HomeMy WebLinkAbout6/30/2014 - STAFF REPORTS - 3.A. OVERSIGHT BOARD FOR THE SUCCESSOR AGENCY TO THE PALM
SPRINGS COMMUNITY REDEVELOPMENT AGENCY
BOARD REPORT
MEETING DATE: June 30, 2014 UNFINISHED BUSINESS
TITLE: APPROVING LOAN TO SUCCESSOR AGENCY IN THE AMOUNT OF
$1,500,000 TO PAY ENFORCEABLE OBLIGATIONS
INITIATED: Department of Community & Economic Development
RECOMMENDATION:
1. Adopt Resolution No. , "A RESOLUTION OF THE OVERSIGHT BOARD OF THE
SUCCESSOR AGENCY TO THE PALM SPRINGS COMMUNITY REDEVELOPMENT
AGENCY APPROVING THE AMENDED AND RESTATED LOAN AGREEMENT
WITH THE CITY OF PALM SPRINGS IN THE AMOUNT OF $1,500,000 FOR
THE PURPOSE OF PAYING ENFORCEABLE OBLIGATIONS FOR THE
PERIOD JANUARY 1, 2014 TO June 30, 2014."
2. Direct the Clerk of the Successor Agency to cause the execution of the Loan
Agreement and direct the Director of Finance to remit the required payment to the
Riverside County Auditor-Controller and provide notice of the payment to the State
Controller's Office and the State Department of Finance.
BACKGROUND AND ANALYSIS:
Pursuant to Health and Safety Code (HSC) section 34176(a)(2), the City of Palm Springs
submitted a Housing Assets Transfer Form (Form) to the California Department of
Finance (DOF) on July 31, 2012 for the period February 1, 2012 through July 31, 2012.
On August 30, 2012, DOF responded, objecting to one item. DOF determined that the
item was a loan issued on August 3, 2011 under an Owner Participation Agreement with
an affordable housing developer. DOF further stated that HSC Section 34163 (b)
prohibited an agency from entering into agreements, obligations, or contracts with any
entity for any purpose after June 27, 2011.
It was the opinion of the City that DOF erred in disallowing the loan "issued" on August 3,
2011, as all of the Redevelopment Agency's approvals related to the Loan, including the
Promissory Note, Deed of Trust, Regulatory Agreement, and Owner Participation
Agreement itself, were made on June 15, 2011, prior to the effective dissolution date of
June 27, 2011. Executing and recording the Note and Deed of Trust for the development
project, as part of the escrow, did in fact occur in August to coincide with the close of
escrow, but the formal Agency approval of the item was made in June.
The loan, then, was executed to effectuate the Agency's performance under an
undeniably allowed enforceable contractual housing obligation, not as a separate
approval of an agreement entered into after the effective date. The City provided copies
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of the full Owner Participation Agreement with the Exhibits which were deemed
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approved at the time of the original approval, as well as evidence of the approval on June
15, 2011 and escrow documents that show the escrow on the property was opened prior
to the Agency approval on June 15, 2011.
Except for the single disallowed item as noted above DOF did not object to an of the
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remaining items listed on the Form.
In September, 2012, the Successor Agency commissioned a required Due Diligence
Review(DDR) of its Low and Moderate Income Housing Fund. The DDR determined the
amount of unencumbered cash in the Low and Moderate Income Housing fund, which
was then required to be remitted to the Riverside County Treasurer pursuant to Health
and Safety Code Section 34179.6(f). In November, 2012 the City wired the amount of
$7,701,693.13 to the County, which was less than the demanded in the November 7,
2012 letter from DOF, and was reduced by the amount of the disputed Housing Asset
Transfer Form item of$1,500,000.
The requested amount was $9,189,521. The City calculated interest in the amount of
$9,515.50 for the July through September period and $2,656.63 for October, and then
subtracted $1,500,000 for the item in dispute, resulting in the total listed above. The
DOF has calculated the amount in dispute of $1,489,829.
The Successor Agency is still disputing the disallowance of the item in question and has
filed an action in Superior Court in Sacramento, as is prescribed in the Dissolution Act.
The action is still pending.
