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R5G-Ordinances Modifying Building Fire Planning And Public Works FeesCOMMISSION ITEM SUMMARY Condensed Title: Ordinances Modifying The Building, Fire, Planning And Public Works Departments' Fees Related To The Building Develo ment Review Process lm lamented On Februa 1, 2010. K~}'_ Intended Outcome Supf!orted: Strengthen Internal Controls; Maximize Efficient Delivery Of Services; Increase Community Satisfaction With City Government; Minimize Taxes I Ensure Expenditure Trends Are Sustainable Over The Long Term; Improve The City's Overall Financial Health And Maintain Overall Bond RatinQ Supporting Data (Surveys, Environmental Scan, etc.): In the 2012 Community Satisfaction survey, which covered the period of 2009 through February 2012, 47% of businesses described their experience with the Building Department as positive, and 58% gave a positive evaluation of the department for overall satisfaction. 54% of businesses perceived the Building Department as being open to hearing their concerns. 50% of businesses thought the Building Department's inspections were consistent over time or believed that the inspections were fair. 70% of businesses rated Building Department employees as courteous and professional and the same percentage thought employees had proper training and knowledge. Issue: Shall the Mayor and City Commission approve the ordinances amending various fees related to the Building Develo ment Review Process in the Cit of Miami Beach? Item Summary/Recommendation: On January 13, 2010, the City Commission approved four ordinances for the Building, Fire, Planning and Public Works departments related to the fees for the Building Development Process. These ordinances went into effect on February 1, 2010 and provided a complete overhaul of the fee structure for the above mentioned departments. Additional changes were adopted by the City Commission in September 2011 that went into effect on October 1, 2011, including reductions to the fees for certain permit types, a continuation of discounts for permit fees related to certain permit types, a waiver of the Consumer Price Index (CPI) adjustments for 2011 and 2012, and the introduction of a cap on permit fees at 10% of the calculated cost of construction. The Administration had stated that it would return to the Committee for additional discussion after the 2011 changes were adopted. The Administration held discussions with the Finance and Citywide Projects Committee (Committee) in July and August, 2012 regarding the following proposals, and the Committee recommended that they be forwarded to the full City Commission for further consideration: 1) Fees related to Planning and Public Works' efforts in the Alteration/Remodeling permit types should be reduced, 2) Discounts should continue past September 30, 2012, 3) The CPI increase for 2013 pursuant to the existing ordinance should not be waived, and 4) Fees related to certain permit types should be revised, based on the evaluation of the 10% cap on permit fees and further evaluation of permit fees in general, and that the CPI increase should not apply to these permit types. Additionally, there is a scrivener's error in Section 15-42 "Adjusted Rates" in the City's Code of Ordinances relative to the fees for the Planning Department where the language refers just to that particular section but should refer to the Article, not the Section. The Administration is recommendinQ that the City Commission adopt the ordinance with the proposed revisions. Board Recommendation: The Finance and Citywide Projects Committee heard this item at its July 10, 2012 and August22, 2012 meetings and recommended that the Ci Commission ado t the ordinances. Financial Information: Source of Amount Account ~ 1 2 I Total Financial Impact Summary: A cumulative loss of permit revenue approximately $295,000 annually for the Building Development Process departments (Building, Fire, Planning and Public Works). AGENDA 1 TE M ---"f<_$_(;.. __ q-JZ.-{ DATE ____ _ MIAMI BEACH 5 MIAMI BEACH City of Miami Beach, 1700 Convention Center Drive, Miami Beach, Florida 33139, www.miamibeachfl.gov TO: FROM: DATE: COMMISSION MEMORANDUM Mayor Matti Herrera Bower and Members of the City Co'Tsion Kathie G. Brooks, Interim City Manager /4/-• September 12, 2012 SUBJECT: ORDINANCES MODIFYING THE BUILDING, FIRE, PLANNING AND PUBLIC WORKS DEPARTMENTS FEES RELATED TO THE BUILDING DEVELOPMENT PROCESS IMPLEMENTED ON FEBRUARY 1, 2010. ADMINISTRATION RECOMMENDATION The Administration recommends that the City Commission adopt the four ordinances amending various fees related to the Building Development Process in the City of Miami Beach. INTRODUCTION On January 13, 2010, the City Commission approved four ordinances for the Building, Fire, Planning and Public Works departments related to the fees for the Building Development Process. These ordinances went into effect on February 1, 2010 and provided a complete overhaul of the fee structure for the above mentioned departments. Additional changes were adopted by the City Commission in September 2011 that went into effect on October 1, 2011, including reductions to the fees for certain permit types, a continuation of discounts for permit fees related to certain permit types, a waiver of the Consumer Price Index (CPI) adjustments for 2011 and 2012, and the introduction of a cap on permit fees at 10% of the calculated cost of construction. The Administration had stated that it would return to the Committee for additional discussion after the 2011 changes were adopted. The Administration held discussions with the Finance and Citywide Projects Committee (Committee) in July and August, 2012 regarding the following proposals, and the Committee recommended that they be forwarded to the full City Commission for further consideration. • Fees related to Planning and Public Works' efforts in the Alteration/Remodeling permit types should be reduced, • Discounts should continue past September 30, 2012, and become permanent rather than roll over from year to year, • The CPI increase for 2013 pursuant to the existing ordinance should not be waived, and • Fees related to certain permit types should be revised downward, based on the evaluation of the 1 0% cap on permit fees and further evaluation of permit fees in general, and that the CPI increase should not apply to these permit types. 