1995-01144-Minutes for Meeting July 18,1994 Recorded 12/15/1994_ 95-01144
MINUTES
Fraley Public Hearing
DESCHUTES COUNTY BOARD OF COMMISSIONERS
July 18, 1994_
Chair Schlangen called the meeting to order @ 5:30 gMm.``'
Commissioners in attendance were Nancy Pope Schlangen, Tom Throop,
and Barry H. Slaughter. Others present were Sue Brewster,
Assistant Legal Counsel; Bruce White, Assistant Legal Counsel;
Damian Syrnyk, Planner; and Anita Mutchie, Recording Secretary.
APPEAL ON DESCHUTES COUNTY HEARINGS OFFICERS FINDINGS AND
RECOMMENDATIONS ON NUB 94-2.
Chair Schlangen made the following statements: The applicant
requested a verification of nonconforming use for a commercial
truck repair and welding shop in a multiple use agriculture zone.
These applications were previously considered by the hearings
officer after a public hearing held on April 19, 1994. Evidence
and testimony were received at that hearing. The hearings officer
denied the applicant's request. The applicant has the burden of
proving that he is entitled to the land use approval sought. The
standards applicable to the application before the Board were as
follows: Chapter 18.120 of Title 18 of the County Zoning Ordinance
and subsection 18.120.010(B)(a) through (B)(c). The procedures
applicable to the hearing provided that the Board of Commissioners
would hear testimony, receive evidence, and consider the testimony,
evidence and information submitted into the record on appeal as
well as the evidence which constituted the record before the
hearings officer. The record developed to this point was available
for public review at this hearing. Testimony and evidence at the
hearing was to be directed toward the criteria set forth in the
notice of the hearing and testimony could be directed to any other
criteria in the comprehensive land use plan of the county or land
use regulations when persons believed such applied to the decision.
Failure to raise issues with sufficient specificity to afford the
Board of Commissioners and parties to the proceeding an opportunity
to respond to the issues precluded appeal to the Land Use Board of
Appeals on the issue.
Chair Schlangen asked if there had been any prehearing contacts
with members of the Board of County Commissioners. Commissioner
Throop stated he had a call from one of the members of the Fraley
family and he immediately explained that he could not talk with
them at which time the conversation was terminated.
The staff offered a report on the prior proceedings and issues
raised by application on appeal.
Damian Syrnyk indicated that he had incorporated the record of the
land use hearing into the present hearing for the e of
N,iCROFILMED i,21'9
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0137-18(39
review. He referred to a packet of information given the Board.
On page one he read the legal description of the property; tax lot
701, Township 17, South Range 12 East, Section 8b which is located
at the intersection of O.B. Riley Road and the Old Bend Redmond
Highway. On page two he indicated the applicable criteria from
chapter 18.120 of the county zoning ordinance which was
highlighted. On page three was a copy from the Oregon revised
statues regarding nonconforming uses also highlighted in yellow.
On page four was a copy of standards from exclusive agricultural Al
zone adopted by Deschutes County in 1972 with out right permitted
uses and conditional. He said those standards were in effect
between February 13, 1973 and November of 1979 when PLS, the first
version of the County Zoning Ordinance, was in effect. He said the
next version of the zoning ordinance, PL15, became effective
November 1, 1979. He then discussed the final pages of the packet
i.e. the multiple use agriculture zone, photocopies of the multiple
use agricultural zone current version from Title 18 of the County
Code with uses permitted out right and uses permitted as
conditional.
He then gave a brief background. He said the County had two
addresses for the subject property, 63810 O.B. Riley Road, Bend,
Oregon as the street address but some of the land use and property
records referred to the property as 63820. He said James Fraley
applied for the verification of nonconforming use in February 1994
pursuant to code enforcement action taken by the County. He said
the action went before the land use hearings officer on April 19,
1994, and that staff reviewed application materials, prepared a
staff report and recommendation of denial to the hearings officer
dated April 12, 1994. He said the hearings record had closed April
29, 1994, and a decision of denial was rendered by the hearings
officer dated June 8, 1994. He said the decision was appealed June
17, 1994.
Damian then discussed the applicable criteria of the application.