The Successor Agency received a copy of a communication between the DOF and the
Riverside County Auditor-Controller dated November 1, 2013, in which the DOF
instructed the Riverside County Auditor-Controller to withhold $1,487,829 from the
Redevelopment Property Tax Trust Fund (RPTTF) distribution due to the Successor
Agency on January 2, 2014 for already approved Enforceable Obligations during the
period from January 1, 2014 through June 30, 2014 ("ROPS 13-14B"), in satisfaction of
the amount that DOF asserted was due under the DDR, nothwithstanding the pending
litigation of the matter.
The Successor Agency had Enforceable Obligations to pay to third parties that would
have been unpaid if the amount described was withheld. These Enforceable Obligations
include amounts payable under a court-approved settlement agreement with a third
party pursuant to settlement of litigation, third party payments under development
agreements, and fees payable in connection with compliance with bond indentures for
continuing disclosure and arbitrate rebate.
To avoid non-payment of the Successor Agency's obligations, the City and the
Successor Agency entered into a Loan Agreement dated November 20, 2013 (the
"RPTTF Loan") to provide funds to the Successor Agency to offset the DOF-directed
withholding of RPTTF, to be repaid to the City from future RPTTF.
On December 16, 2013, the Oversight Board approved the Successor Agency's action to
enter into Loan Agreement, and the Oversight Board action was submitted to the DOF
for review. On January 29, 2014, the Successor Agency received a communication from
DOF stating that the RPTTF Loan was not approved, since they considered it a loan to
pay the DDR amount and not related to payment of Enforceable Obligations.
The City and the Successor Agency staff recommend amending and restating the
RPTTF Loan to clarify that the purpose of the RPTTF Loan was to provide funds to the
Successor Agency to avoid disruption in the payment of its Enforceable Obligations by
pre-funding the amount the DOF asserted was due under the DDR, and thereby avoid
default in its obligations to third parties.
As a separate legal entity, the Successor Agency is not merged with the City, the public
agency that provides for the Successor Agency's governance (Section 34173(g)). The
Successor Agency retains the liabilities of the Dissolved RDA as those do not transfer to
the City (Section 34173(g)). The Successor Agency can sue and be sued in its own
name (Section 34173(g)) and all litigation involving the Dissolved RDA is automatically
transferred to the Successor Agency (Section 34173(g)).
Therefore, City is not the financial "backstop" or guarantor of obligations of separate
government entities, regardless of its status as a Successor Agency. The City is a
separate legal entity and its willingness to serve as the Successor Agency to the
Redevelopment Agency and the Redevelopment Agency's housing program does not
impose any burden or obligations on the general fund of the City. The City is simply
carrying out its responsibilities to administer the assets of the Redevelopment Agency.
In this case, the assets are the OPA and the notes. Thus, the City did propose that this
current dispute can be reasonably resolved by the Successor Agency of the
Redevelopment Agency housing program transferring the assets in the form of the OPA
and the notes to the Successor Agency of the Redevelopment Agency. That remedy has
not been accepted yet.
However, AB 1484 also allows a Successor Agency, subject to Oversight Board
approval, to enter into an enforceable obligation whereby a Successor Agency borrows
money from the City for administrative costs, enforceable obligations, or project-related
expenses and to wind down the Dissolved RDA (Sections 34173(h), 34177.3(b), and
34178(a)), which is the basis for this transaction.
The loan will be placed on a future Recognized Obligation Payment Schedule (ROPS)
for the period of January 1, 2015 through June 30, 2015 or the following period. The City
would be paid from available cash flow of the Redevelopment Property Tax Trust Fund
("RPTTF").
This action authorizes the City Manager or designee to take all actions necessary to
implement this action. The action was also approved by the Successor Agency Board
and City Council on June 18, 2014.
RESOLUTION NO.