6 City Commission Memorandum September 12, 2012 Building Development Process Fees Page 2 of9 Additionally, there is a scrivener's error in Section 15-42 "Adjusted Rates" in the City's Code of Ordinances relative to the fees for the Planning Department where the language refers just to that particular section but should refer to the Article, not the Section. The Administration is recommending the language in the Ordinance be changed for accuracy. BACKGROUND Building Development Process The Building Development Process ("Process") in the City of Miami Beach includes the Building Department, the Fire Department's Fire Prevention Division, the Planning Department and the Public Works' Engineering Division. The Building Department provides process intake, routing, billing, and computer support for the entire Process. The Building Department staff conducts plans review and inspections for plumbing, structural, building, electrical, governmental compliance, elevator, accessibility and mechanical trades as required by the different permit types for compliance with Florida Building Code as well as the Miami Beach City Code. Additionally, the Building Department reviews permit applications for compliance with outside regulatory agencies. The Fire Department's Fire Prevention Division is involved in the majority of building permits issued by the City, with the exception of single-family homes. A Fire Department fee is collected for each building permit corresponding to the Fire Department's review and inspection. The Planning Department serves as staff to the City's Planning Board, Board of Adjustment, Design Review Board, Historic Preservation Board, and Single Family Residential Review Panel. Depending on the scope of the project, a new development is required to receive approval from one or more of these Boards. The Planning Department processes applications, reviews them and prepares recommendations to all of the above Boards. Fees are assessed for the various planning applications according to a fee schedule contained within the City Code. The Planning Department also reviews all building permits for compliance with the City's land development regulations, comprehensive plan and consistency with architectural review guidelines and preservation appropriateness criteria. This zoning review is required to ensure compliance with existing legislation, zoning requirements, and state growth management requirements. The Public Works Department Engineering Division staff conducts plan reviews and inspections for all construction activities that occur within the public right-of-way (streets, roadways, waterways, alleys and sidewalks), public property and easements. The Public Works Department also performs plan review activities supporting a variety of Building Department permits on private property that will connect and/or will have potential impacts to City-owned utilities, right-of-way and/or utility easements. Further, the Building, Fire, and Planning Departments participate in the Certificate of Occupancy or Completion process that allows for the use and occupancy of the structure based on certifying that the use is permitted and that the structure is in compliance with applicable City Codes. 7 City Commission Memorandum September 12, 2012 Building Development Process Fees Page 3 of9 2009 Building Development Process Fees Study In mid-2009, the City initiated a study of costs and fees related to the Process with the consulting firm Maximus Consulting Services Inc. ("Maximus"). The primary focus of the study was to develop a simplified fee structure and associated fee levels for services performed by the Building Department in enforcing the Florida Building Code, as well as services performed by the Fire, Planning, and Public Works Departments in enforcing other Federal, State and City Codes related to building permits. On January 13, 2010, the City Commission approved four ordinances for the Building, Fire, Planning and Public Works departments related to the fees for the Building Development Process, as outlined in the Maximus study. These ordinances went into effect on February 1, 2010 and provided a complete overhaul of the fee structure for the above mentioned departments. At the time of implementation, there were increases in the fees related to the Process for the Fire, Planning, and Public Works Departments. These were offset by discounts in the Building Department fees so that, in the aggregate, the total combined fees charged to the development community were to remain at current levels. Decreases in Building Department revenues were partially replaced by previously set aside Building Department reserves in FY 2009/1 0 and are budgeted to be offset in FY 2011/12 so that costs related to enforcing the Florida Building Code continue to be offset by Building revenues. Subsidies from other general fund revenue sources were $725,000 in FY 2009/10, and $1 million in FY 2010/11. It is important to note that discounts were applied to fees to achieve three (3) objectives: 1) ensure that permits are pulled for small projects. If permit fees represent a large or excessive percent of the project costs, it will discourage customers from pulling permits; 2) provide lower fees for residential projects; and 3) incentivize environmental projects. In 2011, the Administration presented additional permit fee changes to the Committee for consideration. These included additional reductions to the fees for certain permit types, a continuation of discounts for permit fees related to certain permit types, a waiver of the Consumer Price Index (CPI) increases for 2011 and 2012, and the introduction of a cap on permit fees at 10% of the calculated cost of construction. The Committee recommended these additional changes, and they were adopted by the City Commission and made effective on October 1, 2011. During the discussions regarding the 2011 changes, the Administration noted that further changes were still being considered and would be brought back to the Committee for consideration. Discussions were held at the July 10, 2012 and August 22, 2012 Committee meetings, where the Committee recommended that the actions be brought forth to the full City Commission for ratification. Current Discussion Points At this time, the Administration is proposing revising the permit fees as follows: • Discounts should continue past September 30, 2012 When the current fee structure was adopted, there were some discounts built into the fee structure that were set to expire on September 30, 2011. Last year, these were extended and are now set to expire on September 30, 2012. 8 City Commission Memorandum September 12, 2012 Building Development Process Fees Page 4 of9 The original intent of these discounts were: 1) To ensure that permits are pulled for small projects. If permit fees represent a large or excessive percent of the project costs, it will discourage customers from pulling permits; 2) To provide lower fees for residential projects; and 3) To incentivize environmental projects. The Administration is recommending that the ordinance be changed such that the discounts remain permanently in effect. • Fees related to Planning and Public Works' efforts in the Alteration/Remodeling permit types should be reduced As a result of concerns that were raised by certain segments of the development community, as well as some concerns raised by staff, regarding the fee amounts and administrative processes related to the fees, the Administration brought Maximus back to review the status of the permit fee implementation to answer whether or not the City met its original objectives, if staff was applying the fee structure correctly, and to review the issues being encountered and identify appropriate solutions. A copy of the Maxim us report is attached as Attachment A. Maximus' re-evaluation of the City's implementation revealed that the City's new permit fee structure based on square feet is more simple than the previous schedule, which