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HomeMy WebLinkAboutagenda.apz.19930720 - ~ ><;>, 'Or 9- ? ~~ ~~ ~ AGENDA ASPEN PLANNING AND ZONING COMMISSION REGULAR MEETING July 20, 1993, Tuesday 4:30 P.M. 2nd Floor Meeting Room city Hall ------------------------------------------------------------------ ------------------------------------------------------------------ I. COMMENTS commissioners Planning Staff Public I I . MINUTES III. NEW BUSINESS A. Land Use Code Text Amendments - Condominiumization, Francis Krizmanich IV. ADJOURN -- 9 10121�•'DA_ -iTl TO: Mayor and City Council THRU: Amy Margerum, City Manager:_ FROM: Diane Moore, City Planning Direct r Leslie Lamont, Senior Planner DATE: December 7, 1992 RE: Condominiumization - Analysis of Impact of New State Statute (CCIOA) on City of -Aspen Land Use Regulations SUMMARY: On July 1, 1992, a new state statute titled the Colorado Common Interest Ownership Act ("CCIOA") went into effect.. Staff has been analyzing the new statute to determine the impact of CCIOA on planning/regulatory issues within the City. Staff is providing Council with this confidential memorandum (due to potential lawsuits) and has scheduled this issue as a discussion item for the December 7, 1992 Council agenda. As you will recall, several applicants have requested condominiumization and staff has advised them that until such time as the Municipal Code is amended, condominiumizations will follow existing requlations. Two applications are scheduled for second reading on the December 14, 1992 Council agenda. On October 26, 1992, Jed provided with you with a memorandum that outlined the legal implications of the new statute. The section of the Act that addresses "Applicability of local codes" states that: (1) no local building code may impose any requirement upon any structure held in common interest (e.g., a condominium) which it would not impose upon a physically identical structure held in a different ownership (except fire walls), and (2) no zoning, subdivision, or other real estate law, ordinance, or regulation may impose any requirement upon a condominium which it would not impose on a physically identical structure or development under a different form of ownership. . 1 5taff has focused on the impact of the Act on our city land use regulations, particularly Section 24-7- 1007 of the Municipal Code, that sets forth the requirements for the condominiumization of structures. This analysis focuses on the areas of review authority and the cost to the city associated with the elimination of our current condominium regulations. Staff has identified three major areas of concern: Rey Issue 1 - Affordable Housing Impact Fee: Currently, when free market residential units are condominiumized, an impact fee is paid to the Housing Fund to mitigate affordable housing needs generated by the condominiumization. Rey Issue 2 - Six .Month Minimum,Lease Restriction: Currently, a six month minimum lease is required for newly condominiumized units in an effort to maintain long term tenants/residents. Key Issue 3 - Lodge Condominiumization: Lodges that are condominiumized are required to remain in the short term market so that they are available to the general public as tourist accomodations. These issues will be addressed in the Key Issues. section along with staff recommendations. A summary of existing residential and lodge condominimumization regulations is attached as Exhibit "B". CONDOMINIUMIZATION BACKGROUND: Our current condominium regulations were developed as a direct result of impacts created by the condominiumization of units within the community. Previous research on the impacts of condominiumization resulted in a 1977 report. As a result, the Planning and Zoning Commission identified the following problem statements: 1. Condominiumization has served to reduce the rental supply over time. Rental supply is difficult, if not impossible to replace, particularly at the low income level. 2. Condominiumization is likely to result -in displacement of low and moderate income households over time, as the sale price of condominiumized units increases with each resale. Many of these units continue to be rented for a period of time, but usually not rented to the tenant who lived in the unit prior to condominiumization. While this has provided some ownership opportunities for locals in the past, this is not likely to continue as prices spiral further'upward. 2 In 1987, the city planning staff addressed the policy concerns associated with condominiumization. They also believed that condominiumization was much less of a problem in 1988 than in 1980 because much of the housing stock had already been condominiumized. The planning staff conducted research to document the relationship between residential development and the need for affordable housing. Their experience was that "condominiumization resulted in an increased propensity for units to be occupied by tourists, rather than residents". It was also clear from their research that units which house tourists require significantly greater levels of employee services than do units housing residents. They quantified an employee housing impact attributable to condominiumization. The result was the creation in 1988 of the affordable housing impact fee that has since been applied to condominiumizations; this is the fee that exi-sts in our