"A RESOLUTION OF THE OVERSIGHT BOARD OF
THE SUCCESSOR AGENCY TO THE PALM
SPRINGS COMMUNITY REDEVELOPMENT
AGENCY APPROVING AN AMENDED AND
RESTATED LOAN AGREEMENT FROM THE CITY
OF PALM SPRINGS TO THE SUCCESSOR
AGENCY TO PAY ENFORCEABLE
OBLIGATIONS, IN THE AMOUNT OF $1,500,000
WHEREAS, under the Redevelopment Dissolution Act (AB 1X 26), the term "successor
agency" was defined to refer to the Dissolved RDA's Sponsoring Community (the city,
county or city and county that formed the Dissolved RDA), unless that Sponsoring
Community adopted a resolution electing not to serve in that capacity; and
WHEREAS, AB 1484 redefines "successor agency" to mean the successor entity to the
Dissolved RDA pursuant to Health and Safety Code Section 34173 and that "a
successor agency is a separate legal entity from the public agency that provides for its
governance;" and
WHEREAS, the City of Palm Springs is the successor entity to the Community of the
Community Redevelopment Agency of the City of Palm Springs; and
WHEREAS, as a separate legal entity, the Successor Agency is not merged with the
City, the public agency that provides for the Successor Agency's governance (Section
34173(g)); and
WHEREAS, the City is not the financial "backstop" or guarantor of obligations of
separate government entities, regardless of its status as a Successor Agency; and
WHEREAS, Health & Safety Code Section 34171(d)(1)(F) recognizes as an
"Enforceable Obligation" of the Agency contracts or agreements necessary for the
administration or operation of the Successor Agency, including, but not limited to,
agreements concerning litigation expenses related to assets or obligations, settlements
and judgments, and the costs of maintaining assets prior to disposition; and
WHEREAS, Health and Safety Code Section 34173(h) provides that the City may loan
or grant funds to the Successor Agency for administrative costs, enforceable obligations
or project-related expenses and that receipt and use of these funds shall be reflected on
the ROPS or in the administrative budget subject to Oversight Board approval; and
WHEREAS, Health and Safety Code Section 34177.3(b) authorizes the Successor
Agency to create "Enforceable Obligations" to conduct the work of winding down the
Dissolved RDA; and
WHEREAS, Health and Safety Code Section 34178(a) authorizes the Successor
Agency to enter into agreements with the City upon obtaining approval of the Oversight
Board; and
WHEREAS, in September, 2012, the Successor Agency commissioned a required Due
Diligence Review (DDR) of its Low and Moderate Income Housing Fund, which
determined the amount of unencumbered cash in the Low- and Moderate Income
Housing fund, which was then required to be remitted to the Riverside County Auditor-
Controller pursuant to Health and Safety Code Section 34179.6(f); and
WHEREAS, in November, 2012 the City remitted the amount of $7,701,693.13 to the
County, which was less than the amount demanded in the November 7, 2012 letter from
the California Department of Finance ("DOF"), which sought the additional amount of
$1,487,829 that the former redevelopment agency had loaned to a developer for a low-
moderate income senior housing project that in the DOF's opinion was voided by the
Redevelopment Dissolution Act; and
WHEREAS, the Successor Agency engaged the DOF in a "Meet and Confer" process
and is pursuing litigation to make its case as to the validity of the loan to the low-
moderate income senior housing developer, but so far has been unsuccessful and the
litigation is pending; and
WHEREAS, the Successor Agency received a copy of a communication between the
DOF and the Riverside County Auditor-Controller dated November 1, 2013, in which the
DOF instructed the Riverside County Auditor-Controller to withhold $1,487,829 from the
Redevelopment Property Tax Trust Fund ("RPTTF") distribution due to the Successor
Agency on January 2, 2014 for already approved Enforceable Obligations, in
satisfaction of the amount that DOF asserted was due under the DDR, notwithstanding
the pending litigation of the matter; and
WHEREAS, the Successor Agency had Enforceable Obligations to pay to third parties
that would have been unpaid if the amount described was withheld, and therefore, to
avoid non-payment of the Successor Agency's obligations, the City and the Successor
Agency entered into a Loan Agreement dated November 20, 2013 (the "RPTTF Loan")
to provide funds to the Successor Agency to offset the withholding, to be repaid to the
City from future RPTTF; and
WHEREAS, on December 16, 2013, the Oversight Board approved the Successor
Agency's action to enter into Loan Agreement; and
WHEREAS, the Oversight Board action was submitted to the the DOF for review and on
January 29, 2014, the Successor Agency received a communication from DOF stating
that the Loan was not approved, even though the funds had already been transferred to
the County to avoid disruption of the RPTTF payment on January 2, 2014, and such
funds had been distributed to taxing entities; and
WHEREAS, the City and the Successor Agency wish to amend and restate the RPTTF
Loan to clarify that the purpose of the RPTTF Loan was to provide funds to the
Successor Agency to avoid disruption in the payment of its Enforceable Obligations by
pre-funding the amount the DOF claimed was due under the DDR, and thereby avoid
default in its obligations to third parties; and
WHEREAS, in order to establish and declare the terms and conditions upon which the
Loan is to be made and secured, the Successor Agency and the City wish to amend
and restate the RPTTF Loan in full by entering into this Loan Agreement; and
WHEREAS, all acts and proceedings required by law necessary to make this Loan
Agreement, when executed by the Successor Agency and the City, the valid, binding
and legal obligations of the Successor Agency and the City, and to constitute this Loan
Agreement a valid and binding Agreement for the uses and purposes herein set forth in
accordance with its terms, have been done and taken, and the execution and delivery of
this Loan Agreement have been in al respects duly authorized.