He said to approve the request the hearings officer had to find the
applicant had satisfied the criteria and that there were three
questions that had to be satisfied. The first question was whether
the use was lawful on the effective date of the zoning provisions
prohibiting the use. The original zoning, A-1, did not permit
truck repair businesses, or similar operations. The second
criteria was if the use actually existed on the effective date of
the zoning provisions prohibiting the use. The third criteria was
if the use had continued to this date without being interrupted or
abandoned. He said after the hearings officer's review, she found
evidence that the use had been changed at some points and
interrupted as well for a period of approximately two years when
the use had been abandoned. He said that nonconforming uses were
such because they are not permitted outright or permitted as
conditional uses. He said non -conforming uses do not implement the
Comprehensive Plan. It said in a multiple use agricultural zone
the purpose was to provide an area where people could have a
MINUTES PAGE 2 JULY 18, 1994
0137-1�jj
residence or engage in a use that could be allowed conditiona
He stated the County made a conscious decision to not allow truck
repair businesses in the area.
He said the use they were looking at included welding as an
activity as part of that use. He said there was confusion in the
original hearing as to whether two uses or one use encompassing
both activities was being looked at.
Rich Isham asked if there was "no question in the record that from
April of 1969 until 1973 the property was being used for some
purpose and as a result of the zoning ordinance that purpose became
a nonconforming use on the date that ordinance was effective."
Damian stated that was correct. Rick then asked about the use from
that particular date. Damian said the hearings officer determined
the record was not entirely clear and information in the record
indicated some type of a commercial operation was going on that
involved the repair and work on vehicles but the hearings officer
found that the information did not clearly indicate what type of a
use was being looked at and its characteristics. He said one of
the important details the hearings officer did not find was date,
month, or year things actually started at the site. He said the
applicant was raising the issue that there was information in the
record to establish that the use existed. He said the applicant
would also present information that the record itself would
demonstrate the nonconforming use was never abandoned or
interrupted for more than a period of one year.
Bruce White stated that it was clear whether that non -conforming
uses were favored not under the law. He felt it was clear they
were not favored under the law. He said "the law states that you
construe against finding the continuation of a nonconforming use
and that you construe favorably any provisions that would restrict
continuation or expansion of the use." Since non -conforming uses
were not favored under the law, he felt it was the burden of the
proponent of the nonconforming use to prove to the Board that all
of the elements were in position at the time it became
nonconforming. He indicated the exhibit on the board listing the
history of uses of the property had been prepared by the
applicants. He also said it was not enough to say that a use or
activity was occurring at the time, but the level of the activity,
scope, and nature of the activity at the time it became
nonconforming governs what was the use at the time. He said if it
were true that there were truck towing and repair on February 13,
1973, it was important for the Board to know how many trucks, how
often, what times of the day were the trucks being worked on, and
were they being worked on inside or outside.
Commissioner Throop asked if the reason was that a nonconforming
use could not be altered or expanded. Bruce stated that in our
case the ordinances have said they cannot be expanded. He said it
was permissible under state law but not under County ordinances.
MINUTES PAGE 3 JULY 18, 1994
0137-1841
He said the other reason was that they were not favored under the
law and that they existed at variance to our ordinance. He said,
"in applying the criteria, you construe against their continuance
because they are continuing in the face of a policy choice by the
local government to not allow for those kinds of uses in the zone."
Rick Isham questioned if there was a benefit of the doubt if it
would go to the applicant. Bruce White agreed that was correct and
said it was just a matter of law. Commissioner Throop questioned
if the applicant met the criteria whether it was a valid
nonconforming use. Bruce answered yes and that it would mean the
operation in place February 13, 1973, could continue. Commissioner
Throop stated the operation could not be expanded or changed but
that as long as the same kind of operation was continued it would
be valid.
Bruce White stated that to simply put up a number of uses or
activities and say that those could be continued on at any level
was not a permissible reading of the state law. He used as one of
the closest examples found in the case law, a truck repair business
in Prineville where for a number of years the main truck repair
business was shifted to another site. He said there was some
incidental truck repair business going on for a period of years and
then the owners tried to bring the main operation back to the same
site. He said LUBA did not allow this since the business had been
continued on at a lower level. They were not allowed to bring it
back to the increased level but were allowed to continue at the
level of use that was characterized by their minimal use of the
property in the meantime.
He said a nonconforming use did not operate the same as a zoning
ordinance operated. He said this was not a use categorized in the
zoning ordinance and that it was necessary to look to the
provisions of nonconforming use law.
