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HomeMy WebLinkAboutAgenda Item - 2026-05-19 - Number 05.6 - Resolution 26-25, Oakridge Park Apts Tax Exemption 5.6 COUNCIL REPORT V -w 0 GREGO\--" Subject: Resolution 26-25, Northwest Housing Alternatives Oakridge Park Apartments Nonprofit Corporation Low Income Housing Property Tax Exemption Meeting Date: May 19, 2026 Staff Member: Jessica Numanoglu, Director Report Date: May 8, 2026 Department: Community Development Action Required Advisory Board/Commission Recommendation ❑ Motion ❑ Planning Commission Recommends Approval ❑ Public Hearing ❑ Denial ❑ Ordinance ❑ None Forwarded ❑X Resolution ❑X Not Applicable ❑ Information Only Comments: ❑ Council Direction ❑X Consent Agenda Staff Recommendation: Adopt Resolution 26-25, granting an exemption from Lake Oswego property taxes for the Northwest Housing Alternatives (NWHA) Oakridge Park Apartments affordable housing development located at 4255 Oakridge Road and granting approval for NWHA to request a tax exemption from other taxing districts. Recommended Language for Motion: Move to adopt Resolution 26-25. Project/ Issue Relates To: Council goal to "Plan for change and growth, with a focus on enhancing the community's quality of life and sense of place." ❑XCouncil Goals/Priorities ❑Comprehensive Plan ❑Not Applicable ISSUE BEFORE COUNCIL Adoption of Resolution 26-25 to grant a city property tax exemption to the Oakridge Park affordable senior housing apartments and allow NWHA to request a tax exemption from other taxing districts per LOC 24.10.040(2). EXECUTIVE SUMMARY NWHA is requesting a property tax exemption for the Oakridge Park affordable senior housing apartments under LOC Article 24.10, which would exempt the property from the City tax levy for Respect. Fv PI'en e Trust. 503-635-0215 380 A AVENUE PO BOX 369 LAKE OSWEGO, OR 97034 WWW.LAKEOSWEGO.CITY Page 2 the upcoming tax year (Attachment 1). NWHA is also requesting approval from the Council to request a property tax exemption from the Lake Oswego School District,which together with the City tax levy,would constitute more than 51% of the overall tax levy and would exempt the property from the total combined rate of taxation, if approved (Attachment 2).The applicant must apply annually to renew the tax exemption. BACKGROUND NWHA is a nonprofit corporation with a recognized 501(c)(3) status and is the operator of Oakridge Park Apartments located at 4255 Oakridge Road. Oakridge Park is an affordable senior housing community in Lake Oswego with 44 income-restricted apartment units and one manager unit. The apartments were financed and constructed under Section 202 of the National Housing Act to serve income-qualified seniors (62+) and received land use approval in 2007 (LU 07-0031). The apartments opened in 2011 and at initial occupancy, households must be income-qualified low-income seniors based on HUD area median income (AMI) limits (generally not exceeding 60% of AMI). The City Council approved Ordinance 2945 on May 7, 2024, which amended LOC Chapter 24, establishing a property tax exemption program for nonprofit corporation low income housing, pursuant to ORS 307.540- .548. The ordinance allows for a property tax exemption for affordable housing projects that meet certain criteria. See the Discussion section below for an analysis of the specific criteria outlined in LOC Article 24.10 as they relate to this request. NWHA is requesting a City property tax exemption (Attachment 1) for the above-referenced property. If the exemption is approved, the property would no longer be subject to the City tax levy. LOC 24.10.040.b also provides for an exemption to the combined tax levy for all applicable taxing districts. NWHA is seeking approval from the Council to request an exemption from the Lake Oswego School District (LOSD), which combined with the City tax exemption, would constitute more than 51% of the overall tax levy (Attachment 2). If the exemption is approved by the City and the School District, the project would be exempt from the total combined rate of taxation on the property. DISCUSSION LOC 24.10.010—24.10.070, specifically LOC 24.10.030(a), includes a set of criteria that a development must meet to be eligible for the City property tax exemption: a. A property is exempt from property taxation as provided by LOC 24.10.010 to 24.10.070 if: i. The property is