NOW, THEREFORE, BE IT RESOLVED BY THE OVERSIGHT BOARD OF THE
SUCCESSOR AGENCY OF THE COMMUNITY REDEVELOPMENT AGENCY OF THE
CITY OF PALM SPRINGS AS FOLLOWS:
Section 1. The Oversight Board hereby finds and determines that the foregoing
recitals are true and correct, and incorporates them herein by reference.
Section 2. The Loan Agreement by and between the City of Palm Springs and the
Successor Agency of the Community Redevelopment Agency of the City of Palm
Springs, for the purpose of providing a cash flow loan to pay the Successor Agency's
enforceable obligations as described in the Recitals, is hereby approved.
Section 3. The Oversight Board hereby directs staff of the Successor Agency to
submit the approved Loan Agreement to the County Auditor-Controller, the State
Controller and the State Department of Finance; and post this Resolution on the
Successor Agency's website.
Section 5. This Resolution shall take effect five days of its adoption.
OVERSIGHT BOARD CHAIR
STATE OF CALIFORNIA )
COUNTY OF RIVERSIDE ) ss.
I, James Thompson, Secretary of the Oversight Board of the Successor
Agency of the Palm Springs Community Redevelopment Agency hereby certify that
Resolution No. was adopted by the Oversight Board at a Regular Meeting held
on the 30th of June, 2014, and that the same was adopted by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
JAMES THOMPSON
OVERSIGHT BOARD SECRETARY
APPROVED AS TO FORM:
Successor Agency Counsel
AMENDED AND RESTATED LOAN AGREEMENT
, 2014
Palm Springs, California
THIS AMENDED AND RESTATED LOAN AGREEMENT (herein referred to as the
"Loan Agreement"), made and entered into this _ day of 2014 (the
"Effective Date") by and between the SUCCESSOR AGENCY TO THE PALM SPRINGS
COMMUNITY REDEVELOPMENT AGENCY, CALIFORNIA, a public body, corporate and
politic("Successor Agency"), and THE CITY OF PALM SPRINGS, a municipal corporation
and charter city ("City").
RECITALS
WHEREAS, under the Redevelopment Dissolution Act (AB 1X 26), the term "successor
agency" was defined to refer to the Dissolved RDA's Sponsoring Community (the city,
county or city and county that formed the Dissolved RDA), unless that Sponsoring
Community adopted a resolution electing not to serve in that capacity; and
WHEREAS, AB 1484 redefines "successor agency" to mean the successor entity to the
Dissolved RDA pursuant to Health and Safety Code Section 34173 and that"a successor
agency is a separate legal entity from the public agency that provides for its governance;"
and
WHEREAS, the City of Palm Springs is the successor entity to the Community of the
Community Redevelopment Agency of the City of Palm Springs; and
WHEREAS, as a separate legal entity, the Successor Agency is not merged with the City,
the public agency that provides for the Successor Agency's governance (Section
34173(g)); and
WHEREAS, the City is not the financial "backstop" or guarantor of obligations of separate
government entities, regardless of its status as a Successor Agency; and
WHEREAS, Health & Safety Code Section 34171(d)(1)(F) recognizes as an "Enforceable
Obligation" of the Agency contracts or agreements necessary for the administration or
operation of the Successor Agency, including, but not limited to, agreements concerning
litigation expenses related to assets or obligations, settlements and judgments, and the
costs of maintaining assets prior to disposition; and
WHEREAS, Health and Safety Code Section 34173(h) provides that the City may loan or
grant funds to the Successor Agency for administrative costs, enforceable obligations or
project-related expenses and that receipt and use of these funds shall be reflected on the
ROPS or in the administrative budget subject to Oversight Board approval; and
WHEREAS, Health and Safety Code Section 34177.3(b) authorizes the Successor Agency
to create "Enforceable Obligations" to conduct the work of winding down the Dissolved
RDA; and
WHEREAS, Health and Safety Code Section 34178(a) authorizes the Successor Agency
to enter into agreements with the City upon obtaining approval of the Oversight Board; and
WHEREAS, in September, 2012, the Successor Agency commissioned a required Due