was based on construction cost. Maximus spoke at length with Building Department staff to determine if the staff was feeing permit applications correctly and found that indeed they were. With regard to whether or not the Building Development Process departments were recovering more in fees than costs for operation, Maximus determined that the departments were under-recovering their actual costs. Fee collection was actually less than what Maximus originally projected, and not covering the costs of the departments related to the Building Development Process. Based on discussions Maximus had with staff, Maximus proposed refining plan review and permit inspection times for the Alteration/Remodel permit types by the Planning and Public Works Departments. It should be noted that the levels of effort suggested for adjustment are not significant components of the overall fees. Maxim us estimates that the impact to the permit fees collected will result in a savings to customers in the amount of approximately $493,000. This amount will fluctuate depending on the number of permits applied for, the amount of square footage being renovated, and other factors outside of the City's control. The impact to the Planning Department Permit Fee revenue was more significant, estimated at approximately $412,000, and the impact to the Public Works Department budget is approximately $81,000, which will have to be replaced by General Fund dollars to completely fund the operations. The Administration recommends revising the permittees for the Planning and Public Works Departments for Alteration/Remodeling permit types in an effort to provide 9 City Commission Memorandum September 12, 2012 Building Development Process Fees Page 5 of9 more accurate permit fees and additional savings to the City's Building Development Process customers. • The CPI increase for 2013 pursuant to the existing ordinance should not be waived The current ordinances require the fees to be administratively adjusted annually to reflect increase( s) or decrease( s) in the Consumer Price Index for Consumers in the Southeast United States for all items, unless otherwise directed by the City Commission. The Consumer Price Index (CPI) adjustments for 2011 and 2012 were waived by the City Commission, finding it to be in the best interest of the City and the public. As a point of information for the City Commission's consideration, the CPI for the southern region for all items from October 2010 through October 2011 was an increase of 3. 7%. This means that the fees will be increased by 3. 7%. The estimated impact on the Building Development Process departments' FY 2012/13 Current Service Level (CSL) revenues is approximately $404,000 if enacted effective October 15, 2012. Further, the preliminary estimated subsidy for the FY 2012/13 CSL budget from non-Building General Fund revenues is approximately $1.4 million, including indirect costs. Without the use of Building Department reserves set aside in prior years, the subsidy would have been 2.9 million. The Administration is recommending allowing the CPI increases of 3.7% take effect effective October 15, 2012. It should be noted that the respective sections of the City's Code of Ordinances dealing with the fees associated with all four ( 4) departments' role in the Process allow for the fees to be "administratively adjusted annually", and not changed by ordinance. However, since so many other changes are proposed, the Administration felt it necessary to include the adjustment in the attached ordinances to eliminate confusion for the codifier, staff and customers. • Fees related to certain permit types should be revised based on the 10% cap on permit fees and further evaluation of permit fees in general As part of the revisions to the Building Department fees adopted in September 2011, effective October 1 , 2011 , there is a 1 0% cap on permit fees. Section 14-61 (p) of the City's Code of Ordinances requires the Administration to reevaluate the permit fees of any permit application where the permit fees, not including any outside agency fees or surcharges, are greater than 10% of the value of construction as declared on the permit application. Excluded from this process are permit applications where the value of construction is less than $1,000 or the permit fee is the minimum permit fee. The reevaluation process consists of a plan reviewer using industry standard cost estimating resources to confirm whether the value of construction as stated on the permit application is in line with the construction industry. The Administration has determined that the level of effort to reevaluate the construction values for all applications triggered by the 10% cap would detract from the plan review level of service if conducted by existing City staff. So, at the current time, this reevaluation process is being conducted by supplemental staff hired through an agreement between the City and a staffing provider, at a cost of approximately $140,000 per 10 City Commission Memorandum September 12, 2012 Building Development Process Fees Page 6 of9 year. It should be noted that this supplemental staffer is also a licensed inspector, and can be called on to provide other functions as needed by the Department, so the $140,000 is not entirely attributable to the 10% rule. However a very conservative estimate is that approximately 55% of this inspector's time is utilized in conducting the reevaluations. Based on the plans submitted with the permit application, the evaluator uses RS Means data, a widely accepted provider of construction costing, to determine the industry standard value for the work described (determined value). The permit fees are evaluated against the determined value to see if the fees are still greater than 10% of the determined cost. • If the permit fees are less than 1 0% of the determined cost, no refund is processed. • If the fees are still more than 1 0% of the determined cost, a refund is processed after the project construction is complete and passes all required inspections, assuming that the refund meets the requirements of Section 14- 62(b) of the City's Code of Ordinances (refunds must exceed $100 in order to be refunded). • If a construction value cannot be determined by the above-indicated resources, typically either because plans are not required as part of the application submittal or RS Means doesn't have an appropriate category, the actual level of effort for plan review and inspection shall be calculated and charged, but shall not exceed the originally calculated fee at time of permit application. When this occurs, the level of effort costs cannot be calculated until the construction is complete, so a determination as to what the permit fee will be and if any refund is due to the customer cannot be made until after all inspections are complete and the project has received final approval. The 10% permit fee cap has been in place since October 1, 2011. Between October 1, 2011 and July 31, 2012, there were 11,172 permit applications approved. Of those, only 1,481 (13.26%) triggered a 10% cap evaluation. The permit fees associated with the over 11 ,000 approved permit applications exceeded $8.6 million. If the permit fees associated with the permits that triggered the 10% cap were all lowered to no more than 10% of the stated value of construction, the potential reduction in permit fees would be approximately $511,000, which represents approximately 6% of permit fees collected. As of August 1, 2012, 1 ,434, or approximately 97%, of the permits that triggered a 10% cap reevaluation had been evaluated. Of those, 291 were approved for a refund. This represents less than 20% of all permits triggered for reevaluation, and less than 3% of all approved permit applications. Approximately $142,000 has been approved for refunds back to the customers based on the 291 permits. This represents 1.65% of the permit fees collected for the 11,172 permit applications approved as of July 31, 2012. Of those remaining to be reviewed, the maximum amount of any potential refunds was approximately $53,000. This number will be 11 City Commission Memorandum September 12, 2012 Building Development Process Fees Page 7 of9 revised as reevaluation takes place. There are still approximately 180 permits that have been evaluated, but for which an industry standard construction cost could not be determined, either because the permit application does not require a plan submittal, or because RS Means does not include a category or methodology for costing that kind of work out. The permit fees for this work will be determined based on actual level of effort, but shall not exceed the permit fee costs calculated at time of permit application. The total cumulative amount of any potential refunds is approximately $125,000. There are approximately 960 permits (approximately 65% of those triggered for a 10% cap evaluation) that have been reevaluated for which no refund is due to the customer because the permit fees calculated at time of application are less than 10% of the value of work as determined using industry standard cost estimating methodologies, as opposed to the value submitted at the time of application by the applicant. The sum of the refunds approved to date, the maximum exposure of those permit fees yet to be reevaluated, and those that will be determined by level of effort is $320,000. This equates to 3.7% of the approximately $8.6 million collected in permits fees for those permits approved during the stated timeframe. It should be stated that evaluating these plans, determining the industry standard construction cost, and approving and processing any potential refunds is a labor intensive process. The cost of supplemental staff reevaluate all triggered plans is conservatively estimated to be approximately $77,000. Staff time related to reviewing the determinations and processing the refunds has not been captured, but has been time consuming. Recommendations for Permit Fee Changes Related to 10% Permit Fee Cap With the analysis of the 1 0% permit fee cap impact on revenue, staff has also reviewed the types of permits most frequently resulting in a refund after reevaluation of the permit fees. It is important to focus on those permit types approved for a refund, as those are the ones where the reevaluation is reflecting that current permit fees are indeed greater than 10% of the industry standard value of construction. The five (5) permit types that resulted in the most refund approvals are provided here in order from highest number of approvals to lowest. These five (5) permit types alone represent approximately 70% of the permits where the reevaluation resulted in a refund being issued to the customer. • Alteration/Remodeling Permits-54 of 291 (18.56%) • Alteration/Remodeling Condo Permits-46 of 291 (15.81%) • Low Voltage Electrical Permits -44 of 291 ( 15.12%) • Plumbing Alteration/Remodeling Permits -33 of 291 ( 11.34%) • Partial Demolition Permits -25 of 291 (8.59%) As was discussed at the July 10, 2012 Committee meeting, the Administration has already proposed changes to the Alteration/Remodeling and Alteration/Remodeling Condo permit types, by refining the fees for the Planning and Public Works Departments on alteration/remodeling work. It is anticipated that these changes will reduce the 12 City Commission Memorandum September 12, 2012 Building Development Process Fees Page 8 of9 Alteration/Remodeling and Alteration/Remodeling Condo permits fees significantly enough to no longer trigger a reevaluation on the majority of these types of permits. With regard to the Low Voltage Electrical Permits, Plumbing Alteration/Remodeling Permits and Partial Demolition permits, the Administration is proposing permit fee refinement as identified in Appendix A of the City's Code of Ordinances, as outlined in the attached summary of proposed fee recommendations (Exhibit 2), which outlines the permit fees for the Building, Fire, Planning and Public Works Departments. Again, it is anticipated that these reductions will reduce permit fees on these permit types significantly enough to have permit fees remain under 10% of the determined value of construction for the majority of these permit types. In the case of Low Voltage Electrical Permits, a fee will no longer apply to these applications when they are submitted as part of a Master Permit, which will result in further savings to customers. In addition to the top five (5) permit types approved for refund, the Administration is proposing refinements to the following permit types. These permit types represent another approximately 7% of the permit types approved for a refund, which if approved, will address approximately 77% of the permits approved for a refund. • Awning/Canopy/Patio Cover Permit • Signage Permit (both electric and non-electric) • Repair Existing Elevator Permit • Generators/Solar Systems • Solar/Alternative Power • Painting • Installation of Plumbing Fixtures The estimated financial impact of these fee reductions on an annual basis would be approximately $206,000, not including the Alteration/Remodel changes described previously. It should be noted that the Administration does not recommend that the proposed CPI increase be applied to the permit categories outlined for revision above. Additionally, there is a scrivener's error in Section 15-42 "Adjusted Rates" in the City's Code of Ordinances relative to the fees for the Planning Department where the language refers just to that particular section but should refer to the Article, not the section. The Administration is recommending the language in the Ordinance be changed for accuracy. FISCAL IMPACTS OF PROPOSED REVISIONS Based on the projections developed by Maximus and staff, it is anticipated that the fiscal impact for the revisions proposed herein are as follows, assuming similar permit activity: Revision (Savinas )/Cost Planning Department Alteration/Remodeling Fee Revision $(412,000) Public Works Department Alteration/Remodeling Fee Revision $( 81,000) CPI Increase $ 404,000 Fee Revisions Based on 1 0% Cap Evaluation and Further ~(206,000) Evaluation of Permit Fees in General Net Change $(295,000) 13 City Commission Memorandum September 12, 2012 Building Development Process Fees Page 9 of9 CONCLUSION The Administration will continue to further evaluate permit fees for those where refinements