owned or being purchased by a corporation described in section 501(c0(3) or(4) of the Internal Revenue Code that is exempt from income taxation under section 501(a) of the Internal Revenue Code; Respect. Excellence. Trust. Service 503-635-0215 380 A AVENUE PO BOX 369 LAKE OSWEGO, OR 97034 WWW.LAKEOSWEGO.CITY Page 3 ii. Upon liquidation, the assets of the corporation are required to be applied first in payment of all outstanding obligations, and the balance remaining, in cash and in kind, to be distributed to corporations exempt from taxation and operated exclusively for religious, charitable, scientific, literary or educational purposes or to the State of Oregon; iii. At the time the application is filed, the property is: A. Occupied by low income persons; or B. Held for a period not to exceed two years from the date the exemption is granted,for the purpose of developing low income housing. iv. The property or portion of the property receiving the exemption, if occupied, is actually and exclusively used for the purposes described in section 501(c)(3) or(4) of the Internal Revenue Code; Response: The City Attorney's Office has reviewed the above criteria and relevant documents provided by NWHA and concluded that all criteria above have been met (Attachment 3). v. The exemption has been approved as provided in LOC 24.10.060. Response: As discussed under the criteria, above, staff finds that the Oakridge Park property meets the criteria for approval. If Resolution 26-25 is approved by the Council, it will be forwarded to the Clackamas County Assessor as set forth in ORS 307.512 to certify that the property is exempt from taxation under the levy of the City. Tax Exemption for other Taxing Districts Pursuant to LOC 24.10.040, any exemption granted by the City applies solely to the City's portion of the property tax levy. However, the City may authorize a request to seek agreement to the policy of exemption from the other taxing districts. In order to qualify for an exemption from the total combined rate of taxation on the property, the combined tax rate of these districts, together with the City's rate, must equal or exceed 51 percent of the total tax rate on the property. The applicant is requesting City authorization to seek agreement to the policy of exemption from LOSD, which combined with the City, would exceed 51 percent of the total tax rate on the property. If authorization is given by the City, NWHA will request approval of the tax exemption from the LOSD Board. FISCAL IMPACT The Clackamas County Tax Assessor's Office calculated the City property tax contribution for the Oakridge Park property to be approximately$4,665 per year. Respect. Excellence. Trust. Service 503-635-0215 380 A AVENUE PO BOX 369 LAKE OSWEGO, OR 97034 WWW.LAKEOSWEGO.CITY Page 4 RECOMMENDATION Approve Resolution 26-25 (Attachment 4) granting the property located at 4255 Oakridge Road, site of the Oakridge Park apartments,tax exemption status from the City tax levy and grant approval for NWHA to request an exemption from the other taxing districts per LOC 24-10.040. ATTACHMENTS 1. Northwest Housing Alternatives Application for Tax Exemption Request 2. Northwest Housing Alternative Application Addendum 3. City Attorney's Office Tax Exemption Analysis Memorandum, dated May 1, 2026 4. Draft Resolution 26-25 Respect. Fv. „i'en e Trust. -! 503-635-0215 380 A AVENUE PO BOX 369 LAKE OSWEGO, OR 97034 WWW.LAKEOSWEGO.CITY ATTACHMENT 1 /.I o ■■ Northwest Housing 2316 SE Willard, Milwaukie, Oregon 97222 Alternatives p: 503.654.1007 • F: 503.654.1319 • www.nwhousing.org December 5, 2025 Martha Bennett, City Manager City of Lake Oswego 380 A Avenue Lake Oswego, OR 97034 Re: Application for Nonprofit Corporation Low-Income Housing Property Tax Exemption (LOC 24.10.010- 070) Oakridge Park Apartments—2026-2027 Tax Year 4255 Oakridge Rd, Lake Oswego, OR 97035— Property ID C194252/Alt. Property#21E08CB00400 Dear Ms. Bennett, Northwest Housing Alternatives, Inc. ("NHA") respectfully submits this application for a Nonprofit Corporation Low-Income Housing Property Tax Exemption under LOC 24.10.010-070 for the 2026- 2027 assessment year for Oakridge Park Apartments in Lake Oswego, Oregon. 