Cities Index.
Comparison Matrix

Riverside City Council
June 23, 2026

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Comparison Matrix
Meeting
June 23, 2026
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Riverside City Council
Original file
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Text extracted from the city's file for reading and search. Open the original on riversideca.legistar1.com. That file is the official record.

ĚĂƉƚŝǀĞZĞͲƵƐĞʹ ZĞŐŝŽŶĂůWƌŽŐƌĂŵZĞǀŝĞǁDĂƚƌŝdž
>ĂƐƚZĞǀŝƐĞĚ͗ϭϬ͘ϯϬ͘ϮϬϮϱ
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Summary of Programs and Ordinances
dŚŝƐƚĂďůĞƉƌŽǀŝĚĞƐĂƐŶĂƉƐŚŽƚďĂƐĞĚŽŶƚŚĞŵŽƐƚƌĞĐĞŶƚŽƌĚŝŶĂŶĐĞƐĂŶĚƐƵŵŵĂƌŝĞƐĨƌŽŵĞĂĐŚĐŝƚLJΖƐƉůĂŶŶŝŶŐĨƌĂŵĞǁŽƌŬĨŽƌĂĚĂƉƚŝǀĞƌĞͲƵƐĞ͘KǀĞƌĂůů͕ƚŚĞŵŽƐƚƉƌŽŐƌĞƐƐŝǀĞĂƉƉƌŽĂĐŚƚŽŝŶĐƌĞĂƐĞƌĞƐŝĚĞŶƚŝĂůĂŶĚƵƚŝůŝnjĂƚŝŽŶŽĨƚŚĞŽƌĚŝŶĂŶĐĞƐ ĐŽŵĞƐĨƌŽŵ^ĂŶ&ƌĂŶĐŝƐĐŽĂŶĚ>ŽƐŶŐĞůĞƐ͕ƌĞĚƵĐƚŝŽŶŝŶĚĞǀĞůŽƉŵĞŶƚĨĞĞƐ͕ĂůůŽǁĂŶĐĞƐĨŽƌĂĚĚŝƚŝŽŶĂůƐƚŽƌŝĞƐĂŶĚƌĞĚƵĐƚŝŽŶŽĨƉĂƌŬŝŶŐ͘/ŶƚĞƌǀŝĞǁƐǁŝƚŚĚĞǀĞůŽƉĞƌƐǁŝůůŐŝǀĞƵƐŵŽƌĞƉĞƌƐƉĞĐƚŝǀĞĂƐƚŽǁŚŝĐŚŝŶĐĞŶƚŝǀĞƐŵĂŬĞƚŚĞďŝŐŐĞƐƚŝŵƉĂĐƚ͘ Ϯϰϴϴ;ĚĞƚĂŝůĞĚďĞůŽǁͿŝƐĂůƐŽĂƐƚĂŶĚŽƵƚĨĞĂƚƵƌĞ͕ĂƐƚŚĞĐŝƚLJŚĂƐĞƐƐĞŶƚŝĂůůLJĐƌĞĂƚĞĚĂŶŝŵƉƌŽǀĞŵĞŶƚĚŝƐƚƌŝĐƚĂŶĚŐŽǀĞƌŶŝŶŐďŽĂƌĚƚŽĨƵŶĚͬĨŝŶĂŶĐĞĐŽŶǀĞƌƐŝŽŶƉƌŽũĞĐƚƐŝŶƚŚĞĂƌĞĂ͘ Topic San Francisco Long Beach Los Angeles Santa Ana Pasadena Year
Adopted
July 5, 2023 March 11, 2014. Original ARO Adopted in 1999 “Citywide Adaptive Reuse Ordinance”
Approved by City Council December 10,2024
June 20,2020 March 2025
Notes Intentionally incentivizes housing, reduces
fees to increase feasibility. Focused within
the Financial District (FiDi)
The least focused on housing - more of a
guide with exceptions but few incentives.

Originally developed to increase housing,
since expanded to capture more housing and
retain city fabric
As a part of the housing element, the city may
revisit or amend the existing ordinance to
provide additional incentives.