current regulations-. - -- -- - . . Condominiumization Data In order to understand the extent of the condominiumization of lodges and residential units within the City, staff undertook background research on these.units (See Exhibit "C"). The research information can be summarized as follows: *Most of the large free-market residential developments such as Hunter Creek, Lone Pine, Riverview, and a majority of duplex units, which are typically occupied by long term tenants, have been condominiumized and currently have six month minimum lease restrictions in place. It should be noted that the new state statute cannot be applied retroactively, thus the existing six month minimum lease restrictions would not be rendered invalid. Other free-market multi -family residential developments that are located within the L/TR zone district at the base of Aspen Mountain, such as the Dolomites, Gant, Aspen Alps etc... are exempt from the six month minimum lease restriction and may be leased without limitation. These units did not have to undergo city review for .condominiumization because the city code did not require it at that time. Additionally, current* regulations exempt residential units in the L/TR zone district from the six month minimum lease restriction. These units are typically occupied by tourists or residents desiring shorter term occupancies and a six month minimum lease restriction would not be appropriate for their use. * Most of the tenant displacement from condominiumization has already occured since a majority of the condominiumizations have taken place in the 1970's and 19801s. Within the past 3 several years, most of the condominiumizations approved by City Council have been for duplex units. Staff also discovered that there were several citizens petition's in the 1970's protesting condominiumizations due to tenant displacement. Since 1988, approximately $251,527.00 has been collected in affordable housing -impact fees from condominiumization. *- A limited number of waivers have been granted by City Council for the six month minimum lease restriction. * Approximately eight lodges have been condominiumized which represents a small portion of the lodge inventory within the City. STAFF ANAYLSIS OF KEY--ISSUES:- Staff has focused on the impact of the new state statute on Section 24-7-1007 of the Municipal Code as this Section sets forth the requirements for the condominiumization of structures. Assuming that this section will be eliminated from our land use regulations, three key issues were identified by * staff. The following paragraphs will discuss those issues and recommended action. Key Issue 1 - Affordable Housing Impact Fee: Currently, when free market residential units are condominiumizedr an impact fee is paid to the Housing Fund to mitigate affordable housing needs generated by the condominiumization. Response: Since 1988, the City has collected approximately $251,527.00 in affordable housing impact fees from condominiumization. These funds have been used to subsidize the affordable housing program. There are several existing ordinances in place that would address some of the concerns if this fee were eliminated. For example, Ordinance 1 was adopted in January of 1990. Council had determined, as a result of market pressure to redevelop residential 'properties as housing for tourists and second home owners, that portions of the existing housing inventory were threatened with demolition. This produced a depletion in the stock of affordable housing resulting in the displacement of residents and changing the character of existing neighborhoods. The adoption of Ordinance 1, Series of 1990, required the following: 1. In the demolition of resident multi -family housing, the owner shall construct replacement housing equal to at least 50% of the square footage of the residential area demolished. The replacement housing (50%) shall be deed restricted as 4 affordable housing. 2. New or reconstructed single family and duplexes are required to mitigate. employee housing impacts by one of the following methods: a) Payment of an affordable housing impact fee. b) Provision of an -accessory dwelling unit for single family development. c) Duplex units have various options for employee mitigation. While the method used to address the existing affordable housing inventory in Ordinance 1 is different than the affordable housing impact fee for condominiumization, the goal is the same i.e. maintaining the community's stock of affordable housing. Since the current condominiumiz-ation affordable housing impact fee is imposed on existing and new residential units, then the "affordable housing" provisions of Ordinance 1 would address those residential dwelling units that result from the demolition of resident multi- family structures, or -from new or reconstructed single-family and duplex dwellings. An area that would not be addressed (if the existing condominiumization regulations were eliminated) is if an existing multi -family structure would condominiumize, then the provisions of Ordinance 1 would not apply. It is not clear as to how many existing multi -family structures would fall into this category and the loss of dollars to the housing/daycare fund. The City has collected approximately $116,052.00 in housing impact fees since the adoption of Ordinance 1 in 1990. Another area in the Code that would