HomeMy WebLinkAboutOrdinance 1979-015 No Fair Share Feest
ORDINANCE NO. 15-79
AN ORDINANCE OF THE VILLAGE OF NORTH PALM BEACH, FLORIDA,
DETERMINING THAT NO "FAIR SHARE FEES" SHALL BE IMPOSED ON NEW
CONSTRUCTION IN THE VILLAGE OF NORTH PALM BEACH TO OFFSET COSTS
FOR ROAD IMPROVEMENTS CAUSED SOLELY BY NEW DEVELOPMENT,
BE IT ORDAINED BY THE VILLAGE COUNCIL OF NORTH PALM BEACH,
FLORIDA:
Section 1. That the Village of North Palm Beach Code is
hereby amended by adding a new Section to be numbered 6-18 which
said Section reads as follows:
"Sec. 6-18 - It has been determined by the Village
Council that a person seeking a building permit for
any new construction shall not be required to pay
a fair share fee to the Village or to the County
Commissioners of Palm Beach County, Florida, as
set forth in an ordinance, a copy of which is
attached hereto as Exhibit A, adopted by the Board
of County Commissioners of Palm Beach County on
June 19, 1979.
Section 2. An emergency exists which requires the passage
of the ordinance at once in that an Ordinance (copy of which is
attached hereto as Exhibit A) of Palm Beach County adopted on
June 19, 1979, taking effect July 1, 1979, and insufficient time
remains to pass this ordinance on two readings.
Section 3. It is the intent of this Ordinance to exempt
property within the Village of North Palm Beach from the effect of
the Ordinance attached as Exhibit A hereto, to the extent permitted
by Article VIII (1)(f) of the 1968 Florida Constitution.
Section 4. This Ordinance shall take effect immediately
upon passage.
PLACED ON FIRST READING THIS 28TH DAY OF JUNE, 1979.
PLACED ON SECOND, FINAL READING AND PASSED THIS 28TH DAY OF JUNE,
1979.
/s/ W. H. Brown
MAYOR
ATTEST:
/s/ Dolores R. Walker
Village Clerk
EXHIBIT A
rl (P1: t ) j[ 2;;1979-- i
1'ILLAME MU. OFF.)
Norli Palm Beach AN ORDINANCE TO BE KNOWN AS THE "FAIR SHARE CONTRIBUTION
FOR ROAD IMPROVEMENTS ORDINANCE"; PROVIDING FOR SHORT
5 TITLE, AUTHORITY, APPLICABILITY; PROVIDING FOR INTENT AND
6 PURPOSE; PROVIDING FOR RULES OF CONSTRUCTION; PROVIDING
7 FOR DEFINITIONS; PROVIDING FOR FAIR SHARE FEE TO BE
8 IMPOSED ON NEW CONSTRUCTION; REVIEW; PROVIDING FOR TIME
9 OF PAYMENT; PROVIDING FOR USE OF FUNDS COLLECTED; PRO-
10 VIDING FOR TRUST FUNDS ESTABLISHMENT; PROVIDING FOR EX-
11 EMPTIONS AND CREDITS; PROVIDING FOR LIBERAL CONSTRUCTION,
12 SEVERABILITY AND PENALTY PROVISIONS; PROVIDING FOR IN-
13 CLUSION IN THE CODE; AND, PROVIDING AN EFFECTIVE DATE.
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15 BE IT ORDAINED BY THE BOARD OF COUNTY COMMISSIONERS OF PALM BEACH
16 COUNTY, FLORIDA, that:
17 SECTION I. Short Title, Authority and Applicability.
18 A. This ordinance shall be known and may be cited as the "Fair Share
19 Contribution for Road Improvements Ordinance."
20 B. The Board of County Commissioners has authority to adopt this
21 ,ordinance pursuant to Article VIII of the 1968 Florida Constitution, and
22 Chapters 125 and 163, Florida Statutes.
23 C. This ordinance shall apply to the unincorporated area of Palm
24 Beach County, and to the incorporated areas within Palm Beach County to the
25 extent permitted by Article VIII, Section 1(f) of the 1968 Florida Constitution.