Introduces a range of incentives, reduces
regulatory barriers, requires minimum
average unit size, and limited new
construction is permitted in conjunction with
adaptive reuse. Variance could apply for
Historic Resources
Code
Section
Article 2. Sec 2.10.5
Ordinance 122-23; 2023 Amendment; 2024
Amendment

21.450 - Adaptive reuse projects Chapter 1A of the Zoning Code – Article 9.4.6 Section 41-1650 Ordinance No. 7443 Programs AB 2488 authorizes the City and County of
San Francisco to designate one downtown
revitalization and economic recovery
financing district for the purpose of
financing commercial-to-residential
conversion projects with incremental tax
revenues generated by commercial-to-
residential conversion projects within the
district.

The district would be governed by a board
composed of three members of the Board
of Supervisors and two public members.

The district would prepare a financing plan
that includes requirements for affordable
housing, identification of eligible
commercial bui
ldings, and a process for
opted-in projects to receive incremental
tax revenue generated by their projects for
up to 30 years. The bill also specifies that
the commercial-to-residential conversion
projects that opt in are public works
subject to prevailing wage and labor
standards requirements.1
Incentive Program Original ARO adopted in 1999 -Resulting in over 12,000 housing units – allowed only
structures built before 1974 to convert.

Primarily focuses on preservation of historic
structures and conversion to residential
uses.

N/A
ĚĂƉƚŝǀĞZĞͲƵƐĞʹ ZĞŐŝŽŶĂůWƌŽŐƌĂŵZĞǀŝĞǁDĂƚƌŝdž
>ĂƐƚZĞǀŝƐĞĚ͗ϭϬ͘ϯϬ͘ϮϬϮϱ
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Topic San Francisco Long Beach Los Angeles Santa Ana Pasadena Purpose Increase housing, expand flexible
workspace options, and mitigate loss of
historic structures and poor design.

Goal to create opportunities to preserve
historic buildings, and bring new use
opportunities to underutilized sites.

Expand Adaptive Reuse incentives, the
proposed Citywide Adaptive Reuse
Ordinance intends to make housing
opportunities available throughout Los
Angeles.

Preservation of historic structures Promote housing infill and preserve historic structures
Purpose and
Key Features Commercial to Residential. Change an existing building in any Neighborhood Commercial and
Residential (CNR) District permitted use –
except for:
x No AR in single-family or duplex
residential zoning.
x Non-residential uses introduced into any
multi-family res zones must be
compatible with the surrounding
neighborhood as determined by the Site
Plan Review Committee.
x No new residential in any industrial zone.
x Existing building conditions, including
the present height, floor area, any yards
or setbacks, parking and loading spaces,
and open space are considered to meet
Zoning Code requirements.
x Any configuration of units and unit sizes,
new mezzanine or loft spaces, and
shared amenities for residents may be
created.
x In addition, new one-story structures to
provide fitness rooms, lounges, shade
for roof terraces, or other similar features
may be built on the roof and not be
counted as new floor area if these are
accessible to all residents or guests
Any change of use from Nonresidential Use
to dwelling units, guest rooms or joint living
and work quarters in all or any portion of any
Eligible Building
x With diminishing demand for
nonresidential space, there is a need
to reevaluate the City's vacant or
underutilized nonresidential
buildings.
x The City recognizes the need to
incentivize local housing production
that is suitable for the varied needs
of Pasadena residents.
x The proposed Zoning Code
Amendments would reduce
regulatory barriers to:
o Incentivize the conversion of
nonresidential buildings to
multifamily and mixed-use;
o Accommodate innovative
housing types;
o Accelerate the production of
additional housing units;
and
o Encourage the productive
use of underutilized
buildings.

Applicability C-2/C-3 downtown districts, east of
Franklin/13th/N of Townsend.

Multi-Family, Commercial, Industrial (no new
res), Downtown (See map on page 9)
Citywide Project Incentive Areas - midtown specific
plan zoning district (SP-3); the transit zoning
code district (SD-84); the North Main Street
Corridor on both sides of Main Street from
Seventeenth Street to the northernmost Main
Place Drive; and, the East First Street
Corridor on both sides of First Street from
Grand Avenue to Elk Lane
City-wide: existing non-residential buildings
Development standards shall apply to
Adaptive Reuse projects where there is a
conversion from an existing nonresidential
building (excluding buildings or portions of
buildings used for Lodging -H o t e l s , M o t e l s
uses) to multi-family residential use or
mixed-use.

