AGENDA REPORT
Meeting Date: January 18, 2022
Item Number:
To: Honorable Mayor & City Council
From: Ryan Gohlich, AICP, Community Development Director Chloe Chen, Associate Planner
Subject: AN ORDINANCE OF THE CITY OF BEVERLY HILLS EXTENDING INTERIM ORDINANCE NO. 21-O-2833 AMENDING SECTION 10-2-
303 OF THE MUNICIPAL CODE REGARDING ADJUSTING LOT
LINES THAT ARE BETWEEN JURISDICTIONAL BOUNDARIES, AND
DECLARING THE URGENCY THEREOF
Attachments: 1. Ordinance Extending Interim Ordinance No. 21-O-2833
2. Interim Ordinance No. 21-O-2833
3. Ordinance No. 21-O-2834
RECOMMENDATION
It is recommended that the City Council extend the interim ordinance pertaining to lot line adjustments that would either create or expand a lot that crosses the City boundary for an additional one (1) year period beyond its January 25, 2022 expiration date, while the City studies the issue further and develops a permanent ordinance.
INTRODUCTION
At its January 26, 2021, meeting, the City Council voted to adopt an interim ordinance, Ordinance No. 21-O-2833 (Attachment 2) amending Section 10-2-303 of the Beverly Hills Municipal Code (BHMC) to prohibit a lot line adjustment which would either create or expand a lot that crosses the City boundary. The interim ordinance adopted on January 26, 2021 took effect immediately, and was in effect for an initial 45-day period. At its March 2, 2021 meeting, the City Council subsequently extended the Interim Ordinance for an additional ten (10) month and fifteen (15) day period, which sets an expiration date of January 25, 2022. Attachment 3 contains Ordinance No. 21-O-2834 that extended the interim ordinance.
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Meeting Date: January 18, 2022
DISCUSSION
At the January 26, 2021 City Council Meeting, the City Council approved Interim Ordinance 21- O-2833 amending the lot regulations in the City. The interim ordinance was meant to prohibit lot line adjustments that will create or expand a lot that crosses the boundary of the City. Lots that are created or expanded across the City’s border will negatively impact the public health, safety, and welfare because buildings that do not comply with Beverly Hills codes can be built with Beverly Hills access, utilities, and other services. Furthermore, buildings can be built under another city’s zoning regulations without appropriate setbacks.
The extension of the interim urgency ordinance will allow the City to further study the potential impacts to the public health, safety, and welfare resulting from a parcel under split jurisdiction and develop appropriate regulations regarding if and under what circumstances adjusting a lot to create or expand a lot that crosses the City boundary may be appropriate. Staff anticipates bringing forth a permanent ordinance for consideration in the coming months. Per state law, urgency ordinances may be extended by the City Council by a four-fifths (4/5) vote. At this time, it is recommended that the City Council extend the urgency ordinance for a one-year period.
In addition, staff has been considering how to treat single-site covenants or lot tie covenants that involve lots crossing City boundaries. Staff is currently looking into whether the permanent regulations should also prohibit lot tie covenants that would create a site with split jurisdiction, by either combining a lot in Beverly Hills with a lot in a neighboring city, or by combining a lot in Beverly Hills with a lot with pre-existing split jurisdiction conditions. A lot tie or single-site covenant is a mechanism that effectively combines two adjacent lots by requiring that the lots are treated as one site. The City requires that either a lot tie or single-site covenant is recorded on a site when a development is proposed across the lot line boundaries of two separate lots in order to ensure that adverse results do not occur, such as the lots being sold separately with half a residence on each lot. Prohibiting certain lot tie or single-site covenants may limit the development of lots with pre-existing split jurisdiction conditions, or adjacent lots under split jurisdiction (e.g. a lot in Beverly Hills that would be combined with an adjacent lot in Los Angeles) because construction over lot lines is not permitted. This would also effectively prohibit additional lots with split jurisdiction conditions from being created or expanded through a lot tie or single-site covenant. Staff will provide this information for consideration by the Planning Commission and City Council as staff develops the permanent regulations.
GENERAL PLAN CONSISTENCY
The interim urgency ordinance provisions are consistent with the objectives, principles, and standards of the General Plan. The interim urgency ordinance prevents lot adjustments that will either create or increase the size of parcels that cross the boundary of the City into another city.
