Concord City Council
June 24, 2024

1 COUNCILMEMBERS
Edi E. Birsan, Mayor
Carlyn S. Obringer, Vice Mayor
Dominic D. Aliano
Laura M. Hoffmeister
Laura M. Nakamura
Civic Center
1950 Parkside Drive
Concord, CA 94519
www.cityofconcord.org
Special Meeting of the
Concord City Council
Monday,
June 24, 2024
6:30 p.m. - Open Session Council Chamber
1950 Parkside Drive
and/or Various
telephonic/electronic
locations
*IMPORTANT NOTICE ABOUT PUBLIC COMMENTS AND MEETING PARTICIPATION* Members of the public are invited to attend and participate at: Council Chamber, 1950 Parkside Drive, Concord, CA.

Please note the following change to the City’s public comment procedures: Unless a Councilmember is participating in the meeting remotely pursuant to AB 2449, remote public comment will not be accepted. Public comment may be provided in-person or via email, as set forth below. Members of the public desiring to provide comments as a part of the meeting are encouraged to either submit written comments by 3:00 p.m. prior to the meeting or to attend the meeting in person.

Under California law, public comments at special meetings are limited to subjects on the agenda only.

HOW TO PARTICIPATE
The public is invited to participate in the City Council meeting using any of the following methods:

1. IN PERSON:
a.Members of the public can provide in-person comments in the Council Chamber.

Members of the public are encouraged, but not required, to fill out a speaker card. The Council Chamber will have seating available for members of the public to attend in person up to full seating capacity.
2 2. REMOTE: Remote public comment will not be accepted, except when a Councilmember participates remotely pursuant to AB 2449. At the time of the posting of this agenda, none of the Councilmembers have notified the City Clerk’s Office that they intend to participate remotely pursuant to AB 2449, and therefore no remote public comment will be accepted at the meeting. If, after publication of this agenda and before the meeting begins, any councilmember determines that they will need to participate remotely due to just cause or emergency circumstances under AB 2449, their remote participation will be announced at the outset of the meeting in connection with the Roll Call item. If a Councilmember participates in the meeting remotely pursuant to AB 2449, the public may participate and provide public comment remotely, as follows:
a. Zoom:
https://cityofconcord.zoom.us/j/89698878655?pwd=xKsRCawHwTv5rcEgcaxEX1v- PNJu0A.tijW5zPYzcNkOzEm or Zoom Webinar ID: 896 9887 8655 and Passcode:
064418
b.Zoom Phone Numbers. Dial Toll Free: (669) 900-6833 or (346) 348-7799 or (253) 215- 8782.
c.During the meeting, each period for public comment will be announced, and participants may use the “Raise Hand” feature on Zoom to request to speak. If calling in via Zoom use *9 to raise and lower your hand. The meeting host will call on you, by name, and promote you to panelist in the webinar so you can be seen via your camera. Please enable your microphone when it is your turn to speak. In order to ensure the orderly administration of the meeting using this method, providing your name is encouraged, but is not required. (If you need instructions on how to use this feature, please contact the City Clerk by 3:00 p.m. of the meeting date at [email protected]).

3. EMAIL:
a.Public comments can also be submitted via email to [email protected]. Please note that emailed comments will not be read aloud by staff. Any public comments received up until 3:00 p.m. of the meeting date will be:

1. distributed to the Council before the meeting,

2. posted online for public inspection at
https://stream.ci.concord.ca.us/OnBaseAgendaOnline/Meetings/Search, and

3. inserted into the meeting record.
b.As emails containing public meeting comments are part of the official record, note that personal contact information may be published if it is included with your email.

4. TO WATCH OR LISTEN ONLY:
a.Watch on TV on Comcast Channel 28, Astound/Wave Channels 29 and 1026, and AT&T U-verse Channel 99
b.Watch the TV broadcast through the City’s website by following THIS LINK c.Watch Live Streaming of the meeting by following THIS LINK d.Join the Zoom webinar by following THIS LINK
3 OPEN SESSION

1. OPENING
Roll Call

2. CITY COUNCIL CONSIDERATION ITEM
The public is entitled to address the City Council on items appearing on the agenda before or during the City Council’s consideration of that item. Each speaker will be limited to approximately three minutes. Please see “How to Participate” above.
a. Considering – adoption of a Resolution pursuant to the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the Internal Revenue Code of 1986 approving the issuance of the California Municipal Finance Authority multifamily housing revenue bonds in an aggregate principal amount not to exceed $90,000,000 for the purpose of the acquisition, construction, improvement, and equipping of a project titled SB 35 Amendment Streamlined Approval for The Ashbury at 1650 Ashbury Drive (PL23150); APN 126-132-005, also known as The Ashbury, an entitled 183-unit affordable multifamily rental housing project with a site location of 1650 Ashbury Drive, Concord, California and certain other matters relating thereto, and make the CEQA determinations. Report by Sophia Huckabay, Housing Manager.

CEQA: Not a project/exempt pursuant to CEQA Guidelines Sections 15060(c)(2), 15061(b)(3), 15378 and/or Public Resources Code Section 21065.

3. ADJOURNMENT
Next Meeting: Regular Meeting
Date: 6/25/2024 6:30 PM

NOTICE TO THE PUBLIC
There is a 90-day limit for the filing of a challenge in the Superior Court to certain City administrative decisions and orders which require a hearing by law, the receipt of evidence, and the exercise of discretion. The 90-day limit begins on the date the decision is final (Code of Civil Procedure §1094.6). Further, if you challenge an action taken by the City Council in court, you may be limited by California law to raising only those issues you or someone else raised in the hearing or in a written correspondence delivered to the City Council prior to or at the hearing.

In accordance with the Americans with Disabilities Act and California Law, it is the policy of the City of Concord to offer its public programs, services and meetings in a manner that is readily accessible to everyone, including those with disabilities. If you are disabled and require a copy 4 of a public hearing notice, or an agenda and/or agenda packet in an appropriate alternative format; or if you require other accommodation, please contact the ADA Coordinator Tianjun Cao at (925) 671-3243 or [email protected], at least 24 hours in advance of the meeting. Advance notification within this guideline will enable the City to make reasonable arrangements to ensure accessibility.

