HomeMy WebLinkAboutItem 02 Review and Discuss Final Reportand Recommendations from the Development Advisory Committee AGENDA ITEM SUMMARY Meeting Date: 2/13/2017
Meeting Type: Work Session
Staff Contact/Dept.: Jim Donovan / DPW
Staff Phone No: 541-726-3660
Estimated Time: 45 minutes
S P R I N G F I E L D
C I T Y C O U N C I L
Council Goals: Provide Financially
Responsible and
Innovative Government
Services
ITEM TITLE: REVIEW AND DISCUSS FINAL REPORT AND RECOMMENDATIONS
FROM THE DEVELOPMENT ADVISORY COMMITTEE
ACTION
REQUESTED:
Joint Work Session with the Development Advisory Committee (DAC) to review
and discuss the committee’s final report and recommendations.
ISSUE
STATEMENT:
The DAC has completed committee work on the priorities set by City Council to
improve efficiencies and make Springfield more competitive in the economic
development market. The DAC has prepared recommendations for City Council
consideration on Council’s top three priorities: (1) Site Review Applicability (2)
Project advocacy and communication (3) SDC Context.
ATTACHMENTS: 1 – Council Briefing Memo
2 - DAC Final Report to City Council
3 – DAC Advocacy Tracking Table
4 – PC/CC Adopted Mission and Priorities
In 2012 members of the Developer Input Process Joint Work Team completed work
on a limited set of development code amendments and requested that the City
Manager and City Council consider a broader review of Springfield’s development
procedures and fees. The City Council authorized creation of the Development
Advisory Committee’s public improvement procedures, operating guidelines and
mission statement in 2014. The attached final report from the Development
Advisory Committee documents the DAC’s work products and highlights the
following key recommendations Council consideration:
The City Council should direct staff to expand the MDS Major application process
The City Council should direct staff to develop a plan for a major code
revision/update to include an objective ministerial process for proposed projects as
detailed in this report.
The City Council should adopt the attached Advocacy/Communication Matrix as a
status report on the City development process and should direct staff to develop a long
range plan to monitor progress and implement new processes as described in this
report.
The City Council should direct staff to review the use of SDC fees to provide
incentives for some developments and annually review the impacts of the annual CIP
on the SDC fees.
The City Council should direct staff to evaluate options to reduce City costs through
the use of technology and other methods. Those savings should be reflected in the
City’s revised fee schedule.
A Council Briefing Memo from staff on current efforts to implement these
recommendations is also attached.
M E M O R A N D U M City of Springfield
Date: 2/2/2017
To: Gino Grimaldi COUNCIL
From: Anette Spickard, DPW Director
Jim Donovan, Planning Supervisor
BRIEFING
Subject: Development Advisory Committee Report MEMORANDUM
ISSUE: The DAC has completed committee work on the priorities set by City Council to
improve efficiencies and make Springfield more competitive in the economic development
market. The DAC has prepared recommendations for City Council consideration on the top three
priorities set by City Council which were: (1) Site Review Applicability (2) Project advocacy and
communication (3) SDC Context (System Development Charges). This memo is submitted as
background and a current status report to assist Council consideration of the DAC’s
recommendations.
COUNCIL GOALS/
MANDATE:
Provide Financially Responsible and Innovative Government Services
BACKGROUND: In 2012 members of the Developer Input Process Joint Work Team
completed work on a limited set of development code amendments and requested that the City
Manager and City Council consider a broader review of Springfield’s development procedures
and fees. In response to these concerns the City Council authorized creation of the Development
Advisory Committee. In 2014 the City Council and Planning Commission approved the new ad
hoc committee’s public improvement procedures, operating guidelines, and mission statement.
Council worked with the DAC to identify the following top priorities for the committee’s work:
(1) Site Review Applicability (2) Project advocacy and communication (3) SDC Context (System
Development Charges).