Because the City does not have authority over the development of land within the jurisdiction of another city, the portion of a split-jurisdiction lot which is within the jurisdiction of another city would not be subject to the City’s General Plan, and could be developed in a way that is inconsistent with the following goals and policies of the General Plan. Accordingly, the interim urgency ordinance protects against lot adjustments that are inconsistent with these goals and policies.
Land Use Policy LU 2.1 “City Places: Neighborhoods, Districts, and Corridors” calls for the maintenance and enhancement of the character, distribution, built form, scale, and aesthetic qualities of the City’s distinctive residential neighborhoods, business districts, corridors, and open spaces.
Meeting Date: January 18, 2022
Land Use Policy LU 2.3 “Hillside Development” calls for the maintenance of the natural landforms that define the City and requires that development on hillsides and in canyon areas be located, designed, and scaled to respect the natural topography and landscape.
Land Use Policy LU 5.1 “Neighborhood Conservation” calls for the maintenance of the uses, densities, character, amenities, and quality of the City’s residential neighborhoods, recognizing their contribution to the City’s identity, economic value, and quality of life.
Land Use Policy LU 5.7 “Neighborhood Transitions” calls for the regulation of the setback, rear elevation design of buildings, and landscaping of backyards where neighborhoods of differing housing type and density abut to assure smooth transitions in scale, form, and character.
Land Use Goal LU 6 “Single-Family Residential Neighborhoods” calls for the maintenance of the identity, scale, and character of the distinct single-family residential neighborhoods.
ENVIRONMENTAL REVIEW
The draft ordinance has been assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA, Public Resources Code Sections 21000 et seq.), the State CEQA Guidelines (California Code of Regulations, Title 14, Sections 15000 et seq.), and the environmental regulations of the City. The adoption and implementation of the Urgency Ordinance or extension thereof is exempt from the California Environmental Quality Act (CEQA) pursuant to Section 15305 of Title 14 of the California Code of Regulations because the average slope of the City is less than 20 percent and the extension of the Interim Ordinance represents a minor alteration in land use limitations and does not result in any changes in land use or density. In addition, the City Council finds that the adoption and implementation of the Interim Ordinance or extension thereof will not have a significant environmental impact and is exempt from CEQA pursuant to Section 15061(b)(3) of Title 14 of the California Code of Regulations, which states that CEQA applies only to projects which have the potential for causing a significant effect on the environment. This exemption is applicable because the extension of the Interim Ordinance would not result in physical changes to the subject properties and no potential for causing a significant effect on the environment exists. Accordingly, the City Council will consider the staff recommendation to find the Urgency Ordinance exempt from the environmental review requirements of CEQA pursuant to Sections 15305 and 15061(b)(3) of the California Code of Regulations.
FISCAL IMPACT
There is no anticipated fiscal impact to the City.
Ryan Gohlich, AICP
Director of Community Development
Approved By
B0785-0001\2499400v1.doc
Attachment 1
Ordinance Extending Interim Ordinance
No. 21-O-2833
ORDINANCE NO. 22-0-
AN ORDINANCE OF THE CITY OF BEVERLY HILLS
EXTENDING INTERIM ORDINANCE NO. 21-0-2833
AMENDING SECTION 10-2-303 OF THE MUNICIPAL
CODE REGARDING ADJUSTING LOT LINES THAT ARE
BETWEEN JURISDICTIONAL BOUNDARIES, AND
DECLARING THE URGENCY THEREOF
THE CITY COUNCIL Of THE CITY OF BEVERLY HILLS HEREBY ORDAiNS AS FOLLOWS:
Section 1. Legislative Findings.
The City Council ofthe City ofBeverly Hills is concerned about lot line adjustments which create or increase the size of parcels crossing the boundary of the City. Of particular concern is the fact that the City’s regulations permitted the adjustment of lot lines to create or expand parcels located both within the City and another City. The City does not have authority over the development of land within the jurisdiction of another City. Accordingly, when a parcel is located both within the City and another city, a portion of the parcel is subject to the City’s regulations and development standards, and a portion of the parcel is subject to the regulations and development standards ofthat other city. Because the City’s General Plan and zoning and building ordinances would not apply to the portion of the lot which is located in another city’s jurisdiction, a lot line adjustment creating or expanding a lot that crosses the City boundary will not conform to the City’s General Plan or the City’s zoning and building ordinances. This negatively impacts the public health, safety, and welfare because buildings that do not comply with City codes can be built with City access, utilities, and other services and buildings can be built under another city’s zoning regulations without appropriate setbacks. Consequently, the City Council wishes to consider enacting appropriate regulations regarding if and under what circumstances adjusting a -1—
lot line to create or expand a parcel that crosses the City boundary may be appropriate. City staff continues to study the issues related to permanent regulations.