Staff Report
Date: June 24, 2024
To: City Council
From: Valerie J. Barone, City Manager
Reviewed by: Kevin Marstall, PE, Director of Community Development Prepared by: Sophia Huckabay, Housing Manager
[email protected]
(925) 671-3387
Subject: Considering adoption of a Resolution pursuant to the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the Internal Revenue Code of 1986 approving the issuance of the California Municipal Finance Authority multifamily housing revenue bonds in an aggregate principal amount not to exceed $90,000,000 for the purpose of the acquisition, construction, improvement, and equipping of a project titled SB 35
Amendment Streamlined Approval for The Ashbury at 1650
Ashbury Drive (PL23150); APN 126-132-005, also known as The Ashbury, an entitled 183-unit affordable multifamily rental housing project with a site location of 1650 Ashbury Drive, Concord, California and certain other matters relating thereto, and make the CEQA determinations.

CEQA: Not a project/exempt pursuant to CEQA Guidelines
Sections 15060(c)(2), 15061(b)(3), 15378 and/or Public
Resources Code Section 21065.

Report in Brief
On May 28, 2024, the City conducted a Tax Equity and Fiscal Responsibility Act of 1986 (TEFRA) public hearing to consider approving the issuance of up to $90,000,000 in California State tax exempt bonds at the request of Pacific West Communities, Inc., through its affiliate TPC QOZB-Concord, LP (Borrower), owns 1650 Ashbury Drive, the site of the entitled SB 35 Amendment Streamlined Approval for The Ashbury at 1650

2.a2.a2.a2.a2.a

City Council Agenda Report
Agenda Item No. 2.a
June 24, 2024
Ashbury Drive (PL23150); APN 126-132-005, also known as The Ashbury project (“Project”).

The purpose of a TEFRA hearing is to assist with releasing the bond financing necessary to move forward with a fully affordable project. At the close of the May 28, 2024 hearing, the Council did not adopt the resolution approving the financing. The item before Council today presents an amended resolution for their consideration.

If approved, the TEFRA bond financing would allow for the acquisition, construction, improvement, and equipping of the Project. Bond repayment is the sole responsibility of Pacific West Communities, Inc., and the CMFA; the City is not responsible for the debts, liabilities, and obligations incurred through this bond financing. The Project is eligible for this type of financing because it would be a 100% affordable project, and it meets the Federal requirements of 20 percent of the Project units being made available to households earning 50% of the Area Median Income (AMI) or below, or 40 percent of the units being made available to households earning 60% of AMI or below.

Recommended Action
Adopt a Resolution, Attachment 1, pursuant to the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the Internal Revenue Code of 1986 approving the issuance of the California Municipal Finance Authority multifamily housing revenue bonds in an aggregate principal amount not to exceed $90,000,000 for the purpose of the acquisition, construction, improvement, and equipping of a project titled SB 35 Amendment Streamlined Approval for The Ashbury at 1650 Ashbury Drive (PL23150); APN 126-132-005, also known as The Ashbury, an entitled 183-unit affordable multifamily rental housing project with a site location of 1650 Ashbury Drive, Concord, California and certain other matters relating thereto, and make the CEQA determinations.

Background
The purpose of a TEFRA hearing is to assist with releasing the bond financing necessary to move forward with a fully affordable project. The City held a TEFRA hearing on the Project on May 28, 2024. At the close of the hearing, the Council did not adopt the resolution approving the financing. The item before Council today presents an amended resolution for their consideration.

Pacific West Communities, Inc. (Developer), through its affiliate TPC QOZB-Concord, LP, owns 1650 Ashbury Drive for The Ashbury apartment project. The Project received its entitlements on February 6, 2024, as a 183-unit affordable housing complex, through an SB 35 affordable housing streamlined approval.

The City also received on June 17, 2022, an additional project application under SB 330, from the Developer for The Ashbury apartment complex for a mixed-income project that would include 183 units, whereby 163 units are set aside as market rate and 20

City Council Agenda Report
Agenda Item No. 2.a
June 24, 2024
units as very low-income. This alternative project is in the California Environmental Quality Act (CEQA) review process and is not, yet, entitled.

Despite this additional application, the Developer has indicated a desire to continue with TEFRA financing to support the approved SB 35 project (PL23150) for a fully affordable project that has already received its entitlements as described in this report.

In order for all or a portion of the bonds to qualify as tax-exempt bonds, the City must conduct a public hearing (the “TEFRA Hearing”) providing members of the community an opportunity to comment on the use of tax-exempt bonds for the financing of the Project. This hearing was held on May 28, 2024. Prior to such TEFRA Hearing, reasonable notice was provided to the members of the community.

The Joint Exercise of Powers Agreement (JPA) provides that the CMFA is a public entity, separate and apart from each member executing such agreement. The debts, liabilities, and obligations of the CMFA do not constitute debts, liabilities, or obligations of the members executing such agreement. The City became a member of the CMFA JPA in February of 2022.

Analysis
Bond Issuer and Development Team
The CMFA, a San Diego based Joint Powers Authority, created on January 1, 2004, will serve as the bond issuer. To date, over 350 municipalities, including the City of Concord, have become members of the CMFA, resulting in over 500 affordable multi- family projects statewide.

The development team includes:
 Borrower: TPC QOZB-Concord, LP. is a California limited partnership. The Project is owned by the Borrower.
 Developer: Pacific West Communities, Inc. (“PWC”) is the General Partner to Borrower and is listed as developer on the California Tax Credit Allocation Committee Joint Application for 4% Federal Low-Income Housing Tax Credits with Tax-Exempt Bonds. PWC was formed as a real estate development and financing firm, specializing in the construction and rehabilitation of affordable workforce housing throughout the western United States. With a particular emphasis on the use of the affordable housing tax credits, PWC and its related companies develop multi-family and senior housing in the states of California, Arizona, New Mexico, Utah, Oregon, Montana, Idaho, Nevada, Colorado, Washington, and Wyoming. Currently PWC owns and operates approximately 110 developments with over 6,000 units of affordable housing.  Property Management: ConAm Management Corporation is the assigned property management group for the Project. ConAm has over 45 years of

City Council Agenda Report
Agenda Item No. 2.a
June 24, 2024
property management experience, and over 35 year of affordable property management experience that includes affordable housing compliance, on-going employee education and development in affordable housing compliance, accounting/financial reporting, and capital asset management. They currently manage over 33,000 affordable housing units across over 300 communities in California, and over 50,000 total residential units across 12 States.  Resident Services: Central Valley Coalition for Affordable Housing (CVCAH) is an organization described in Section 501(c)(3) of the Code and is the managing general partner to the Borrower. CVCAH will operate the Project and will provide supportive services for the Project. CVCAH has been providing social services since 1999 to low-income families and seniors living in affordable housing apartments. CVCAH will offer health and wellness programs and skill building classes. These programs will include classes such as computer training, home- buyer education classes, resume building, nutrition classes, crisis intervention, cleanliness and hygiene assessments, and other related topics.

