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HomeMy WebLinkAboutOrdinance 2004-218 ORDINANCE NO. 2004- Z1B AN ORDINANCE OF THE CITY COMMISSION OF THE CITY OF SUNNY ISLES BEACH, FLORIDA, AMENDING SECTION 265-23 OF THE LAND DEVELOPMENT REGULATIONS, RELATING TO TRANSFER OF DEVELOPMENT RIGHTS; PROVIDING FOR REVISED DEFINITIONS; PROVIDING FOR AMENDMENTS TO THE PROVISION ON TDRS TRANSFERRED FROM A CITY OWNED SENDER SITES; PROVIDING FOR AMENDED DEVELOPMENT LIMITATIONS ON TDRS TRANSFERRED FROM PRIVATELY-OWNED SENDER SITES; PROVIDING FOR A CLARIFICATION TO THE PROVISION ON TDRS FROM A PRIV ATEL Y OWNED SENDER SITE TO A PRIVATELY OWNED RECEIVER SITE; PROVIDING FOR CLARIFICATIONS TO DEVELOPMENT LIMITATIONS UPON RECEIVING SITES;PROVIDING FOR AMENDMENTS TO THE REVIEW PROCESS BY THE CITY COMMISSION AND RECORDING OF DOCUMENTS; PROVIDING FOR AN AMENDMENT TO THE ZONING IN PROGRESS PROVISION AND THE TDR BANK PROCEDURES AND LIMITATIONS; PROVIDING FOR A REPEALER; PROVIDING FOR SEVERABILITY; PROVIDING FOR AN EFFECTIVE DATE WHEREAS, the City's Transfer of Development Rights Ordinance (the "TDR Ordinance") describes a relatively novel concept and is a still evolving ''work in progress;" and WHEREAS, as the City continues to be developed, open space, parks and recreational facilities, and parking for those facilities remains an immediate and pressing need of the City and that need can be met through this TDR Ordinance. WHEREAS, complex and creative permutations of the original concept and rationale for the Ordinance are being suggested at the same time that the language and intent of the TDR Ordinance are being studied and applied for the first time, and any ambiguities during the application process shall be resolved in a manner which is in the best interests of the City and its residents; and THE CITY COMMISSION OF THE CITY OF SUNNY ISLES BEACH, FLORIDA, AFTER CAREFUL CONSIDERATION, HEREBY ORDAINS AS FOLLOWS: Section 1. Amendment of Section 265-23 ofthe Land Development Regulations. Section 265-23 of the City's Land Development Regulations is hereby amended as follows: 02004-218 Amd TDRs -- Sec. 265-23 1 1. 265-23 (1). Purposes and Applicability. This section is intended to provide for greater flexibility in the pattern of development by allowing for the transfer of development rights (unused floor area and density) from one parcel to another where the City Commission determines that (a) such transfers will assist in the renewal, rehabilitation, and redevelopment of commercial, Town Center and beachfront property and that (b) preservation and enhancement of open space, natural resources, historical and archeological resources, preservation of view corridors, concentration of public parking, or provision of educational or other public purpose objective may be achieved through such shifts in the development pattern. 2. 265-23 (2). Definitions: As used in this section, the following terms shall have the meanings indicated: Administrator: shall mean the Planning and Zoning Administrator. Bank Statement: shall mean the statement used to record deposits and withdrawals from the TDR Bank, as herein defined, in accordance with this Section. Comprehensive Plan: The Comprehensive Plan of the City of Sunny Isles Beach, Florida, as adopted October, 2000. LDRs: Land development regulations of the City of Sunny Isles Beach, adopted December 10, 2002, as the same may be amended from time to time, consistent with the Comprehensive Plan ofthe City of Sunny Isles Beach. Receiving Districts: Areas within the corporate boundaries of the City that are permitted to receive transferable development rights as defined in the City's Comprehensive Plan. Sending Sites (Sender Sites): Any areas within the corporate boundaries of the City that are permitted to transfer development rights as permitted by and as set forth herein provided that such site shall be deemed by the City Commission to be appropriate or advisable for use as open space, parks, park amenities or recreational facilities or parking for those facilities (hereinafter individually and collectively referred to as "a park or parks" as the case may be."). Any site to be used for any purpose other than a park may not be treated as a Sender Site as defined herein and no transferable development rights may be calculated and transferred therefrom. Sever: The removal of a development right from property rights possessed by an owner of real property. The term connotes a removal or separation, in perpetuity, as distinguished from a restriction or limitation, which may be overridden, deleted or is subject to a time frame. Transferable Development Rights: A development right is an appurtenant right of land ownership that has an economic value separate from the land itself, subject to reasonable 02004-218 Amd TDRs -- Sec. 265-23 2 regulation by local government under its police power, and that may be transferred from the land from which the right is severed (Sender Site, also referred to in this Section 265-23 as "sending site") to another piece of land (Receiver Site, also referred to in this Section 265-23 as "receiving site"). Once severed, if only a portion of the development rights attributable to a Sender Site is transferred to a receiving site, the remaining development rights may be deposited in a TDR Bank in accordance with the provisions of this section. Transferable Development Rights means the maximum floor area ratio (square footage) and density (dwelling units) exclusive of variances that would be permitted to be transferred by the property's zoning on the date of the transfer approval which will be calculated and allocated by a formula developed by the City. These rights are sometimes referred to herein as "TDRs. 3. 