Variances for Historic Resources
Eligibility
Consideratio
ns
Must not seek density bonus (under
section 206.5 or 206.6) and must not
expand an existing building’s envelope
where the addition is more than 33% of the
Citywide, specific incentives for properties
within the coastal district.

Citywide (was downtown-focused), now
applies citywide to commercial and lower-
density residential zones.

NA x Project must involve conversion of
existing building into multi-family
residential or mixed use
ĚĂƉƚŝǀĞZĞͲƵƐĞʹ ZĞŐŝŽŶĂůWƌŽŐƌĂŵZĞǀŝĞǁDĂƚƌŝdž
>ĂƐƚZĞǀŝƐĞĚ͗ϭϬ͘ϯϬ͘ϮϬϮϱ
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Topic San Francisco Long Beach Los Angeles Santa Ana Pasadena existing building’s Gross Floor Area; if a
project exceeds this limit, the additions in
excess of 33% must meet generally
prevailing code requirements.
x Buildings must have a valid
certificate of occupancy issued at
least 5 years prior
x Buildings or portions of buildings
used for lodging/hotels/motels are
explicitly excluded from using this
section
Eligible
Buildings
Nonresidential buildings.

Must be in defined downtown districts,
<33% addition to GFA.

Existing buildings citywide as specified by the
AR zones; must meet city/historic standards;
special rules in coastal zone.

All structures must conform with the building
andzoning codes at time of construction.
15 year minimum waiting period after
building permit issuance before proposed
adaptive reuse of building; parking
areas/structures within a building may be
converted in at least 5 years have elapsed
since BP issuance; at least 5 years has
elapsed + approva
l by the zoning
administrator.

Buildings built before July 1974 or
listed/eligible as historic.

Existing nonresidential building (excluding
buildings or portions of buildings used for
Lodging - Hotels, Motels uses)
x Note: under current Pasadena law,
hotels of under 80 rooms may be
converted to affordable housing.

Waived/
Reduced
Developmen
t Controls
Lot coverage waived, open space waived,
streetscape and pedestrian improvements
waived, DU exposure fulfilled through
alternative standards, bike parking, DU mix
requirement waived, transportation
demand management waived, protected
pedestrian/cycling/transit-oriented street
frontage requirements for existing waived,
height requirement flexibility.

Nonconforming setbacks may remain,
existing height exempt from est. height limits
(Any new or additional habitable space or
floors must comply with height limits, unless
waived by the SPR Committee), existing
parking to remain.

Units size: Res units must be a min. 450 sq.ft
and project avg no less than 700 sq.ft.

Must comply with Floor Area Ratio (FAR),
Landscaping, Lot Coverage, Open Space,
and any other applicable development
standards of the underlying zone, unless
waived by the SPR Committee.

Min Unit size: exempt (must meet building
code)
FA: existing floor area may be maintained
Ͳ Adaptive reuse projects that remove
internal spaces to create courtyards
or light wells may add equivalent
area on the site or adjacent lot
Height: existing may be maintained, if
affordable is provided 2 additional stories
above zone’s allowable height are permitted
Yards: existing may be maintained
Amenities: 1 new story permitted and not
counted as new FA as long as its accessible
to all residents
Step backs/transitional height: exempt
Open space/Landscaping: new
OS/landscape not required but 50% of
existing outdoor OS must be maintained and
ROW trees must be provided/existing street
trees maintained.

Setbacks: may remain
Height: May remain, rooftop construction is
included in the height exemption
Loading: no new loading zone required is it
does not exist
Unit size minimum: 500 SF
Ground
-floor commercial req - ground floor
of a multi-level building with three stories or
more containing street frontage shall be
used as commercial/retail space.