are recommended, as well as the remaining permit fee types, on a regular basis and bring further recommendations to the Finance and Citywide Projects Committee for review and discussion. The Administration recommends that the City Commission revise the scrivener's error in Section 15-42 of the City's Code of Ordinances, and revise fees related to the Building Development Process as described in this memorandum, Exhibits 1 and 2, and the attached ordinances, including: • Fees related to Planning and Public Works' efforts in the Alteration/Remodeling permit types should be reduced, as referenced in Exhibit 1, and • Discounts should continue past September 30, 2012, rather than rolling over from year to year, • The CPI increase for 2013 pursuant to the existing ordinance should not be waived, and • Fees related to certain permit types should be revised, based on the evaluation of the 10% cap on permit fees and further evaluation of permit fees in general, and that the CPI increase should not apply to these permit types, as referenced in Exhibit 2 and the attached ordinances. KGB/JGG/SS/KT T:\AGENDA\2012\9-12-12\Permit Fee Revisions\Permit Fee Revisions memo 09122012.doc 14 City ofJ'Jt/iami Beach, Florida Building Development Services-Review of Implementation of Fee Study i'Jtlay 2011 INTRODUCTION t'J< h . ..i bH: .1 This report is a review of the implementation of the development fee study conducted in 2009. It includes two deliverables; the first reviews the structure of the fees with cost/ revenue analysis, the second reviews current issues with the fee structure and proposes recommendations for improvement. REVIEW OF IMP LENT ATION OF FEE STUDY (FIRST DELIVERABLE) The City of Miami Beach contracted with MAXIM US to conduct a cost of services study of its development service fees. The study was completed in the fall of 2009, after which The City of Miami Beach enacted the new fee schedule in February 1, 2010. The adopted fee schedule includes discounts on various fee services from the full cost determined through the cost analysis. The objectives of the study were to: a) Simplify the fee structure b) Ensure that fees are revenue-neutral c) Review if the City applied the fees correctly based on the final report SIMPLICITY OF THE NEW FEE STRUCTURE The City of Miami Beach spent a significant amount of staff time and effort during the cost of service study to make sure that the data it provided was accurate and reasonable. It also took the time to understand our proposed Nexus model and adapt it to the specific needs of the City. The City's development services fee schedule is a thirty-page document-many times longer than we see in most cities, mostly due to the desire to tailor the schedule to a variety of specific development activities. Length by itself does not create complexity, but it can make it harder to find a specific item in a long list. It made the process of developing the fee schedule take much longer than it usually does, but it is not our finding that the resulting fee schedule is too complicated. We feel that the City took a move toward simplicity by emphasizing per square foot charges in construction tables. We also recommend that the City limit the number of unique new fee types that evolve over time, but a limited number of periodic changes is not, in our opinion, a violation of the "keep it simple" principle. REVENUE-NEUTRAL To conduct a cost versus revenue comparison since the adoption of the new fee schedule, we requested the following information from the City: • Revenue generated with new fees by month since adoption • City cost based on the FY 2010/11 adopted budget • Permit demand associated with those fees MAXIMUS Consulting Services, Inc. -I - 15 City of Miami Beach, Florida Builtling Developmelll Services-Review of lmplementatioll of Fee Study May 2011 A detailed analysis with graphs of actual revenue and budgeted cost by month is attached to this report in Excel format. The table below shows the variance of revenue projection based on the change in fully- loaded hourly rates from FY 2008-09 to FY 2010-11. The building department hourly rate has increased by 12% but the hourly rates for Planning, Public Works and Fire have all decreased. 2008/09 2010/11 Fully-loaded Fully-loaded hourly rate hourly rate %Change Building $ 114.00 $ 127.53 12% Planning $ 108.08 $ 98.80 -9% Public Works $ 103.07 $ 85.49 -17% Fire $ 95.46 $ 93.29 -2% The table below shows the summary of actual revenue and budgeted costs for the four departments involved in development services. FY 2007/08 2009 Maximus Study 2011 Review Percent Total MAXIMUS Total MAXIMUS Cost Projected Percent Projected Recovery Actual Revenue Estimated Percent Actual Revenue at Full Cost Revenue with with March 2010-Cost for FY Cost TOTAL REVENUE Revenues Cost Recovery Discounts Discounts Feb 2011 2010/11 Recovery BUILDING Annual Revenue • $ 9,732,237 $ 9,536,470 $ 8,144,734 $ 7,833,458 $ 10,680,846 Monthly Average $ 811,020 $ 794,706 102% $ 678,728 85% $ 652,788 $ 890,071 73% PLANNING Annual Revenue $ 452,023 $ 1,597,016 $ 1,337,078 $ 1,163,547 s 1,453,285 Monthly Average s 37,669 $ 133,085 28% $ 111,423 84% $ 96,962 $ 121,107 80% PUBUC WORKS (Engineering) Annual Revenue s 650,448 $ 1,313,507 s 1,184,707 s 599,599 s 1,090,211 Monthly Average $ 54,204 $ 109,459 50% $ 98,726 90% $ 49,967 $ 90,851 55% FIRE (Prevention) Annual Revenue s 648,049 $ 1,836,380 $ 1,499,136 $ 1,408,680 s 1,799,652 Monthly Average $ 54,004 ~ 153,032 35% s 124,928 82% s 117,390 $ 149,971 78% GRANO TOTAL $ 11,482,757 $ 14,283,373 80% $ U,16S,655 85% $ 11,005,284 $ 15,023,994 73% Proj. Revenues with Proposed Revisions $ 7,833,458 $ 652,788 s 751.274 s 62,606 $ 520,265 $ 43,355 $ 783,847 $ 65,321 $ 9,888,844 "Excludes One time project Closeout revenues in the amount of$ 2,673,120collected in FY 2007/08and $922,627 collected between March 2010 and February 2011 Our understanding is that the development industry itself has changed since 2009, resulting in a shift from major new construction to minor remodeling projects. That appears to be the most likely reason for the shortfall. MAXIMUS Consulting Services, (nc. -2- 16 City of Miami Beach, Florida Building Development Services-Review of Implementation of Fee Study May 2011 APPLICATION OF FEE STRUCTURE Has the City applied the fee schedule correctly? Not having directly observed how City staff calculated fees, MAXI MUS cannot answer this question based on direct observation of how fees were calculated. However, City staff demonstrated to us that they understood how to calculate and apply fees. Alteration/remodel applications generated the most discussion in this project, but that discussion was more an expression of concern that the prices seemed high than how to apply fees. During this project, we had several conversations with City staff that left us confident that they know how to apply fees correctly and that reasonable processes are in place to avoid charging unfair or excessive fees. One additional piece of evidence that staff are applying fees correctly is the finding that revenues from permits are roughly equal to the underlying costs of each category of service and in no case is revenue greater