The Project
The Ashbury is a 183-unit multifamily project located at 1650 Ashbury Drive. It is located within half of a mile of BART, grocery stores, restaurants, and shops, allowing residents access to needed resources and amenities.

Table A below describes the unit breakdown per household income level and bedroom size. Please see Attachment 2 for current maximum income limits per the State of California associated with each income category:

Table A: Number of Income-Restricted Units per Income Level and Bedroom Size

City Council Agenda Report
Agenda Item No. 2.a
June 24, 2024
On-site amenities will include a pool, patio area, children’s play area, large multipurpose clubhouse, and a picnic area. Units facing the courtyards have large private patios.

The Project is inspired by Italianate style architecture. The building will be broken up into three horizontal sections (base, middle, and top). The two courtyards facing Ashbury Drive help to further break up the building. The project entry is at the corner of Ashbury Drive and Amador Avenue and will lead to surface level parking. The Project will include a pedestrian-oriented plaza, defined by a corner awning that complements the architecture and will include a total of 107 parking spaces comprised of both outdoor and indoor parking.

The total estimated bond issuance is $90,000,000, which includes a contingency reserve. The funds are purposed to be utilized for the following activities:
 Land Costs
 Construction Costs
 Construction Contingency Reserve
 Financing Costs
 Architecture & Engineering Costs
 Developer Fees
 Soft Costs & Contingency Reserve
 Post Construction Interest & Reserves
The CMFA and JPA
The City first joined the CMFA in February of 2022 when the City held a TEFRA hearing for, and approved the release of, the municipal bonds associated with The Lakes Apartments project, and then in October of 2022 for The Argent project (now known as Blue Oak Square).

The CMFA was created pursuant to a Joint Exercise of Powers Agreement to promote economic, cultural, and community development, through the financing of economic development and charitable activities throughout California. The CMFA assists local governments, non-profit organizations, and businesses with the issuance of low-risk, taxable and tax-exempt bonds aimed at improving the standard of living in California.

The CMFA’s representatives and its Board of Directors have 40 years of experience in bond financings.

The Bonds to be issued by the CMFA for the Project will be the sole responsibility of the Borrower and the City will have no financial, legal, moral obligation, liability, or responsibility for the Project or the repayment of the bonds. All financing documents with respect to the issuance of the bonds will contain clear disclaimers that the bonds

City Council Agenda Report
Agenda Item No. 2.a
June 24, 2024
are not obligations of the City or the State of California but are to be paid for solely from funds provided by the Borrower.

Exclusive of holding the TEFRA hearing and making a decision authorizing the release of the bonds associated with the Project, no other participation or activity of the City or Council, with respect to the issuance of the bonds, will be required. Additionally, the CMFA shares 25% of all issuance fees directly with its member communities. Upon approving the issuance of the bonds, the City will receive a one-time issuance fee from the CMFA of approximately $22,000.

If developed as an affordable housing project (with or without the Council’s approval to release municipal bond financing through the TEFRA hearing process), the Project will be exempted from paying property taxes by the State Board of Equalization and the Contra Costa County Assessor’s Office. If developed as a market rate housing project the City would receive property taxes consistent with California State law.

Regional Housing Needs Allocation
The City’s Housing Element contains policies and programs for meeting the current and future housing needs of all income levels in a community. All 183 units of The Ashbury project will count towards the City’s RHNA goals.

The site is a 1.84-acre lot zoned as DMX. The current Housing Element’s site inventory list indicates that it slated for 184 above moderate units.

Alternatives
Alternatively, Council could choose not to approve and adopt the Resolution approving the issuance of the bonds by the CMFA for the benefit of Pacific West Communities, Inc., to finance the Project. This would decrease the likelihood of the Project being developed as an affordable housing project as the developers would need to identify a different source of financing.

Financial Impact
There is no financial impact to the City. The Project will be financed and administered by the CMFA. As an affordable housing project, the Project will be tax exempt. The approval of the TEFRA bonds does not affect the tax-exemption status.

The CMFA shares a portion of the issuance fees it receives with its member communities. With respect to the City, it is expected that a $22,000 issuance fee attributable to the City will be granted by the CMFA to the general fund of the City. Such grant may be used for any lawful purpose of the City. The funds will not be recognized within the budget until after receipt.

City Council Agenda Report
Agenda Item No. 2.a
June 24, 2024
Environmental Determination
Pursuant to Public Resources Code Section 21065, CEQA Guidelines Sections 15060(c), 15061(b)(3), and/or 15378, City Council action on this item is not subject to environmental review under the California Environmental Quality Act (CEQA) of 1970, as amended, because it will not result in a direct or a reasonably foreseeable indirect physical change in the environment, and falls within the “common sense” exemption set forth in CEQA Guidelines Section 15061(b)(3), excluding projects where “it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment.”
Public Contact
The City Council Agenda was posted. Notice of the May 28, 2024, Public Hearing was published in the East Bay Times newspaper on May 18, 2024, in accordance with Public Hearing notification procedures, which satisfies the minimum notification time required for this action.