Chair Schlangen asked if code enforcement had any reflection on
this hearing. Bruce stated that he had participated as an advocate
in the code enforcement hearing in prosecuting what he believed, in
his role as a prosecutor, to be a use not allowed by the zone and
that had a nonconforming use defense that he did not believe to be
valid.
Sue Brewster said this began as a code enforcement case last June
and that Bruce covered that case. When it was time for the trial
the parties agreed to use the form of nonconforming use permit. In
November it was noticed that nothing had been done so another
citation was issued and in February there was a hearing before
District Court where they were asking to dismiss the case on double
jeopardy grounds. Sue stated this was denied by the court. A
motion had also been filed in circuit court asking that circuit
court make a ruling on the 1977 variance. She said that circuit
court took the county position which was that they did not have any
MINUTES PAGE 4 JULY 18, 1994
013'7-1842
jurisdiction as this was a land use matter. Sue stated that it was
agreed in district court to wait until the hearings officer heard
the case and another trial was set for the end of August 1994 thus
this case was still a pending code complaint case.
Larry Erwin, attorney representing the owners of the property, came
forward and offered further history. He said that after Mr. Fraley
had been operating his business for a few years, a neighbor
complained to the county that there were problems with the
operation of the business. A citation was issued for operating a
business in a MUA zone for which Mr. Fraley was not zoned. He said
there was no dispute about the MUA zone and that there was a
commercial repair facility and storage area present. He said that
Mr. Fraley went to trial and during the trial the judge said to
Bruce White and Mr. Erwin that they were getting nowhere, that
violation hearings could go on "all day," but what was needed was
to resolve the issue. He said Bruce White took the position that
he had to go through the violation process first in order to
exhaust his legal remedies in order to get into circuit court and
that he had a "theory that we had an adequate remedy at law which
was the violation process and so he felt he had to do that." He
said he agreed with the judge and Mr. White that handing Mr. Fraley
citations would not solve the problem. He said a Fraley Ordinance
was passed whereby they could apply for verification of
nonconforming use. He said that Mr. White had told him this was in
place but Mr. Erwin could not find one in place. Therefore, one
was passed. He said at that point it was also discovered that a
variance was granted in 1977 and a partition in 1979 and that was
discussed with Mr. White. Another citation was given to them, and
ultimately Mr. Erwin filed the application. He said the other
violations were still pending.
Chair Schlangen questioned the minor partition. Mr. Erwin
responded that Mr. Bill Lee was the first person in the "chain of
title of significance" that owned the property and he had a home
and business in one area. He said that business consisted of
welding repairs, commercial tow trucks which hauled diesel, had
rigs and semi -rigs, and stored materials.
Mr. Erwin said this was important because he felt the time to look
at what use was permitted was in 1977 or 1979 and that in 1972 Mr.
Lee built the building. At that time the operation consisted of
vehicle repair, welding, truck repairs, diesel, truck/tractor
repairs, heavy equipment repairs, mobile home repairs, trailer
repairs, repairs on all types of construction equipment; the
business was very intense with many vehicles and equipment parked
on the property and shop. He said during that time vehicles were
also brought in and out at various times of the day and night. He
said in 1977 Mr. Lee wanted to get an Oregon Department of Veterans
Affairs loan and in order to do that it would need to be
residential. Because his residence and business were combined, he
applied for a variance and ultimately a minor partition and asked
MINUTES PAGE 5 JULY 18, 1994
013 7-18
the county to allow him to split off the subject property, limit
the commercial activity to that approximate one -acre portion, and
leave the other 7-8 acres as the residential portion.
Mr. Erwin said that in order to grant a variance and minor
partition the use must be lawful at that time. Rick Isham asked
for a code section. Mr. ????? said it was 9.010 of the Code in
effect in 1977 and that the information could be found in the blue
notebook before the Board.
Rick Isham said a nonconforming use was not an unlawful use. Mr.
Erwin said that was correct. Mr. Isham asked if 9.010 would not
apply to a valid nonconforming use. Mr. Erwin said if it were not
a valid nonconforming use it was an illegal use and a variance
could not be granted nor would a partition be granted. Mr. Isham
asked if the use of the property was recognized indirectly by the
granting of the variance. Mr. Erwin responded, "certainly." Mr.