Diligence Review(DDR) of its Low and Moderate Income Housing Fund, which determined
the amount of unencumbered cash in the Low- and Moderate Income Housing fund, which
was then required to be remitted to the Riverside County Auditor-Controller pursuant to
Health and Safety Code Section 34179.6(f); and
WHEREAS, in November, 2012 the City remitted the amount of $7,701,693.13 to the
County, which was less than the amount demanded in the November 7, 2012 letter from
the California Department of Finance ("DOF"), which sought the additional amount of
$1,487,829 that the former redevelopment agency had loaned to a developer for a low-
moderate income senior housing project that in the DOF's opinion was voided by the
Redevelopment Dissolution Act; and
WHEREAS, the Successor Agency engaged the DOF in a "Meet and Confer" process and
is pursuing litigation to make its case as to the validity of the loan to the low-moderate
income senior housing developer, but so far has been unsuccessful and the litigation is
pending; and
WHEREAS, the Successor Agency received a copy of a communication between the DOF
and the Riverside County Auditor-Controller dated November 1, 2013, in which the DOF
instructed the Riverside County Auditor-Controller to withhold $1,487,829 from the
Redevelopment Property Tax Trust Fund ("RPTTF") distribution due to the Successor
Agency on January 2, 2014 for already approved Enforceable Obligations, in satisfaction of
the amount that DOF asserted was due under the DDR, nothwithstanding the pending
litigation of the matter;
WHEREAS, the Successor Agency had Enforceable Obligations to pay to third parties that
would have been unpaid if the amount described was withheld, and therefore, to avoid
non-payment of the Successor Agency's obligations, the City and the Successor Agency
entered into a Loan Agreement dated November 20, 2013 (the "RPTTF Loan") to provide
funds to the Successor Agency to offset the withholding,to be repaid to the City from future
RPTTF;
WHEREAS, on December 16, 2013, the Oversight Board approved the Successor
Agency's action to enter into Loan Agreement;
WHEREAS, the Oversight Board action was submitted to the the DOF for review and on
January 29, 2014, the Successor Agency received a communication from DOF stating that
the Loan was not approved, even though the funds had already been transferred to the
County to avoid disruption of the RPTTF payment on January 2, 2014, and such funds had
been distributed to taxing entities;
WHEREAS, the City and the Successor Agency wish to amend and restate the RPTTF
Loan to clarify that the purpose of the RPTTF Loan was to provide funds to the Successor
Agency to avoid disruption in the payment of its Enforceable Obligations by pre-funding the
amount the DOF claimed was due under the DDR, and thereby avoid default in its
obligations to third parties;
WHEREAS, in order to establish and declare the terms and conditions upon which the
Loan is to be made and secured, the Successor Agency and the City wish to amend and
restate the RPTTF Loan in full by entering into this Loan Agreement; and
WHEREAS, all acts and proceedings required by law necessary to make this Loan
Agreement, when executed by the Successor Agency and the City, the valid, binding and
legal obligations of the Successor Agency and the City, and to constitute this Loan
Agreement a valid and binding Agreement for the uses and purposes herein set forth in
accordance with its terms, have been done and taken, and the execution and delivery of
this Loan Agreement have been in al respects duly authorized.
NOW, THEREFORE, in consideration of the premises and the mutual agreements herein
contained, the parties hereto do hereby agree as follows:
ARTICLE I.
THE LOAN; ESTABLISHMENT OF FUNDS
Section 1.01 Authorization. The City hereby agrees to loan to the Successor
Agency, , the principal amount of One Million Five Hundred Thousand
Dollars ($1,500,000) all under and subject to the terms of this Loan
Agreement (the "Loan"). This Loan Agreement constitutes a continuing
agreement with the Successor Agency to secure the full and final payment of
the Loan, subject to the covenants, agreements, provisions and conditions
herein contained.