Attachments

1. TEFRA Resolution – The Ashbury

2. 2024 Maximum Income Limits

Res. No. 24-XX 1

BEFORE THE CITY COUNCIL OF THE CITY OF CONCORD

COUNTY OF CONTRA COSTA, STATE OF CALIFORNIA
A Resolution Pursuant to the Tax Equity and Fiscal
Responsibility Act of 1982 (TEFRA) and the Internal
Revenue Code of 1986 Approving the Issuance of the
California Municipal Finance Authority Multifamily
Housing Revenue Bonds in an Aggregate Principal
Amount Not to Exceed $90,000,000 for the Purpose of
the Acquisition, Construction, Improvement, and
Equipping a Project titled, “SB 35 Amendment
Streamlined Approval for of The Ashbury at 1650
Ashbury Drive (PL23150), APN 126-132-005,” also
known as The Ashbury, an Entitled 183-Unit
Affordable Multifamily Rental Housing Project with
a Site Location of 1650 Ashbury Drive, Concord,
California and Certain Other Matters Relating
Thereto
Resolution No. 24-XX
/
WHEREAS, Pacific West Communities, Inc. (the "Developer") a partnership of which TPC QOZB-Concord, LP, a California Limited Partnership (the "Borrower") or a related person to the Developer is the general partner, has requested that the California Municipal Finance Authority (the "Authority") adopt a plan of financing providing for the issuance of exempt facility bonds for a qualified residential rental project pursuant to Section 142(a)(7) of the Internal Revenue Code of 1986 (the "Code") in one or more series issued from time to time, including bonds issued to refund such exempt facility bonds in one or more series from time to time, and at no time to exceed $90,000,000 in aggregate principal amount (the "Bonds"), to finance or refinance the acquisition, construction, improvement, and equipping of a multifamily rental housing project located at 1650 Ashbury Drive, Concord, California as amended, approved, and conditioned on February 6, 2024, and titled, “SB 35 Amendment Streamlined Approval for The Ashbury at 1650 Ashbury Drive (PL23150); APN 126- 132-005”, and is also know as The Ashbury, (the "Project"); and WHEREAS, the Developer has applied with the City under Senate Bill (SB) 330 for the consideration of approval for the project with the same building envelope and unit count, but a different unit mix which is not the subject of this TEFRA hearing or approval; and Attachment 1

Res. No. 24-XX 2
WHEREAS, pursuant to Section 147(f) of the Code, the issuance of the Bonds by the Authority must be approved by the City of Concord (the "City") because the Project is located within the territorial limits of the City; and
WHEREAS, the City Council of the City (the "City Council") is the elected legislative body of the City and is one of the "applicable elected representatives" required to approve the issuance of the Bonds under Section 147(f) of the Code; and
WHEREAS, the Authority has requested that the City Council approve the issuance of the Bonds by the Authority in order to satisfy the public approval requirement of Section 147(f) of the Code and the requirements of Section 4 of the Joint Exercise of Powers Agreement Relating to the California Municipal Finance Authority, dated as of January 1, 2004 (the "Agreement"), among certain local agencies, including the City; and
WHEREAS, notice of such public hearing that was held on May 28, 2024, was has been duly given as required by Section 147(f) of the Code, and this City Council has heretofore held such public hearing at which all interested persons were given an opportunity to be heard on all matters relative to the financing or refinancing of the Project and the Authority’s issuance of the Bonds therefor; and WHEREAS, it is in the public interest and for the public benefit that the City Council approve the issuance of the Bonds by the Authority for the aforesaid purposes.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF CONCORD DOES RESOLVE AS FOLLOWS:

Section 1. The foregoing recitals are true and correct.

Section 2. Council’s approval of this resolution is specific to the Project entitlement authorized and conditioned by PL23150, including but not limited to, Condition of Approval #6 regarding the use of a skilled and trained workforce. The Council’s approval is not being made for any other entitlements and may not be transferred to another entitlement, even if a subsequent development project proposed is functionally equivalent. A new TEFRA hearing shall be required to consider the issuance of bonds to fund a project entitled by any approval other than PL 23150.

Section 32. The City Council hereby approves the issuance of the Bonds by the Authority. It is

Res. No. 24-XX 3
the purpose and intent of the City Council that this resolution constitutes approval of the issuance of the Bonds by the Authority, for the purposes of (a) Section 147(f) of the Code by the applicable elected representative of the governmental unit having jurisdiction over the area in which the Project is located, in accordance with said Section 147(f) and (b) Section 4 of the Agreement.

Section 43. The issuance of the Bonds shall be subject to the approval of the Authority of all financing documents relating thereto to which the Authority is a party. The City shall have no responsibility or liability whatsoever with respect to the Bonds.

Section 54. The adoption of this Resolution shall not obligate the City or any department thereof to (i) provide any financing to acquire or construct the Project or any refinancing of the Project; (ii) approve any application or request for or take any other action in connection with any planning approval, permit or other action necessary for the acquisition, construction, rehabilitation installation, or operation of the Project; (iii) make any contribution or advance any funds whatsoever to the Authority; or (iv) take any further action with respect to the Authority or its membership therein.

Section 65. The officers of the City are hereby authorized and directed, jointly and severally, to do any and all things and to execute and deliver any and all documents which they deem necessary or advisable in order to carry out, give effect to and comply with the terms and intent of this resolution and the financing transaction approved hereby.

Section 76. The City Clerk shall forward a certified copy of this Resolution to the Authority in care of its counsel:

Justin Cooper, Esq.

Orrick, Herrington & Sutcliffe
405 Howard Street
San Francisco, CA 94105
Section 87. This resolution shall become effective immediately upon its passage and adoption. //
//

Res. No. 24-XX 4
PASSED AND ADOPTED by the City Council of the City of Concord on May 28, 2024, by the following vote:

AYES: Councilmembers -
NOES: Councilmembers -
ABSTAIN: Councilmembers -
ABSENT: Councilmembers -
I HEREBY CERTIFY that the foregoing Resolution No. 24-XX was duly and regularly adopted at a regular meeting of the City Council of the City of Concord on May 28, 2024.

Joelle Fockler, MMC
City Clerk
APPROVED AS TO FORM:

Thomas S. Capriola
Senior Assistant City Attorney

30% AMI 50% AMI 60% AMI 70% AMI 80% AMI 100% AMI 110% AMI 120% AMI Extremely Low Very Low Lower Low Low Median Moderate Moderate 1 Person $32,700 $54,500 $65,400 $76,300 $84,600 $109,000 $119,900 $130,800 2 Persons $37,400 $62,300 $74,760 $87,220 $96,650 $124,550 $137,005 $149,500 3 Persons $42,050 $70,100 $84,120 $98,140 $108,750 $140,150 $154,165 $168,150 4 Persons $46,700 $77,850 $93,420 $108,990 $120,800 $155,700 $171,270 $186,850 5 Persons $50,450 $84,100 $100,920 $117,740 $130,500 $168,150 $184,965 $201,800 6 Persons $54,200 $90,350 $108,420 $126,490 $140,150 $180,600 $198,660 $216,750 7 Persons $57,950 $96,550 $115,860 $135,170 $149,800 $193,050 $212,355 $231,700 8 Persons $61,650 $102,800 $123,360 $143,920 $159,500 $205,500 $226,050 $246,650 Income Calculations: This information is based on amounts provided by HUD and CA Dept. of Housing and Community Development Department (HCD). It is updated annually in the spring. 60% = 1.2 x 50% AMI. 70% = 1.4 x 50% AMI. 110% = 1.1 x 100% AMI. HUD/HCD provides 30%, 50%, 80%, 100% and 120% AMI. Please note, these are not simple mathematical calculations.