26 SECTION II. Intent and Purpose.
27 A. The Board of County Commissioners has determined that the phenomenal
28 growth rate which the County is experiencing will necessitate extensive road
29 network improvements, costing approximately 2 1/2 billion dollars by the year
30 , 2000, exclusive of right of way costs, in order to maintain the existing level
31 of service and quality of life found in Palm Beach County. In order to finance
32 the necessary new capital improvements, several combined methods of financing
33 ,will be necessary; one of which will require new developments to pay a "fair
34 share fee."
35 B. It is the purpose of this ordinance to establish a Countywide system
36 to assist in raising the funds necessary to improve the major road network system,
so as to accommodate the increased demand which new development will have on the
ORDINANCE NO. 79-
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road system. The new users will only be required to pay the cost of road im-
provements to the extent that their presence necessitates such improvements.
C. All land development is deemed to create a traffic impact and there-
fore create a demand for increased road capacity. As a result of this new
building construction the existing major road network system is being seriously
impacted to a point beyond which government can finance improvements to these
roads.
D. Increasing the capacity of roads in order to make them safe and more
efficient is the recognized responsibility of government and is in the best
interest of the public's health, safety and welfare.
E. It is in the interest of the public's health, safety, welfare and con-
venience for the County to regulate land development by requiring the payment
of road impact fees as a condition precedent to the issuance of a building
permit for new construction for the exclusive purpose of improving the major
road network system impacted within a predefined zone in which the develop-
ment is located.
F. It is the purpose of this ordinance to continue to allow growth in
Palm Beach County but to do so in a manner which requires the new development,
causing the road impact problems, to share the financial burden of growth
by requiring the new development to pay their pro rata share for the cost of
road improvements to the extent that their presence necessitates such improve-
ments. Thus the existing residents of Palm Beach County will be afforded
some relief from the costs of providing road improvements solely necessary
to meet the needs of the new development.
G. It is not the purpose of this ordinance to collect any money from
new development in excess of the actual amount necessary to offset the impact
on the major road network system caused by new development. It is specifical-
ly acknowledged that this ordinance has approached the problem of determining
the "fair share fee" in a conservative and reasonable manner. This ordinance
will only partially recoup the governmental expenditures associated with
growth. The established residents will still be required to supplement the
contributions of the new development.
H. The Technical Data, Findings and Conclusions herein are based in
part on the following studies and reports:
Report on the proposed Palm Beach County Fair Share Contribution for
Road Improvements Ordinance - August 10, 1978, revised September 8, 1978 by
Palm Beach County Engineering, Planning and Legal Staffs. Economic Aspects
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1 of the proposed Palm Beach County Road Impact Fee Ordinance - Jan. 2, 1979 by
2 Joint Center for Environmental and Urban Problems Fla. International University
3 and Florida Atlantic University; West Palm Beach Urban Area Transportation Study
4 Plan Reevaluation. (Year 2000 Study) - May 17, 1979 - by Peat, Marwick & Mitchell
5 Company; Update Study of Vehicular Traffic Generation Characteristics in Palm
6 Beach County - Jan. 1975 - by Kimley-Horn & Associates; Trip Generation &
7 Informational Report - 1976 - by Institute of Transportation Engineers; Trip
8 Ends Generation Research 1979 by State of Fla. D.O.T., Division of Transporta-
9 tion Planning.
10 SECTION III. Rules of Construction.
11 For the purposes of administration and enforcement of this ordinance, un-
12 less otherwise stated in this ordinance, the following rules of construction
13 shall apply to the text of this ordinance.
14 (1) In case of any difference of meaning or implication between the
15 text of this ordinance and any caption, illustration, summary table, or
16 illustrative table, the text shall control.
17 (2) The word "shall" is always mandatory and not discretionary;
18 the word "may" is permissive.
19 (3) Words used in the present tense shall include the future; and
20 words used in the singular number shall include the plural, and the plural
21 the singular, unless the context clearly indicates the contrary.
22 (4) The phrase "used for" includes "arrange for", "designed for",
23 "maintained for" or "occupied for".
24 (5) The word "person" includes an individual, a corporation, a
25 partnership, an incorporated association, or any other similar entity.
26 (6) Unless the context clearly indicates the contrary, where a regu-
27 lation involves two (2) or more items, conditions, provisions, or events con-
28 nected by the conjunction "and", "or" or "either...or", the conjunction shall
29 be interpreted as follows:
30 (a) "And" indicates that all the connected terms, conditions,
31 provisions or events shall apply.
32 (b) "Or" indicates that the connected items, conditions, pro-
33 visions, or events may apply singly or in any combination.