than the underlying cost pool. RECOMMENDATIONS ON CURRENT ISSUES (SECOND DELIVERABLE) In 2009, the City of Miami Beach adopted a new fee schedule for permits issued by the departments of Building, Fire, Planning and Public Works (Engineering). City staff have gained experience using this schedule and feel that certain changes may improve the ease of use and collective understanding of how to apply the fees in the ordinance. The purpose of this report is to address current issues and potential new fee categories that were identified during brainstorming sessions with the City of Miami Beach. This report addressed the following issues: • The latest proposed "glitch ordinance" drafted to amend the fee schedules • Current issues with the fee structure, including: o Alterations/Renovation Permits o Single Family Homes o ROW fees/crane fees o High rise fees MAXIM US also reviewed ten alteration/renovation projects that the City deemed illustrative of questions about how to apply the pricing in the ordinance. These examples are provided in a separate file. "GLITCH BILL"-METHODOLOGY The basic premise of activity-based costing is simple -apply an inclusive hourly that reflects the cost of resources to the time required to provide a service. In our 2009 study, a critical piece of our methodology was the hourly rate calculation. The model applies hourly rates to City staff explanations of time requirements to provide various services With respect to the "glitch bill," we find that the City correctly applied the MAXIMUS methodology in calculations to arrive at prices for newly-listed services. MAXIMUS Consulting Services, Inc. -3- 17 Ci~v of lltliami Beaclt, Florida Building Development Services-Review of Implementation of Fee Stm~r Muy 2011 We have three recommendations regarding the "Glitch Bill." 1) While it is sometimes necessary to add additional fee categories, the City should implement a review process so that the new fee categories add clarification and simplification and are not overly complicated or duplications of another fee. We understand the City's need for the additional fees in the glitch bill and believe that these add clarification. 2) Continue the practice of applying rates to estimated time to provide services. In 2009, we worked with staff to estimate the time to perform each service. We spent a great deal of time refining these efforts and checking them against available hours and comparing them to the reported effort required by other local building development services. By extending time estimates by quantities of each transaction type, we built up a total time requirement for each department. We reconciled the total time reported for each department to the time available in each department. net of the time required for paid leave and administrative duties. 3) In the same vein, we suggest that the City of Miami Beach use the annual quantities multiplied by the new fee prices to determine the financial impact of these changes. The only new category that we recommend is one for "other projects not listed." It is impossible to predict all of the types of construction that may occur. In such cases, we recommend adding a category to the fee schedule as follows: "Other projects not listed. In case of a project not otherwise listed, the Building Director or designee shall apply the hourly rates for each department involved to an estimate of time required to review and inspect a new project." ALTERATIONS/REMODEL HISTORY Typically, we use a model with a category for alteration/remodel permits in different occupancy types. The effort required for such permits is less than that involved in construction of new premises. In earlier drafts of our analysis for the City of Miami Beach, our model contained Level 2 Alteration categories for various occupancy types. During draft reviews of our results in 2009, the cost of these activities were deemed sufficiently similar to new construction to merit eliminating the Level 2 Alteration permits in each occupancy type where it had been to that point and simply using the new construction category to price alteration/remodeling permits. Recently. City staff indicated that for some of the applications received. the new construction category might result in an unreasonably high cost-defined as a permit whose price is a significant cost relative to the cost of the underlying construction work itself. This may reflect construction industry trends in the last two years, in which, nationally, there are more small alteration projects and fewer projects involving new construction or significant remodeling. MAXIMUS Consulting Services, Inc. -4- 18 City of Jl;Jiami Beach, Florida Builtling Development Services-Review of Implementation of Fee Study 1\t/ay 2011 In reviewing the current situation, MAXI MUS finds that a reasonable resolution is to determine if the scope of remodeling will involve departments other than Building. The new construction permit pricing assumes involvement of the departments of Building, Fire, Planning and Public Works. After a detailed review, it was determined that all departments are still involved, but that the labor estimates for Planning and Public Works needed to be reduced to match the actual time that staff spend on these projects. ATTACHMENTZ City of Miami 8(!ach, Florida PROPOSED RENOVATION AND NEW CONSTRUCTION FEES PROPOSED DISCOUNTED FEE: ·lriCI\1mei'IQI Fee Per T01AI.AAOJEcTCOST Squue Footage lnCI\1mental Sq Ft (Per flundiitd Sit l't) la ... l Oceuponcy Typo FROM I UP TO Building I Fino I I PUblcJ Planning Works , TOTAl. FRoM I TO 0 500 f 300.00 $ 452« $ 131.17 $ 48.3&, s 522.44 $0 $ Uf420 B Busines~ 501 2,500 $ 255.92 $ 33.41 s 8lU2 $ ,0.83 s 378.54 ,$ 211110.74 s 1o.f45.01 2.501 25,000 $ 80.83 $ 7.40 $ 9.48 $ 0.63. $ .98J4 $ 10,243:18 .s 32.22Uo 25,001 50,000 $ 3U7 $ 5.71 $ 8.60 $ 0.62 $ $2.$0 $ 32.2'80.® $ 45.375.00 METHODOLOGY We worked with City staff to review and update the time spent working on Level 2 alterations. The departments of Building and Fire reviewed their previous estimates and confirmed that they were reasonable. The departments of Planning and Public Works submitted changes. We used the same methodology as in the 2009 study: 1) We worked with staff to determined the labor effort for each type of Level 2 alteration by occupancy type 2) If staff asked us to scale the tim~ estimates by project size, we did so based on the same scaling percentages as the 2009 study 3) We extended the departmental hourly rates to the time data that the departments supplied to reflect the cost of each activity 4) We update the fee schedule to show the actual cost and then applied the same percentage discounts to the recommended fees as in 2009 SPECIAL CASES There are two special cases that need to be noted: 1) Planning requested that we calculate a separate fee for alterations done in historic districts because they require additional labor effort. While we understand their desire for this request, we found that the difference or percent fee increase for historic properties was about 1 %, which we believe is not sufficiently material to justify the complexity of adding a new category to the fee schedule. 