265-23.3 Establishment of Sending and Receiving Sites; TDRs Transferred; Fees. a. Establishment of Sender Sites. Any property in any zoning district, upon the approval of the City Commission, in its sole discretion, after a public hearing, may be eligible as a sending site, subject to the terms, conditions and limitations of this Ordinance. b. TDRs transferred from City Owned Sender Sites. Upon the adoption of this Ordinance, the City shall deposit all development rights (in terms of square footage and dwelling units) from its Sender Sites as they are defined hereunder in the TDR Bank for distribution and transfer in accordance with all of the procedures and limitations of this ordinance except the five year limitation set forth in Sec. 23.3 c.(5) below and specifically as limited by the following: ill All monies received by the City in connection with the transfer of development rights from City-owned sites shall be utilized for capital outlays and improvements only. (2) In no case shall the transfer of any TDR's from a City Owned Site currently designated as park sites interfere with the use of those public parks and said parks shall forever remain as public parks. (3) TDRs may not be transferred from any parks that existed within the boundaries of the City on the date of the City's incorporation, provided however, TDRs from properties acquired by the City subsequent to the date of incorporation and which were or will be developed and utilized as parks shall be calculated based the underlying zoning existing at the time of the City's acquisition of said parks, and may be severed and transferred from those such sites acquired by the City to the TDR Bank for subsequent sale or use by the City. 02004-218 Amd TDRs -- Sec. 265-23 3 c. TDRs Transferred from Privately-Owned Sender Sites. (1) Application Process for Sender Sites. Owner of prospective Sender Site shall submit a complete application to the City Planning & Zoning Administrator. A complete application shall include but not be limited to: the applicable fee, names, addresses and signatures of all fee simple owners of the prospective Sender Site (which shall require disclosure of ownership as more fully set forth in Section 7 (a) of this Ordinance), a certificate of resolutions and agreements from Miami-Dade County, a current survey, current environmental audit, a deed conveying good, marketable and insurable title and a commitment of title insurance, all in a form acceptable to the City Attorney, and such other materials that staff may reasonably request. After all required documentation and all required fees have been submitted to the City in a timely fashion, staff shall review the complete application, prepare written findings and recommendations, and place the application on the City Commission agenda for its consideration at a public hearing. The application shall be subj ect to the same notice and hearing requirements required by the LDR's for zoning applications. (2) Public Hearing. After a public hearing, the City Commission shall determine, in its sole discretion, whether the proposed sending site is acceptable for use by the City, in accordance with the expressed intent of this Ordinance. (3) Conveyance of Privately Owned Sender Sites to City. Upon approval by the City Commission the Sender Site shall be conveyed to the City unencumbered, free and clear of any or all liens and mortgages, after correction of title defects and outdoor code violations, if any and payment of any outstanding fines or fees owed to the City, all in a manner and form acceptable to the City Attorney. All taxes, fees and all other charges, including but not limited to assessments, on an approved Sender Site shall continue to be paid by the owner until the date the title is conveyed to the City. After title to the approved Sender Site has been conveyed to the City in the manner described in this subsection, the City shall authorize the release of the TDR's and shall record such release in its records and in the Public Records of Miami-Dade County, Florida, as set forth herein. No use shall be made of the TDR's from the approved sending site until documentation evidencing such release of TDR's has been recorded. (4) Development Limitations on Privately Owned Sender Sites. The approved Sender Site shall then remain undeveloped forever except as a park. (5) Limitation on use ofTDRs from Approved Sender Sites. 