34 (c) "Either...or" indicates that the connected items, con-
35 ditions, provisions or events shall apply singly but not in combination.
36 (7) The word "includes" shall limit a term to the specified example,
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1 but is intended to extend its meaning to all other instances or circumstances
2 of like kind or character.
3 SECTION IV. Definitions.
4 A. Accessory Building or Structure: A detached, subordinate building,
5 the use of which is clearly incidental and related to that of the principal
6 building or use of the land, and which is located on the same lot as that
7 of the principal building or use.
8 B. Arterial Road: A road which is a main traffic artery carrying rela-
9 tively high traffic volumes for relatively long distances. This classification
10 includes all roads which function above the level of a collector road.
11 C. Building: Any structure, either temporary or permanent, having a roof
12 and used or built for the enclosure or shelter of persons, animals, vehicles,
13 goods, merchandise, equipment, materials or property of any kind. This term
14 shall include tents, trailers, mobile homes, or any vehicles serving in any
15 way the function of a building.
16 D. Building Permit: An official document or certificate issued by the
17 authority having jurisdiction, authorizing the construction of any building.
18 The term shall also include tie -down permits for those structures or buildings
19 that do not require a building permit, such as a mobile home, in order to be
20 occupied.
21 E. Capacity: The maximum number of vehicles for a given time period
22 which a road can safely and efficiently carry; usually expressed in terms of
23 vehicles per day. For the purposes of this ordinance the capacity of a road
24 shall be 6000 vehicles per day per through lane.
25 F. Collector Road: A road which carries traffic from local roads to
26 arterial roads. Collector roads have more continuity, carry higher traffic
27 volumes, and may provide less access than local roads.
28 G. Collecting Agency: That governmental authority having jursidicition
29 to authorize the construction of any building.
30 H. Dwelling Unit: A single family house, single family apartment or
31 mobile hone used for human habitation.
32 I. External trip: Any trip which either has its origin from or its
33 destination to the development site and which impacts the major road network
34 system.
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1 J. Fair Share Fee; Road Impact Fee; or Fee: The fee required to be paid
2 in accordance with this ordinance.
3 K. Internal Trip: A trip which has both its origin and destination
4 within the development site.
5 L. Local Road: A road designed and maintained primarily to provide
6 access to abutting property. A local road is of limited continuity and is
7 not for through traffic.
8 M. Major Road Network System: All arterial and collector roads within
9 Palm Beach County, including new arterial and collector roads necessitated by
10 land development.
11 N. Planned Development: A land area under unified control designed and
12 planned to be developed in a single operation or by a series of prescheduled
13 development phases according to an officially approved final Master Land Use
14 Plan, including Planned Unit Developments, Planned Commercial Developments and
15 similar planned developments.
16 0. Site Related Improvements: Road construction or road improvements at
17 or near the development site which are necessary to interface the development's
18 external trips with the major road network system or which are necessary to in-
19 terface the development's internal trips with the major road network system
20 where a portion of the major road network system is included within the develop-
21 ment.
22 P. Traffic Impact Analysis: A study prepared by a qualified professional
23 engineer, licensed to practice within the State of Florida, to determine the
24 vehicular impact of the development upon the major road network system. This
25 study includes, but is not limited to: determination of trip generation; trip
26 distribution; traffic assignment; capacity analyses; and, improvements to the
27 roadway system necessitated by the development, such as required new roads,
28 additional laneage and signalization.
29 Q. Trip: A one-way movement of vehicular travel from an origin (one
30 trip end) to a destination (the other trip end). For the purposes of this
31 ordinance trip shall have the meaning which it has in commonly accepted traffic
32 engineering practice and which is substantially the same as that definition in
33 the previous sentence.
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R. Trip Generation: The attraction or production of trips caused by a
given type of land development.
S. Zone: Those geographical areas as identified on the attached Exhibit
SECTION V. Fair Share Fee to be Imposed on New Construction; Review.
A. It has been determined by the Board of County Commissioners that new
development in the County should be charged a reasonable "Fair Share Fee" to
help offset the costs for road improvements caused solely by new development.
B. As a condition to the issuance of a building permit applied for //
after the effective date of this ordinance for any new construction, the
applicant shall pay a Fair Share Fee in the amount and manner required by this
ordinance which shall be used exclusively within the zone in which the develop-
ment is located and for the exclusive purposes set forth in this ordinance.