address the construction of new residential development 'is Article 8, Growth Management Quota System. If new residential development is proposed, then the applicant is required to provide -affordable housing for a minimum of 35 % of the employees generated by the proposed development. This effectively addresses the provision of affordable housing through growth management competition. Staff believes that existing ordinances will address most of the affordable housing issues associated with the elimination of the condominiumization affordable housing impact fee. Recommendation: Staff recommends that the sunset provision for Ordinance 1, Series of 1990, be eliminated as Ordinance 1 will play an important role in maintaining our affordable housing inventory. This is also a recommendation contained within the draft Aspen Area Community Plan. Key Issue - six Month Minimum Lease Restriction: Currently, 5 a six month minimum lease is required for newly condominiumized units in an effort to maintain long term tenants/residents. Response: Concern regarding the elimination of the six month minimum lease has focused on the following: If the restriction is eliminated from existing or future condominiums, units may be short termed more often, potentially displacing local tenants/residents. * In discussions with a local appraiser, -the six month minimum lease restriction may impact the sales price for lower priced units by keeping the sales price lower. A six month minimum lease restriction on luxury/high end condo units has a minimal impact. The implication is that if the restriction is eliminated, the price of units could increase and potentially impact the price of new residential units or --units not currently- subject. to. deed restrictions. * Residential condominiums within the residential zone districts such as R-6, R-15, R-15A, R-15B, R-30 etc...zone districts are currently required to adhere to the six month minimum lease restriction (except for two shorter tenancies per year) . If future six month minimum restrictions are eliminatedf* then our traditional residential neighborhoods may see an increase in short-term use of the units and impact the character of the neighborhood. Staff Is research has shown that most of the multi -family structures (and a majority of the duplexes) within the City have already been condominiumized so the eliminination of the restriction would only impact newly constructed structures and some of the existing non- condominiumized structures. Additionally, the Housing Authority, the City of Aspen and Pitkin County have been active in the construction of affordable housing for the community; approximately 525 affordable housing dwelling units have been constructed since 1985. ' The affordable housing supply -has increased somewhat since the 1970's and 1980's and this offers residents more housing options. *The new state statute is not retroactive,* thus the existing six month minimum lease restrictions currentlyinplace would not be rendered invalid. Although existing condominiums would be able to apply (as they are today) for removal of the six month restriction, staff would strongly encourage Council to maintain the six month minimum lease restriction on existing condominiums. Another item to consider is that both the Planning Department and the Housing Authority staff do not actively enforce the six month minimum lease restriction. Within the past two years, the Planning Department has received two calls inquiring about the six month minimum lease restriction. 6 Recommendation: Staff recommends that Council consider addressing the land use issues posed by the elimination of the six month minimum lease restriction through amendmends to the permitted use section within the various residential zone districts. For example, the permitted use section of the residential zone districts would restate the six month minimum lease restriction (along with exceptions for shorter tenancies). The language could be written so that all residential units would have to adhere to this restriction, or the language could be specific for duplexes or multi -family structures. *This approach would be a major policy decision as the focus would be on the use of all residential dwellings within the zone _district, not just condominiumized residential units. ' There probably -would be considerable backlash -to this -concept _in- addition to an increase in enforcement. If the language was specific to duplexes and multi -family residences within the zone districts, then single family homeowner resistence would be eliminated. Key Issue 3 .- Lodge Condomi.niumization: Lodges that are condominiumized are required to remain in the short term market so that they are available to the general public as tourist accomodations. Response: The -concern is that the lodges remain in.the short term rental market and provide for the lodging needs of the resort. Our research has shown that a small portion of the lodges within the city have been condominiumized. One .way to approach these concerns is to amend the permitted use sections for, the Lodge/Tourist Residential (L/TR) and the Lodge Preservation (LP) zone districts to restrict any long term leasing of the lodge units and encourage short term usage of these units. For your information, staff has not had discussions with lodge owners regarding this issue. Recommendation: Staff recommends that Council consider amending the permitted use sections of L/TR and LP zone districts to restrict long term leasing of the lodge units. RECOMMENDATION SUMMARY: 1) Eliminate the sunset provision for Ordinance 1, Series of 1990. 