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Ordinance No. 10561 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18, 19 20' 21I 22 23 24 25 26 27 28 ORDINANCE NO. 1056 AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF VERNON ADDING ARTICLE II TO CHAPTER 5 TO THE CODE OF THE CITY OF VERNON RELATIVE TO BUSINESS LICENSE TAXES AND FEES, ESTABLISHING A DATE FOR AN ELECTION TO BE HELD TO APPROVE THE LEVY OF THE BUSINESS LICENSE TAXES CONTAINED HEREIN; AND DECLARING THAT SAID ORDINANCE SHALL TAKE EFFECT IMMEDIATELY WHEREAS, Chapter 15 of the Code of the City of Vernon, California, 1959, establishes license taxes and fees on various enterprises doing business in the City of Vernon; and WHEREAS, Sections 15.36 through 15.38 of said Code, approved by the voters of the City of Vernon at an election held December 10, 1996, established special taxes for certain activities related to the treatment and disposal of hazardous materials and hazardous waste; and WHEREAS, the City Council desires to establish business license taxes to replace the license taxes and license fees for other businesses subject to Chapter 15 of said Code, and make all business license tax and special tax provisions part of a new Chapter 5 of said Code; and WHEREAS, Article XIIIC of the California Constitution, enacted by the passage of Proposition 218 at the statewide election held in November, 1996, requires submission of existing general tax measures to the local electorate for approval at a regular municipal election on or before November 5, 1998; and WHEREAS, the next general municipal election in the City of Vernon will be held on April 14, 1998, and will be the only general municipal election held prior to November 5, 1998; and 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 171' 18 19 20 21 22 23 24 251 26 27 28 WHEREAS, because the fees currently imposed by Chapter 15 might be construed to be general taxes, it is the desire of the City Council to submit them for voter approval pursuant to Article XIIIC; and WHEREAS, it is the intent of the City Council that the proceeds of the general taxes established by this ordinance be for general City purposes, and that the same be imposed for the purpose raising revenue, not for the purpose of regulation; and WHEREAS, Article XIIIC provides that the voters may establish a maximum tax rate for general taxes, and that increases in taxes which do not exceed said maximum tax rate do not require voter approval; and WHEREAS, Government Code § 53739(b), as amended by urgency legislation effective July 1, 1997, provides that an ordinance or resolution presented for voter approval pursuant to Article XIIIC may provide that the tax rate stated in the ordinance or resolution may be adjusted for inflation pursuant to a clearly identified formula stated in that ordinance or resolution, and that if the ordinance or resolution is approved by the requisite number of votes at an election held for that purpose, the governing board of the adopting local government may thereafter impose the tax at any rate or amount that is less than or equal to the inflation -adjusted maximum amount authorized by the voter -approved ordinance or resolution; and WHEREAS, it is the desire and intent of the City Council that this ordinance, if approved by the voters, establish maximum rates for business license taxes for the various businesses currently subject to business license taxes or fees under Chapter -2- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15 of the Code of the City Vernon, and that the maximum tax rates be adjusted annually based upon increases in the Consumer Price Index for All Urban Consumers, for the Los Angeles -Anaheim - Riverside Area, as published by the Bureau of Labor Statistics of the United States Department of Labor, 1982-84 base year; and WHEREAS, it is the desire and intent of the City Council that this ordinance be revenue -neutral in effect on local businesses, such that despite the establishment of the maximum tax rates and allowance for inflation -adjustments provided for in the ordinance, there will be no increase in amounts paid for business licenses for calendar year 1998; and WHEREAS, this ordinance does not impose, increase, extend or otherwise affect the special taxes imposed by Sections 15.36 through 15.38 of the Code; and WHEREAS, Section 4.3 of the Charter of the City of Vernon Jallows an ordinance to be introduced and adopted at one in the same meeting if it relates to an election; and WHEREAS, the City Council desires to submit the taxes established in this