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HomeMy WebLinkAbout10/06/1998, 2 - SIGN AMORTIZATION AND ABATEMENT PROGRAM council j acEnaa Repoat "� a CITY OF SAN LU I S O B I S P O b FROM: Arnold Jonas, Community Development Director Prepared By: Ronald Whisenand,Development Rel Manage SUBJECT: SIGN AMORTIZATION AND ABATEMENT PROGRAM CAO RECOMMENDATION Accept the report on the sign amortization and abatement program and adopt a resolution directing staff to correct non-conforming signs as individual re-development, remodeling, expansion, or sign program updates are proposed. DISCUSSION Situation With assistance from the community and the Architectural Review Commission (ARC), the City Council adopted a comprehensive update to the City's Sign Regulations on July 3, 1997. The purpose of this ARC work program was to correct cumbersome sign regulations and make the ordinance easier to understand and apply. As discussed in Council's May 20, 1997 report on the new sign regulations, the second phase of the work program is consideration of a possible reactivation of the City's Sign Amortization Program. Amortization is a program that provides for the gradual elimination or replacement of non- conforming signs over a reasonable time period. Sign amortization in the City of San Luis Obispo began with the first comprehensive sign ordinance amendment dating back to September 3, 1977. In order to meet legal requirements, the City's program contained amortization periods ranging from two to ten years depending on the value of the non-conforming sign. The purpose of the program was to allow continued use of non-conforming signs but ultimately ensuring that community sign standards would be met. Following a survey that began in 1977, the City mailed notices to all property owners of non- conforming signs giving them the time frame that they had to work with in order to bring their signs into compliance. With an original ordinance date of September 3, 1977, all non- conforming signs were to be removed or replaced with conforming signs by September 3, 1987. Many of the property owners who were subject to the City's Sign Amortization Program cooperated and brought their signage into compliance. Research into the City's sign amortization files, combined with a field survey conducted earlier this year, noted that 118 of 160 properties with non-conforming signs made the necessary changes to comply. There remain 42 property owners that were subject to the 1977 amortization program who have failed to bring their signs into compliance. Council Agenda Report-Sign Amortization and Abatement Program Page 2 The City's amortization program remains in effect and was in no way modified or superseded by more recent amendments to the City's Sign Regulations. The program was slowed down however in the early 1990s due to work load, staffing, and other enforcement priorities. Currently, City staff and the ARC gain compliance on a case by case basis when development applications are processed for building modifications or for new signs on properties where fully amortized signs remain. Summary of the Law Advertising signage is one area that is heavily regulated by State law. The California Business and Professions Code contains several key statutes that govern how cities regulate non- conforming signs. In summary, amortization programs established prior to March 12, 1983 are lawful and signs that have had their amortization periods rum, can be abated. Since San Luis Obispo's amortization program was established in 1977, we have the ability to abate any remaining signs that have not been removed or made to comply with standards contained in that 1977 sign ordinance. Changes in our sign regulations made after 1983 do not permit us to establish an amortization program without payment of"fair and just" compensation. There are exceptions however in the case of illegal, abandoned, damaged(beyond 50%),modified, moved, and hazardous signs. In addition to statutes that regulate the amortization and removal of non-conforming signs, State law also addresses how city's must accomplish abatement of these amortized signs. As would be expected, any action by the City to declare these signs nuisances and abate them, requires all affected property owners to be notified and given an opportunity to present arguments or "protests"before the City Council why their sign(s) should not be abated. Abatement Decisions The first decision that the Council needs to make is how to proceed with the City's 