2) Amend the permitted use sections of the various residential zone districts to restate the six month minimum lease restriction for duplexes and multi -family units. 3) Amend the permitted use sections of the L/TR and LP zone districts to restrict long term leasing of lodge units. 7 4) Approve the pending condominiumization applications under existing ordinances with a reservation stating if the condominiumization ordinances should change after an approval (within a reasonable period of time thereafter), the applicant will be. allowed the benefits of any change by way of the retroactive application of the new ordinance (e.g. if the requirement of an impact fee is repealed, the applicant will get its previously paid fee refunded).. Exhibit "B" Section 24-7-1007 of the Municipal Code sets forth the condominiumization, regulations for residential and lodge units. The regulations are summarized as follows: 1) condominiumization of residential units a. Existing residents must be given a right of first refusal on the sale of an existing unit that is being condominiumized. b. Residential condominiums may only be leased for terms of not less than six months, with the exception of two shorter tenancies per year (to allow locals to rent their units over the holidays) and this applies to residential dwelling units in the R-6, R-15, R-15A, R-1.5B,. R-30, R/-MF, .MHP, •SCI, NC,. and C zone districts. Residential dwelling units in the RR, C-1 and O zone districts shall be restricted to six month minimum leases unless an applicant .can prove that unit is in an area that is predominantly short term accomodations. Residential dwelling units in the L/TR zone district or any zone - district with Lodge (L) overlay may be leased. without limitation. c. An affordable housing impact fee is applied to the condominiumization of existing and new residential units, however, the condominiumization shall be exempt from the impact fee if affordable housing has been provided pursuant to GMQS. The fee ranges from $3,350 to $8,050 per unit. The fee is not applied to the condominiumization of units restricted to the affordable housing guidelines. An applicant may request a waiver of the impact fee by demonstrating that the unit will remain available to employees of the community, however, it would -still be subject to six month minimum lease requirement and deed restricted'asa resident occupied unit. 2) condominiumization of lodges a) The condominium units shall remain in the short term rental market and shall be used as temporary tourist accommodations available to the general public. b) The lodge shall provide minimum sleeping accommodations for two employees. 9 c) The condominiumized lodge shall provide on -site management and maintenance. d) The lodge condominium units shall remain available to the general tourist market and this condition may be met by inclusion of the units in a local reservation system. e) The common areas of the lodge shall remain as common areas. ku Exhibit "C" 1) Residential Condominiumization: The earliest record of a condomini.umization that required city review occured in 1973. There are many units that were condominiumized prior to 1973; a rough conservative estimate would be 350 dwelling units. These units, such as the Gant, Aspen Alps, and Dolomites did not have to undergo city review to condominiumize their structure because the code did not require it. Number of free market units condominiumized (after 1973) in accordance with city regulations: Approximately 750 units NOTE: Fully deed restricted affordable housing units are not included in this f igure . . 2) six month minimum lease The end of 1977-appears to have been the approximate date when six month minimum leases were established in the city land use. regulations. However, some projects as early as 1973 had six month minimum lease restrictions placed on them. Approximately 15% of the 750 units condominiumized do not have six month minimum lease restrictions. This is due to the fact that waivers were granted, city regulations were not in place that required six month minimum lease restrictions, units in the L/TR zone district were exempted along with historic landmarks. It should be noted that the city rarely granted waivers from the six month minimum lease restriction. 3) Affordable Housing Impact Fees: As discussed previously, these fees were added to the condominiumization regulations (residential units only) in 1988. The City has collected $251,527400 in affordable housing impact fees from condominiumization. 4) Lodge Condominiumization City records indicate that eight lodges have been condominiumized that required city review. 11 M Exhibit ','D" Summary of Ordinance 1, Series of 1*990 Resident Multi -family (historically occupied by working residents) : 1) In the demolition of a resident multi -family housing, the owner shall construct replacement housing of at.least 500 of the.square footage of the residential area demolished. The replacement housing (500) shall be deed restricted as affordable housing. Single-family and Duplex: 2) Remodeling and expansion of existing single-family and duplex units is exempt andd-is-not required —to _mitigate.. -fo-r-.,affordable. housing. 