1. Property Description • Property name: Oakridge Park Apartments • Street address:4255 Oakridge Rd, Lake Oswego, OR 97035 • Assessor Property ID: C194252 • Alternate Property#: 21E08CB00400 • Tax Code Area: 007-093 • Property description (per assessor):420 LAKE VIEW VILLAS FIRST ADD PT LT 3 • Number of residential units:45 total senior(62+) apartment homes, including 1 on-site manager unit and 44 resident units • Subsidy/Regulatory status: o Financed and constructed under Section 202 of the National Housing Act to serve income-qualified seniors (62+) o Project Rental Assistance Contract(PRAC)with HUD (OR165061002) providing rental assistance for up to 44 units, currently expiring October 31, 2025 O 9%federal LIHTC allocation under Section 42 of the Internal Revenue Code, administered by OHCS, with a long-term affordability commitment requiring 44 of the 45 units to be rent-restricted and occupied by low-income tenants for 60 years from completion (November 10, 2011) Oakridge Park Limited Partnership is an Oregon limited partnership formed to construct and operate Oakridge Park Apartments, an age-restricted (62+) senior housing community in Lake Oswego. Page 1 of 4 ATTACHMENT 1/PAGE 1 OF X ■■ Northwest 6 %) Housing 2316 SE Willard, Milwaukie, Oregon 97222 Alternatives p: 503.654.1007 • f: 503.654.1319 • www.nwhousing.org 2. Charitable Purpose of the Project Oakridge Park Apartments furthers NHA's charitable mission by: • Providing affordable,service-rich senior housing(62+) in Lake Oswego to older adults with low incomes. • Ensuring long-term affordability through both Section 202/PRAC and LIHTC regulatory commitments. • Offering stable, accessible housing for seniors who are at high risk of housing cost burden and displacement absent subsidized housing. All residential units at Oakridge Park are devoted to this charitable housing purpose. 3. Certification of Income Levels of Low-Income Senior Occupants Oakridge Park is regulated by both Section 202/PRAC and Section 42 LIHTC requirements: • Tenant households must meet income eligibility criteria as low-income seniors(62+) under HUD and OHCS standards at initial occupancy(generally not exceeding 60%of AMI). • At least 44 of the 45 units are required to be rent-restricted and occupied by low-income senior tenants for a period of 60 years from completion. NHA certifies that Oakridge Park Apartments is operated in full compliance with these regulatory agreements and that the property functions as low-income housing for seniors within the meaning of LOC 24.10.030 and LOC 24.10.020. 4. How the Property Tax Exemption Will Benefit Residents In the 2024 tax year, Oakridge Park Apartments paid $16,278 in property taxes. Granting the requested exemption for the 2026-2027 tax year will enable NHA to: • Address deferred maintenance, including ongoing repair and replacement of building components to preserve safe, accessible senior housing. • Offset rising operating costs, particularly property insurance premiums and increasing labor costs associated with building operations and resident services. Page 2 of 4 ATTACHMENT 1/PAGE 2 OF X ■■ Northwest 6 %) Housing 2316 SE Willard, Milwaukie, Oregon 97222 Alternatives p: 503.654.1007 • f: 503.654.1319 • www.nwhousing.org • Maintain stable, affordable rents for very low-income senior residents by reducing reliance on rent increases to cover non-discretionary operating cost growth. When combined with the exemption requested for Hollyfield Village,these savings will redirect a substantial amount of resources each year into capital preservation and operating stability for Lake Oswego's existing stock of deeply affordable senior housing. 5. Future Development/Held for Future Use Oakridge Park Apartments is a completed,occupied senior housing project.The property is not being held for future development, and the provisions of LOC 24.10.040(1)(d) relating to undeveloped property do not apply. 6. Nonprofit Status and Federal Tax Exemption Northwest Housing Alternatives, Inc. is an Oregon nonprofit corporation described in IRC§ 501(c)(3) and exempt from taxation under§ 501(a). NHA's activities at Oakridge Park Apartments are exclusively charitable within the meaning of§ 501(c)(3). 7.Compliance with LOC 24.10.030 Criteria Oakridge Park Apartments meets all criteria in LOC 24.10.030: 1. Ownership/Control by Qualifying Nonprofit o The property is owned by Oakridge Park Limited Partnership, formed to own and operate the project as affordable senior housing. NHA is the nonprofit sponsor and operator of the project and participates in the ownership/management structure, such that the property is nonprofit-sponsored low-income housing for purposes of ORS 307.540-548 and LOC 24.10.010-070. 