1977 Sign Amortization Program. The 42 property owners of the remaining non-conforming signs have clearly had proper notice and sufficient time (over 20 years) to bring their signage into compliance. If the Council should choose to bring the remaining amortized signs into compliance through an abatement process, the first step would be to hold a public hearing where the Council would declare those remaining signs as illegal and a public nuisance. The next step will be schedule an objection hearing before the City Council where property owners of these illegal signs can present evidence and the Council can allow or overrule any objection. This objection hearing must be properly noticed (using a format dictated by the statutes) and the property posted. Following the protest hearing(s), all remaining illegal signs would be turned over to the City's enforcement officer for abatement. It is important to note that although the above process would be the quickest and most effective method to gain compliance, it will certainly not be without controversy. Although there are a few visibly non-conforming signs in town, primarily large free-standing pole signs (i.e. Royal 02 Council Agenda Report-Sign Amortization and Abatement Program Page 3 Oak Motel, Vagabond Inn, and Dennys on Madonna Road), there are others that many would not necessarily consider offensive or out of compliance (i.e. Boston Bagel's hanging sign, Gus's Grocery awning sign, or the landmark Madonna Inn sign). The Council therefore needs to consider the significance of any action to start a citywide abatement program. Although the amortization program established in 1977 has received less attention in the past decade, it is important to note that staff is still pursuing the removal or replacement of non- conforming signage throughout the City. The current process involves working with property owners when they come in with redevelopment plans or new signage programs. A recent example would be the Shell station on Madonna Road as part of a station remodel. Through the ARC process, the applicants agreed to lower the non-conforming freeway pole sign to the then current standard of 25 feet. Since any action on this important program will have an effect on existing business interests, staff presented the Sign Amortization Program options to the Chamber of Commerce for review and input. The Chamber strongly supports the City's Sign ordinance but feels that forcing compliance through abatement is not necessary. The Chamber therefore recommends that the City take a moderate approach whereby remaining non-conforming signs are brought into compliance through on-going remodeling and redevelopment efforts. This approach would require a long time period (perhaps decades) to achieve compliance, with some signs not changing in the foreseeable future. Issues with Taking the Recommended Action Pursuing an aggressive abatement program will certainly affect 42 businesses in San Luis Obispo. Signage is critical exposure for all businesses and is not without expense. However, this community has consistently demanded quality signage with adoption of every sign ordinance dating back to 1977. The question is how fast does the Council wish to accomplish bringing our non-conforming signs into compliance. Although staff's current method of gaining compliance on a case by case basis may be taking longer than some may like, we still feel that the process is effective. In addition, in recent years the City has made great efforts to change the perception that it is "unfriendly" to business. An aggressive abatement program would likely become a "media event" and negatively effect the progress we have made and the economic development goals established by Council. We would therefore recommend that the Council direct staff to continue with this approach and to work with property owners to ensure that future development plans are sensitive to our current community's sign standards. FISCAL IMPACT Continuing with our present method of sign amortization will involve no additional staff resources. Sign issues will be addressed through the normal planning application process where processing fees are paid by the applicants pursuant to the City's fee schedule. A•3 Council Agenda Report-Sign Amortization and Abatement Program Page 4 Reactivating a more aggressive sign amortization program with abatement, will also involve use of existing staff resources. The notification and hearing process will be accomplished by Community