Section 1.02. Purpose. The Loan is made to enable the Successor Agency to
avoid default on previously-approved Enforceable Obligations to third parties
as a result of the DOF's direction to the Riverside County Auditor-Controller
to withhold $1,487,829 from the Successor Agency's January 2, 2014
RPTTF distribution,.
Section 1.03 Terms of the Loan. The Loan shall be deemed an Enforceable
Obligation of the Successor Agency and shall be paid in one installment
placed on a future Recognized Obligation Payment Schedule (ROPS)for the
period of January 1, 2015 through June 30, 2015 or each following period
until paid. The City would be paid in whole or in part from available cash flow
of the RPTTF after payment of debt service on the Successor Agency's
bonded debt, up to the amount of available RPTTF in such period, subject to
prior claims of other enforceable obligations.
Interest shall be calculated at the Local Area Investment Fund ("LAIF") rate.
Interest on the installment of the Principal of a Loan will be calculated on the basis
of a 360-day year of twelve 30-day months. Any portion of the installment of
principal and interest which is not paid when due will continue to accrue interest
from and including the Interest Payment Date with respect to which principal or
interest is payable to but not including the date of actual payment.
Any principal balance due may be repaid in full or in part without penalty in the
event and to the extent that the Successor Agency receives sooner repayment of its
loan in full or in part to the senior housing developer.
Loan Payments shall be payable by the Successor Agency to the City in
immediately available funds which constitute lawful money of the United States of
America.
The purpose of the Loan is to provide cashflow to the Successor Agency to meet its
enforceable obligations; therefore, repayment of the Loan is not subject to the
provisions of Health and Safety Code Section 34191.4.
1.04 Acceleration of Obligation. Upon the failure to make payment due under this
Agreement as and when the same becomes due and payable (whether by
extension, acceleration or otherwise), or any breach of any other promise or
obligation in this Agreement or in any other instrument now or hereafter
securing the indebtedness evidenced hereby, then, and in any of such
events, City may, at its option, declare this Agreement and the entire
indebtedness hereby evidenced, including, without limitation, all accrued
interest, to be immediately due and payable and collectible then or thereafter
as City may elect, regardless of the date of maturity, and notice of the
exercise of said option is hereby expressly waived by Successor Agency.
ARTICLE ll.
OTHER PROVISIONS
2.01 Severability. The unenforceability or invalidity of any provision or provisions of
this Agreement as to any persons or circumstances shall not render that provision
or those provisions unenforceable or invalid as to any other provisions or
circumstances, and all provisions hereof, in all other respects, shall remain valid and
enforceable.
2.02 Modifications. Neither this Agreement nor any term hereof may be waived,
amended, discharged, modified, changed or terminated orally; nor shall any waiver
of any provision hereof be effective except by an instrument in writing signed by
Successor Agency and City. No delay or omission on the part of City in exercising
any right hereunder shall operate as a waiver of such right or of any other right
under this Agreement.
2.03 No Waiver by City. No waiver of any breach, default or failure of condition
under the terms of this Agreement or the obligation secured thereby shall be implied
from any failure of the City to take, or any delay be implied from any failure by the
City in taking action with respect to such breach, default or failure from any prior
waiver of any similar or unrelated breach, default or failure.
2.04 Governing Law. This Agreement has been executed and delivered by
Successor Agency in the State of California and is to be governed and
construed in accordance with the laws thereof.
2.05 Oversight Board Approval and Department of Finance Review. All
actions taken by the Successor Agency are subject to review and approval by
the Oversight Board of the Successor Agency, constituted under Health and
Safety Code Section 34179, and all Oversight Board actions are subject to
review and approval of the DOF. No action taken by the Successor Agency is
deemed effective until five days after the approval by the Oversight Board, and
is still subject to review by the DOF.
SIGNATURES ON THE FOLLOWING PAGE
IN WITNESS WHEREOF, Successor Agency and the City have executed this
Agreement as of the date and year first above written.
"Successor Agency"
SUCCESSOR AGENCY TO THE PALM
SPRINGS COMMUNITY
REDEVELOPMENT AGENCY, a public
body
By:
Executive Director
ATTEST:
Assistant Secretary
APPROVED AS TO FORM:
Successor Agency Counsel
,,City"
THE CITY OF PALM SPRINGS, a
California Charter City
By:
City Manager
ATTEST:
City Clerk
APPROVED AS TO FORM:
City Attorney