2. Use for Charitable (501(c)(3)) Purposes o The property is used exclusively to provide affordable rental housing to low-income seniors(62+), a charitable purpose recognized under§ 501(c)(3). 3. Occupied by Low-Income Persons Page 3 of 4 ATTACHMENT 1/PAGE 3 OF X ■■ Northwest Housing 2316 SE Willard, Milwaukie, Oregon 97222 Alternatives p: 503.654.1007 • F: 503.654.1319 • www.nwhousing.org o At least 44 of the 45 units are rent-restricted and occupied by low-income senior tenants as required by the Section 202 and LIHTC regulatory agreements, satisfying the low-income occupancy requirements in LOC 24.10.020 and 24.10.030. 8. Contact and Oath/Affirmation Applicant/ Nonprofit Sponsor Northwest Housing Alternatives, Inc. 2316 SE Willard St Milwaukie, OR 97222 Contact: Zachary Schroeder Email: schroeder@nwhousing.org Phone: (415) 214-0846 The undersigned, on behalf of Northwest Housing Alternatives, Inc., affirms that: • The information in this application is true and correct to the best of my knowledge. • NHA is familiar with the requirements of LOC 24.10.010-070 and will operate Oakridge Park Apartments in compliance with those requirements. • NHA agrees to provide any additional information reasonably required by the City Manager to evaluate this application. Lindsay Hallberg Chief Financial Officer Northwest Housing Alternatives, Inc. Date: Page 4 of 4 ATTACHMENT 1/PAGE 4 OF X ATTACHMENT 2 ■■01..121 Northwest Housing Alternatives 2316 SE Willard, Milwaukie, Oregon 97222 p: 503.654.1007 • f: 503.654.1319 • www.nwhousing.org May 5, 2026 Jessica Numanoglu, Community Development Director City of Lake Oswego 380 A Avenue Lake Oswego, OR 97034 Re:Addendum to Application for Nonprofit Corporation Low-Income Housing Property Tax Exemption (LOC 24.10.010-070) Oakridge Park Apartments—2026-2027 Tax Year 4255 Oakridge Rd., Lake Oswego, OR 97035—Property ID C194252/Alt. Property#21E08CB00400 Dear Jessica, On December 5, 2025, Northwest Housing Alternatives, Inc. ("NHA") submitted an application for a Nonprofit Corporation Low-Income Housing Property Tax Exemption pursuant to LOC 24.10.010-070 for the 2026-2027 assessment year for Oakridge Park Apartments in Lake Oswego, Oregon. At the time of submission,we did not fully understand that the application would apply only to the City of Lake Oswego's tax levy. Our intent from the outset was to pursue exemption consideration across all eligible taxing jurisdictions in support of the long-term affordability and sustainability of the community. With respect for the City's process and Council's authority, NHA would like to exercise its ability under ORS 307.543(2) and respectfully requests City Council approval to initiate outreach and seek participation from the remaining taxing districts. We greatly appreciate the City's partnership and consideration of this request. Please let us know if there is any additional information we can provide to assist in your review. If you need additional information, please contact me at (503)407-1232 or mitchell@nwhousing.org. Sincerely, Laura Mitchell Asset Manager ATTACHMENT 2/PAGE 1 OF 1 ATTACHMENT 3 ED MEMORANDUM seel CITY ATTORNEY'S OFFICE I o OREGO "‘ TO: Mayor and City Council Jessica Numanoglu, Community Development Director FROM: Erica Tatoian, City Attorney SUBJECT: Northwest Housing Alternatives, Inc. Determination for Eligibility for Tax Exemption under Article 24.10 Nonprofit Corporation Low Income Housing DATE: May 1, 2026 BACKGROUND Article 24.10 of the City Code adopts provisions of ORS 307.540 to 307.558 to grant tax exemption status to qualifying nonprofit corporations for low-income housing from the City's tax levy. Northwest Housing Alternatives, Inc. ("NWHA") has submitted applications for Article 24.10 tax exemption status for two developments: Oakridge Park Apartments and Hollyfield Village Apartments. This memorandum confirms that both properties are eligible for the tax exemption status under Article 24.10. DISCUSSION Under LOC 24.10.030(a)(i)-(iv), real property is eligible for a tax exemption from the city tax levy if: The property is owned or being purchased by a corporation described in section 501(c)(3) or (4) of the Internal Revenue Code that is exempt from