Common area spaces: may not exceed 50%
of the ground floor square footage
Open Space: 10% of building SF, at least 25%
of OS must be community/rec room, the
remaining may be private balconies
relaxed parking and zoning requirement
Height: For appurtenances and residential
amenities: Existing height may be exceeded
by max of 15’ and will not count toward max
height requirements
Floor Area:
x Additional floor created within
existing building will not count
toward FAR max
x
Residential Amenities can increase
exiting floor areas up to 10% and will
not count towards FAR Max
Unit Size: The average unit size shall be a
minimum of 450 square feet. No average unit
size is required for projects that are 100
percent affordable or have less than 10 units.

Parking NA x Shared parking shall conform to the code
for any project
Parking Impacted Area
x 1/DU + 1/guest
x Required parking spaces to be the
number that existed on site, and
maintained and not reduced but allows
some reconfiguration of spaces without
penalty
New parking spaces not be required for any
converted use within the building,
New SF associate with new units: 2
spaces/DU
No new parking is required
Shared Parking:
x Requires: Administrative MCUP,
being within an allowable walking
ĚĂƉƚŝǀĞZĞͲƵƐĞʹ ZĞŐŝŽŶĂůWƌŽŐƌĂŵZĞǀŝĞǁDĂƚƌŝdž
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ϰͮ WĂŐĞ
Topic San Francisco Long Beach Los Angeles Santa Ana Pasadena x 2/1,000 SF of usable internal non-res
space
x In MU the first 3,000 SF of non are
exempt from parking requirements
x Up to 75% of spaces provided may be
tandem
x Any further reductions must be approved
by SPR
Outside Parking Impact. Areas
x No add’l onsite parking required for
conversion to res
x 1/1,000 SF of internal usable non-res
space
x In MU the first 6,000 SF of non are
exempt from parking requirements
x Up to 50% of spaces provided may be
tandem
x Reduction in number of spaces allowed
if new residential use requires fewer
spaces, or under AB2097
distance, contract, and location
within Zoning district.
x May Require: A parking study to
determine share parking reduction
x Loading spaces may be shared
Tandem Parking:
x Allowed for Multi-Family and
residential component of mixed-use
(Assigned to same unit, up to 30%).

Day-Care Centers and homes,
x Other non residential uses (Tandem:
75% of total off street parking; Triple
Stacked: 50% of off street)
x Dimensions: 2 combined spaces (9’
x34’)- could be modified through
MCUP
Off Street Parking
x No new parking shall be required,
existing parking may be reduced
x Car-Share can help reduce
residential parking requirements (1
car share = 5 parking spaces) up to
lesser of 20% reduction and 10 car
-
share parking spaces
Density
limits
No density limit for projects in:
x Northeast Waterfront Historic District
x Jackson Square Historic District
x Jackson Square Historic District
Extension
NA New residential uses not subject to minimum
lot area per unit requirements of their zone
The project can exceed the maximum general
plan density for the site provided the
Adaptive Reuse Project is in compliance with
the development standards.

Adaptive Reuse Projects shall not be subject
to dwelling unit per acre requirements.

Average unit size shall be a minimum of 450.
(Does not apply to projects that are 100%
affordable or have less than 10 units)
FAR:
x Additional floor area created within
existing building shall not count
toward FAR
x Additional floor area compliant
with Building or Fire Codes does
not count towards Floor area ratio
maxs
x Building existing floor area can be
increase up to 10% for residential
amenities
ĚĂƉƚŝǀĞZĞͲƵƐĞʹ ZĞŐŝŽŶĂůWƌŽŐƌĂŵZĞǀŝĞǁDĂƚƌŝdž
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Topic San Francisco Long Beach Los Angeles Santa Ana Pasadena Height
x For appurtenances and residential
amenities: Existing height may be
exceeded by max of 15’ and will
not count toward max height
requirements
Affordable
Housing
NA NA x Affordable Hosing Linkage Fee - Adaptive
Reuse conversions subject to Affordable
Housing Linkage Fee ordinance
x As part of Unified Adaptive Reuse
Projects, new construction may utilize
unlimited density as an incentive
x Two additional stories, not considered
as new floor area or height, up to
maximum height allowed by Zone or
Height District may be added on top of
existing buildings
NA x No requirement for affordable, but
incentive is no average unit size is
required for projects that are 100
percent affordable or have less than
10 units.