Erwin said from 1973 forward when the ordinance was passed, Mr.
Lee's activities did not change and he was doing the same sorts of
things and that the record reflected that.
Mr. Erwin said it was a valid nonconforming use in 1973, 1977, and
1979. He said one of the letters found in the county files was
asking Mr. Lee the uses of the property during the last five years
and that Mr. Lee listed the things that were done there. Mr. Erwin
said the record reflected that Mr. Lee was involved in storage of
materials, construction equipment, repairs, etc. At the time of
Mr. Lee's divorce, other people started operating the business. He
then referred to a chronology list before the Board. He said the
building had been in the same condition since 1972, that it was
metal, had a hydraulic hoist for vehicle repairs, and this had not
changed.
He said the hearings officer had attempted to make distinction as
to times when it had been a mobile home repair and truck repair and
since they were different it was abandonment. He said that was not
a valid distinction and that this was a commercial repair shop. He
referred to the LUBA Crook County truck repair case. He said the
LUBA court stated the changes in the volume or intensity generally
do not constitute an impermissible change in a nonconforming use
provided such changes are attributable to growth or fluctuations in
business conditions and are not accompanied by alterations in the
nature of or physical structures employed by the nonconforming use.
He said that was exactly what was present and that the structure
and use had not been altered.
He said the denial of a verification of the nonconforming use would
be to condemn this business. He referred to a case v.s. Clackamas
County where a repair facility had been used as such in the past as
well as currently. He said that in the Hangdon case the court
stated LUBA was wrong when it talked about the nature of the
business to be the decisive inquiry. He said this was what the
MINUTES PAGE 6 JULY 18, 1994
0137-184
hearings officer had done. He said in that past issue the court
had stated the more relevant question was whether there was a
common use that the various operations shared. He said in terms of
abandonment, the hearings officer made a statement that there was
a two year period where an interruption or abandonment was present.
He said this was not supported by the record. He said it was still
being used as a repair facility when A-1 Mobile Home Repair used
it.
Mr. Erwin stated there had not been an abandonment, although there
may have been some differences in intensity but a nonconforming use
could be approved on that basis. He stated if there was a nuisance
problem, that could be taken care of by nuisance ordinances. The
Fraley's could be authorized to operate during certain hours. He
stated they have been examined by the Department of Environmental
Quality and they have a clean bill of health. The underground
storage tanks which had previously been used on this site had been
removed. He felt the applicant had more than met the burden of
proof and the non -conforming use should be approved as a repair and
storage facility.
Myer Avedovech, attorney, testified on behalf of the proponent of
the appeal. He stated he had read the transcripts from the
previous testimony and felt that most of the complaints regarding
this use were about hours of operation, noise, etc. He felt it was
important that the Board take the time to review the transcripts.
He felt the Hearings Officer seemed to hold the applicant to a very
high standard of proof. He stated Mr. Fraley was doing structural
repair to recreational vehicles, trailers, semi -trucks, but his
primary function was working on diesel engines which was not
different from what A-1 Mobile Home was doing in repair. He stated
the use has been there and was still going there and Mr. Fraley
should be allowed to continue. He stated the uses have been
defined in the transcript and felt the use should be allowed to
continued.
Jim Fraley, applicant, stated he has known of this building since
1973. He stated this was a family run business and it would
devastate his family if they were denied the use of this building.
He stated his business had been labeled as strictly heavy diesel
repair but they were not. He stated the do structural repair and
all kinds of repairs.
Commissioner Schlangen requested that Mr. Fraley describe what kind
of activity takes place at this site each day. Mr. Fraley stated
it was an acre in size and their primary business was trucks but
they also work on a lot of cars, utility pick ups, motor homes and
they do some fabricating and welding. He stated they try to keep
the site clean and do not have trash laying around such as engines
and transmissions. Mr. Fraley stated that when he moved onto that
site, he removed two semi -truck loads of trash from the property.