C. The Fair Share Fee shall be determined by using the following methods:
1. Independent Calculation. Any person may determine his Fair Share
Fee by providing traffic and economic documentation that his actual economic
impact on the major road network system is less than the Fair Share Fee as
determined under subparagraphs C. 2, 3, and 4 below. The documentation sub-
mitted shall show the basis upon which the Fair Share Fee has been calculated,
including but not limited to, generation rates, geographic zones of impact,
cost of replacing the capacity of roadways used by the development's traffic
and allowable credits which may be paid by future occupants. This documentation
shall be prepared and presented by qualified professionals in the respective
fields. The mathematical assumptions, formulas and generation rates used in
this orginance shall not be used as a basis without independent documentation.
2. Fair Share Formula(s).
a. The following Fair Share Formula(s) may be used for those
planned developments for which a traffic impact analysis has been prepared for
the purposes of determining the external trips imposed by the development on
the major road network system. The Official Daily Trip Generation Rate as
shown in subparagraph C.3.a. and b. shall be used as the basis for calculating
the total external trips for a planned development. The County Engineer shall
review the traffic impact analysis and determine the Fair Share Fee to be paid
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in accordance with the formula(s) established in C.2.b. Any applicant may
challenge the County Engineer's determination of the fee by filing a petition
with the Board of County Commissioners to determine the appropriate Fair Share
Fee within sixty (60) days of the determination by the County Engineer.
b. The cost to construct one (1) lane of roadway for one (1)
mile shall be Three Hundred Thousand Dollars ($300,000.00) and the cost
to construct one (1) lane of roadway for one-half (z) mile shall be One Hundred
Fifty Thousand Dollars ($150,000.00).
Residential:
External trips 2* X Cost to construct 1 lane for 1 mile = Fair Share Fee
Capacity of 1 lane
* Given a 50/50 directional split.
Non -Residential:
External trips t 2* X Cost to construct 1 lane for : mile = Fair Share Fee
Capacity of 1 lane
* Given a 50/50 directional split.
3. Fee Schedule. The following fee schedule is presented for those
developments for which a traffic impact analysis has not been prepared. The
following fees have been calculated using the formula(s) presented in paragraph
C.2.b. using accepted trip generation rates for each land use as observed in
Palm Beach County or trip generation rates based upon acceptable state and
national averages. For the convenience of the public the fees which are based
on trip generation have been converted to a dollar amount based on dwelling
unit, building square footage, bed, parking space, or room depending upon the
particular land use.
a. Residential:
Official Daily Trip
Type of Development Generation Rate Fee
Single Family House 12 per dwelling unit $300 per unit
Multi-family/townhouse dwelling 8 per dwelling unit $200 per unit
Mobile Home 7 per dwelling unit $175 per unit
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1 b. Non -Residential:
2
Official Daily Trip
3 Type of Development Generation Rate Fee
4 General Office Building 20 per 1000 square feet $ 250 per 1000 sq. ft.
5 Office Building, Medical 75 per 1000 square feet 937 per 1000 sq. ft.
6 Hospital 15 per bed 187 per bed
7 Nursing Home 3 per bed 37 per bed
8 General Commercial 100 per 1000 square feet 1,250 per 1000 sq. ft.
9 Warehouse 5 per 1000 square feet 62 per 1000 sq. ft.
10 Motel 15 per room 187 per room
11 General Recreational 3 per parking space 37 per parking space
12 Shopping Centers:
13 150,000 or less
square feet 100 per 1000 square feet 1,250 per 1000 sq. ft.
14 150,000 to 499,999
square feet 60 per 1000 square feet 750 per 1000 sq. ft.
15 500,000 to 999,999
square feet 35 per 1000 square feet 437 per 1000 sq. ft.
16 1,000,000 square feet
and over 30 per 1000 square feet 375 per 1000 sq. ft.
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General Industrial 6 per 1000 square feet 75 per 1000 sq. ft.
