PUD criteria, including compliance with the South Hills
Study, tree preservation and natural feature protection, and prior to the public hearing before the Hearings
Official, this application was withdrawn by the applicant.
3. Do the geological conditions on these sites render the properties un-buildable?
No. Concerns regarding geologic conditions were a prominent issue in the Green Valley Glen PUD.
While it was determined that this particular development application did not satisfy the geotechnical
standards, this does not preclude the property owner from submitting a proposal with new evidence that
meets these standards, nor do such concerns render this property un-buildable. The same is true for the
Beverly property. It is important to stress that none of the information available on either property, in and
of themselves, renders these sites un-buildable. In the context of the South Hills Study and the Eugene
Code tentative PUD approval criteria, and understanding that the subject properties are designated and
zoned for low-density residential development, an appropriate level of residential development is still
possible on these properties.
4. Are there other site conditions or constraints that would preclude development of these
properties?
As with most South Hills PUD’s, there are a number of constraints and assets of a given site that need to
be addressed as part of the development application process. The challenge is to create a project which
appropriately balances these various interests. Such factors as natural resources, topography,
circulation/access, infrastructure and many others all need to be addressed. While these sites may have
certain challenges in achieving this appropriate balance, there are no circumstances which fundamentally
prevent these sites from being developed for residential use.
2
ATTACHMENT D
Public Works
Parks and Open Space Division
City of Eugene
1820 Roosevelt Boulevard
M
Eugene, Oregon 97402
EMORANDUM
(541) 682-4800
(541) 682-4882 FAX
www.eugene-or.gov/parks
Date: May 4, 2007
To: Johnny, Medlin, Parks and Open Space Division Director
From: Carolyn Weiss, Parks and Open Space Planning Manager
Subject: Ridgeline Park System: Assessment of Potential Property Acquisitions
City Council is considering using eminent domain to acquire two properties located along the
headwaters of Amazon Creek. This memo is written to provide information from a “parks” perspective
on the value of these two properties.
The Beverly property consists of approximately 26 acres located south of Martin Street, between City
owned parkland and right of way for West Amazon Drive. The property consists of a stream corridor,
wetlands, and a fir forest. The Green property consists of approximately 40 acres along Dillard Road
and south of existing Ridgeline Parkland. The property consists of steep terrain, headwater streams,
wetlands, and a fir forest.
Acquisition of these sites would be beneficial as natural areas for the values of water quality and
wildlife habitat protection. Because Ridgeline Trail connectivity is already provided in this area,
recreational trails values would not be significantly increased as a result of the acquisitions.
Policy Direction
The Parks, Recreation and Open Space Comprehensive Plan, Strategy I-25 on pg. 54, identifies
willing sellers as the preferred acquisition approach.
“I-25 Identify and pursue opportunities with willing sellers as the preferred approach when
evaluating parkland and natural open space acquisition options. Consider willingness of seller as a
key criterion when prioritizing acquisition opportunities.”
Funding
The Parks, Recreation and Open Space Project and Priority Plan calls for acquiring 50 additional
acres of Amazon Creek Headwaters as a Priority 1 project.
It assumed that property could be obtained at raw land values. The funding plan estimated an
acquisition cost of $765,000 in 2004 with approximately 25% of the total coming from external
funding partners (grants).
It should be noted that leveraging the City’s funding for the acquisition of these properties may not be
possible under an eminent domain scenario or if purchase offers exceed appraised value. The
following chart identifies external funding sources typically utilized for natural area acquisition and
limitations on the use of their funding.
Eligible to Apply for
Funding for Beverly Eligible with Use of Eligible if purchase price
GRANT PROGRAM and Green Properties Eminent Domain exceeds appraised value
YES NO NO
USDF, Forest Legacy Program
YES NO NO
USFS, North American Wetlands
Conservation Act
YES YES NO
Oregon State Parks, Local
Government Grant Program
YES NO NO
Oregon Watershed Enhancement
Board
Summary
The Beverly and Green properties represent an opportunity to obtain land that is adjacent to existing
Ridgeline Parkland and has high natural resource values with respect to water quality and wildlife
habitat. While these properties will not enhance the recreation values of the Ridgeline Trail by any
substantial measure, both properties would make good additions to the City’s park system as natural
areas if acquired at or near to a raw land value.
Page 2
ATTACHMENT "E"
VICINITY MAP
.,' .
~~~ lifif~ ~~~~~,->>, )
99~b{~ ~ lliilli1 ~i~JJ\ y 1 at;t:t,75~JI~'-:' y
~ ~ I IH~~ ~;: ~(.:" ~~J~ 7 I, .....u ~:::~
N rr -- t ~ _ ~ .:' , I r-r] r-l g - 1 11.::::::::::::::::::::::::::.:.::..
~ F- ~ N.: ! t.L ~ ~ '.. ~. :.:....:.:.:.:.:.:.:.:.:.:.:.:.:.:.;.:.:.:..
3 ~ m=\ \t j} \ 'fjjfWiAF8
~ .l.. ~I ~ \ ~-::: Q- q:: ~ r1i#"'::'DfJ-'j~, ~ ,'~ y ~~~nH:a
- ~.hJSB r< r-- = Jj.::::~ .~ ~ ~'" &.t ~~~o /Lv"':::'~:":::'::::::,::::":"::,~,:,,:,,,,:::,,:::,,':.:..r;:;.
: tj~J 7T e:1~t w rt 'i~@:n:im!M~~m@@j@!
~'I~~. ~I~I~Q ~.,::::::::g::::Eil:~:@:~Hi~ii:~:!:::::::~.':".
~~~<- ~ ,.~~~ ~ ~REENVAli / IjfJ.:~:ll:iii[:f:::~:::if:~:.:...
~;.: DEE '{ ~ A. I.GLEN PUO ~ 'J :::~::~:i::::::::::::::::::i:~~:::::::..
~ .,::~di::i@~illl~llllllil"I'I'I!I'llllliiiil:l.lii:Bi11;111111~lllltl'lllll~ ~ ~ I J .
. .:.::::::~~~~Ij~j~j~j~j~j~j~j~~j~j~j~j~j~j~tj~j~j1~j~j~j~j~j~j~j~rj~j~j~j~j~j~j~j~j~j~j~j~j~j~j~j~j~fjfj~j~j~j~lj~tjlfj~j~j~rtj~j~ JIt~ttj~j~j~j~j. :tj~jt~j~j~jtt~j~jf~j~j} ==
,.................................. .......... ..... ~ I 1 '~ ,.
. . .~.:::::..:::::::::::::::::::::::::: .::::::: ......: :~ ~..., ~ "\J I \
:::~~::~n:m!!i!::i::i!;!l::!illlill:l(:i::::i:::i:~::iif.;;:::~i:if. ~ . I ~ ~ \
.jl ..~.".)l)~ -I I ~
ri::~:i::::i:~:i:::::i::';.l DENOTES CITY OWNED LAND
....................