Development. Abatement cases will be referred to the Neighborhood Services Manager for initiation of required action. Work will be on a "as time allows" basis factoring existing case loads and priorities. However, with the existing case load, it may be some time before all of the cases could be processed and signs removed or replaced. Even with such delays, however, compliance issues would be resolved in a much shorter period of time than through attrition. ALTERNATIVES The Council has two main alternatives to staff's recommended action: 1. Abandon the City's sign amortization program. Taking this action would mean that the 42 remaining properties would be allowed to retain their non-conforming signs. The signs could be maintained and copy changed to accommodate new business owners. Such action would be inequitable to those businesses which previously brought their signage into compliance. 2. Reactivate the City's sign amortization program. This alternative involves full reactivation of the program and initiating the hearings necessary to declare the remaining signs public nuisances. This option would require a two step process outlined above that would include a hearing to declare the nuisance and a second to allow land owner objections. Attachments 1. Resolution in support of taking moderate approach 2. Resolution declaring remaining non-conforming signs as public nuisances and setting an objection hearing. 3. Chamber of Commerce correspondence M 'ING AGENDA DATE �d ITEM # RESOLUTION NO. (1998 Series) A RESOLUTION OF THE COUNCIL OF THE CITY OF SAN LUIS OBISPO DIRECTING STAFF TO BRING NON-CONFORMING SIGNS SUBJECT TO THE CITY'S 1977 AMORTIZATION PROGRAM INTO COMPLIANCE WITH REMODELING AND REDEVELOPMENT OF THE PROPERTY WHEREAS, the City of San Luis Obispo adopted Ordinance No. 709 (1977 Series) on August 2, 1977 that established new sign regulations for the City of San Luis Obispo; and WHEREAS, these 1977 sign regulations contained provisions for amortization of signs made non-conforming by the new regulations including provision for written notice and a valid amortization period commencing on September 3, 1977; and WHEREAS,there remain properties listed on the attached "Exhibit A"that were subject to the City's amortization program who have failed to bring their signs into compliance; and WHEREAS, the City Council desires that these remaining signs be brought into compliance as soon as practical in order to insure quality and uniform signage within the City. BE IT RESOLVED,by the City Council of the City of San Luis Obispo as follows: SECTION 1. The City Council reaffirms the purposes the City's Sign Regulations calling for the protection and enhancement of the character and natural beauty of the community through proper signage and goals and objectives of the City's Sign Amortization Program. SECTION 2. The City Council hereby directs staff to require any remaining non- conforming sign that was subject to the City's 1977 Sign Amortization Program to be made to comply upon re-development, remodeling, or expansion of the use or abandonment, modification,moving, or other physical change in the property's signage. On motion of seconded by , and on the following roll call vote: AYES: NOES: ABSENT: the foregoing resolution was passed and adopted this_day of 1998. OrOUNCIL ❑CDD DIR STAO CTfi-N DIR [IItCAO CCfJR E CH... CkTORNEY GFW DIR LERKIORIG C5;0LICE CYF ❑Mei AM CDIR r � UTI UTIL DIR ❑ E rkRS DIR Resolntion No. (1998 Series) Page 2 Mayor Allen Settle ATTEST:• City Clerk APPROVED AS TO FORM: Att ey ffJ gensen v2' �P "EXHIBIT A" SITE ADDRESS CURRENT PROPERTY NON-CONFORMING SIGN(S) AMORT. BUSINESS DESCRIP. PERIOD ENDS 1708 Beach Sandercock 003-625-015 Large Roof Sign Jan. 1983 Moving 2143 Broad Gaslight Lounge 003-746-035 non conforming roof sign- too many Dec. 1982 signs 1127 Broad Boston Ba el 002-422-016 hanging sign Feb. 1983 2145 Broad Manuels liquor 003-746-035 sign too laze"Manuels" Dec. 1982 1460 Calle Joaquin Denny's 053-151-036 non-conforming,large pole sign sep. 1987 22 Chorro Mobil 052-174-002 non-conforming le sign Oct. 1982 767 Chorro Mc Lains Photo 002-302-018 wood sign,too laze Mar. 1983 1030 Chorro Mission News 002-425-001 wood sign,too low to sidewalk Feb. 1983 774 Foothill Cork&Bottle 052-041-079 non-conforming ole sign Sep. 1985 798 Francis SL Powerhouse 004-923-008 prohibited hanging wood sign May 1983 214 Hi era Pauls dry clean 003-711-043 non-conforming,too laze Apr. 1983 236 Hi era Hayward 003-711-041 no permits,too large Oct. 1988 245 