ordinance to the voters of the City for approval pursuant to Article XIIIC of the California Constitution and Government Code § 53720, et sea. THE CITY COUNCIL OF THE CITY OF VERNON HEREBY ORDAINS: SECTION 1: Article II, entitled "General Taxes," consisting of Sections 5.20 through 5.32, is hereby added to the Code of the City of Vernon, California, 1959, to read as set forth in Exhibit "A," attached hereto and made a part hereof by reference. -3- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SECTION 7: The City Council of the City of Vernon orders that the business license taxes established by this ordinance be put to a vote of the people at the general municipal election to be held on April 14, 1998, said election to be formally established by resolution of the City Council. Voters shall indicate their approval or disapproval of this ordinance and the taxes established by this ordinance by voting "yes" or "no" on the following proposition: MEASURE A Shall an ordinance entitled "AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF VERNON ADDING ARTICLE II TO CHAPTER 5 TO THE CODE OF THE CITY OF VERNON, CALIFORNIA, 1959, RELATIVE TO BUSINESS LICENSE TAXES AND FEES, ESTABLISHING A DATE FOR AN ELECTION TO BE HELD TO APPROVE THE LEVY OF THE BUSINESS LICENSE TAXES CONTAINED HEREIN; AND DECLARING THAT SAID ORDINANCE SHALL TAKE EFFECT IMMEDIATELY" be approved? YES NO Said proposition shall be designated "Measure "A"" on the ballot unless given a different designation by county election officials. SECTION 8: The business license taxes established by this ordinance shall not become effective and shall not be levied on any business unless and until the proposition is approved by a majority of the votes cast on the issue at the aforesaid general municipal election on April 14, 1998. SECTION 9: The renumbering of any article or section of the Code of the City of Vernon shall not constitute a change in its intent or purpose, and it shall have the same effect and -4- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 lenforceability as if it had never been renumbered. Any Code section numbers not used shall be reserved for future use. SECTION 10: The City Council of the City of Vernon may, by ordinance, amend, repeal, renumber or recodify any or all of the provisions of Article II of Chapter 5 of the Code of the City of Vernon enacted by this ordinance, except that no ordinance imposing, extending or increasing the taxes established by this ordinance shall be effective unless approved by the voters if required pursuant to the law applicable at the time of such action. SECTION 11: If any section, subsection, sentence, clause, phrase or word of this ordinance is for any reason held to be invalid or unconstitutional, such decision shall not affect the validity of the remaining portions of this ordinance; it being the intention of the City Council of the City of Vernon to pass and adopt this ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that one or more of the sections, subsections, clauses, sentences or phrases thereof may be declared to be invalid or unconstitutional. SECTION 12: There being no newspaper printed, published or circulated in the City of Vernon, the City Clerk is hereby directed to certify to the passage of this ordinance and shall post the same, or cause the same to be posted, within fifteen (15) days after its passage in accordance with Section 36933 of the Government Code, in three (3) of the most public places in the City of Vernon, to wit: the northwest corner of 38th Street and Santa Fe Avenue, the northeast corner of Leonis Boulevard and Pacific Boulevard, and on the bulletin board in the lobby of the -5- 1 2 3 4 5 6 7 8 9''. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 271 281 City Hall of said City, located at 4305 Santa Fe Avenue, all in the City of Vernon, County of Los Angeles, State of California. SECTION 13: Pursuant to Chapter 4.3(a) of the Charter of the City of Vernon, this ordinance shall be introduced and adopted at one regular or special meeting of the City Council and shall be in full force and effect immediately upon adoption. INTRODUCED AND ADOPTED this 6th day of January, 1998. ATTESTy, BRUCE V. MALKENHORST, City Clerk EONIS C. MAL URG, MaiYor 1 2 3 4 5 6 7 8 9 10 11 12 STATE OF CALIFORNIA ) ) ss COUNTY OF LOS ANGELES ) I, BRUCE V. MALKENHORST, City Clerk of the City of Vernon, do hereby certify that the foregoing Ordinance, being Ordinance No. 1056, was duly and regularly introduced and adopted at a regular meeting of said City Council held on Tuesday, January 