2) Staff report that Change of Use should be charged as New Construction. The City needs to clearly indicate this on the fee schedule. Our analysis has assumed that no permits are change of use. This assumption will undervalue the predicted revenue, but the City was not able to estimate how many alteration permits at this time require a change of use at this time. Ml\XLMUS Consulting Services, Inc. -5- 19 City ofllt/iami Beach, Florida Building Development Services-Review of Implementation t~{ Fee Study May 2011 REVENUE IMPACT The City asked MAXIM US to determine the financial impact of this change. The table below reflects the updated data from Planning and Public Works. Revenue Comparison Current Revenue Predicted Revenue (w/ (Building, Fire, Planning, updated labor and Public Works) discounts) Total $ 3,906,651 $ 3,413,214 Additional Public Subsidy $ (493,437) Additional Planning Subsidy $ (412,273) Additional Public Works Subsidy $ (81 '164) SPECIALTY PERMITS VERSUS LEVEL 2 RENOVATIONS/NEW CONSTRUCTION The current fee schedule contains specialty permits for construction permits such as kitchen and bath remodels. The City asked what to do when an application covers what would normally be several different specialty permit items -should they be charged for specialty permits and when should they be charged based on the square footage of the occupancy type of Level 2 alteration/remodel (which is the same fee as new construction)? The purpose of the fee schedule is to charge people what it costs to provide the services their requests invoke. The cost for specialty permits was determine based on how much staff time it would required to provide just that item. When a person needs to permit multiple work items, the staff time required is actually less (due to economies of scale). For example, inspectors can often make one trip to inspect multiple items. The point at which the City's labor estimate for providing services based on level 2 alteration/remodel become more efficient than for specialty permits (usually after 2-3 specialty permits are needed) is when the applicant should be charge for a level 2 alteration/remodel. The challenge here is that there are so many permutations of what an applicant may wish to do, that it is not feasible to produce a schedule that anticipates all of those project types. The schedules follow an average cost methodology. MAXIM US is not aware of any legal requirement to price services based on the requirements of single customers. It is not even clear that such a method would provide reduced fees Theoretically, it would result in lower charges for some and higher charges for others. With actual revenue data suggesting that City collections are below the full cost recovery levels suggested in the 2009 report, it seems that, despite City concern about potentially overcharging, that assessing a specialty permit fee for each feature is valid. SINGLE FAMILY HOMES MAXIMUS Consulting Services, Inc. -6- 20 City of Miami Beach, Florida Building Development Services-Review of lmpleme11tatitm of Fee Stm(v iUay 2011 The Building Department reviewed all labor time estimates and confirmed that the new construction fee schedule time estimates were correct. Based on this, the City of Miami Beach can make a policy decision to discount single family homes if it wishes, although the cost data would support full cost pricing. The City has already decided to discount all custom homes less than 1 ,500 square feet. However, this is a policy decision and does not affect how much it actually costs the city to provide these services. Square Footage TOTAl.. PROJECT COST TOTAl.. PROJECT COST I class! Occupancy Type FROM I UP TO FROM I TO FROM I TO Percent I Discount 0 1.500 $0 $ 9,635.18 $0 $ 9,905.78 -63% ---· R-3 Dwellings-Custom Homes 1,501 2,500 $ 9,775.68 $ 11,039.98 $ 6,419.20 $ 11,039.91'1 0% --2,50'1 10.000 $ 11.180.46 $ 21.fl78.00 $ 11,180AG $ 21,576.00 0% --10,001 50,000 $ 21,703.02 $ 72.384.00 $ 21,703.02 $ 72,384.00 0% In our experience, it is rare to discount single-family home permit prices. With all due respect to limiting charges to applicants, these calculations reflect the value of the work done, they amount to small percentages of total project cost and charging based on cost protects other taxpayers from having to pay part of the cost of these private-benefit transactions. RIGHT OF WAY FEES/CRANE FEES Public Works used to charge based for blocking of Right-of-Way, (plus .25 Per L.F. per day, plus a Right-of-Way obstruction fee of $10.53 per square ft per day. The City is now charging for the blocking of right Crane operators complained that the current $953 ROW obstruction fee which the crane operators pass onto their customers was too costly for crane lifts requiring less than 2 hours to complete. Public Works was tasked to create a flexible ROW obstruction fee to be assessed separately for local, collectors and arterial roadways/street corridors; by implementing a priority/standard plan review process with priority reviews being processed as an emergency review to be completed on the same day submitted. The flexible obstruction rates for priority/standard reviews clearly demonstrate that staff reduced level of efforts per category produced a significant fee reduction for crane operations performed within the public rights of way. In the "Glitch Bill" amending the original fee schedule, Public Works has proposed charging for ROW based on the corridor classification (local, collector, arterial) and whether the review is propriety or standard. This is a standard structure for Public Works and MAXIMUS Consulting Services, Inc. -7 - 21 City oj1tliami Beach, Florida Buildillg Developmellt Services-Review of Implemeutatioll of Fee Stm{v lttlay 2011 MAXIM US supports this change. This change also makes it easier for Public Works to provide labor based justifications for their fees. HIGH-RISE PERMITS In 2009, MAXIM US worked with City staff to gain an understanding of labor efforts for each service. We ask City staff to decompose their work into steps and will estimate the time required for each step. Since it is not feasible to ask how long the City spends with intake, plan review, and inspection for each occupancy type and each size project within each occupancy type, we make some simplifying assumptions. • For certain permit types, we asked questions about effort level differences for projects of different sizes in a single occupancy type. For example, we asked staff how long it took to provide a group of services for the following sized businesses. Related Standard IBC BUilding Use Occupanc Class e. ., IBCIFBC Occu anc Size s B Business 500 " complete all lines-commercial Scaling 2500 .. complete allllnes-Commercia/.Scal/ng 5.000 .. complete al/llnes--commercial Scaling 10000 " complete aflllnes-Commercial Scaling 25,000 " complete allllnes--commerclal Scallng 50,000 B Business-High Rise <50,000 sf 25,000 B Business-High Rise 50,000 sf to 100,000 sf 75,000 B Business-High Rise >100,000 sf 150,000 • The City's answers about how much longer it takes to serve a larger-sized project within these key occupancy types represent a percentage difference that we can apply to related occupancy