Maximum Income Limits (2024)*
City of Concord
*Based on Area Median Income (AMI) in the Oakland Metropolitan Statistical Area Some affordable housing units are restricted based on income. The table below shows income limits for 2024 (effective May 9, 2024).

Household Size
Attachment 2

Correspondence Received
Agenda Item No. 2.a
June 24, 2024

From: James Lloyd <[email protected]>
Sent: Monday, June 24, 2024 1:23 PM
To: Concord City Council Email <[email protected]>; Nakamura, Laura <[email protected]>; Hoffmeister, Laura <[email protected]>; Aliano, Dominic <[email protected]>; Obringer, Carlyn <[email protected]>; Birsan, Edi <[email protected]> Cc: Hart, Michael <[email protected]>; Planning <[email protected]>; Barone, Valerie <[email protected]>; Fockler, Joelle <[email protected]>; Brown, Susanne <[email protected]>; Marstall, Kevin <[email protected]>
Subject: CalHDF public comment for 24June2024 TEFRA hearing

Dear Concord City Council,
Please see attached CalHDF's public comment regarding the proposed bond issuance for 1650 Ashbury Place, which will be heard at tonight's Council meeting. CalHDF originally submitted this to the Council on June 10, 2024, and we are resubmitting the letter given that the project will be heard during tonight's Council meeting.

Sincerely,

James M. Lloyd
Director of Planning and Investigations
California Housing Defense Fund
[email protected]

Jun 10, 2024
City of Concord
1950 Parkside Drive
Concord, CA 94519
Re: Proposed Housing Development Project at 1650 Ashbury Drive By email:[email protected]; [email protected]; laura.ho[email protected]; [email protected]; [email protected]; [email protected] CC: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] DearConcordCityCouncil,
TheCaliforniaHousingDefenseFund(“CalHDF”) submitsthislettertoremindtheCouncilof itsobligationtoabidebytheHousingAccountabilityAct(“HAA”)whenevaluatingthe proposed100%a ordable,183-unitprojectat1650AshburyDrive.CalHDFurgestheCouncil toreverseitsMay28,2024denialoftheproject,inaccordancewithStatelaw.

The Project is Protected by the Housing Accountability Act and by SB 35 Theprojectwasonlysubjecttoministerialapprovalduringthelanduseapprovalsprocess duetotheapplicationofSB35.(Gov.Code,§65913.4 )ThefactthataTaxEquityandFiscal ResponsibilityAct(TEFRA)hearingwasneededdoesnotgivetheCitydiscretionto disapprovetheproject. Infact,initsquestionsandcomments,theCounciltreatedtheMay 28,2024TEFRAhearingasalanduseentitlementhearing,ratherthanahearingona tax-exemptbondissuance,asnotedbytheCaliforniaMunicipalFinanceAuthority representativeattime2:59duringthehearing. 1ThissubvertstheintentandfunctionofSB

35. Additionally,theHAA(Gov.Code,§65589.5)requirestheCouncilto approvezoningand generalplancomplianthousingdevelopmentprojectsunless
indingscanbemade
1 https://stream.ci.concord.ca.us/OnBaseAgendaOnline/Meetings/ViewMeeting?id=1130&doctype=1 360 Grand Ave #323, Oakland 94610
www.calhdf.org

regardingspeciic,objective,writtenhealthandsafetyhazards.TheHAAalsobarscities fromimposingconditionsontheapprovalofsuchprojectsthatwouldreducetheproject’s densityunless,again,suchwritten indingsaremade.Asoutlinedinthesta report,asa fullyentitledproject,theproposeddevelopmentcomplieswithlocallanduserules, includingtheCity’szoningcodeandGeneralPlan.TheHAA’sprotectionsthereforeapply, andtheCitymustnotrejecttheproject,exceptbasedonhealthandsafetystandards,as outlinedabove.

Critically,theHAAspeci
iesthat“disapproval”ofahousingdevelopmentproject“includes,” withoutlimitation,anyvotestodisapprove“anyrequiredlanduseapprovalsorentitlements necessaryfortheissuanceofabuildingpermit.”(Id.atsubd.(h)(6)(A.)TheCouncil’srecent decisiontodenytheprojectisthereforeaviolationoftheHousingAccountabilityAct.The City’srefusaltomoveforwardwithTEFRAcerti icationconstitutesanunlawful,and actionable,disapprovalundertheHAA. See California Renters Legal Advoc. & Educ. Fund v.

City of San Mateo(2021),68Cal.App.5th820,844.

Council May not Reject Project for Being Eligible for a Property Tax Exemption TheCouncilalsomaynotdenytheprojectduetotheprojectbeingeligibleforawelfare propertytaxexemption(emphasisadded).(Gov.Code,§65589.5,subd.(d)(2)(B).):
(2)Thehousingdevelopmentprojectoremergencyshelterasproposedwouldhavea speci
ic,adverseimpactuponthepublichealthorsafety,andthereisnofeasiblemethod tosatisfactorilymitigateoravoidthespeci ic,adverseimpactwithoutrenderingthe developmentunaordabletolow-andmoderate-incomehouseholdsorrenderingthe developmentoftheemergencyshelter inanciallyinfeasible.Asusedinthisparagraph,a “speciic,adverseimpact”meansasigni icant,quantiiable,direct,andunavoidable impact,basedonobjective,identi iedwrittenpublichealthorsafetystandards,policies, orconditionsastheyexistedonthedatetheapplicationwasdeemedcomplete.The followingshallnotconstituteaspeci ic,adverseimpactuponthepublichealthorsafety:
(A)Inconsistencywiththezoningordinanceorgeneralplanlandusedesignation. (B)Theeligibilitytoclaimawelfareexemptionundersubdivision(g)ofSection214of theRevenueandTaxationCode.