As part of the DAC’s work on the priorities set by City Council, below is a final status report on
each of the Committee’s top 3 priorities:
Staff summary of DAC priority items:
Site Review Applicability (Ministerial Site Plan) – As a result of the February 8, 2016
work session, the DAC finished its work on the expansion of the current Minimum
Development Standards as a ministerial site review procedure. Staff received approval of
the proposed Springfield Development Code amendments from the Springfield Planning
Commission, Oregon Department of Land Conservation and Development (DLCD), and
the expanded standards were adopted by City Council, which became effective on
December 21, 2016.
Project Advocacy & Communication - The DAC’s review of project advocacy
improvements was extensive and has been recorded in tabular and narrative form. The
Committee identified issues and opportunities for examination with staff to target
possible process improvements or additional resources that may be required to implement
the recommendations for improvement. During this review the Committee has noted
numerous communication and advocacy improvements already in practice in DPW as a
result of the Committee and staff’s work. The staff has worked with the Committee in
preparing the final version of the advocacy table which identifies 25 items with
individual statuses, action to be taken, resources, and priority. Attachment 2 of this AIS
Attachment 1 Page 1 of 2
MEMORANDUM 2/9/2017 Page 2
packet. The results of that tabular data are summarized below:
“A” Priority / No Action Items: These items were determined to be the highest
priority and of the sixteen, fifteen were noted as items already in practice. The
conclusion of the Committee was to continue these practices and continue to
emphasize these practices with existing and new staff. The one item of the sixteen
that was placed as an “A” priority and is not already in practice is electronic plan
review, which staff is currently evaluating and testing software.
“B” Priority / Action Needed: These items were determined to be a medium
priority and were 6 of the twenty five total items identified. These items were
noted as practices or process improvements to be evaluated and would require
dedication of medium to high staff time for implementation.
“C” Priority / Action Needed: These items were determined to be a lower priority
and were 3 of the twenty five total items identified. These items were noted as
policy related items, which require more staff time and are typically longer range
goals for implementation in city wide initiatives such as a code update project.
SDC Context – During the course of the DAC’s work, methodologies for transportation
SDC’s were updated and adopted by City Council. This process involved a separate
advisory committee, which included the vice chair of the DAC. The DAC reviewed the
standard timelines and public involvement procedures for utility, building, planning and
other fees affecting the development process. Recommendations on future fee projects
have been included in the final DAC report to City Council which is included in
Council’s packet as Attachment 1.
RECOMMENDED ACTION: Staff supports the Committee’s recommendations forwarded for
consideration and inclusion in development review policy, procedures and customer service
updates. DPW staff will continue to implement customer service improvements and work with
Council to find the appropriate time and process for implementation of code and policy
recommendations. Staff will provide follow up reports for Council and future DAC Committees
as directed.
Attachment 1 Page 2 of 2
Report to Springfield City Council
Development Advisory Committee – October 2016
Executive Summary
In 2012 members of the development community in Springfield raised concerns to the City
Manager regarding the development processes within the City. In response to these concerns
and at the recommendation of the City Manager, the City Council created the ad hoc
Development Advisory Committee.
The Committee identified the following issues to be addressed:
1.Site Review Applicability – The City of Springfield requires Site Plan Review for projects
but does not provide an option for a ministerial review under which a larger or more
complex development proposal would objectively meet all Code criteria – thus providing
for certainty of consent as well as reduced cost and time.
2.Project Communication and Advocacy – While developers understand the need for staff
to remain objective regarding all proposed projects, at times internal staff conflicts arise
which delay project application reviews and approvals.
3.System Development Charges – The Committee understands the SDC process and
methodology for development of fees however had suggestions regarding use of the
charges to encourage specific project types and locations.
4.Fees – The Committee had suggestions on options which might be implemented to
improve overall efficiencies in the City processes and developer costs.
The Development Advisory Committee has met on a regular basis for four years to discuss
issues and develop recommendations for consideration by the City Council. The Committee has
developed twelve recommendations overall. The following summarizes these recommendations.