Approval
Process
If a project seeks exceptions that are
waived or modified in subsection (d)
above, the hearing requirements in
Section
309 shall not apply as to the
consideration of those exceptions. But if a
project seeks exceptions not otherwise
waived or modified in subsection (d)
above, the hearing requirements of
Section
309 shall apply.

Determination of adaptive re-use is at the
discretion of the Zoning Administrator,
Building Official and Fire Official.

Site Plan Review (SPR) required and coastal
permit if applicable, plan check, CoO.

By-right
Buildings at least 15 y/o and parking/parking
structures at least 5 years old –r e v i e w b y
Dept. of Building and Safety
Ͳ Does not include sites with historic
resources as identified in
HistoricPlacesLA
Discretionary
Buildings between 5-15 years old must be
approved by the zoning administrator
Not subject to CEQA
City planning approval, administrative
standards, fire/building code compliance.
x The adaptive reuse pathway is
streamlined compared to typical full
discretionary development reviews.
x The review authority for eligible projects
is the Director rather than a full
commission in many cases.
x Applicants still need to follow the
standard building permit process
(engineering, fire, life safety, etc) once
zoning/design review is cleared.

What r
Adaptive reuse projects meeting the
ordinance criteria will undergo a
consolidated design review process with
the Director designated as the review
authority, regardless of project size
thresholds that would normally trigger
Design Commission review.

Incentives Waived Development or Development
Impact Fee. Waived on any net new GFA of
residential up to 110% of the FGA of non-
res converted to res.

Mitigation flexibility (historic/resource), code
waivers, flexible parking, maintained context
for neighborhoods.

Density bonuses, open space and parking
waivers, minimum unit size removed,
affordable housing linkage.

Allowed residential in nonresidential zones;
project qualifies even if base zone doesn’t
permit residential.
x Relaxed parking requirements
x Exemptions from dwelling unit per
acre requirements
x Flexibility on floor area ratios for
modifications within existing
buildings
ĚĂƉƚŝǀĞZĞͲƵƐĞʹ ZĞŐŝŽŶĂůWƌŽŐƌĂŵZĞǀŝĞǁDĂƚƌŝdž
>ĂƐƚZĞǀŝƐĞĚ͗ϭϬ͘ϯϬ͘ϮϬϮϱ
ϲͮ WĂŐĞ
Topic San Francisco Long Beach Los Angeles Santa Ana Pasadena x Height allowances of up to 15
additional feet for residential
amenities
Historic
Preservation
Streamlined admin Certificates of
Appropriateness, relaxed minor permits for
historic buildings.

All projects follow local/state/federal historic
provisions.

Fire/life safety flexibility for historic reuse,
but must comply w/ existing state law.

Applies to eligible historic buildings,
exception/process to request alternative
standards adopted.

Variance for Historic Resources
Unique/
Notable
Provisions
Flexible Workspace land use type,
expanded retail/entertainment rights,
alternative building code standards for
reuse.

Special development standards for coastal
projects, adaptive reuse manual.

Deviations from the building code can be
requested and are reviewed on a case by
case basis
Exempts mezzanines/lofts from floor area,
density waivers for conversions, triggers
pandemic recovery focus.

Ground floor commercial required; minimum
unit size 500 sf; must comply with Housing
Opportunity Ordinance.

Average unit size shall be a minimum of 450.
(Does not apply to projects that are 100%
affordable or have less than 10 units)
flexibility on floor area ratios for
modifications within existing buildings, and
height allowances of up to 15 additional feet
for residential amenities
Each dwelling unit must have at least 150
square feet of open space, which can include
common areas
Limited new construction is permitted in
conjunction with adaptive reuse projects,
allowing up to a 50% increase in units or up
to the maximum General Plan density,
whichever is less
Units
Created
Data not available Data not available Enabled the creation of more than 12,000 housing units in Downtown alone
Data not available May be too early to quantify.