Councilmembersrepeatedlybroughtuptheabilityoftheprojecttoclaimawelfare exemptionduringthehearingasaconcern,includingViceMayorObringerattime2:03and CMHomeisterat2:18. CMAlianospeci icallycitedthedevelopmentbeingtax-exemptas oneofthereasonsforhisnovote.
2 of 5 Page 17 of 28
The City is Discriminating Based on a Protected Class
Forpurposesofstatefairhousinglaw(SeeGov.Code,§8899.50, inter alia.),residentsof low-incomeareaprotectedclass.TheCityisobligatedbystatelaw(ibid.)nottodiscriminate againstsuchresidentsbasedonprotectedcharacteristics.

TheCouncilwashostiletoana ordablehousingdevelopmentinthedowntownarea,with Councilmembersspeci icallycitingresidents’incomesandrelativelackofdisposable income.CMAliano,whorepresentsthedistrictthattheprojectwouldbelocatedin, speciicallycitedtheproject’sstatusasa ordablehousingasareasonforhisno-vote.At time2:44,CMAlianostatedclearlythatheis notsupportingtheprojectbecauseitwouldbe 100%aordable,statingastrongpreferencethattheprojectwouldgoforwardasmarket ratehousinginstead.Similarly,ViceMayorObringeralsosupportedCMAliano’sposition, statingthatit “doesn’tseemfair”toputmorea ordablehousingdowntown.CM Homeisterattime2:58alsolistedtheproject’sa ordabilityasareasonforhernovoteout ofaconcernfordowntownbusinesses,astheresidentswouldnot,inherview,have suficientdisposableincome.

Denial Endangers the Substantial Compliance of the City’s Housing Element TheCouncil’sdecisiontodenythe100%a ordableprojectbringsintoquestionwhetherthe Cityremainsinsubstantialcompliancewithitshousingelement,giventhattheCityisnot anywhereclosetoachievingitsRegionalHousingNeedsAllocationforeitherthe5th HousingElementcycleor6thHousingElementcycle.

IntheCity’sapproved2023-2031HousingElement,inTable1,reviewof2015-2023Housing ElementPastAccomplishments,underProgramH-1.5.4&ProgramH-1.9.3,theCitycites 1650AshburyDrivebothasbeinga313-unit,100%a ordablehousingprojectandalso as beingevidenceofitsachievingtheprograms’goals.AndtheHousingElementlists1650 AshburydriveasSite45intheSitesInventory,slatedfor184unitsofhousing.Asdiscussed duringthehearingattime2:08,theprojectwasoriginallyslatedtobea313unit,twophase project, butnegativelendingconditionsforcedittobecurtailedtoasinglephase.Itis unclearwhytheCitywouldcitethisasa100%a ordableprojectinitsHousingElementifit wastheintentoftheCounciltodenytheproject.

TheCityfailedtoachieveits5thHousingElementgoalofitsHousingNeedsAllocation objectiveof3,478units.Concord’sRHNAallocationfor2023-2031is5,073units,including 1,292extremely&verylowincome,744low-income,847moderateincome,and2,190above moderateincome.TheAshburywouldallowtheCitytodevelop183unitstowardsits extremelylow,verylow,andlow-incomeRHNAtargets.Suchopportunitiesdonotcome frequently.Infact,ViceMayorObringerstatedherselfthat itseemedunlikelythattheCity 3 of 5 Page 18 of 28
wouldsee100%a ordablehousing anywhereelseinthecityanytimesoon,statingat2:57,“I don’tknowthatwe’regoingtoseea ordablehousinganywhereelseinotherpartsofthecity anytimesoon.”Perplexing,sheusedthisasajusti icationforvotingagainsttheproject.

ThedecisiononthepartoftheCounciltodenytheprojectisnotonlyanHAAviolation,butit alsocallsintoquestionwhethertheCity’sHousingElementremainsinsubstantial compliancewithstatelaw,asitwillhavedisapproveda100%a ordableprojectitspeci ically listedinitsHousingElement.

TheHousingElementLawgivesenforcementauthoritytoHCDtoensurejurisdictionscarry outthepromisesmadeintheirhousingelements.(Gov.Code,§65585,subd.(i).)Afailureto carryoutthesepromisesallowsHCDtorevokeitsdeterminationthattheCity’shousing elementcomplieswithstatelaw.ThegeneralpublicalsohasarighttosuetheCitytorequire implementationofthehousingelement’sprograms.(See Gov.Code,§65583,subd.(h) [creatingacauseofaction“toenforcetheprogramactionsofthehousingelement”viaa traditionalmandamussuit].)Ineithercase,arevocationoftheCity’scompliancestatus exposesittopenalties,includingthesuspensionoftheCity’szoningcodethroughthe “builder’sremedy”provisionoftheHousingAccountabilityAct.(Gov.Code,§65589.5,subd. (d)(5).)
<>
Asyouarewellaware,Californiaremainsinthethroesofastatewidecrisis-levelhousing shortage.Newhousingsuchasthisisapublicbene
it;itwilldirectlymitigateour
homelessnesscrisis,itwillbringnewcustomerstolocalbusinesses,anditwillreduce displacementofexistingresidents.Furthermore,theallocationofaportionofthestate’stax exempt,privateactivitybondvolumecap,whichgenerates4%LowIncomeHousingTax Credits,isapreciouscommodity,widelysoughtbycommunitiesseekingtoenhancetheir a
ordablehousingstock.ThenotionthattheCitywoulddisapproveafully-entitled,100% aordableprojectthathasalreadybeenallocatedthesefederaltaxcreditsisba inggiven thatweareinthemidstofahomelessnessandhousingcrisisacrossthestate,andthis projectwouldbewithinwalkingdistanceofaBARTstationandalltheemployment opportunitiesconnectedthereto.

Whilenooneprojectwillsolvethehousingcrisis,theproposeda ordabledevelopmentisa stepintherightdirection.CalHDFurgestheCounciltoreverseitsdecisionandapprovethe project,consistentwithitsobligationsunderstatelaw.

CalHDFisa501(c)3non-pro itcorporationwhosemissionincludesadvocatingforincreased accesstohousingforCaliforniansatallincomelevels,includinglow-incomehouseholds.