types. The standard MAXIM US Nexus model contains an occupancy category for business and business high-rise (as seen above). However, MAXIMUS confirmed that the labor required to provide a business permit and a business high=rise permit were sufficiently similar to combine the two categories. In addition, the City grouped occupancy types where the cost per square foot for permits greater than 50,000 was similar. On average, it always requires more time to permit a larger building. As a result, the cost of a larger project should be more than a smaller sized permit of the same occupancy type. However, the cost for square foot actually decreases. The City has taken this unique aspect into consideration when developing their fees. Many cities, especially those that have not based their fee structure on an activity-based costing study, do not take this into consideration. MAXI MUS Consulting Services, Inc. -8- 22 Ci(l' r?f'Miami Beach, F1orida Building De1•e!opment Service.'i-Review r~f'lmplemellfatiou r~l Fee Stut~V May2011 Staff spent significant time deciding that this was the best solution. Unless the underlying facts have changed -and we have not seen evidence of this -we recommend no change to the structure of the 2009 report on this point. PUBLIC WORKS REVENUE FY20071\J8 2009 Ma~mus Study 2011 Rovmw Percent Cost Recovery Percent Cost Actual Total MAXIMUS based on r-Y T a tal MAXIMU S RecO\'OfYW!Ih Revenue Esurna:ed Full 2007108 Projected Revenue Adopted March 2010 · Est:mawd Cost Percent Cos! TOT ''L REVENUE 1\ctuat Rovanues Cost Rovonues wilh Adopted t:ees Fees Feb20!1 forFY2010/t 1 Recovery PUBLIC VVORKS (Eng,neenng) 1\nnual Revenue $650.448 $1,313.507 $ t' t84.707 5599,599 s 1,090,211 Monthly Awrage S54.20tl 5109,459 50(YG $96.726 90% $49,967 s 90,851 55''/o Potential New R!es (General Amd)· Not Implemented Coastal Re"ew 15.461 S IJ,290 fsaw'aiCapaCity-----------t---·----···-·---·· ·· --------------!---·-··-· +-- CerHf!calion Letter Appllcallon Backnow Annual lnspecuon Perm11 {Fire ~::ppresS!Cn Feel Annual Revenue Mjusted $650,448 $54,204 185.528 15·1.607 $957,911 S79,826 68°1\1 180.000 154,000 $837,417 S599,599 s 795,066 $59,785 87% $49,967 s 66,256 75t:.'o Based on our initial review. it appeared as if Public Works was only recovering 55% of costs, while most other departments were recovering closer to 75%. The main reason for this difference is that our analysis included three new potential fee categories that were not implemented. Excluding these, Public Works actually recovered 75% of cost. In addition, the Public Works department has continued to see a decline in permit activity. This is the main reason Public Works less than 100%, of cost. In 2008, Public Works performed 936 right-of-way permits. In 2011 the annualized number is projected to be 638, which is a 68% decline in permit volume. MAXIM US Consulting Services. Inc. -9- 23 ~ ~ Total Additional Public Subsidy Additional Plannmg Subsidy Additional Public Works Subsidy Revenue Comparison Current Revenue (Building, Fire, Planning, Public Works) $ 3,906,651 Predicted Revenue (w/ updated labor and discounts) $ 3,413,214 $ (493,437) $ (412,273) $ (81,164) ~ U'l Public Public Building Building Fire Fire Planning Planning Works Works Total Total Current Proposed Current Proposed Current Proposed Current Proposed Current Proposed Total ~ Fee Fee Difference Fee Fee Difference Fee Fee Differgnce Fee Fee Difference Fee Fee Difference Generator-Single Family $ 377.00 $ 151.00 $ (226.00) $ $ $ -$ 123.00 $ 49.00 $ (74.00) $ $ $ $ 500.00 $ 200.00 $ (300.00) Generator~Commercial Under 10,000 sq It or non-life safety related generator $ 2,392.00 $ 1,196.00 $ (1,196.00) $ 262.00 $ 131.00 $ (131.00) $ 346.00 $ 173.00 $ (173.00) $ $ $ $ 3,000.00 $ 1,500.00 $ (1 ,500.00) 10,000 to 50,000 sq ft $ 2,983.00 $ 1,492.00 $ (1,491.00) $ 501.00 $ 251.00 $ (250.00) $ 346.00 $ 173.00 $ (173.00) $ $ $ $ 3,830.00 $ 1,916.00 $ (1,914.00) Above 50,000 sq It $ 3,190.00 $ 1,784.00 $ (1 ,406.00) $ 810.00 $ 453.00 $ (357.00) $ 346.00 $ 194.00 $ (152.00) $ $ $ $ 4,346.00 $ 2,431.00 $ (1,915.00) Solar(Photovoltaic)/Alternate Power Systems-Single family $ 489.00 $ 245.00 $ (244.00) $ $ -$ $ 11.00 $ 6.00 $ (5.00) $ -$ $ $ 500.00 $ 251.00 $ (249.00) Systems-Commercial/Multi-family $ 1,899.00 $ 950.00 $ (949.00) $ $ $ -$ 21.00 $ 11.00 $ (10.00) $ $ -$ I $ 1,92o.oo $ 961.00 $ (959.00) Transfer Switch for Future Generator(per unit) $ 291.00 $ 146.00 $ (145.00) $ $ $ $ 9.00 $ 5.00 $ (4.00) $ $ $ $ 300.00 $ 151.00 $ (149.00) Painting Permit Residential $ 35.00 $ 27.00 $ (8.00) $ $ $ $ 65.00 $ 65.00 $ I $ $ $ -$ 100.00 $ 92.00 $ (8.00) Commercial $ 115.00 $ 27.00 $ (88.00) $ $ $ $ 109.00 $ 109.00 $ $ 26.00 $ 26.00 $ $ 250.00 $ 162.00 $ (88.00) Plumbing Fixtures Fixture Rough,under 5 units $ 200.00 $ 100.00 $ (100.00) $ $ $ $ $ $ $ $ -$ $ 200.00 $ 100.00 $ (100.00) Fixture Sets replacement, Up to 5 units $ 143.00 $ 100.00 $ (43.00) $ $ $ $ $ $ $ $ $ $ 143.00 $ 100.00 $ (43.00) Installation of traction elevators and escalators, per unit. Each additional story over 10 $ 154.00 $ 84.00 $ (70.00) $ $ $ $ $ $ $ -$ $ $ 154.00 $ 84.00 $ (70.00) Elevator Repairs (Jack/Oil lines) $ 519.00 $ 250.00 $ (269.00) $ $ $ $ $ $ $ $ -$ $ 519.00 $ 250.00 $ (269.00) Elevator Repairs (Can Interior/ Others) $ 291.00 $ 250.00 $ (41.00) $ $ $ -. $ $ $ $ $ $ $ 291.00 $ 250.00 $ (41.00) Partial Demolition Under 300 sq ft $ 711.00 $ 228.00 $ (483.00)11 $ 73.00 $ 23.00 $ (50.00) $ 50.00 $ 16.00 $ (34.00)11 $ $ $ -$ 834.00 $ 267.00 $ (567.00) 300-1 000 sq ft $ 711.00 $ 711.00 $ -II$ 73.00 $ 73.00 $ $ 50.00 $ 50.00 $ II$ 24.oo $ 24.00 $ -$ 858.00 $ 858.00 $ The following are other permit types recommended for fee reductions. The Total Difference in fees reflects the minimum amount of savings a customer may experience if these proposed fees are adopted, as the basis for calculation is changing from square footage to per unit or vice versa. Building Sign I Each $ 142.00 $ 116.00 $ (26.00) $ $ $ $ 108.00 $ 108.00 $ II$ $ $ -II$ 250.00 $ 224.00 $ (26.00) Awnings,canopies and patio covers -New Single Family Home (Per Unit) $ 91.00 $ 150.00 $ 59.00 $ $ $ $ 81.00 $ $ (81.00)11 $ 10.00 $ $ (10.00)11 $ 182.00 $ 150.00 $ (32.00) All Other Occupancies 1-30 Units $ 198.00 $ 146.00 $ (52.00) $ 98.00 $ 95.00 $ (3.00) $ 118.00 $ 108.00 $ (10.00) $ 25.00 $ -$ (2500)11 $ 439.00 $ 349.00 $ (90.00) Each additional 10 units over 30 $ 493.00 $ 185.00 $ (308.00) $ 203.00 $ $ (203.00) $ 168.00 $ $ (168.00) $ 25.00 $ -$ (25.00)11 $ 889.00 $ 185.00 $ (704.00) The following permit type is recommended for fee revision. Savings will be realized for any quantity of signs under four (4) signs. However, in Fiscal Year 2011/2012, no permit applications have included more than three (3) signs. Electric Sign One Electric Sign $ 247.00 $ 71.00 $ (176.00) $ $ -$ $ -$ 29.00 $ 29.00 $ -$ $ $ 247.00 $ 100.00 $ (147.00) 2-5 Electric Signs $ 366.00 $ $ (366.00) $ $ $ -$ $ $ $ $ -$ $ 366.00 $ $ (366.00) Each Additional Sign over 5 $ 47.00 $ $ (47.00) $ $ $ $ $ $ -$ $ $ $ 47.00 $ $ (47.00) Each Additional Sign over 1 $ $ 71.00 $ 71.00 $ $ $ $ $ 29.00 $ 29.00 $ $ $ $ $ 100.00 $ 100.00 ----\\'"") "':>(. ?:" ~ r;-\'J ORDINANCES TO BE SUBMITTED 26