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19 4. Other Developments. For developments not electing to proceed
20 under subparagraph C.1. above, and where the County Engineer has determined
21 that the development is not covered by subparagraph C.2. and 3. above, the
22 appropriate traffic generation rate and thus the fee to be paid in accordance
23 with this ordinance shall be determined by the County Engineer. The applicant
24 may challenge the County Engineer's determination provided he submits to the
25 County Engineer's Office a traffic generation statement prepared by a qualified
26 Professional Engineer who is licensed to practice in the State of Florida. If
27 the County Engineer's Office rejects this proposed generation rate, then the
28 applicant may petition the Board of County Commissioners to determine the appro-
29 priate Fair Share Fee within sixty (60) days of the rejection of the proposed
30 generation rate by the County Engineer.
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1 D. Review. The amount of the Fair Share Fee shall first be reviewed by
2 the Board of County Commissioners in January 1981; and thereafter the amount of
3 the Fair Share Fee shall be reviewed annually during the month of January by
4 the Board of County Commissioners. The review shall consider trip generation
5 rates and actual construction costs for work contracted for by the County and
6 the Florida Department of Transportation within Palm Beach County. The purpose
7 of this review is to analyze the effects of inflation on the actual costs of
8 roadway construction and to insure that the fees charged the newcomer will not
9 exceed their pro rata share for the cost of road improvements necessitated
10 solely by their presence.
11 SECTION VI. Time of Payment.
12 A. The Fair Share Fee for new construction shall be due and payable at
13 the time of issuance of a building permit. All funds collected shall be prop-
14 erly identified by zone and promptly transferred to the Palm Beach County
15 Comptroller's Office for deposit in the appropriate trust fund to be held in
16 separate accounts as determined in Section VIII of this ordinance and used
17 solely for the purpose as established by this ordinance.
18 B. The Collecting Agency shall be entitled to retain two percent (2%)
19 of the total funds collected to offset the costs associated with collection
20 of these funds.
21 SECTION VII. Use of Funds Collected.
22 A. The funds collected by reason of the establishment of a road impact
23 fee in accordance with this ordinance shall be used solely for the purpose of
24 construction or improving roads, streets, highways, and bridges on the major
25 road network system, including but not limited to:
26 1. design and construction plan preparation,
27 2. right of way acquisition,
28 3. construction of new through lanes,
29 4. construction of new turn lanes,
30 5. construction of new bridges,
31 6. construction of new drainage facilities in conjunction
32 with new roadway construction
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1 7. purchase and installation of traffic signalization,
2 8. construction of new curbs, medians and shoulders, and
3 9. relocating utilities to accommodate new roadway construction.
4 All funds shall be used exclusively within the zones from which they were
5 collected. Said funds shall not be used to maintain the existing major
6 road network system.
7 SECTION VIII. Trust Funds Established.
8 A. There are hereby established forty (40) separate trust funds, one
9 for each zone as shown on Exhibit "A" attached hereto and incorporated
10 herein by reference.
11 B. Funds may be withdrawn from these accounts for use solely in accord-
12 ance with the provisions of Section VII of this ordinance; provided, that the
13 disbursal of such funds shall require the approval of the Board of County
14 Commissioners, after recommendation of the County Engineer.
15 C. Any funds on deposit not immediately necessary for expenditure shall
16 be invested in interest bearing sources. All income derived shall be
17 deposited in the applicable trust account.
18 D. The fees collected pursuant to this ordinance may be returned to
19 thethen present owner if the fees have not been spent (encumbered) by the
20 end of the calendar quarter immediately following six (6) years from the
21 date the fees were paid. Refunds shall be made in accordance with the
22 following procedure:
23 1. The present owner must petition the Board of County Commis-
24 sioners for the refund within one (1) year following the end of the sixth (6th)
25 year from the date on which the fee was paid.
26 2. The petition must be submitted to the County Engineer and must
27 contain:
28 a. a notarized sworn statement that the petitioner is the
29 current owner of the property;
30 b. a copy of the dated receipt issued for payment of the fee;
31 c. a certified copy of the latest recorded deed; and,
32 d. a copy of the most recent ad valorem tax bill.
33 3. Within three (3) months from the date of receipt of a
34 petition for refund the County Engineer will advise the petitioner and the
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1 Board of County Commissioners of the status of the fee requested for refund.
2 For the purpose of this section, fees collected shall be deemed to be spent
3 (encumbered) on the basis of the first fee in shall be the first fee out.
4 In other words, the first money placed in a trust fund account shall be the
5 first money taken out of that account when withdrawals have been made in
6 accordance with subparagraph B. above.