3) New or reconstructed single-family and duplexes will be required to'mitigate employee housing impacts by one, of the following methods: a. Payment of an Affordable Housing Impact Fee. b. Provision of an accessory dwelling unit (ADU) for single family development. c. Duplex units have the following options: the applicant provides one free market/one resident occupied unit; two free market units with one accessory dwelling unit; two resident occupied units; or the affordable housing impact fee. 12 Re ular Meetin As en Citv Council Decembe ORDINAN CE 81 SERIES OF 1992 - Undergrounding Improvement District Cemetery Lane Series of 1992; Councilwoman Richards moved to read A dl ance in favor, , motion carried. seconded by Councilwoman Pendleton. ORDINANCE #81 (Series of 1992) AN ORDINANCE OF THE CITY COUNCIL OF THE =STRICT WITHIN TY OF ASPEN, COLORADO, TO CREATE A LOCAL IMPROVEMENTDISTRICT THE PURPOSE OF THE BOUNDARIES OF THE CITY OF ASPEN CONVERTING EXISTING OVERHEAD ELECTRICAND COMMU IC N OOF FACILITIES TO UNDERGROUND ELOCATION; s read by the�city DETAILS AND SPECIFICATIONS THEREFOR wa clerk Wilson, assistant city manager, reminded Council they took Cindy W �This district has to action on this district at the last lic hearing will be January 11, be approved by ordinance. The p 1993. Series of 1992, Councilwoman Richards moved to adopt ordinance`Pendleton. Roll call on first reading; seconded by Councilman vote; Councilmemb ers Pendleton, yes; Richards, yes; Mayor Pro Tem Peters, yes. Motion carried. CONDOMINIUMIZATION DISCUSSION last July the Diane Moore, planning director, reminded CouncilStaff has Colorado Common Interest Ownership Act went into effect. Moore said made some recommendations on Aspen s regulations.act fee.' Currently the first issue is the affordable housing imp act fee r paid when a free market unit is,condominiumi n 'needs generated by the n-impto the housing fund to mi second issueate the is the 6 month minimum lease condom iniumi-zation. The restri ction, which is required in an effort to maintain ong term residents. The third issues is lodtheshortterm dirental market for units are requiredto remaiodge n in tourist accommodations. '1 staff has done extensive research in this Ms. Moore told Council t be applied retroactively and area. The new state statute canno tin 6 month minimum leases cannot be rendered ninvalid. the existing impact fee, Ms. Moore told Council under ��tohe Thereareexisting ordinances in ce 1988, the city has collected $2 1not through condominiumi- place which address affordablehousing nt quota system also addresses zation. The growth man g ' n of affordable housing units. Ms. Moore recommended construction 6 Regular Meeting AspenCityCouncil December 7, 1992 the sunset provision of ordinance #1, 1990 be eliminated as this ordinance addresses key elements of affordable housing. Ms. Moore told Council a lot of existing units in Aspen have already been condominiumized and the 6 month minimum lease restrictions will remain in place. Any existing unit can apply to Council for elimination of that restriction. Ms. Moore said in lodge condominiumization the consideration is that the units remain in the short term market. Very few lodges in Aspen have been condominiumized. Ms. Moore suggested staff look in the LP or LTR zone district permitted and conditional uses to regulate this. Leslie Lamont, planning office, pointed out the ordinance #1 fee is either paid or an applicant provides. an accessory dwelling unit. Councilwoman Pendleton asked how ordinances become self -enforcing. Mayor Pro Tem Peters said in the past there have been strict penalties for non-compliance. Councilwoman Richards said there seems to be no enforcement for the 6 month minimum lease restric- tions. Amy Margerum, city manager,, said this is usually self - enforcing with condominiumization associations or neighbors. Mayor Pro Tem, Peters said enforcement is a different issue Council can address. Mayor Pro Tem Peters asked if condominiumization is enough like subdivision to require certain mitigation and impacts. Jed Caswall, city attorney, said an argument can be made that condomin- iumization is a certain form of subdivision and that is where it is located in the city's land use code. Caswall said the state legislature does not agree. Caswall-sa ' id an argument can be made that land use is not of state concern but is of municipal interest. This attempt by . the legislature to diminish the city's subdivision regulations is in violation of Article XX of the Colorado Constitu- tion and unenforceable in home rule cities. Caswall said the legislature may have intended to pre-empt local government. Caswall said the city could mount a legal challenge to this statute; however, the real issue is whether the city would rather .look at alternatives outlined by staff and other legislation to address areas of concern. Caswall told Council Aspen is the only municipality that has an ordinance that could conflict with this state statute. Mayor Pro Tem Peters said the original purpose of the condominiumi- zation regulations is still valid. Councilwoman Pendleton said the Community Plan also recommended the elimination of the sunset provisions in ordinance W1. Councilwoman Richards agreed and said she would like to