Because the public process of adopting permanent regulations may be lengthy, and to prevent the adjustment of lot lines which will create or expand parcels that cross the boundary of the City in the intervening period, the City Council adopted Ordinance No. 2 1-0-2833, an interim ordinance that took effect immediately on January 26, 2021 (the “Interim Ordinance”). The Interim Ordinance amends Section 10-2-3 03 of Article 3 of Chapter 2 of Title 10 of the Beverly Hills Municipal Code to prohibit a lot line adjustment which would either create or expand a lot that crosses the City boundary. The Interim Ordinance was extended for a period of ten (10) months and fifteen (15) days on March 11, 2021 in accordance with Government Code Section 65858.
Section 2. Authority.
Pursuant to Government Code Section 65858, the City Council may adopt, as an urgency measure, an interim ordinance to protect the public health, safety, and welfare to prohibit uses that may be in conflict with a zoning proposal that the legislative body, planning commission, or the planning department is considering or studying or intends to study within a reasonable time. After public notice, the City Council may extend the interim ordinance first by a period of ten (10) months and fifteen (15) days, and then by an additional one (1) year pursuant to Government Code Section 65858. Notice of the public hearing at which the City Council considered adopting this extension ordinance was duly published on December 24, 2021, in the Beverly Hills Courier, and on December 30, 2021, in the Beverly Hills Weekly and in the Beverly Press. -2-
Section 3. Urgency Findings.
The City Council finds and determines that failing to implement immediate changes to the City’s lot line adjustment regulations would result in an immediate threat to the public health, safety, and general welfare. As described in Section 1, the City’s regulations permit lot line adjustments which create or expand parcels crossing City boundaries, resulting in parcels subject to both the City’s zoning and building regulations and another city’s zoning and building regulations. Because the City’s General Plan and zoning and building ordinances would not apply to the portion of the lot which is located in another city’s jurisdiction, such lot line adjustments will not conform to the City’s General Plan or the City’s zoning and building ordinances.
Accordingly, without appropriate regulations, the continued adjustment of lot lines to create or expand parcels under split jurisdiction will negatively impact the public health, safety, and general welfare. Thus, to preserve the public health, safety, and general welfare, the City Council declares it is necessary that this Ordinance take immediate effect to prevent these harms.
Section 4. CEOA findings.
The City Council hereby finds that the adoption and implementation of the Interim Ordinance or extension thereof is exempt from the California Environmental Quality Act (CEQA) pursuant to Section 15305 of Title 14 of the California Code of Regulations because the average slope of the City is less than 20 percent and the extension of the Interim Ordinance represents a minor alteration in land use limitations and does not result in any changes in land use or density.
In addition, the City Council finds that the adoption and implementation of the Interim Ordinance or extension thereof will not have a significant environmental impact and is exempt from CEQA pursuant to Section 1506 1(b)(3) of Title 14 of the California Code of Regulations, which states that CEQA applies only to projects which have the potential for causing a significant effect on the -3-
environment. This exemption is applicable because the extension ofthe Interim Ordinance would not result in physical changes to the subject properties and no potential for causing a significant effect on the environment exists.
Section 5. Severability.
If any section, subsection, subdivision, sentence, clause, phrase, or portion of this Ordinance or the application thereof to any person or place, is for any reason held to be invalid or unconstitutional by the final decision of any court of competent jurisdiction, the remainder of this Ordinance shall be and remain in full force and effect.
Section 6. Approval and Extension of Ordinance.
This Ordinance, adopted as an urgency measure for the immediate protection of the public safety, health, and general welfare, containing a declaration of the facts constituting the urgency, and passed by a minimum fourfifths (4/5) vote ofthe City Council, shall take effect immediately upon its adoption and shall amend and extend the effect of the Interim Ordinance for a period of one (1) year, as provided in Government Code Section 65858.
Section 7. Publication.