Hi era Ratliff welding 003-721-034 non-conforming roof sign Apr. 1983 532 Hi era Campbell's 002-402-028 non-conforming roof sign Mar. 1983 669 Hi era Davidson's 002-422-019 non-conforming,too large Mar. 1983 1212 Hi era San Luis Liqr. 002-331-005 non-conforming ole sign Mar. 1983 100 Madonna Madonna Inn 004-511-009 non-conforming,too large,in setback Sep. 1987 208 Madonna Denny's 004-871-015 non-conforming laze pole sign Jun. 1988 210 Madonna Vagabond Inn 004871-016 non-conforming laze pole sign Sep. 1987 212 Madonna IHOP 004871-010 non-conforming laze pole sign Aug. 1982 214 Madonna Royal Oak 004871-010 non-conforming GIANT pole sign Sep. 1987 886 Monterey Bello's 002-416-018 non-conforming ojectin sign Apr. 1983 1266 Monterey Am. Cleaners 001-222-015 non-conforming sign,too large Apr. 1983 1335 Monterey Computer Stuff 002-333-004 non-conforming projecting sign May 1983 1441 Monterey Mid State Elec. 001-231-024 Non-conforming roof sign A r. 1983 1599 Monterey Cap.Jacks vid. 001-234-005 non-conforming ole sign Feb. 1982 1601 Monterey Pepe Delizados 001-237-001 non-conforming ole sign Se . 1985 1628 Monterey Palm Motel 001-142-003 non-conforming le sign in setback Sep. 1983 1670 Monterey Villa Motel 001-142-007 Non-conforming sign Dec. 1987 1701 Monterey Standard Mot. 001-151-014 Non-conforming sim too large Dec. 1982 2223 Monterey Motel Inn 001-112-018 Non-conforming ole sign Sep. 1987 !000 Olive Olive Tree Inn 001-112-018 Non-conforming, in setback' Sep. 1987 1001 Olive Coachman 001-204-021 non-conforming monument signs Sep. 1987 1638 Osos Gus's Grocery 003-553-014 awning sign where not allowed Jan. 1983 150 Pismo SDRC rec. 002-501-002 too large,non-conforming Feb. 1983 1951 Santa Barbara 2 businesses? 003-647-016 Signs in Setback, city right o way Feb. 1983 296 Santa Rosa Shell 001-113-010 non-conforming ole sign Jan. 1983 363 Santa Rosa Union 76 001-112-016 non-conforming ole sign Sep. 1987 313 South McCarth 's 004-811-013 non-conforming roof sign Jan. 1983 1340 Taft Union 76 001-042-022 non-conforming ole sign Oct. 1982 625 Toro El Torn motel 001-121-030 non-conforming ole si s Oct. 1982 1390 Walker I CN signs 002-505-005 non-conforming ole sign aband. A . 1983 RESOLUTION NO. (1998 Series) A RESOLUTION OF THE COUNCIL OF THE CITY OF SAN LUIS OBISPO DECLARING VARIOUS ILLEGAL ON-PREMISES ADVERTISING DISPLAYS AS PUBLIC NUISANCES AND SETTING AN OBJECTION HEARING WHEREAS, the City of San Luis Obispo adopted Ordinance No. 709 (1977 Series) on August 2, 1977 that established new sign regulations for the City of San Luis Obispo; and WHEREAS, these new sign regulations contained provisions for amortization of signs made non-conforming by the new regulations including provision for written notice and a valid amortization period commencing on September 3, 1977; and WHEREAS, those properties listed on the attached "Exhibit A" were subject to the City's amortization program, were notified to remove or conform with the amended sign regulations, and have failed to comply with the program; and WHEREAS, Section 5494 of the California Business and Professions Code states that these non-conforming signs are presumed illegal "once the amortization period provided by the ordinance or regulation rendering them non-conforming has lapsed and conformance has not been accomplished"; and WHEREAS, the City Council conducted a public hearing on October 6, 1998 and has considered testimony of interested parties and the evaluation and recommendation of staff; and BE IT RESOLVED,by the City Council of the City of San Luis Obispo as follows: SECTION 1. The City Council reaffirms the purposes the City's Sign Regulations calling for the protection and enhancement of the character and natural beauty of the community through proper signage and goals and objectives of the City's Sign Amortization Program. SECTION 2. The City Council finds and determines that the signs listed on the attached "Exhibit A"are public nuisances and shall be subject to abatement. SECTION 3. The City Council hereby directs staff to conspicuously post "Notice to Remove Illegal Advertising Display" on those properties identified in "Exhibit A" as well as provide written notice of proposed abatement in a manner as prescribed by law. 41. 8 Resolution No. (1998 Series) Page 2 On motion of seconded by and on the following roll call vote: AYES: NOES: ABSENT: the foregoing resolution was passed and adopted this_day of . 