The City Council should direct staff to expand the MDS Major application process
The City Council should direct staff to develop a plan for a major code revision/update
to include an objective ministerial process for proposed projects as detailed in this
report
The City Council should adopt the attached Advocacy/Communication Matrix as a
status report on the City development process and should direct staff to develop a long
range plan to monitor progress and implement new processes as described in this
report.
The City Council should direct staff to review the use of SDC fees to provide incentives
for some developments and annually review the impacts of the annual CIP on the SDC
fees.
The City Council should direct staff to evaluate options to reduce City costs through the
use of technology and other methods. Those savings should be reflected in the City’s
revised fee schedule.
Attachment 2 Page 1 of 8
Background
In 2012, members of the development community in Springfield raised concerns to the City
Manager regarding the development process. The concerns focused on the length of time
required for the development process, uncertainty regarding the decision process and the cost
of development. In response to these concerns and at the recommendation of the City Manager,
the City Council created the ad hoc Development Advisory Committee in July 2012.
Their directive to the Development Advisory Committee was to:
1.Review the customer service process and requirements of land use and economic
development in the City of Springfield to be competitive in attracting development;
2.Provide the Planning Commission and City Council with recommendations on
improving this process and outcome consistent with the Council goal of promoting
and enhancing our hometown feel while focusing on livability and environmental
quality;
3.Provide a robust forum and venue for citizen participation in this process.
The tasks completed during the first few months included a thorough discussion of the
Committee members’ concerns, development of a process for the Committee work and a
ranking of the issues to be addressed. The Committee members determined that the issues
ranked as follows:
1.Site Review Applicability – Initial discussions of this topic included a variety of potential
options to the current process. Proposals included a range of options from eliminating
Site Plan Review if the zoning already allows the use to requiring site plan review in only
a few cases.
2.Project Advocacy and Communication – Committee members agreed that the manner
and level of communication between staff and the public had improved in recent months
however there were some suggestions for further improvement. In addition, while the
members understood that the staff had to remain objective regarding proposed projects,
at times during the development process internal conflicts sometimes arise between City
departments. The Committee therefore suggested that a method for addressing these
internal conflicts be created.
3.System Development Charges – The Committee members posed questions about use
of SDC funds – not specifically about the methodology. The questions regarding uses
included
o Incentives – whether SDC rates and revenues should be used to encourage
development in specific neighborhoods, on specific types of properties or for
specific enhancements to public infrastructure
o Equity – whether SDC revenue should be allocated specifically for projects
proximate to where they are generated
o Credits – whether the City might explore options for developers to sell or buy
SDC credits.
Attachment 2 Page 2 of 8
o Capital Improvement Plan - Committee members also asked whether the Capital
Improvement Plan (CIP) should be reviewed to identify projects as “needed”
(e.g. new streets) or “desirable” (e.g. increasing the density of street trees).
4.Fees – Committee members indicated interest in reviewing how to use fee revenues to
improve efficiencies while reducing costs. Examples from the Committee included:
o Adjust the technical fee based on electronic submittal vs hard copy submittal
o Reduce fees for digitally signed plans
o Tracking staff time for work on projects to allow for well-prepared submittals to
have a reduced charge
5.Planning Application Fees – The Committee members had specific concerns regarding
the planning application fees. The questions in this category were related to item #4
above.
6.Incentivizing the Development of Brownfields and Redevelopment – The Committee had
suggestions regarding the ways in which the City might encourage the development of
brownfields as well as encourage new and innovative enhancements to public
infrastructure. Many of the ideas are consistent with items #3, #4 and #5 above.
These priority topics were presented to the City Council in Spring 2013. Based on this
discussion, the Development Advisory Committee began their work. Since that time the
Committee has met on a regular basis – at times meeting twice a month. Our discussions are
represented in the following Findings and Recommendations.