6, 1998, and thereafter was duly signed by the Mayor of the City of Vernon, by the following vote: 13 14 15 16 17 (SEAL) 18 19 20 21 221 23 24 25 26 27 1 281 AYES: Councilmen: Malburg, Ybarra, Davis Gonzales, McCormick NOES: Councilmen: None ABSENT: Councilmen: None ,y r BRUCE V. MALKENHORST, City Clerk -7- EXHIBIT A CHAPTER 5 BUSINESS LICENSE TAXES AND OTHER CITY TAXES Article II. General Taxes Sec. 5.20. Purpose. This article is enacted solely to raise revenue for general municipal purposes and is not intended for regulation. Sec. 5.21. Business license taxes imposed. There are hereby imposed upon all businesses in the city license taxes in the amounts hereinafter prescribed. Sec. 5.22. Business license tax rates. (a) Every person doing business or engaged in any business, profession, trade or occupation, or performing any act, or otherwise dealing in or with goods, wares or merchandise, and not elsewhere specifically licensed by other provisions of this chapter, shall pay a license tax for each calendar year or portion thereof for the privilege of doing business in the City of Vernon as follows: MAXIMUM TAX RATE FOR EVERY PERSON EMPLOYING: 0 or 1 employee (warehousing with no employees in the City of Vernon shall pay the minimum of $120.00 per year) $ 125.00 2 to 10 employees 190.00 11 to 25 employees 260.00 26 to 50 employees 360.00 51 to 75 employees 480.00 76 to 100 employees 595.00 1 of 11 - A EXHIBIT A MAXIMUM TAX RATE FOR EVERY PERSON EMPLOYING: 101 to 150 employees 710.00 151 to 200 employees 830.00 201 to 250 employees 950.00 251 to 300 employees 1,070.00 301 to 400 employees 1,190.00 401 to 500 employees 1,310.00 501 to 600 employees 1,435.00 601 to 700 employees 1,670.00 701 to 800 employees 1,905.00 801 to 900 employees 2,140.00 901 to 1,000 employees 2,380.00 1,001 to 1,100 employees 2,615.00 1,101 to 1,200 employees 2,850.00 1,201 to 1,300 employees 3,085.00 1,301 to 1,400 employees 3,325.00 1,401 to 1,500 employees 3,560.00 1,501 to 1,600 employees 3,795.00 1,601 to 1,700 employees 4,030.00 1,701 to 1,800 employees 4,270.00 1,801 to 1,900 employees $4,505.00 1,901 and more employees $4,740.00 (b) The rates for the business license taxes imposed in Sections 5.23 through 5.29 are as follows: 2 of 11 - A MAXIMUM TAX RATE CATEGORY (1) Central Station Industrial Protective Service (§5.23(a)) (minimum tax) $335.00/yr. (2) Auctioneer (§5.24(a)) $120.00/day (3) Still Photography (§5.24(b)) $ 65.00/day (4) Taxicab Service (§5.24(c)) $180.00/yr. (5) Vehicle Towing Service (§5.24(d)) $180.00/yr. (6) Peddler (§5.25(a)) $220.00/yr. (7) Catering Vehicle -Cold Food (§5.25(b)(1)) $190.00/yr. (8) Catering Vehicle -Hot Food (§5.25(b)(1)(i)) $235.00/yr. (§5.25 (b) (1) (ii) ) (9) Catering Vehicle -Daily (§5.25(b)(2)) $ 55.00/day (10) Peddler/Caterer-Transfer (§5.25(d)) $ 65.00 (11) Peddler (§5.25(e)) $635.00/yr. (12) Fruit/Vegetable Vendor (§5.25(f)) $190.00/yr. (13) Junk/Scrape Metal Dealer (§5.27(a)) $1,425.00/yr. (14) Rag or Paper Dealer (§5.27(b)) $ 935.00/yr. (15) Secondhand Pipe Dealer (§5.27(c)) $1,425.00/yr. (16) Shows, Circuses, etc. (§5.29(a)) $ 180.00/day (17) Sideshow (§5.29(b)) $ 120.00/day (c) Business License Tax For Warehousing (V.C.C. Sec. 5.28) (1) The minimum warehousing license tax shall be $200.00 per year and the maximum warehousing license tax shall be $1, 990.00 per year. Warehousing shall include distributing and wholesale businesses which are not conducted in conjunction with a manufacturing business. (2) For every person engaged in or carrying on the business of warehousing in the City of Vernon, the tax rate per 3 of 11 - A square foot shall be as follows: First 5,000 sq. ft. All square footage over 5,000 sq. ft. ANNUAL TAX $200.00 $ 0.0350 per sq. ft. in addition to the $200.00 (3) Each additional offsite warehousing facility which a business may have in the City of Vernon shall have a business license and the tax rate per square foot shall be as follows: First 5,000 sq. ft. All square footage over 5,000 sq. ft. ANNUAL TAX $200.00 $ 0.0175 per sq. ft. in addition to the $200.00 (4) If the warehousing facility is 5,000 square feet or less, then the minimum rate applies. (5) Every person engaged in or carrying on the business of warehousing in conjunction with a manufacturing business and where said business has 100 employees or more at the same location, the business license fee will be based on the number of employees, and the warehousing activity at the same location is exempt from the square footage fee. Sec. 5.23. Central station industrial protective service. (a) Every person