The City Clerk shall certify to the adoption of this Ordinance and shall cause this Ordinance and her certification, together with proof of publication, to be entered in the Book of Ordinances ofthe Council of this City.
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ADOPTED:
EFFECTIVE:
ROBERT WUNDERLICH
Mayor of the City of Beverly Hills
ATTEST:
HUMA ARMED
City Clerk
APPROVED AS TO FORM: APPROVED AS TO CONTENT:
LAURENCE S. WIENER GEORGE CHAVEZ
City Attorney City Manager
1 RY)d GHLICH, AICP
Community Development
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B07$5-0001\2611547v5 .doc
Attachment 2
Interim Ordinance No. 21-O-2833
ORDINANCE NO. 21-0- 2833
AN URGENCY ORDINANCE OF THE CITY OF
BEVERLY HILLS AMENDING SECTION 10-2-
303 OF THE MUNICIPAL CODE REGARDING
ADJUSTING LOT LINES THAT ARE BETWEEN
JURISDICTIONAL BOUNDARIES AND
DECLARING THE URGENCY THEREOF.
THE CITY COUNCIL OF THE CITY OF BEVERLY HILLS HEREBY ORDAINS AS FOLLOWS:
WHEREAS, Section 10-2-805 of the City of Beverly Hills Municipal Code provides for the approval of a lot line adjustment if the adjustment will not deny access to any parcel, will not result in a conflict with any public or private easement, and when the proposed lot configurations meet all standards of the zoning, subdivision, and building ordinance provisions, except that existing, legally nonconforming lots need not meet all standards of the zoning, subdivision, and building ordinance provisions, provided that the adjustment will result in either a decrease or no change in the degree of any existing nonconformity, and will not create a new nonconformity; WHEREAS, California Government Code Section 66412(d) requires the City to approve a lot line adjustment between four or fewer existing adjoining parcels where the land taken from one parcel is added to an adjoining parcel and where a greater number of parcels than originally existed is not thereby created, provided that the resulting parcels conform to the City's General Plan, any applicable specific plan, any applicable coastal plan, and the City's zoning and building ordinances; and
WHEREAS, the City has received an application to adjust a lot line that is coterminous with the City boundary, which if approved, would result in a parcel located both within the City and another city; and
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WHEREAS, there are a number of similarly situated properties that are split by a property line that overlays the City boundary; and
WHEREAS, when a parcel is located both within the City and another city, then a portion of the parcel is subject to the City's regulations and development standards, and a portion of the parcel is subject to the regulations and development standards of that other city; and WHEREAS, the City does not have authority over the development of land within the jurisdiction of another city; and
WHEREAS, a lot line adjustment that results in a lot with a split jurisdiction will not conform to the City's General Plan or the City's zoning and building ordinance because the City's General Plan and zoning and building ordinance will not apply to that portion of the lot which is in the other jurisdiction. This will negatively impact the public health, safety, and welfare because buildings can be built with Beverly Hills access, utilities, and other services that do not comply with Beverly Hills codes, and buildings can be built under another city's zoning regulations without appropriate setbacks; and
WHEREAS, the City Municipal Code does not currently address the adjustment of a lot line that is coterminous with the City boundary resulting in a parcel or parcels located both with the City and another city; and
WHEREAS, the City will study the potential impacts to the public health, safety, and welfare resulting from a parcel under split jurisdiction and develop appropriate regulations regarding if and under what circumstances adjusting a lot line that is coterminous with the City boundary may be appropriate; and
WHEREAS, the City Council finds that if the City does not adopt this Urgency Ordinance, then under existing City regulations, lot lines that are coterminous with the City boundary may be adjusted to create parcels located within the City and another city, and therefore, would create a current threat to the public safety, health and welfare.
Section 1. Authority.
Pursuant to Government Code Section 65858, the City Council may adopt, as an urgency measure, an interim ordinance to protect the public safety, health, and welfare to prohibit uses that may be in conflict with a zoning proposal that the legislative body, planning commission or the planning department is considering or studying or intends to study within a reasonable time.
Section 2. CEQA Findings.