02004-218 Amd TDRs -- Sec. 265-23 4 The owners, successors, heirs or assigns of approved sender site will be permitted to bank, in accordance with section 265-23.7.2 hereunder, any Development Rights from the sender site for a five (5) year period from the date of the City Commission meeting at which the subject site was approved as a sender site. At the expiration of the five (5) year period, the TDR's from the approved sender site shall expire and become extinguished and unusable. d. Establishment of Receiver Sites: All property within the Town Center, Business District abutting Collins Avenue and the Mixed Use High Density/Resort zoning districts are herewith established as Receiver Districts. Receiver Sites (also referred to in this Section 23 as "receiving sites") may be developed as otherwise permitted by the Land Development Regulations, as may be amended from time to time, in combination with the development rights available to the site, provided that the overall density achieved is consistent with, and does not exceed, the overall density and intensity allowable by the Comprehensive Plan and subject to Section 265.23.5 hereinbelow. If an approval was granted prior to the adoption of this Ordinance, pursuant to which a permit has been issued, that site shall not be available as a Receiver Site, unless the prior approval is revoked or abandoned by the Applicant and a new development order is secured hereunder. e. Fees. Application fees for consideration of applications for establishment of Sender Sites and Receiver Sites and for TDRs shall be established by the City Commission. The applicant shall be responsible for all applicable application fees. Hiring of consultants to review data including engineering, planning, legal, appraisal, technical or environmental issue, shall be chargeable to the applicant in accordance with Ordinance No. 2001-132. 4. 265-23.4 Calculations. a. Transferable Development Rights from City owned Sender Sites: In the case of City owned sites, calculations will be based on the zoning permissible at the time of incorporation and prior to the City's acquisition of the site for public purposes. The square footage of a transferable development right for a unit shall be calculated and determined by dividing the permitted floor area of the sending site by the permitted density on said sending site. Only whole units may be purchased and transferred to the receiving site. The foregoing, however, is subject to all limitations set forth herein and in the City's Comprehensive Plan. b. Cost of Transferable Development Rights from City owned Sites: 1. Appraisal. At the time of approval of the TDRs, the City Commission may consider the acceptance of the appraised land value for the receiving site as follows: the cost for a square foot of development right shall be determined by the market value of the Receiver Site as determined by a current real estate appraisal (updated no more than three months from date 02004-218 Amd TDRs -- Sec. 265-23 5 the application is heard at a public hearing) prepared for the City by an appraiser, selected by the City Manager, but paid for by the owner of the receiving site. The appraisal amount shall then be divided by the permitted floor area ratio including bonuses on the Receiver Site. Since the issuance of city-owned TDRs shall be from a TDR Bank, as described herein, the formula set forth in 265-23.4(a) above shall be applied to the totality of the banked square footage divided by the allowable density based on the underlying zoning. 2. Non-Refundable Deposit. Approval of Receiving Site shall be subject to payment of a non-refundable deposit of ten (10%) per cent of cost of City-owned TDRs, which shall be paid within three (3) days of date of City Commission approval of the application. Failure to make such deposit within the prescribed time frame shall result in an automatic voiding of the Commission approval. c. Transferable Development Rights from a Privately Owned Sender Site; Receipt of TDRs by a Privately Owned Receiver Site. 1. In the case of privately owned sites, the City shall determine the floor area ratio and density on the site based on the existing zoning. In cases where a privately owned site of greater than three (3) acres of frontage along Collins Avenue, in the Town Center, is offered to the City, for the purposes set forth herein, the City may accept said Sender Site and may provide to the owner the maximum density of 80 units per acre and a maximum floor area ratio of 3.75 provided the owner of the Sender Site shall either commit to provide public improvements in accordance with a design approved by the City Commission or shall fund said improvements as a condition of and no later than the actual transfer of the TDRs. Notwithstanding anything to the contrary, the property owner conveying the approved Sender Site shall have up to five (5) years to utilize such development rights in accordance with Section 3 c. (5) hereinabove. It is understood that the development rights to be transferred to a receiving site shall be approved by the City Commission through the site plan approval process as specified herein and as otherwise provided in this Section 265-23. 