1998. Mayor Allen Settle ATTEST: City Clerk APPROVED AS TO FORM: City Attorney Jeff Jorgensen Z• q "EJMIT A" SITE ADDRESS CURRENT PROPERTY NON-CONFORMING SIGN(S) AMORT. BUSINESS DESCRIP. PERIOD ENDS 1708 Beach Sandercock 003-625-015 Large Roof Sign Jan. 1983 Movin 2143 Broad Gaslight Lounge 003-746-035 non conforming roof sign- too many Dec. 1982 signs 1127 Broad Boston Bagel 002-422-016 hanging sign Feb. 1983 2145 Broad Manuels liquor 003-746-035 sign too laze"Manuels" Dec. 1982 1460 Calle Joaquin Denny's 053-151-036 non-conforming,large pole sign Sep. 1987 22 Chorro Mobil 052-174-002 non-conforming ole sign Oct. 1982 767 Chorro Mc Lains Photo 002-302-018 wood sign,too large Mar. 1983 1030 Chorro Mission News 002-425-001 wood sign,too low to sidewalk Feb. 1983 774 Foothill Cork&Bottle 052-041-079 non-conforming ole sign Sep. 1985 798 Francis SL Powerhouse 004-923-008 prohibited hanging wood sign May 1983 214 Hi era Pauls dry clean 003-711-043 non-conforming,too lare Apr. 1983 236 Hi era Hayward 003-711-041 no permits,too large Oct. 1988 245 Hi era Ratliff welding 003-721-034 non-conforming roof sign Apr. 1983 532 Hi era Campbell's 002-402-028 non-conforming roof sign Mar. 1983 669 Higuera Davidson's 002-422-019 non-conforming,too la Mar. 1983 1212 Hi era San Luis Li r. 002-331-005 non-conforming ole sign Mar. 1983 100 Madonna Madonna Inn 004-511-009 non-conforming,too large,insetback S . 1987 208 Madonna Denny's 004871-015 non-confonnin large le si Jun. 1988 210 Madonna Vagabond Inn 004871-016 non-conformin large le si S . 1987 212 Madonna IHOP 004-871-010 non-conforminglarge ole signAu . 1982 214 Madonna Royal Oak 004-871-010 non-conforming GIANT pole sign Sep. 1987 886 Monterey Bello's 002-416-018 non-conforming projecting sign Apr. 1983 1266 Monterey Am. Cleaners 001-222-015 non-conforming sign, too laze Apr. 1983 1335 Monterey Computer Stuff 002-333-004 non-conforming projecting sign May 1983 1441 Monterey Mid State Elec. 001-231-024 Non-conforming roof sign Apr. 1983 1599 Monterey Cap.Jacks vid. 001-234-005 non-conforming ole sign Feb. 1982 1601 Monterey Pepe Del dos 001-237-001 non-conforming le sign Sep. 1985 1628 Monterey Palm Motel 001-142-003 non-conforming pole sign in setback Sep. 1983 1670 Monterey Villa Motel 001-142-007 Non-conforming sign Dec. 1987 1701 Monterey Standard Mot. 001-151-014 Non-conforming sign,too large Dec. 1982 2223 Monterey Motel Inn 001-112-018 Non-conforming le sign Sep. 1987 !000 Olive Olive Tree Inn 001-112-018 Non-conforming,in setback' Sep. 1987 1001 Olive Coachman 001-204-021 non-conforming monument signs Se . 1987 1638 Osos Gus's Grocery 003-553-014 awning sign where not allowed Jan. 1983 150 Pismo SDRC rec. 002-501-002 too large,non-conforming Feb. 1983 1951 Santa Barbara 2 businesses ? 003-647-016 Signs in Setback,city right o way Feb. 1983 296 Santa Rosa Shell 001-113-010 non-conforming ole sign Jan. 1983 363 Santa Rosa Union 76 001-112-016 non-conforming ole sign S 1987 313 South McCarth 's 004811-013 non-conformingroof si Jan. E 1340 Taft Union 76 001-042-022 non-conformingole sign Oct. 625 Toro El Toro motel 001-121-030 non-conformingole signs s Oct. 1390 Walker CN signs002-505-005 non-conformingole sign aband. A r. RECEIVED San Luis Obispo Chamber of Commerce MAY 27 1998 1039 Chorro Street • San Luis Obispo, California 93401-3278 CITY OF SAN LUIS OBISPO (805) 781-2777 • FAX (805) 543-1255 COMMUNITY DEVELOPMENT e-mail: slochamber®siochamberorg David E. Garth, President/CEO May 26, 1998 Ron Whisenand Development Review Manager City of San Luis Obispo 990 Palm Street San Luis Obispo, CA 93401 Re: Sign Ordinance Enforcement Dear Ron The San Luis Obispo Chamber of Commerce has been actively involved with the City's Sign Regulations since the late 1970s. The Chamber believes the purpose of the ordinance is two-fold. One it serves as a "level playing field", requiring all businesses in the City to comply with the same regulations. Two, it is a useful economic development tool since it improves the aesthetic quality of the City. The Chamber has been, and continues to be,in favor of moderate enforcement levels of the ordinance. The Chamber feels that enforcement is appropriate when a permit for development change is issued on a property. It is at that time that any existing non- complying signs should be brought into compliance. At this time, the Chamber does not think it is necessary force compliance. The moderate approach is working well and is not unduly burdensome. Thank you for seeking our input on this matter. Sincerely, TEN YEARS Shelly Stanwyck Director of Governmental Affairs 0 ACCREDITED C.. R