This Ordinance and the Amendment were assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental regulations of the City. The City Council finds that adoption of the Amendment is exempt from CEQA pursuant to Section 15305 of Title 14 of the California Code of Regulations because the average slope of the City is less than 20 percent and the Amendment represents a minor alteration in land use limitations and does not result in any changes in land use or density. In addition, the City Council finds that the adoption of the Amendment will not have a significant environmental impact and is exempt from CEQA pursuant to Section 15061(b)(3) of Title 14 of the California Code of Regulations, which states that CEQA applies only to projects which have the potential for causing a significant effect on the environment. This exemption is applicable because the Amendment would not result in physical changes to the subject properties other than the adjustment of lot lines, and no potential for causing a significant effect on the environment exists.
Section 3. The City Council hereby amends Section 10-2-303 of Article 3 of Chapter 2 of Title 10 of the Beverly Hills Municipal Code to add a new paragraph E and re-lettering existing paragraph E to read as follows, with all other provisions in Section 10-2-303 remaining in effect without amendment:
"E. City Boundary: A lot line shall not be adjusted which would either create or expand a lot that crosses the City boundary.
F. Variances: Whenever the size of the parcel of land to be subdivided, its street and alley frontage, its contour, and its location with reference to surrounding property, are such that the requirements of this section work undue and unusual hardship, and a different size and arrangement would not result in undue detriment to surrounding property or the residents thereof, the planning commission may, in its discretion, approve a different size and arrangement of the lots in the proposed subdivision."
Section 4. Severability.
If any section, subsection, subdivision, sentence, clause, phrase, or portion of this Ordinance or the application thereof to any person or place, is for any reason held to be invalid or unconstitutional by the final decision of any court of competent jurisdiction, the remainder of this Ordinance shall be and remain in hill force and effect.
Section 5. Approval and Extension of Ordinance
This Ordinance, being an Interim Ordinance adopted as an urgency measure for the immediate protection of the public safety, health, and general welfare, containing a declaration of the facts constituting the urgency, and passed by a minimum four-fifths (4/5) vote of the City Council, shall take effect immediately upon its adoption and shall continue in effect for a period of not longer than forty-five (45) days. After notice pursuant to Section 65090 of the California Government Code and public hearing, the City Council may extend the effectiveness of this Interim Ordinance as provided in Government Code Section 65858.
Section 6. Publication.
The City Clerk shall certify to the adoption of this Ordinance and shall cause this Ordinance and his certification, together with proof of publication, to be entered in the Book of Ordinances of the Council of this City.
ADOPTED: January 2021
-ATTEST:
(SEAL)
UUMA AHM^D
.City Clerk
APPROVED AS TO FORM:
LAURENCE S. WIENER
City Attorney
LESTER J. FRIEDMAN
Mayor of the City of Beverly Hills,
California
APPROVED AS TO CONTENT:
GEORGEXHAVEZ
City Manager
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B0785-0001\2496978vl.doc
Attachment 3
Ordinance No. 21-O-2834
ORDINANCE NO. 21-0- 2834
AN ORDINANCE OF THE CITY OF BEVERLY
HILLS EXTENDING INTERIM ORDINANCE
NO. 21-0-2833 AMENDING SECTION 10-2-303
OF THE MUNICIPAL CODE REGARDING
ADJUSTING LOT LINES THAT ARE BETWEEN
JURISDICTIONAL BOUNDARIES AND
DECLARING THE URGENCY THEREOF
THE CITY COUNCIL OF THE CITY OF BEVERLY HILLS HEREBY ORDAINS AS FOLLOWS:
Section 1. Legislative Findings.
The City Council of the City of Beverly Hills is concerned about lot line adjustments which create or increase the size of parcels crossing the boundary of the City. Of particular concern is the fact that the City's regulations permitted the adjustment of lot lines to create or expand parcels located both within the City and another City. The City does not have authority over the development of land within the jurisdiction of another City. Accordingly, when a parcel is located both within the City and another city, a portion of the parcel is subject to the City's regulations and development standards, and a portion of the parcel is subject to the regulations and development standards of that other city. Because the City's General Plan and zoning and building ordinances would not apply to the portion of the lot which is located in another city's jurisdiction, a lot line adjustment creating or expanding a lot that crosses the City boundary will not confomi to the City's General Plan or the City's zoning and building ordinances. This negatively impacts the public health, safety, and welfare because buildings that do not comply with City codes can be built with City access, utilities, and other services and buildings can be built under another city's zoning regulations without appropriate setbacks. Consequently, the City Council wishes to -1-
consider enacting appropriate regulations regarding if and under what circumstances adjusting a lot line to create or expand a parcel that crosses the City boundary may be appropriate.