2. No Receiver Site, or site plan on that Receiver Site, may be approved by the City Commission unless a Sender Site has been first been identified and approved by the City Commission, or the owner of the Receiver Site commits to purchase TDRs from the City in accordance with Section 265-23.4 above, or the owner of the Receiver Site commits to purchase TDRs already deposited in the TDR Bank from a privately owned Sender Site. The formal approval by the City Commission of the transfer of the TDRs whether from a privately owned Sender Site, City-owned TDRs or TDRs from a privately owned Sender Site, already deposited in the TDR Bank, shall occur simultaneously with the approval of the Receiver Site's site plan although the actual transfer may occur later but in no event may a building permit on the Receiver Site issue until such transfer has actually occurred and been documented as provided hereinbelow. d. Cost of Transferable Development Rights Issued by Private Owners From Privately Owned Sender Sites: The price of TDRs from approved privately owned Sender Sites shall be determined by the 02004-218 Amd TDRs -- Sec. 265-23 6 private owners. 5. Section 265-23.5 a. Development Limitations Upon Receiving Sites. (i) Within the Receiving Districts, development rights shall be limited by a combination of the underlying zoning regulations, approved bonuses and allowable development rights transferable to the land in the Receiving Districts. Notwithstanding anything to the contrary, and in accordance with the Comprehensive Plan, neither the transferable density or intensity of permitted uses shall net exceed thirty percent (30%) of the maximum residential density permitted on the Receiver Site and in no case shall the resulting density bonus increases on any given Receiver Site exceed the number of dwelling units attainable on the Sender Site(s) under these plan provisions so as to assure no net increase in City-wide residential dwelling unit Comprehensive Plan capacities. Furthermore, the maximum amount of undeveloped floor area that may be transferred from a Sender Site to a site within the Receiving District shall not exceed (30%) of the receiving site based on the base floor area ratio plus bonuses allowable at the time of the Land Development Regulations in effect at the time of application. (ii) Parking and all other requirements of the LDRs shall be required in accordance with any additional density acquired through the transfer of development rights. If a property owner of a Receiver Site avails itself of the parking buy-down provided in Section 265-46A(2) (b), that calculation shall be made on the base zoning plus bonuses but shall not include TDRs. (iii) All TDR's purchased or transferred shall be used within 24 months from the date of rendition of the authorizing City Commission resolution, or all such TDR's shall thereafter be fully extinguished and there shall be no refunds from the City. (iv) The transfer of development rights to a receiving site will not decrease required open space, buffers, setbacks or cause a request for variances or any other adverse impact to surrounding site or increase allowable height, if applicable. (v) No property upon which a prior zoning approval was granted may apply for transferable development rights unless a site plan application is made for the entire site. (vi) In no event shall a site plan on a Receiver Site be approved with any structure exceeding 550 feet in height. 02004-218 Amd TDRs -- Sec. 265-23 7 6. Section 265-23.6 Land Ineligible for Consideration as Receiving Sites. No transferable development rights shall be assigned or transferred to any land outside the Town Center, Business District abutting Collins Avenue and the Mixed Use High Density resort zoning districts/ or for any land which has received a density or floor area variance. 7. Section 265-23.7 Procedures Pertaining to the Approval of Development Rights For Use on a Potential Receiving Site. a. Application. An applicant for the transfer of development rights to a potential receiving site shall file a complete application with the Planning and Zoning Administrator, together with a complete site plan application and all requirements contained in Section 265-18 including but not limited to: i) Every application shall contain, as applicable: a) the names, addresses and signatures of all fee simple owners of all properties included in the receiving site. "Fee simple owner," for the purpose of this requirement, shall be defined as all parties having a financial interest, either direct or indirect, in the subject matter of the application. Such disclosure shall include, but not be limited to, disclosure of all natural persons having an ownership interest, direct or indirect, in all properties involved. b) the street address, folio number and legal description of each parcel of land included in the potential receiving site, a description of adjacent lands, including land uses, densities, circulation systems, public facilities and the impact, if any, of the requested transfer of development rights. c) a current certified survey, plans, including but not limited to, a site plan elevation, landscaping, an area analysis of surrounding properties including but not limited to street elevations, height of buildings, surrounding floor area ratio and density and construction schedules; d) a site conditions map including a three dimensional model of the proposed development potential (site plan) without TDRs and a separate