MINUTES PAGE 7 JULY 18, 1994
0137_18 5
Bill Prewitt testified that he had been involved with land use
issues since 1973. He stated this particular property was owned by
Bill Lee. He stated he had been involved in this property since
1973 at its inception. He stated this property had been used for
commercial industrial use since 1973. He stated there has been a
use there all the time since then but was not sure whether the
level of use had gone up and down. He stated this was clearly a
commercial industrial use under a non -conforming use. Bill Prewitt
stated the question was whether this was a legal non -conforming use
or not. He felt the documents since 1973 indicated that it had
been used for a commercial industrial use. He stated that if a use
causes excessive noise, smoke, etc. these things could be
controlled. A conditional use permit could be issued for these
problems which stated works hours would be 8 a.m. to 5 p.m., no
night time hours, no excessive lights, no loud equipment which
produces smoke, etc. He testified that the property values in this
area have not decreased.
Jeannie Fraley testified in support of this appeal. She stated she
had lived here since 1969. She stated as long as she could
remember there had been equipment on this property. She stated
that if the neighbor had a problem, she felt they should have come
to talk to them. She felt this issue had stemmed from a personal
problem with Mr. Suydam. She submitted written testimony as to the
happenings regarding Mr. Suydam.
Lloyd Suydam testified in opposition to this non -conforming use
variance. He stated he lived immediately adjacent to the property
in question. He stated he passes by this property several times
everyday. He has lived there since 1985. He stated that two or
three years ago he had a petition signed by the entire neighborhood
in order to get the county to act on this matter. At that time the
County thought that the place had a variance to operate. The
variance that was referred to was a variance to split property and
had nothing to do with operating a diesel truck repair business.
He stated that in order for him to get any action taken on this
issue he had to write to the governor. He stated there were
several complaints from the neighbors over the years but nothing
was done until this point.
He stated A-1 Mobile Home Repair was strictly travel trailers and
mobile home repairs which were strictly structural. It was a one
man operation and he was very quiet and low key. He felt the
Fraley's use had totally changed the use. He stated this was a
very noisy, dirty, smokey use. He stated he lived down wind from
this use and was not able to open his windows during the summer
time because of the dust and diesel smoke. He stated the road
condition had deteriorated with all the truck traffic. He stated
that there were school bus stops along the road and it was not safe
to have that many trucks on the road with the school bus stops. He
stated the twenty-four hour operations was a problem due to air
brakes being tested or a horn honking at 2 a.m. in the morning. He
MINUTES PAGE 8 JULY 18, 1994
stated that this property had not been cleaned up until the last
hearing was held. He felt the applicant had another place to which
to move his business. He felt this business was devaluing their
property due to the noise and close proximity of the truck repair
business. He stated there was a lot of evidence that shows that
this business had not always been there as it was at the present
time.
Commissioner Slaughter requested Mr. Suydam show him where his
property was located on the map. Mr. Suydam did so.
Robin Pfeifher stated she lived across the street from the Fraley's
business. She stated the scope and intensity were the issues and
that the issues of pollution and noise and working twenty-four
hours a day were in fact a direct consequence of the increase in
scope and intensity. If this business had not grown larger and
changed, they would not be here today. She questioned that if
people had lived here for 10 years, why this had not been brought
up before. She stated that in the short time that she has lived
there, she has been awakened early in the morning on Sundays. She
stated things have changed. She felt she should not have to get up
at 2 a.m. to ask someone to not be noisy. She stated there was a
possibly to put restrictions on this business, but she felt that
every time they did not meet those restrictions she would have to
call and make a complaint.
Bruce Ronning testified in opposition to this non -conforming use.
He stated he was not available for the earlier hearings on this
issue. He stated he had concerns regarding noise, pollution, air
quality, visual pollution, and odd working hours. He stated he was
concerned that if this use was approved, how would the County
enforce compliance. He stated industrial uses were grouped
together in order that they can be monitored, but this was separate
from other industrial uses which would make it difficult to
monitor.
Jim Fraley felt he was taking a "bum rap" for traffic and tearing
up the road. He stated all kinds of trucks travel that road
including trucks from Bend Aggregate. He stated that they normally
do not park down below, except for four times during the last year.
Occasionally that has happened, but he cannot work on that many
trucks at one time. He stated he usually started work at about 8
a.m. and finished up at 6-6:30 p.m. He stated they cannot work
twenty-four hours per day. He stated there have been times when
trucks have pulled up into their yard.
Commissioner Schlangen asked Mr. Fraley if he had other industrial
property where he worked on engines. Mr. Fraley stated that he did
not.
Mr. Erwin stated that the County could restrictions on non-
conforming uses. The County could say this use has existed since
MINUTES PAGE 9 JULY 18, 1994
0137-18" l
1973; however this business shall only operate during normal
business hours and include other restrictions.