income taxation under section 501(a) of the Internal Revenue Code; Oakridge Park Apartments. According to the Clackamas County tax assessor, 4255 Oakridge Road is owned by Oakridge Park LP. The general partner for Oakridge Park LP is Oakridge GP LLC, whose sole member and manager is NWHA. NWHA is an Oregon nonprofit corporation organized for charitable purposes under Internal Revenue Code §501(c)(3). Respect. Excellence. Trust. Service 503-635-0225 380 A AVENUE PO BOX 369 LAKE OSWEGO, OR 97034 WWW.LAKEOSWEGO.CITY ATTACHMENT 3/PAGE 1 OF 4 Page 2 Under ORS 307.518(4), a partnership "shall be considered a nonprofit corporation" for purposes of the low-income property tax exemption if the nonprofit is the general partner of the partnership and the nonprofit corporation is responsible for the day-to-day operation of the property that is the subject of the exemption. Under ORS 307.022, the property of an LLC qualifies for a tax exemption if the LLC is wholly owned by a nonprofit whose property is exempt from taxation. Under ORS 307.022, ORS 307.518, and LOC 24.030(a)(i), NWHA qualifies as the property owner for tax exemption purposes because it manages Oakridge GP LLC, the general partner of Oakridge Park LP, which owns 4255 Oakridge Rd. ORS 307.518 allows a limited partnership to be treated as a nonprofit corporation when a nonprofit, like NWHA, is responsible for the day- to-day operations of the property. Additionally, ORS 307.022 provides that property held by an LLC can qualify for exemption if the LLC is wholly owned by a nonprofit corporation and the property would qualify for exemption if held directly by the nonprofit. As the manager of the general partner LLC, NWHA exercises operational control over the property, fulfilling the statutory requirements. This structure effectively positions NWHA as the owner for purposes of the low-income housing tax exemption, aligning with the legislative intent to support nonprofit- managed affordable housing projects. This criterion is met. Hollyfield Village Apartments. According to the Clackamas County tax assessor, Hollyfield Village Apartments LP is the owner of 4077 Sunset Drive. The general partner for Hollyfield Village Apartments LP is Hollyfield Village Acquisition LLC, a manager-managed LLC, managed by NWHA. Under ORS 307.022, ORS 307.518, and LOC 24.030(a)(i), NWHA qualifies as the property owner for tax exemption purposes because it manages Hollyfield Village Acquisition LLC, the general partner of Hollyfield Village Apartments LP, which owns 4077 Sunset Drive. ORS 307.518 allows a limited partnership to be treated as a nonprofit corporation when a nonprofit, like NWHA, is responsible for the day-to-day operations of the property. Additionally, ORS 307.022 provides that property held by an LLC can qualify for exemption if the LLC is wholly owned by a nonprofit corporation and the property would qualify for exemption if held directly by the nonprofit. As the manager of the general partner LLC, NWHA exercises operational control over the property, fulfilling the statutory requirements. This structure effectively positions NWHA as the owner for purposes of the low-income housing tax exemption, aligning with the legislative intent to support nonprofit-managed affordable housing projects. This criterion is met. 503.675.3984 380 A Avenue PO Box 369 Lake Oswego, OR 97034 www.ci.oswego.or.us ATTACHMENT 3/PAGE 2 OF 4 Page 3 ii. Upon liquidation, the assets of the corporation are required to be applied first in payment of all outstanding obligations, and the balance remaining, in cash and in kind, to be distributed to corporations exempt from taxation and operated exclusively for religious, charitable, scientific, literary or educational purposes or to the State of Oregon; Per ORS 307.022, the "corporations" for these applications are Oakridge GP LLC and Hollyfield Village Acquisition LLC whose sole member and manager is NWHA. Staff has reviewed the Northwest Housing Alternatives, Inc. Amended and Restated Articles of Incorporation, dated August 14, 1995, and finds that Section 3.2 of those Articles meets the requirement of LOC 24.10.030(a)(ii). This criterion is met. iii. At the time the application is filed, the property is: A. Occupied by low-income persons; or B. Held for a period not to exceed two years from the date the exemption is granted, for the purpose of developing