three dimensional model showing the development potential utilizing the proposed transfer of development rights (both models shall be constructed of balsa wood, foam board, corrugated or like material); e) status of financing, if applicable; evidence of ownership; f) amount of consideration, including purchase price of the property, an executed closing statement, or, an executed copy of the purchase and sale contract if Applicant is a contract purchaser; g) a general description of the manner in which the project shall be constructed, impact if any of the transfer of development right to adjacent properties, copies of any covenants affecting the receiving site(s); and 02004-218 Amd TDRs -- Sec. 265-23 8 h) any other agreements required by the Land Development Regulations and this Section or that may be reasonably requested by the City Manager or other .. . reVIewmg agencIes. b. Review and Recommendation by Planning and Zoning Administrator. The Planning and Zoning Administrator shall review the application and shall forward its written findings of facts and recommendations to the City Commission together with all site plans. The application shall be subject to the same notice and hearing requirements applicable to zoning applications under the Land Development Regulations. c. Scheduling of Hearing. Prior to the scheduling of a hearing to consider the transfer of development rights to a Receiver Site, all required documentation and all required fees, as described in this Section, shall have been submitted to the City in a timely fashion and reviewed and approved by City staff. d. Review and Approval by City Commission. The City Commission after reviewing the application and the written findings and recommendations of the Planning and Zoning Administrator may, in its sole discretion, approve with modifications or conditions, approve less than the full amount of requested TDRs, in which case the Applicant shall return to the City Commission with revised site plan for its further consideration or deny the application for transfer of development rights. (i) It is understood that until a transfer of development rights is so approved by the City Commission, said TDRs have no intrinsic or inherent value and cannot be considered as a "matter of right" in the valuation of any potential Sender or Receiver Site. Further, such transfers are subject to all the terms and limitations of this Ordinance. It is solely the final approval by the Commission, in its complete discretion, and based on the criteria set forth herein, that gives rise to any value for TDRs. (ii) A resolution authorizing the withdrawal and transfer of TDRs from the Bank must be issued prior to such transfer, but, once adopted, the transfer shall automatically change the TDR Bank Statement to reflect the approved transaction subsequent to the mandatory recording of such resolution by the City in the Official Records of Miami-Dade County, Florida, designed to both evidence and ensure the severance of said zoning rights from Sender Site and the accrual and accumulation of those development rights to the Receiver Sites or deposit of same in the TDR Bank. If the TDRs are purchased directly from the TDR Bank, the procedures set forth in Section 265-23.8a.(iii) shall be followed. The issuance of a resolution approving such transfer shall automatically change the TDR Bank Statement. (Hi) The City Commission shall review the application for TDRs based on the following criteria, provided however that approval of the application, in whole or in part, is solely within the Commission's discretion: 02004-218 Amd TDRs -- Sec. 265-23 9 a. The project is consistent with the Comprehensive Plan and will not reduce the levels of service set forth in the plan. b. The project is consistent with the intent of this Ordinance entitled "Purposes and Applicability." c. The project meets all other criteria set forth in the LDRs. d. The transfer of development rights is desirable on the individual site being considered for purposes of enhancing overall development. e. The development on the receiving site shall be designed to produce an environment of desirable character and harmony with the neighborhood, resulting in a superior quality of development and open space relationships with high standards for recreational and parking areas. e. Recording of Documents. Prior to issuance of a building permit, documentation evidencing the transfer shall be recorded against the titles to both the sending and receiving sites, as may be applicable, in the Public Records of Miami-Dade County, Florida and an irrevocable covenant running with the land, which shall include the additional FAR (TDR), required parking and all other conditions, restrictions, and obligations imposed as conditions of the approval by the City Commission and the LDRs, shall be recorded against the title to the receiving site, in the Public Records of Miami-Dade County, Florida. The covenant and all other documents recorded pursuant to this Section shall include a warning that the approval of the TDRs shall be extinguished, become null and void and shall be of no further force nor effect in the event no building permit is issued for the receiving