Commissioner Throop requested that Mr. Erwin describe the reasons
that the Hearings Officer denied this issue. Mr. Erwin stated that
Ms. Fancher felt she had no choice as it was an all or nothing
issue. She took a very strict approach and put a burden on the
applicant that was nearly impossible to meet. He stated they had
submitted statements from neighbors and everyone along that road
near that property. He felt Ms. Fancher did not want to determine
the exact level of use, the normal business fluctuation, and the
normal business cycle over twenty-two years. He felt the hearings
officer got caught too tied up in the minutia to look at the big
picture.
Chair Schlangen questioned if the use was not stopped from 1984.
Mr. Erwin responded no and that the hearings officer said there was
no use for two years except for the repair of motor homes and
mobile homes. He referred to Mr. Grogan's letter and statement
that he was repairing motor homes, mobile homes, and travel
trailers.
Myer Avedovech said he had four pictures that he wanted to
introduce into evidence for clarification. One was Mr. Suydam's
property with the shop, a photo of the neighbor Pfeiffer property,
Robinson & Son business on O.B. Riley Road, and the State of Oregon
yard on O.B. Riley Road.
Chair Schlangen asked for rebuttal. Lloyd Suydam said the highway
was further from the residential zone than the business and was not
a problem. He said the level of use had increased considerably.
He said it was never a truck repair shop and it was not a diesel
tractor repair business. He said Ralph's A-1 Motor Homes was a
motor home repair business involving structural repairs but no
engine work. He said this information was documented in the papers
before the Board. He said it was not a level of use but a change
of use and that level of use could not be regulated by saying they
could have one truck or two trucks a day. This would not change
the noise and pollution problems or that their properties were
being devalued by its presence. He said it did not belong and that
Liz Fancher was correct when she stated it was an all or nothing
thing.
Mr. Suydam stated that this was not commercial property but a
residential, MUA-10, neighborhood. He referred to the pictures
handed out by Myer Avedovech and said the businesses illustrated
were about three miles away. He said the people within 500 feet of
the property were the pertinent people. He said that in 1992 he
took a petition of every resident within 500 feet and stating they
did not want the business present.
MINUTES PAGE 10 JULY 18, 1994
01317- 1 3
Chair Schlangen asked Mr. Suydam if he had a business in his
residence. He said no, he had a metal shed on his property about
20' x 20' for storage purposes only. Chair Schlangen asked about
the access to his property. Mr. Suydam said he had a driveway off
Highway 20 which was "impossible to use due to traffic" as well as
a deeded access from the Old Bend -Redmond Highway.
Commissioner Throop asked when the property was purchased. Mr.
Suydam said October 1984 or 85. Commissioner Throop asked why he
would purchase the property knowing the category of uses occurring
on the Fraley property. He said at the time he was working for a
security company and that Mr. Fraley's business had nothing in it.
He had been hired to check the vandalism problems related to the
Lee's divorce case on the property he now owns. He said in doing
so, he had to pass by the building doing diesel service and there
was nothing in that building. He said when "Ralph came in it was
very quite." He said it was in receivership from 1984 until
purchased by "Sophie" in 1987 or 1988. He said he had no concerns
about purchasing his property because he knew "the grandfather
clause had expired." Commissioner Throop asked why he thought the
grandfather clause had expired. Mr. Suydam said it was because the
uses had changed as well as ceased. He said the building was
totally vacant and not used at all in approximately 1983 and 1984.
He submitted aerial photographs showing the area in question all
grown over with weeds and brush. He said the photographs were
dated 6/23/79, 5/5/85, and 7/28/90. He said there was only one
vehicle in all the photographs.
Chair Schlangen asked if there were requests to leave the record
open. No requests were offered. Therefore, the record was closed,
the public hearing was closed, and Chair Schlangen stated a
decision would be made on Wednesday, August 3, 1994, at the 10 a.m.
Board of Commissioners meeting.
DATED this /_ day of , 1994, by the
Board of Commissioners of schutes County, Oregon.
Nancy P pe S hlangen, Chair
Tom Throop, Commissioner
ATT
h7V
Recording Secretary Barry A. Slaughter, Commissioner
MINUTES PAGE 11 JULY 18, 1994