Planning
Department
Contact
Information
San Francisco Planning Department
(628) 652-7600
[email protected]
Community Development / Planning Bureau
– City of Long Beach
Permit Center / Planning counter:
562.570.6194
[email protected]
Main Public Counter (Metro/Downtown DSC)
Phone: (213) 482-7077
[email protected]
[email protected]
Planning & Building Agency – City of
Santa Ana (Planning Division)
Phone: (714) 647-5804
Email: [email protected]
Planning & Community Development
Department (Current Planning and Zoning
Services)
(626) 744-4009
[email protected]
Other
Resources
Spur Presentation AR Technical Manual (2014) LA Fact Sheet Adaptive Reuse Zoning Code Amendments Presentation to City Council
Additional Resource Links
ϭ͘ ŚƚƚƉƐ͗ͬͬƚĞƌŶĞƌĐĞŶƚĞƌ͘ďĞƌŬĞůĞLJ͘ĞĚƵͬǁƉͲĐŽŶƚĞŶƚͬƵƉůŽĂĚƐͬϮϬϮϭͬϭϭͬĚĂƉƚŝǀĞͲZĞƵƐĞͲEŽǀĞŵďĞƌͲϮϬϮϭ͘ƉĚĨ Ϯ͘ ŚƚƚƉƐ͗ͬͬƉĞƌŬŝŶƐĐŽŝĞ͘ĐŽŵͬŝŶƐŝŐŚƚƐͬƵƉĚĂƚĞͬƐĂŶͲĨƌĂŶĐŝƐĐŽͲĂĚŽƉƚƐͲŽƌĚŝŶĂŶĐĞͲĨĂĐŝůŝƚĂƚĞͲĐŽŶǀĞƌƐŝŽŶͲŽĨĨŝĐĞͲďƵŝůĚŝŶŐƐͲŚŽƵƐŝŶŐ ĚĂƉƚŝǀĞZĞͲƵƐĞʹ ZĞŐŝŽŶĂůWƌŽŐƌĂŵZĞǀŝĞǁDĂƚƌŝdž
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ϳͮ WĂŐĞ