engaged in conducting a central station protective signaling system for watchmen, fire alarm or supervisory services shall pay a minimum license tax pursuant to section 5.22 each year at the time of applying for or renewal of the license. (b) The licensee shall pay to the City of Vernon two percent of the gross receipts of business arising from the licensee's operations conducted in the city of Vernon, less the minimum 4 of 11 - A previously paid. (c) Definitions. Protective systems include, but are not restricted to, automatic sprinklers, standpipes, carbon dioxide systems, automatic covers and other devices used for extinguishing fires, and for controlling temperatures or other conditions dangerous to life or property. Protective signaling systems are electrically operated circuits, instruments, or other devices, together with the necessary electrical energy, designed to transmit alarms or supervisory or trouble signals, necessary for the protection of life or property. Central station systems are systems or groups of systems, the operations of which are signaled to, recorded in, maintained or supervised from a central station for the protection of life or property. (d) Any license granted under this section must be approved by the fire and/or police department of the city before issuance of said license is given to the applicant. Sec. 5.24. Persons without a fixed place of business. The following persons not having a fixed place of business within the city shall pay the tax indicated in Section 5.22: (a) Every person, firm or corporation engaged in or carrying on the business of an auctioneer for the sale at auction of any real or personal property shall pay a tax for each day of auctioning. (b) Every person, firm, or corporation engaging in the business of commercial still photography shall pay a tax each day. 5 of 11 - A (c) Every person, firm, or corporation providing taxicab service in the city other than from a taxicab stand, as such terms are defined in Chapter 23 of the Code, shall pay a tax each year. (d) Every person, firm, or corporation providing vehicle towing services in the city shall pay a tax each year. Sec. 5.25. License Taxes for peddlers, caterers, and street vendors. (a) For every person engaged in or carrying on the business of a peddler for the purpose of selling or offering for sale any goods, wares or merchandise, a tax pursuant to Section 5.22 each year, or portion of year thereof, except as otherwise specifically set forth herein. The first license of any newly established peddler shall set forth a license tax prorated upon the basis of calendar quarters, or fractions thereof, remaining in the current calendar year. All licenses for persons engaged in or carrying on the business of a peddler shall be annual licenses only. No refunds shall be granted to any peddler who terminates his business in the city before the expiration date of said license. No such license may be transferred from one person to another. (b) Catering vehicles operating on the streets of the city which service its businesses shall comply with the appropriate requirements of all city departments having jurisdiction. Said catering vehicles shall first obtain the appropriate clearance and approval of all such departments prior to licensing. (1) Catering vehicles shall be defined and license taxes payable pursuant to Section 5.22 determined for each of the following: 6 of 11 - A (i) Any catering vehicle engaged in the preparation and sale of hot food and drink items from said vehicle. (ii) Any catering vehicle engaged in the preparation and sale of cold food and drink items only from said vehicle. (2) Catering vehicles, not otherwise licensed, operating in the city to serve an auction or other special event, shall pay a daily tax pursuant to Section 5.22 for each day of said operation. (c) No license shall be issued to a peddler or to a catering vehicle until such catering vehicle or peddler's vehicle has been inspected and approved by the fire department and the health department. (d) A license for a peddler's vehicle or a catering vehicle may be transferred from vehicle to vehicle upon payment of the established transfer fee pursuant to Section 5.22; provided, however, that all requirements of city departments having jurisdiction are given compliance. (e) For every peddler who calls attention to his wares, or advertises the same by use of music, entertainment, speech, fancy or grotesque dress, or otherwise, upon any public street, alley, or other public place, doorway of any room or building, unenclosed or vacant lot or parcel of land within the city, shall pay a tax pursuant to Section 5.22 each year, or any monthly portion thereof. (f) Every person conducting, managing, or carrying on the business of selling fruits and/or vegetables from a vehicle, and having no fixed place of business in the city, shall pay a tax pursuant to Section 5.22 each year or portion thereof. 