look at other language in Ordinance #1 that would make it clear for changes in use that they will fall under this 7 Regular Meeting Aspen City Council December 7, 1992 ordinance. Mayor Pro Tem Peters agreed with the elimination of the sunset provisions of Ordinance #1. Mayor Pro Tem Peters supported the planning office recommendation to limit the allowed uses in the residential zone district to basically long term uses. Councilwoman Pendleton agreed with staff recommendation. Councilwoman Pendleton requested staff look at the enforcement 'issues. Mayor Pro Tem Peters said he would like all residential zones covered. Councilwoman Richards said 'taking units in a residential zone and turning them into short term business licensing and sales taxes should come into play. Mayor Pro Tem Peters said short term uses in residential zone districts should be eliminated other than those like Christmas rentals. Mayor Pro Tem Peters said the LTR and LP zone districts have allowed short term uses by right. Councilwoman Pendleton said these uses should be kept in the LTR and LP districts. Ms. Moore said staff has not had discussions about changing the lodge districts with local lodge owners. Ms. Moore pointed out the community has always encouraged maintaining small lodges. Mayor Pro Tem Peters said there should be exemptions for some long term units for owners, managers and staff. Councilwoman Richards said she would like to hear comments of the lodge owners from staff. Mayor Pro Tem Peters said he would like to hear from staff on more areas for self -enforcement. Amy Margerum, city manager, said the code may have to be amended in.some areas to impose fines. Councilwoman Pendleton said for the amount of .money the city collects, she would just as soon eliminate the condominium fee. Councilwoman Richards said she is more interested in maintaining the character of neighborhoods and the inventory of affordable housing. Mayor Pro Tem Peters agreed with eliminating the fee for housing impact. Caswall recommended Council hold up all condominium applications while staff processes a code amendment rather than process applications and accept fees. Caswall said the city can schedule first reading for condominiumization ordinances but put off second reading until code amendments are adopted. (Mayor Bennett came into the meeting). Ms. Margerum said she is concerned about holding people up while an amendment is processed. Ms. Margerum suggested applicants could proceed and the city could hold the fee is escrow. Caswall said applicants would have to -file a legal action within 30 days after approval of the condominiumization challenging the city's right to impose conditions upon them. Councilman Peters said Council has agreed to eliminate the sunset provision in Ordinance #1; to start amending zone districts to 0 Regular Meeting Aspen Citv Council December 7, 199 limit uses to long term and short term as appropriate; to get direction back regarding the impact on lodge owners, and an interim strategy on the fees. ASPEN MOUNTAIN LODGE NON-COMPLIANCE Jed Caswall, city attorney, reminded Council this is a continuation of an October 26th hearing on the issue of possible sanctions for non-compliance on the Ritz -Carlton not meeting the deadline for a certificate of occupancy for the hotel. There was also a hearing to extend the construction deadline for the Ritz. Council granted a request to extend the schedule for the Ritz and that they obtain their final c/o by December 4,F .1992. Caswall reported on December 4 the c/o was signed. Council decided to continue determination on the non-compliance to December 14th. Caswall told Council Savanah Limited Partnership agreed to move this hearing up to this meeting. At this meeting, Council is to make a determination on whether a sanction or penalty should be imposed against Savanah for failure to meet the December lf 1992, deadline for a c/o. Caswall recommended that Savanah reimburse the planning staff for the time spent in having to address the non-compliance as a possible sanction. Bob Hughes, representing the applicant, reminded Council they found that the reasons for the delay were beyond the control of the applicant. Hughes said if there were any mistakes, it was in deciding not to seek an extension sooner than they did. Hughes said he does not feel this is appropriate for sanctions. Amy Margerum,, city manager, said if an extension were sought, the applicant would have been charged for staff time. Mayor Bennett closed the public hearing. Councilman Peters moved to impose a $3800 penalty reflecting the increased costs of staff time associated with Savanah's failure to complete by the appropriate date; seconded by Councilwoman Pendleton. Mayor Bennett said he feels this is reasonable and appropriate. Councilwoman Richards asked if all other conditions have been met. Ms. Margerum told council staff went through the PUD agreement to make sure all conditions were met. Ms. Margerum noted the c/o is not for the entire building. Caswall said the c/o that was issued reserves certain rights to the city; because of the weather and continuing construction, staff was unable to conduct a thorough site visit. Councilwoman Richards said she understood the ice rink site was not to be used as a parking lot. Perry Harvey said the portion of the site used for construction storage is to be cleaned A