Findings and Recommendations
1.Site Review Applicability
The Committee discussed this issue at length. The concern by Committee members was
that every project developed within Springfield must undergo a form of site plan review
while in the experience of Committee members, in the nearest neighboring jurisdiction
many proposed developments are allowed to move forward without a site review.
Committee members believed that this difference places Springfield at a disadvantage
and therefore determined to explore how the City of Springfield might develop a
ministerial process for Site Review. Under the ministerial process, a potential developer
would need to present a project which objectively meets all Code criteria. Meeting these
criteria would result in approval of the project by staff without a public notification
process.
Findings:
o Very minor projects currently may need only a very simple Counter
Determination or a Land Use Compatibility Statement while Minor additions or
changes to an existing development (less than 5000 square feet) may be allowed
Attachment 2 Page 3 of 8
to submit under the MDS minor review, and larger (less than 25,000 square feet)
may submit under MDS major review. Other proposed projects including,
“change of use”, must submit under the standard Site Plan Review process.
o Under the current Site Plan Review process, the City staff can work with the
applicant to develop alternate methods to address Code requirements; public
notice is required as part of the Site Plan Review process
o Under a proposed ministerial process, staff would not have the flexibility to
develop alternate methods to meet Code requirements and public notice would
not be required because the proposed project would be in clear compliance with
all Code criteria
o While the ministerial process can be described as being based on clear,
objective standards, the development of standards to meet this clear and
objective standard is difficult.
o According to the City Attorney, regardless of the type of process used (ministerial
or discretionary) a project could still potentially be subject to an appeal from
opponents of the development
Given these Findings, the Committee elected to proceed with the task of reviewing the
Code and developing proposed modifications which would meet the “clear and objective”
standard. Over several months the Committee drafted proposed Code language which
was focused on eliminating any subjectivity. During the course of this work it became
clear that there were several code sections which required technical expertise to draft.
These code sections included transportation, storm water, sanitary sewer and fire and
life safety standards. City staff recommended that to include these standards in a
ministerial review would require department staff to develop new Code language. In
addition, all Code sections would need to be reviewed by the City Attorney in order to
verify that the new sections were objective in order to meet the ministerial standard.
At this point, staff encouraged the Committee to explore the option of expanding the
MDS Major category of site review in lieu of creating a new option of complete ministerial
review. Staff suggested that expanding the MDS major to 50,000 square feet might be a
process that could be implemented more quickly and would likely be less susceptible to
challenge by opponents.
Staff further suggested that MDS Major applications were reviewed by the City in an
average of 4.7 weeks during the period of January 2012 to mid-September 2014, while
Site Plan Review applications were reviewed by the City in 5.1 weeks in the period
ending November 2014.
While members of the Committee appreciated the timeline for City review, some
members of the Committee indicated that the concerns expressed at the beginning of
the process were not addressed by Staff’s proposal. Cost, time and certainty are all
issues which caused concerns for developers. While the review by City staff may
Attachment 2 Page 4 of 8
happen quickly, this timeline does not take into account the time and cost associated
with the preparation of applications. Moreover the issue of certainty cannot be
overlooked.
For example, a developer may want to purchase or lease a site for development. Before
finalizing the purchase or lease, the developer needs to know that the type of
development proposed can be accommodated on the site. This goes to the issue of
certainty. If it takes 6 – 8 weeks to develop applications and then 5 weeks for City
review, the developer must wait 11- 13 weeks to be certain that the development
proposal can proceed. Conversely, if a potential developer understands that under a
ministerial process, he/she can proceed with certainty under a straightforward process
that strictly follows Code requirements and allows no discretion by the City, then the
developer can understand his/her options before paying for development of applications.
A new ministerial process would thus reduce the cost and time required for preparation
of simplified applications in addition to the time required for City review. Additionally, the
ministerial process would offer a high level of certainty that is not typically the case in the
existing Site Plan Review process. Expanding the MDS Major process would not seem
to address the current disadvantage which exists when developers compare cost, time
and certainty for development in Springfield.