ϯ͘ ŚƚƚƉƐ͗ͬͬƐĨďŽƐ͘ŽƌŐͬƐŝƚĞƐͬĚĞĨĂƵůƚͬĨŝůĞƐͬŽϬϭϮϮͲϮϯ͘ƉĚĨ ϰ͘ ŚƚƚƉƐ͗ͬͬĚŽĐƵŵĞŶƚƐ͘ĐŽĂƐƚĂů͘ĐĂ͘ŐŽǀͬƌĞƉŽƌƚƐͬϮϬϭϲͬϯͬƚŚϮϯĂͲϯͲϮϬϭϲ͘ƉĚĨ ϱ͘ ŚƚƚƉƐ͗ͬͬƉůĂŶŶŝŶŐ͘ůĂĐŝƚLJ͘ŐŽǀͬŽĚŽĐƵŵĞŶƚͬϲϳϮϱĨϯϰϳͲϳĨĚďͲϰϮĨĂͲĂĂϲĞͲϰϰĐϯϳĨϴĨĂϵϵϵͬ&ĂĐƚͺ^ŚĞĞƚͺͲͺĚĂƉƚŝǀĞͺZĞƵƐĞͺKƌĚŝŶĂŶĐĞ͘ƉĚĨ ϲ͘ ŚƚƚƉƐ͗ͬͬǁǁǁ͘ŚĐĚ͘ĐĂ͘ŐŽǀͬŚŽƵƐŝŶŐͲĞůĞŵĞŶƚƐͬĚŽĐƐͬƐĂŶƚĂͲĂŶĂͲϲƚŚͲĂĚŽƉƚĞĚϬϳϮϲϮϮ͘ƉĚĨ ϳ͘ ŚƚƚƉƐ͗ͬͬǁǁǁ͘ƐĂŶƚĂͲĂŶĂ͘ŽƌŐͬĚŽĐƵŵĞŶƚƐͬĂĚĂƉƚŝǀĞͲƌĞƵƐĞͲŽƌĚŝŶĂŶĐĞͲĂŶĚͲĞůŝŐŝďůĞͲůŽĐĂƚŝŽŶƐͲŵĂƉͬ ϴ͘ ŚƚƚƉƐ͗ͬͬƐĨƉůĂŶŶŝŶŐ͘ŽƌŐͬƉƌŽũĞĐƚͬĚŽǁŶƚŽǁŶͲĂĚĂƉƚŝǀĞͲƌĞƵƐĞͲƉƌŽŐƌĂŵ ϵ͘ ŚƚƚƉƐ͗ͬͬĐŽĚĞůŝďƌĂƌLJ͘ĂŵůĞŐĂů͘ĐŽŵͬĐŽĚĞƐͬƐĂŶͺĨƌĂŶĐŝƐĐŽͬůĂƚĞƐƚͬƐĨͺƉůĂŶŶŝŶŐͬϬͲϬͲϬͲϮϬϭϯϱ ϭϬ͘ ŚƚƚƉƐ͗ͬͬǁǁǁ͘ƐŽŵ͘ĐŽŵͬŶĞǁƐͬƐŽŵͲƐŚĂƉĞƐͲŶĞǁͲďƵŝůĚŝŶŐͲĐŽĚĞͲŐƵŝĚĞůŝŶĞƐͲƚŽͲŚĞůƉͲŝŶĐƌĞĂƐĞͲŽĨĨŝĐĞͲƚŽͲƌĞƐŝĚĞŶƚŝĂůͲĐŽŶǀĞƌƐŝŽŶƐͲŝŶͲĚŽǁŶƚŽǁŶͲƐĂŶͲĨƌĂŶĐŝƐĐŽͬ ϭϭ͘ ŚƚƚƉƐ͗ͬͬǁǁǁ͘ƐĨ͘ŐŽǀͬƐŝƚĞƐͬĚĞĨĂƵůƚͬĨŝůĞƐͬϮϬϮϰͲϬϵͬ'ͲϮϵͺĚĂƉƚŝǀĞZĞƵƐĞͺϮϬϮϰϬϵϮϱ͘ƉĚĨ ϭϮ͘ ŚƚƚƉƐ͗ͬͬǁǁǁ͘ůŽŶŐďĞĂĐŚ͘ŐŽǀͬŐůŽďĂůĂƐƐĞƚƐͬƵƉůĂŶͬŵĞĚŝĂͲůŝďƌĂƌLJͬĚŽĐƵŵĞŶƚƐͬƌĞƐŽƵƌĐĞƐͬƵƉůĂŶͲƉŚĂƐĞͲϭͲͲͲnjŽŶŝŶŐͲĐŽĚĞͲƵƉĚĂƚĞ ϭϯ͘ ŚƚƚƉƐ͗ͬͬǁǁǁ͘ƐƉƵƌ͘ŽƌŐͬƐŝƚĞƐͬĚĞĨĂƵůƚͬĨŝůĞƐͬϮϬϮϱͲϬϵͬĂĚĂƉƚŝǀĞͺƌĞƵƐĞͺďƌŽĐŚƵƌĞ͘ƉĚĨ ϭϰ͘ ŚƚƚƉƐ͗ͬͬůďďƵƐŝŶĞƐƐũŽƵƌŶĂů͘ĐŽŵͬďƵƐŝŶĞƐƐͬŶĞǁƐͬƌĞǀŝƐŝƚŝŶŐͲƚŚĞͲůŽŶŐͲďĞĂĐŚͲĂĚĂƉƚŝǀĞͲƌĞƵƐĞͲŽƌĚŝŶĂŶĐĞͬ ϭϱ͘ ŚƚƚƉƐ͗ͬͬĐŝƚLJĐůĞƌŬ͘ůĂĐŝƚLJ͘ŽƌŐͬŽŶůŝŶĞĚŽĐƐͬϮϬϮϭͬϮϭͲϭϮϯϬͲ^ϵͺŵŝƐĐͺϳͺϭϬͲϯϬͲϮϬϮϰ͘ƉĚĨ ϭϲ͘ ŚƚƚƉƐ͗ͬͬǁǁǁ͘ƐĂŶƚĂͲĂŶĂ͘ŽƌŐͬǁŝƐĞƉůĂĐĞͲƉƐŚͲĂĚĂƉƚŝǀĞͲƌĞƵƐĞͲĚĞǀĞůŽƉŵĞŶƚͬ

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