7 of 11 - A Sec. 5.26. [Reserved] Sec. 5.27. Dealers in junk, metal, rags, paper, etc. (a) For every person having a fixed place of business in the city, and engaged in conducting, managing, or carrying on the business of buying or selling, at wholesale or retail, any old metal such as old iron, brass, copper or other metals, commonly known as junk or scrap metal, shall pay a tax pursuant to Section 5.22 each year. (b) For every person engaged in the business of buying or selling or otherwise dealing in used or secondhand rags or papers, and who is commonly known as a secondhand rag or paper dealer maintaining a fixed place of business in the city, shall pay a tax pursuant to Section 5.22 each year. (c) Every person engaged in the business of conducting or operating, at wholesale or retail, any secondhand steel or cast iron oil pipe, water pipe, oil -well casing, and/or fittings for the same, and who is commonly known as a secondhand pipe dealer, maintaining a fixed place of business in the city, shall pay a tax pursuant to Section 5.22 each year. Sec. 5.28. Warehousing tax. (a) Every person engaged in or carrying on the business of warehousing in the city, including refrigerated warehousing, which is not in conjunction with a manufacturing business in the city shall pay the following tax pursuant to Section 5.22 each year. (1) A set tax for each location based on a specified minimum square footage. (2) An additional tax for each location shall be charged based on each additional square foot or increments thereof up to a 8 of 11 - A maximum tax. (b) Each manufacturing business located in the city which operates warehousing, including refrigerated warehousing, in conjunction with said business at the same location shall be subject to these taxes unless said manufacturing business employs one hundred or more persons at that location. (c) Each additional off -site warehouse operated in conjunction with a manufacturing business shall pay said taxes separately for each warehousing location. Sec. 5.29. Shows, circuses, rodeos and other amusements. Every person engaged in the business of conducting a show, circus, rodeo, or other type of amusement in the city, for which an admission fee is charged to or in any way collected from the persons attending the same, and which is carried on for a period of time less than thirty days at one location, shall pay a license tax pursuant to Section 5.22 for each day or portion thereof during that time for the privilege of doing business in the city, as follows: (a) A tax per day for such show, circus, rodeo or other type of amusement; (b) A tax per day for each sideshow for which an admission fee is charged, and which is operated as a side attraction to a show, circus, rodeo or other type of amusement licensed under paragraph (a) above; and (c) No license shall be issued for any businesses, pursuant to this chapter, unless the city council shall have first authorized the issuance of such license. 9 of 11 - A Sec. 5.30. Penalties. Whenever the license tax required by this article is not paid on or before the delinquency date, a penalty of ten percent of the amount due for the license tax shall be imposed, and an additional penalty of ten percent of the original license tax shall be added at the close of business on the last day of each calendar month thereafter. Every penalty shall become a part of the license tax required by this article. In no case shall the total penalty for delinquent license taxes exceed fifty percent of the original license tax for each year. Sec. 5.31. Setting license tax rates by resolution; adjustment for inflation. (a) Pursuant to section 2(b) of Article XIIIC of the California Constitution, the tax rates established by this article are maximum rates, and the city council may impose business license taxes at any rate or amount that is equal to or less than the maximum rates or amounts authorized by this article. (b) The maximum rates established by this article shall be revised annually based upon changes in the Consumer Price Index for All Urban Consumers (CPI-U), All Items Index, Los Angeles -Anaheim - Riverside Area (1982-84=100) (hereinafter "CPI") published by the United States