7 4. When the money requested is still in the trust fund account
8 and has not been spent (encumbered) by the end of the calendar quarter
9 immediately following six (6) years from the date the fees were paid, the
10 money shall be returned with interest at the rate of six percent (6%) per
11 annum.
12 E. The fees collected pursuant to this ordinance may be returned to
13 the present owner if the building permit is cancelled due to noncommencement
14 of construction. Refunds may be made in accordance with Section VIII, D, 2,
15 and VIII, D, 3, provided the then present owner petitions the Board of County
16 Commissioners for the refund within three (3) months from the cancellation
17 date of the building permit.
18 SECTION IX. Exemption and Credits.
19 A. The following shall be exempted from payment of the Fair Share Fee:
20 1. Alterations of expansion of an existing dwelling unit where no
21 additional units are created.
22 2. The construction of accessory buildings or structures which will
23 not increase the traffic counts associated with the principal building or of
24 the land.
25 3. The replacement of a destroyed or partially destroyed building
26 or structure with a new building or structure of the same size and use.
27 4. The construction of publicly -owned governmental buildings.
28 B. Credits:
29 1. In lieu of paying the Fair Share Fee, the developer may elect
30 to construct part of a major road network system which is in addition to
31 his site related improvements. The developer shall submit the proposed
32 construction which he intends to do along with a certified cost estimate to
33 the County Engineer. The County Engineer shall determine if the proposed
34 construction is an appropriate substitute for the road impact fee and the
35 amount of credit to be given and the timetable for completion.
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1 2. Where a proposed major network road runs through a development
2 and where the developer is only required to construct two (2) lanes of the
3 roadway, the developer may elect, upon submission of a certified cost esti-
4 mate and approval of the County Engineer, to construct more than two (2) lanes
5 and receive credit to the extent of the additional lanes constructed.
6 3. The developer may challenge any determination made by the County
7 Engineer pursuant to subparagraphs B.1. and .2 above by filing a petition with
8 the Board of County Commissioners.
9 SECTION X. "Sunset" Provision.
10 A. This ordinance shall "sunset" or cease to exist four (4) years from
11 its effective date, unless renewed by an affirmative vote of the Board of
12 County Commissioners.
13 B. In the event that this ordinance is allowed to "sunset" by the
14 Board, any and all funds collected during the life of the ordinance shall
15 continue to be disposed of in the manner set forth in Sections VII and VIII,
16 as if this ordinance were still in effect.
17 SECTION XI. Liberal Construction, Severability and Penalty Provisions.
18 A. The provisions of this ordinance shall be liberally construed to
19 effectively carry out its purposes in the interest of public health, safety,
20 welfare and convenience.
21 B. If any section, phrase, sentence or portion of this ordinance is for
22 any reason held invalid or unconstitutional by any court of competent juris-
23 diction, such portion shall be deemed a separate, distinct, and independent
24 provision, and such holding shall not affect the validity of the remaining
25 portions thereof.
26 C. Any building permit used for new construction as covered by this
27 ordinance but without payment of the fee as required by this ordinance shall
28 be void.
29 D. A violation of this ordinance shall be a misdemeanor punishable
30 according to law; however, in addition to or in lieu of any criminal prosecu-
31 tion Palm Beach County or any individual paying the Fair Share Fee shall have
32 the power to sue in civil court to enforce the provisions of this ordinance.
33 SECTION XII. Inclusions in the Code.
34 The provisions of this ordinance shall become and be made a part of the
35 Code of Laws and Ordinances of Palm Beach County, Florida. The sections of
36 this ordinance may be renumbered or relettered to accomplish such; and
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1 the word "ordinance" may be changed to "section", "article", or another
2 appropriate word.
3 SECTION XIII. Effective Date.
4 The provisions of this ordinance shall become effective on July 1, 1979.
5
APPROVED AND ADOPTED by the Board of County Commissioners of Palm Beach
6
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County, Florida, on the day of
, 1979.
8 PALM BEACH COUNTY, FLORIDA, BY
ITS BOARD OF COUNTY COMMISSIONERS
9
10
By:
11 Chairman
12
Acknowledged by the Department of State, State of Florida, on the
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day of , 1979.
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Acknowledgement from the Department of State received on
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, 1979, at .m.
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19 APPROVED AS TO FORM
AND LEGAL SUFFICIENCY
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ArrarXH'YY
eOUN1 ATTORiVEY
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