YoumaylearnmoreaboutCalHDFat www.calhdf.org.
4 of 5 Page 19 of 28
Sincerely,
DylanCasey
CalHDFExecutiveDirector
JamesM.Lloyd
CalHDFDirectorofPlanningandInvestigations
5 of 5

From: Debra Ballinger <[email protected]>
Sent: Monday, June 24, 2024 2:56 PM
To: City Clerk <[email protected]>
Subject: Support for The Asbury

Good afternoon, Mayor Birsan and Councilmembers,

United Latino Voices supports the issuance of multifamily housing revenue bonds for The Ashbury. I was not notified of this meeting, so this is very last minute. We are disturbed the City failed to approve the TEFRA resolution for the Project and very appreciative that this has come back for discussion.

The City of Concord must build more affordable housing according to its housing element.

The goal of AFFH is to provide more affordable housing opportunities in more locations, not fewer affordable housing opportunities. This means that the "white picket fence" property can also be considered for affordable housing. However, as the State's HCD notes, "the obligation of AFFH to increase affordable housing opportunities in one place does not permit the City to block affordable housing in another. AFFH is focused on ensuring households with protected characteristics have equal access to opportunity." I look forward to continuing discussion the rezoning to meet that requirement as well. ALl of this will help meet Concord's RHNA goals.

We need more affordable housing in Concord to address displacement, build opportunity, and stem the growth of the unhoused.

Thank you,
Debra

--
Debra Ballinger
Interim Executive Director
United Latino Voices

Res. No. 24-XX 1

BEFORE THE CITY COUNCIL OF THE CITY OF CONCORD

COUNTY OF CONTRA COSTA, STATE OF CALIFORNIA

A R esolution Pursuant to the Tax Equity and Fiscal
Responsibility Act of 1982 (TEFRA) and the Internal
Revenue Code of 1986 A pproving the Issuance of the
California Municipal Finance Authority M ultifamily
Housing Revenue Bonds in an Aggregate Principal
Amount Not to Exceed $90,000,000 for the Purpose of
the Acquisition, Construction, Improvement, and
Equipping a Project titled, “SB 35 Amendment
Streamlined Approval for of The Ashbury at 1650
Ashbury Drive (PL23150), APN 126-132-005,” also
known as The Ashbury, an Entitled 183-Unit
Affordable Multifamily Rental Housing Project with
a Site Location of 1650 Ashbury Drive, Concord,
California and Certain Other Matters Relating
Thereto
Resolution No. 24- XX

/

WHEREAS, Pacific West Communities, Inc. (the "Developer") a partnership of which TPC QOZB-Concord, LP, a California Limited Partnership (the "Borrower") or a related person to the Developer is the general partner , has requested that the California Municipal Finance Authority (the "Authority") adopt a plan of financing providing for the issuance of exempt facility bonds for a qualified residential rental project pursuant to Section 142(a)(7) of the Internal Revenue Code of 1986 (the "Code") in one or more series issued from time to time, including bonds issued to refund such exempt facility bonds in one or more series from time to time, and at no time to exceed $90,000,000 in aggregate principal amount (the "Bonds"), to finance or refinance the acquisition, construction, improvement , and equipping of a multifamily rental housing project located at 1650 Ashbury Drive , Concord, California as amended, approved, and conditioned on February 6, 2024, and titled, “SB 35 Amendment Streamlined Approval for The Ashbury at 1650 Ashbury Drive (PL23150); APN 126- 132-005”, and is also know as The Ashbury, (the "Project"); and WHEREAS, the Developer has applied with the City under Senate Bill (SB) 330 for the consideration of approval for the project with the same building envelope and unit count, but a different unit mix which is not the subject of this TEFRA hearing or approval; and Attachment 1

Res. No. 24-XX 2
WHEREAS, pursuant to Section 147(f) of the Code, the issuance of the Bonds by the Authority must be approved by the City of Concord (the "City") because the Project is located within the territorial limits of the City; and
WHEREAS, the City Council of the City (the "City Council") is the elected legislative body of the City and is one of the "applicable elected representatives" required to approve the issuance of the Bonds under Section 147(f) of the Code; and
WHEREAS, the Authority has requested that the City Council approve the issuance of the Bonds by the Authority in order to satisfy the public approval requirement of Section 147(f) of the Code and the requirements of Section 4 of the Joint Exercise of Powers Agreem ent Relating to the California Municipal Finance Authority, dated as of January 1, 2004 (the "Agreement"), among certain local agencies, including the City; and

WHEREAS,
notice of such public hearing that was held on May 28, 2024, was has been duly given as required by Section 147(f) of the Code, and this City Council has heretofore held such public hearing at which all interested persons were given an opportunity to be heard on all matters relative to the financing or refinancing of the Project and the Authority’s issuance of the Bonds therefor; and

WHEREAS,
it is in the public interest and for the public benefit that the City Council approve the issuance of the Bonds by the Authority for the aforesaid purposes .

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF CONCORD DOES RESOLVE AS FOLLOWS:

Section 1. T he foregoing recitals are true and correct.

Section 2. Council’s approval of this resolution is specific to the Project entitlement authorized and conditioned by PL23150, including but not limited to, Condition of Approval #6 regarding the use of a skilled and trained workforce. The Council’s approval is not being made for any other entitlements and may not be transferred to another entitlement, even if a subsequent development project proposed is functionally equivalent. A new TEFRA hearing shall be required to consider the issuance of bonds to fund a project entitled by any approval other than PL 23150.

Section 32. The
City Council hereby approves the issuance of the Bonds by the Authority. It is

Res. No. 24-XX 3
the purpose and intent of the City Council that this resolution constitutes approval of the issuance of the Bonds by the Authority, for the purposes of (a) Section 147(f) of the Code by the applicable elected representative of the governmental unit having jurisdiction over the area in which the Project is located, in accordance w ith said Section 147(f) and (b) Section 4 of the Agreement.

Section 43. T
he issuance of the Bonds shall be subject to the approval of the Authority of all financing documents relating thereto to which the Authority is a party. The City shall have no responsibility or liability whatsoever with respect to the Bonds.

Section 54. The adoption of this Resolution shall not obligate the City or any department thereof to (i) provide any financing to acquire or construct the Project or any refinancing of the Project; (ii) approve any application or request for or take any other action in connection with any planning approval, permit or other action necessary for the acquisition, construction, rehabilitation installation, or operation of the Project; (iii) make any contribution or advance any funds whatsoever to the Authority; or (iv) take any further action with respect to the Authority or its membership therein.