low-income housing; Oakridge Park Apartments. Oakridge Park Apartments was financed and construction under Section 202 of the National Housing Act to serve income-qualified seniors (62 years and older). It is subject to a long-term affordability commitment requiring 44 of its 45 units to be rent- restricted and occupied by low-income tenants until 2071. Tenants must meet income eligibility criteria as low-income seniors whose income does not exceed 60% of the HUD area medium income. As a result, the property serves persons qualifying as "low-income" as that term is defined in LOC 24.10.020. This criterion is met. Hollyfield Village Apartments. Hollyfield Village is a project for purposes of Internal Revenue Code §42 Low-Income Housing Tax Credit (LIHTC), serving residents who rely on project-based Section 8 rental assistance. Under applicable regulations, residents of Hollyfield Village must be income-qualified low-income seniors based on HUD area median income limits and remain subject to ongoing income certification and rent restrictions under LIHTC and Section 8 program rules. As a result, the property serves persons qualifying as "low-income" as that term is defined in LOC 24.10.020. This criterion is met. iv. The property or portion of the property receiving the exemption, if occupied, is actually and exclusively used for the purposes described in section 501(c)(3) or (4) of the Internal Revenue Code. The applicant has affirmed that both Oakridge Parks Apartments and Hollyfield Village Apartments are used exclusively to provide affordable rental housing to low-income seniors, a charitable activity under IRC §501(c)(3). This criterion is met. 503.675.3984 380 A Avenue PO Box 369 Lake Oswego, OR 97034 www.ci.oswego.or.us ATTACHMENT 3/PAGE 3 OF 4 Page 4 Documents Reviewed 1. Clackamas County Property Account Summary, https://ascendweb.clackamas.us/ParcelInfo.aspx?parcel number=00242758 2. Clackamas County Property Account Summary, https://ascendweb.clackamas.us/ParcelInfo.aspx?parcel number=00242204 3. Oregon SOS website and associated filings for Oakridge Park LP, Oakridge GP LLC, and Hollyfield Village Apartments LP, and Hollyfield Village Acquisition LLC 4. Northwest Housing Alternatives, Inc. Amended and Restated Articles of Incorporation, dated August 14, 1995 503.675.3984 380 A Avenue PO Box 369 Lake Oswego, OR 97034 www.ci.oswego.or.us ATTACHMENT 3/PAGE 4 OF 4 ATTACHMENT 4 RESOLUTION 26-25 A RESOLUTION OF THE LAKE OSWEGO CITY COUNCIL APPROVING A NONPROFIT CORPORATION LOW INCOME HOUSING TAX EXEMPTION FOR THE OAKRIDGE PARK AFFORDABLE SENIOR APARTMENTS LOCATED AT 4255 OAKRIDGE ROAD FROM THE CITY TAX LEVY AND AUTHORIZING NORTHWEST HOUSING ALTERNATIVES TO REQUEST A TAX EXEMPTION FROM OTHER TAXING DISTRICTS. WHEREAS, the City Council approved Ordinance 2945 on May 7, 2024, which amended LOC Chapter 24 to establish a property tax emption program for nonprofit corporation low-income housing pursuant to ORS 307.540- .548; and WHEREAS, Northwest Housing Alternatives, a nonprofit corporation with 501(c)(3) status, as determined by the Internal Revenue Service, filed an application requesting an exemption to the City tax levy for the 45-unit Oakridge Park affordable senior apartments located at 4255 Oakridge Road and requesting authorization to request a tax exemption from the other taxing districts; and WHEREAS, the Lake Oswego City Council considered the application at its May 19, 2026, meeting and found that the application met the criteria for an exemption to the City tax levy pursuant to LOC 24.10.030 and gave authorization to request an exemption from the other taxing districts per LOC 24.10.040(2); and NOW,THEREFORE, BE IT RESOLVED by the City Council of the City of Lake Oswego that: Section 1. The City Council approves an exemption to the City tax levy for the Oakridge Park affordable senior apartments at 4255 Oakridge Road and authorizes Northwest Housing Alternatives to request an exemption from the other taxing districts. Section 2. Effective Date. This Resolution shall take effect upon passage. Considered and enacted at the regular meeting of the City Council of the City of Lake Oswego on the 19th day of May, 2026. AYES: NOES: EXCUSED: ABSTAIN: Joseph M. Buck, Mayor Resolution 26-25 Page 1 of 2 ATTEST: [aural Hawkins, City Recorder APPROVED AS TO FORM: Erica Tatoian, City Attorney Resolution 26-25 Page 2 of 2