w eo..wee ME'"TIE AGENDA DATE /o & .P ITEM # -- MEMO To: Council Members Roalman, Romero, Williams and Mayor Settle, and John Dunn, Jeff Jorgensen, Arnold Jonas, Ronald Whisenand, and Lee Pierce From: Council Member Ken Schwartz Re: October 6 Agenda Item 2, Sign Amortization and Abatement Program It pains me to learn that we are still talking about sign abatement after years(beginning well before 1977) of community debate on signs. I recognize that we are now dealing with some of the more difficult non-conforming signs, and possibly the most intransigent sign owners, but, nevertheless, I believe that there is a middle ground between the two positions contained in the staff report that might hasten the removal of these non-conforming signs. I recommend that the Council: 1. Defer action on this item and continue the matter for a period of say, 3 months, 2. Direct the staff to formulate a letter to be sent to the owner of each of the remaining non-conforming signs and to "personalize" each letter so that it relates to the specific problems of the sign(s)in question. The essential parts of such letter would be: a. A statement to the effect that the City Council has deferred taking a strict abatement action until owners of non-conforming signs could be polled by staff to determine the specific time period within which each owner plans to remove or otherwise bring his/her non-conforming sign(s)into conformity with the sign ordinance. b. Provide specific time periods from which the owner would choose;e.g. I plan to remove or bring my non-conforming sign into compliance before July 1, 1999;before July 1, 2000;before July 1, 2001. Enclose a post card return. c. The results ofthis poll will be reported back to the City Council at its meeting of March 1999, at which time the Council will determine if owner's abatement time schedules are sufficiently expeditious to warrant Council delay in pursuing abatement action. It is unfair to the the vast majority of owners of non-conforming signs who worked with the City to remove or modify their signs only to find that the City has not moved diligently to require the removal or modification of the remainder. rE33etEKKIORIG CIL DD DIA ❑FIN DIR ❑FIRE CFS RNEY ❑PW DIR 0 POLICE CHF O RTC DIR t]tlTll DIR 0 p a DIR MErTh AGENDA DATE ITEM # _ MEMO To: Council Members Roalman, Romero, Williams and Mayor Settle, and John Dunn, Jeff Jorgensen,Arnold Jonas,Ronald Whisenand, and Lee Pierce From: Council Member Ken Schwartz* Re: October 6 Agenda Item 2, Sign Amortization and Abatement Program It pains me to learn that we are still talking about sign abatement after years(beginning well before 1977)of community debate on signs. I recognize that we are now dealing with some of the more difficult non-conforming signs, and possibly the most intransigent sign owners,but, nevertheless, I believe that there is a middle ground between the two positions contained in the staff report that might hasten the removal of these non-conforming signs. I recommend that the Council: 1. Defer action on this item and continue the matter for a period of say, 3 months, 2. Direct the staff to formulate a letter to be sent to the owner of each ofthe remaining non-conforming signs and to "personalize" each letter so that it relates to the specific problems of the sign(s)in question. The essential parts of such letter would be: a. A statement to the effect that the City Council has deferred taking a strict abatement action until owners of non-conforming signs could be polled by staff to determine the specific time period within which each owner plans to remove or otherwise bring his/her non-conforming sign(s)into conformity with the sign ordinance. b. Provide specific time periods from which the owner would choose;e.g. I plan to remove or bring my non-conforming sign into compliance before July 1, 1999;before July 1, 2000;before July 1, 2001. Enclose a post card return. c. The results of this poll will be reported back to the City Council at its meeting of March , 1999, at which time the Council will determine if owner's abatement time schedules are sufficiently expeditious to warrant Council delay in pursuing abatement action. It is unfair to the the vast majority of owners of non-conforming signs who worked with the City to remove or modify their signs only to find that the City has not moved diligently to require the removal or modification of the remainder. roA"rO DD DIR❑FIN DIR ❑FIRE CH;ZF EY t7 PIN DIR RIG ❑POLICE CHF 0 HEC DIR O UTIL DIR O PERS DIR