Section 65. The
officers of the City are hereby authorized and directed, jointly and severally, to do any and all things and to execute and deliver any and all documents which they deem necessary or advisable in order to carry out, give effect to and comply with the terms and intent of this resolution and the financing transaction approved hereby.

Section 76. The
City Clerk shall forward a certified copy of this Resolution to the Authority in care of its counsel:

Justin Cooper , Esq.

Orrick, Herrington & Sutcliffe
405 Howard Street
San Francisco, CA 94 105
Section 87. Th is resolution shall become effective immediately upon its passage and adoption. //
//

Res. No. 24-XX 4
P ASSED AND ADOPTED by the City Council of the City of Concord on June 24, 2024 May 28, 2024, by the following vote:

AYES: Councilmembers -
NOES: Councilmembers -
ABSTAIN: Councilmembers -
ABSENT: Councilmembers -
I HEREBY CERTIFY th at the foregoing Resolution No. 2 4-XX was duly and regularly adopted at a regular meeting of the City Council of the City of Concord on May 28, 2024 June 24, 2024.

Joelle Fockler, MMC
City Clerk

APPROVED AS TO FORM:

Thomas S. Capriola
Senior Assistant City Attorney

Res. No. 24-XX 1

BEFORE THE CITY COUNCIL OF THE CITY OF CONCORD

COUNTY OF CONTRA COSTA, STATE OF CALIFORNIA

A Resolution Pursuant to the Tax Equity and Fiscal
Responsibility Act of 1982 (TEFRA) and the Internal
Revenue Code of 1986 A pproving the Issuance of the
California Municipal Finance Authority M ultifamily
Housing Revenue Bonds in an Aggregate Principal
Amount Not to Exceed $90,000,000 for the Purpose of
the Acquisition, Construction, Improvement, and
Equipping of The Ashbury, an Entitled 183-Unit
Affordable Multifamily Rental Housing Project with
a Site Location of 1650 Ashbury Drive, Concord,
California and Certain Other Matters Relating
Thereto
Resolution No. 24-XX
/

WHEREAS, Pacific West Communities, Inc. (the "Developer") a partnership of which TPC QOZB-Concord, LP, a California Limited Partnership (the "Borrower") or a related person to the Developer is the general partner , has requested that the California Municipal Finance Authority (the "Authority") adopt a plan of financing providing for the issuance of exempt facility bonds for a qualified residential rental project pursuant to Section 142(a)(7) of the Internal Revenue Code of 1986 (the "Code") in one or more series issued from time to time, including bonds issued to refund such exempt facil ity bonds in one or more series from time to time, and at no time to exceed $90,000,000 in aggregate principal amount (the "Bonds"), to finance or refinance the acquisition, construction, improvement , and equipping of a multifamily rental housing project located at 1650 Ashbury Drive , Concord, California (the "Project"); and
WHEREAS, pursuant to Section 147(f) of the Code, the issuance of the Bonds by the Authority must be approved by the City of Concord (the "City") because the Project is located within the territorial limits of the City; and
WHEREAS, the City Council of the City (the "City Council") is the elected legislative body of the City and is one of the "applicable elected representatives" required to approve the issuance of the Bonds under Section 147(f) of the Code; and
WHEREAS, the Authority has requested that the City Council approve the issuance of the Benched Alternative Attachment 1
Agenda Item No. 2.a
June 24, 2024

Res. No. 24-XX 2
Bonds by the Authority in order to satisfy the public approval requirement of Section 147(f) of the Code and the requirements of Section 4 of the Joint Exercise of Powers Agreement Relating to the California Municipal Finance Authority, dated as of January 1, 2004 (the "Agreement"), among certain local agencies, including the City; and

WHEREAS,
notice of such the public hearing held on May 28, 2024, has been was duly given as required by Section 147(f) of the Code, and this City Council has heretofore held such public hearing at which all interested persons were given an opportunity to be heard on all matters relative to the financing or refinancing of the Project and the Authority’s issuance of the Bonds therefor; and

WHEREAS,
it is in the public interest and for the public benefit that the City Council approve the issuance of the Bonds by the Authority for the aforesaid purposes .

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF CONCORD DOES RESOLVE AS FOLLOWS:

Section 1. The foregoing recitals are true and correct.

Section 2. The City Council hereby approves the issuance of the Bonds by the Authority. It is the purpose and intent of the City Council that this resolution constitutes approval of the issuance of the Bonds by the Authority, for the purposes of (a) Section 147(f) of the Code by the applicable elected representative of the governmental unit having jurisdiction over the area in which the Project is located, in accordance w ith said Section 147(f) and (b) Section 4 of the Agreement.

Section 3. The issuance of the Bonds shall be subject to the approval of the Authority of all financing documents relating thereto to which the Authority is a party. The City shall have no responsibility or liability whatsoever with respect to the Bonds.

Section 4. The adoption of this Resolution shall not obligate the City or any department thereof to (i) provide any financing to acquire or construct the Project or any refinancing of the Project; (ii) approve any application or request for or take any other action in connection with any planning approval, permit or other action necessary for the acquisition, construction, rehabilitation installation, or operation of the Project; (iii) make any contribution or advance any funds whatsoever to the Authority; or (iv) take any further action with respect to the Authority or its membership

Res. No. 24-XX 3
therein.

Section 5. The officers of the City are hereby authorized and directed, jointly and severally, to do any and all things and to execute and deliver any and all documents which they deem necessary or advisable in order to carry out, give effect to and comply with the terms and intent of this resolution and the financing transaction approved hereby.

Section 6. The
City Clerk shall forward a certified copy of this Resolution to the Authority in care of its counsel:

Justin Cooper , Esq.

Orrick, Herrington & Sutcliffe
405 Howard Street
San Francisco, CA 94 105
Section 7. This resolution shall become effective immediately upon its passage and adoption.

PASSED AND ADOPTED by the City Council of the City of Concord on May 28, 2024 June 24, 2024, by the following vote:

AYES: C ouncilmembers -
NOES: Councilmembers -
ABSTAIN: Councilmembers -
ABSENT: Councilmembers -
I HEREBY CERTIFY th at the foregoing Resolution No. 2 4-XX was duly and regularly adopted at a regular meeting of the City Council of the City of Concord on May 28, 2024 June 24, 2024.

Joelle Fockler, MMC
City Clerk
APPROVED AS TO FORM:

Susanne Meyer Brown Thomas S. Capriola
Senior Assistant City Attorney