In February 2016 the City Council received information on the creation of the new
ministerial standard and the expansion of the MDS Major application process. At that
time, the Council directed the staff to proceed with the expansion of MDS Major and to
consider a future option for the development of a ministerial process.
o An expansion of MDS Major will likely increase the number of projects which can
be reviewed in a more expedited process.
o A ministerial process will likely improve the time, cost and certainty issues (while
meeting Code development standards) for developers who are considering
Springfield among other locations for development. Such a process will increase
Springfield’s competitiveness for development.
o The expansion of the MDS Major option to include projects up to 50,000 square
feet likely can be implemented quickly.
o The development of a ministerial process will require a more significant Code
review and Code modifications.
Recommendations
o It is recommended that the City Council provide direction to staff to complete
tasks necessary to expand the MDS Major application process to include projects
up to 50,000 square feet. Staff should develop a timeline for completion of this
work. The timeline should include a report to Council in one year to describe the
Attachment 2 Page 5 of 8
implementation process together with information on the type and number of
projects which have utilized the process.
o It is recommended that the City Council consider implementation of a major code
revision/update process which can address the development of a ministerial
process as well as other Code updates.
o With the work of the ad hoc Development Advisory Committee nearing
completion, it is recommended that the City Council appoint a new ad hoc group.
The new group would function as a visioning group to work with staff on the Code
revision/update process and be given the following tasks:
Work with staff to develop a vision for the new process
Meet with staff on a quarterly basis as they draft Code language
which addresses the vision
Focus on the concerns of time, certainty and cost as related by
the development community
2.Project Communication and Advocacy
Committee members agreed that the manner and level of communication with staff has
improved in recent months. The Committee emphasized that these improved processes
must continue and that a monitoring process should be established to demonstrate this.
It is important to note that the Committee also provided suggestions for further
improvement.
While acknowledging the improvements, the Committee also developed a broad list of
issues which came from experiences of members and colleagues. The list of items was
reviewed in detail during a series of meetings and staff provided information on the
manner in which some issues are already being addressed as well as the potential for
making further changes.
The Committee has developed a matrix of all items and grouped them in the following
categories:
A. Items which are being addressed as an ongoing practice
B. Items which will require minor action by staff and a change in practice
C. Items which will require a medium to high level of staff time and may require
policy and/or code actions
D. Items which were suggested but which cannot be accomplished due to legal
restraints
Findings
o Items in Category A were identified by the development community at initial
meetings in 2012 and City staff have addressed many of these
o Items in Category B are items which can be addressed with a limited amount of
staff work
Attachment 2 Page 6 of 8
o Items in Category C require a high level of staff work but would improve the
development process and increase Springfield’s competitiveness
Recommendations
o It is recommended that the City Council accept the Advocacy/Communication
Matrix as a status report on the City development process.
o It is recommended that the City Council direct staff to establish a process to
monitor the ongoing practice of these items.
o It is recommended that the City Council direct staff to include Category B items
as priority tasks and to develop performance indicators to monitor effectiveness
of implemented changes.
o It is recommended that the City Council direct staff to review the Category C
items and to develop a strategic plan which incorporates these items into a long
range plan.
3.System Development Charges/Incentives for Brownfield Developments
The Committee discussed the use of System Development Funds for City projects.
Findings
o The rates for System Development Charges are reviewed on a regular basis.
o The methodology used to develop rates is completed using a public process
o The projects used in the SDC methodology are included in the City’s Capital
Improvement Projects lists
Recommendations
o It is recommended that the City Council direct staff to consider how SDC
revenues might be targeted to encourage developments in specific
neighborhoods or for specific types of projects
o It is recommended that the City Council consider the use of SDC exemptions as
an incentive for the development of brownfield sites.
o It is recommended that the City Council encourage new and innovative
enhancements to public infrastructure.
o It is recommended that the City Council include a summary SDC impact review
each year at the time the CIP is reviewed. The summary would include
information regarding how much of the total SDC fund is allocated to each project
in the CIP- allowing a more specific understanding of how each project affects
the available SDC funds.