Because the public process of adopting permanent regulations may be lengthy, and to prevent the adjustment of lot lines which will create or expand parcels that cross the boundary of the City in the intervening period, the City Council adopted Ordinance No. 21-0-2833, an interim ordinance that took effect immediately on January 26, 2021 (the "Interim Ordinance"). The Interim Ordinance amends Section 10-2-303 of Article 3 of Chapter 2 of Title 10 of the Beverly Hills Municipal Code to prohibit a lot line adjustment which would either create or expand a lot that crosses the City boundary.
Section 2. Authority.
Pursuant to Government Code Section 65858, the City Council may adopt, as an urgency measure, an interim ordinance to protect the public health, safety, and welfare to prohibit uses that may be in conflict with a zoning proposal that the legislative body, planning commission, or the planning department is considering or studying or intends to study within a reasonable time. After public notice, the City Council may extend the interim ordinance by a period of ten (10) months and fifteen (15) days, pursuant to Government Code Section 65858. Notice of the public hearing at which the City Council considered adopting this extension ordinance was duly published.
Section 3. Urgency Findings.
The City Council finds and determines that failing to implement immediate changes to the City's lot line adjustment regulations would result in an immediate threat to the public health, safety, and general welfare. As described in Section 1, the City's regulations permit lot line adjustments which create or expand parcels crossing City boundaries, resulting in parcels subject -2-
to both the City's zoning and building regulations and another city's zoning and building regulations. Because the City's General Plan and zoning and building ordinances would not apply to the portion of the lot which is located in another city's jurisdiction, such lot line adjustments will not conform to the City's General Plan or the City's zoning and building ordinances.
Accordingly, without appropriate regulations, the continued adjustment of lot lines to create or expand parcels under split jurisdiction will negatively impact the public health, safety, and general welfare. Thus, to preserve the public health, safety, and general welfare, the City Council declares it is necessary that this Ordinance take immediate effect to prevent these harms.
Section 4. CEOA Findings.
The City Council hereby finds that the adoption and implementation of the Interim Ordinance or extension thereof is exempt from the California Environmental Quality Act (CEQA) pursuant to Section 15305 of Title 14 of the California Code of Regulations because the average slope of the City is less than 20 percent and the extension of the Interim Ordinance represents a minor alteration in land use limitations and does not result in any changes in land use or density.
In addition, the City Council finds that the adoption and implementation of the Interim Ordinance or extension thereof will not have a significant environmental impact and is exempt from CEQA pursuant to Section 15061(b)(3) of Title 14 of the California Code of Regulations, which states that CEQA applies only to projects which have the potential for causing a significant effect on the environment. This exemption is applicable because the extension of the Interim Ordinance would not result in physical changes to the subject properties and no potential for causing a significant effect on the environment exists.
Section 5. Severabilitv.
If any section, subsection, subdivision, sentence, clause, phrase, or portion of this Ordinance or the application thereof to any person or place, is for any reason held to be invalid or unconstitutional by the final decision of any court of competent jurisdiction, the remainder of this Ordinance shall be and remain in full force and effect.
Section 6. Approval and Extension of Ordinance.
This Ordinance, adopted as an urgency measure for the immediate protection of the public safety, health, and general welfare, containing a declaration of the facts constituting the urgency, and passed by a minimum four-fifths (4/5) vote of the City Council, shall take effect immediately upon its adoption and shall amend and extend the effect of the Interim Ordinance for a period of ten (10) months and fifteen (15) days. After notice pursuant to Section 65090 of the California Government Code and public hearing, the City Council may extend the effectiveness of the Interim Ordinance for an additional one year period, as provided in Government Code Section 65858.
Section 7. Publication.
The City Clerk shall certify to the adoption of this Ordinance and shall cause this Ordinance and her certification, together with proof of publication, to be entered in the Book of Ordinances of the Council of this City.
ADOPTED: March 2 ,2021
LESTER J. FRIEDMAN
Mayor of the City of Beverly Hills,
California
City Clerk
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APPROVED AS TO FOBIM:
LAURENCE S. WIENER
City Attorney
APPROVED AS TO CONTENT:
GE0Rer(2lfAVEZ
City Manager
B0785-C001\2499355vl.doc