Department of Labor, Bureau of Labor Statistics. In the event said CPI for the twelve-month period ending March 31 of each year (the "adjustment date") is higher than said CPI for the twelve-month period ending March 31, 1997, the maximum tax rates set forth in this article shall be increased by multiplying said tax rate by a fraction, the numerator of which is the CPI on the adjustment date and the denominator of which is the CPI existing 10 of 11 - A for the twelve-month period ending March 31, 1997. The resulting adjusted tax rates shall then be the maximum tax rates for the tax year commencing the next January 1st. There shall be no reduction in rates by operation of this provision. If, in the future, said CPI shall be changed so that the base year differs from that used as of the effective date of this article, it shall be converted in accordance with the conversion factor published by the United States Department of Labor, Bureau of Labor Statistics. The city clerk shall submit a written report to the city council setting forth the adjustments to the maximum tax rates required by this section, which the city council shall approve by resolution. (c) Periodically, the city clerk shall submit to the city council a recommendation for revising the rates of business license taxes and related fees and deposits so that revenues from license taxes remain a significant portion of total revenue available to meet expenditures, provided, that the recommended license tax rates shall not exceed the maximum tax rates authorized by this chapter. A complete license tax and fee schedule shall be adopted by resolution of the city council. Should the council, for any reason, fail to adopt such a resolution, the maximum tax rates as determined by this section shall be deemed the schedule of taxes to be levied pursuant to this chapter. Sec. 5.32. Effective date of article. This tax rates established by this article shall take effect immediately. 11 of 11 - A DOCUMENTS AFFIDAVIT OF POSTING STATE OF CALIFORNIA ) COZTNTY OF LOS ANGELES ) ss CITY OF VERNON ) I, Gloria, J. Orosco, Chief Deputy C'ty Cler f the City of Vernon, do hereby certify that on the day of 9 8, I did have posted three (3) copies of: Ordinance No. 1056 - An Ordinance of the City Council of the City of Vernon Adding Article II to Chapter 5 to the Code of the City of Vernon Relative to Business License Taxes and Fees, Establishing a Date for an Election to be Held to Approve the Levy of the Business License Taxes Contained Herein; and Declaring that Said Ordinance Shall Take Effect Immediately one in each of the following places, to wit: at the northwest corner of 38th Street and Santa Fe Avenue; the northeast corner of Leonis Blvd., and Pacific Blvd.; and on the bulletin board in the Lobby of the City Hall of the City of Vernon, located at 4305 Santa Fe Avenue, all in said City, there being no newspaper of general circulation printed and published in the City of Vernon. G ria J. Orosco C ief Deputy City Clerk Date: l Subscribed and sworn to before me this " of Soa&U 1998 SHARON L DUCKWORTH � OOWA.#MUMM6 Notary Public in and for the ie Notary — Cd mb ` LOS ANGELES COUNTY County of Los Angeles, State of My Comm. Expires JUN 9.1999 California CITY COUNCIL LEONIS C. MALBURG Mayor THOMAS A. YBARRA Mayor Pro -Tern Wm. 'BILL" DAVIS Councilman H. "LARRY" GONZALES Councilman W. MICHAEL McCORMICK Councilman BRUCE V. MALKENHORST City Administrator/City Clerk FAX: (213) 581-7924 CITY HALL 4305 SANTA FE AVENUE, VERNON, CALIFORNIA 90058 TELEPHONE (213) 583-8811 April 23, 1998 Peter H. Maclearie, President Coded Systems 120 Main Street Avon, New Jersey 07717 Dear Mr. Maclearie: DAVID B. BREARLEY City Attorney FAX: (818) 330-5818 KEVIN WILSON Director of Community Services & Water FAX: (213) 588-2761 KENNETH J. DeDARIO Director of Light & Power FAX: (213) 583-1983 DAVE TELFORD Fire Chief FAX: (213) 581-1385 LOUIS ROSENKRANTZ Police Chief FAX: (213) 581-1178 Enclosed herewith is one copy each of Ordinance Nos. 1056 and 1057 to be incorporated into the Vernon Municipal Code. Prior to your final incorporation of this supplement, please FAX or mail a draft for our review to ascertain that there are no discrepancies between the actual ordinance and your interpretation of same. We will notify you immediately if we are in concurrence, or of any discrepancies. After final review, forward 55 sets of the supplement to my attention. If you have any questions, please do not hesitate to contact me. GJO/mm enclosure Very truly yours, CITY OF VERNON riaJ J. Oro co Chief Deputy;City Clerk 92