site within twenty-four (24) months from the date the Resolution is rendered, and shall contain a statement by which the owner(s) of the Receiver Site shall agree to bind itself, its successors and assigns with regard to all conditions, restrictions, and obligations contained therein, and, further, shall include a statement prohibiting any changes, amendments, modifications or releases to the document without the prior written approval of the City Manager and the City Attorney after approval by the City Commission at a public hearing. All documents recorded pursuant to this section shall be in a form acceptable to the City Attorney and shall be recorded at the expense of the applicant. Copies of documents recorded pursuant to this Section shall be delivered to the City by the applicant. f. Zoning in Progress. Notwithstanding Section 2 hereinbelow or any other provision to the contrary in the Land Development Regulations, all applications for transfers of development rights shall be subject to all of the terms and provisions of the TDR ordinance in effect at the time the application is filed. 8. Section 265-23.8 TDR Bank; Establishment of TDR Bank; deposits and withdrawals from TDR Bank; Limitations; 02004-218 Amd TDRs -- Sec. 265-23 10 (a) TDR Bank. The City Commission may by resolution adopt procedures for the establishment of a "TDR Bank" (the Bank") which shall be maintained and operated by the City Manager or its designee for the deposit and withdrawal/purchase by private developers of development rights and shall be retroactive to all TDR transactions. (i) A fee shall be established by resolution to be paid by the depositor or purchaser for each transaction. (ii) The Bank Statement attached as Exhibit "A" to each City Commission resolution authorizing the TDR's and the deposit or withdrawal of development rights shall reflect approved sites and the units of TDR's attributable to each site. The Bank Statement shall be amended administratively and dated each time transfers are made in accordance with this Section. (Hi) With respect to a purchase of TDRs from a privately owned, previously approved Sender Site (as opposed to the portion of City-owned TDRs), a purchaser may withdraw said TDRs from the TDR Bank pursuant to the original City Commission approval of a Receiver and Sender Site. The adoption of this withdrawal and transfer resolution may not be withheld by the City Commission in accordance with this section unless the terms and conditions of the original approvals have not been met (or otherwise waived) or the City has not received a written and notarized authorization from the owner of the Sender Site (and seller of all TDRs severed therefrom) and an indemnification and hold harmless of the City from both seller and purchaser as to any and all claims that may arise between the private parties as a result of such transaction. With respect to a purchase of TDRs from the City, a purchaser may withdraw same from the TDR Bank pursuant to a City Commission resolution issued by the City Commission in its sole discretion in accordance with this Section. b. Time Limitations on Private TDR Transactions. All development rights from an approved privately owned Sender Sites conveyed to the City shall be deposited in the TDR Bank as provided in this subsection. Withdrawals of TDRs from the Bank must occur no later than five (5) years from the date of the City Commission action approving the applicable sending site in accordance with Section 265-23.3 (c)(5) hereinabove. Each depositor at time of initial deposit, shall execute a written waiver of its rights, if any, to assert any claim to those development rights except as specifically permitted by the terms of this Ordinance. All requirements of this Section shall be met prior to the actual transfer (withdrawal) of development rights from the Bank. Section 2. Repealer. All ordinances or parts of ordinances in conflict herewith be and the same are hereby repealed except that this amendment shall not apply to previously approved TDR's which transfers shall be accomplished in accordance with the terms of the ordinance in effect at the time of said transfer. 02004-218 Amd TDRs -- Sec. 265-23 11 Section 3. Severability. If any provision of this Ordinance is for any reason held invalid or unconstitutional by any court of competent jurisdiction such provision shall be deemed a separate, district, and independent provision and such holding shall not affect the validity of the remaining proVIsIons. Section 4. Effective Date. This Ordinance is effective ten (10) days after its adoption on second reading. PASSED and ADOPTED on first reading the ~day of ~-6~ , 2004. PASSED and ADOPTED on second reading this la~ay of ~~v'EJ'A6tftG 2004. '. I ATTEST: ~~~~ Jane A. Hines, City Clerk APPROVED AS TO FORM AND LEGAL SUFFICIENCY: ~ Lynn M. Dannheisser, City Attorney Moved by: C-oV\f\V'f'vlS < IbNf.JPrGLf..S l~ Second by: C ~ YV"..l <; ~ In 1OE:.iL ~~ 2. J N VOTE: 5-0 Mayor Norman S. Ede1cup Vice Mayor Gerry Goodman Commissioner Roslyn Brezin Commissioner Daniel Iglesias Commissioner Lewis Thaler (yes) ~ (yes) ~ (yes) -lL- (yes) ~ (yes) ~ (no)_ (no)_ (no)_ (no)_ (no)_ 02004-218 Amd TDRs -- Sec. 265-23 12