Attachment 2 Page 7 of 8
4.Fees/Planning Application Fees
The Committee discussed suggestions regarding how fees might be adjusted to improve
overall efficiencies. For example, members suggested that planning applications as well
as building plans could be submitted online to reduce cost and time. In addition,
members suggested that applications which are complete when submitted could be
charged a lower fee than those applications which require multiple submittals.
Findings
o Periodically the City completes a review of fees to evaluate how the Planning and
Public Works fee schedules reflect City costs. Staff is currently planning to
commence this process to review fees.
o Currently proposed developments are charged the same fee for applications
without regard to the application complexity or number of revisions/reviews
required.
Recommendations
o It is recommended that the City Council direct staff to review options for fee
revisions. For example, in lieu of a standard fee for all applications, the City could
charge on an hourly basis for the review of applications.
o It is recommended that the members of Development Advisory Committee be
included in the Fee Review Project.
Attachment 2 Page 8 of 8
A No Action/ongoing practice
B Action Needed (will require some staff time
and/or a change in practice)
C Action Needed (will require medium to high
staff time and possible policy/code changes)
Item Number &
Status Advocacy Item Action to be Taken Action Resources Estimated Timeframe Priority
1 Electronic review system accessible by all
reviewers and public
Blue Beam electronic plan
review currently being
tested
Process Improvement New
Software/Upgrades N/A A
2
During review provide general guidance for
how to adjust per staff comments but don't
provide suggested design
N/A existing practice N/A N/A A
3 Keep comments restricted to code items
and include code references N/A existing practice N/A N/A A
4 Counter staff is someone with experience N/A existing practice
Re-filled POD and
Senior Planner
positions
N/A A
5 Continuous staff assignments starting at
DIM N/A existing practice
Re-filled POD and
Senior Planner
positions
N/A A
Status/Priortiy Key
DEVELOPMENT ADVISORY COMMITTEE ADVOCACY ITEMS
Attachment 3 Page 1 of 5
Item Number &
Status Advocacy Item Action to be Taken Action Resources Estimated Timeframe Priority
6 Applicant/public able to submit written
questions to weekly staff meetings
Applicants can currently
call or email assigned
project staff with
questions, which are either
answered at time of
request or reviewed with
staff supervisor during one
of two weekly meetings
and response is then
communicated to applicant
existing practice N/A N/A A
7
Planner empowered to resolve conflicts
between city departments/applicant and
act as single voice for the city
N/A
existing practice which was
implemented during
department re-organization
N/A N/A A
8 Documentation of counter meetings
Staff currently maintains a
log of all counter questions
associated with each
property
existing practice N/A N/A A
9 Applicant can request written response or
teleconference for Pre-Submittal Meeting
Already in progress / need
to add this option to
application
existing practice N/A N/A A
Attachment 3 Page 2 of 5
Item Number &
Status Advocacy Item Action to be Taken Action Resources Estimated Timeframe Priority
10
Send Draft Conditions Of Approval, Staff
Reports, and Conditions to applicant for
feedback
N/A existing practice N/A N/A A
11 Expedited review with higher fee N/A existing practice N/A N/A A
12 Find all review comments on first round
(PIP & Building Permits)
Already in Progress /
reminder to continue this
practice (Asperational)
existing practice N/A N/A A
13
Understand give and take between what
would be ideal for the city and what is
really needed
Already in Progress /
reminder to continue this
practice during staff
meetings (possibly memo
to staff or poster)
existing practice N/A N/A A
14 Notify applicants whose projects are about
to expire
already in progress /
reminder to continue
process
existing practice N/A N/A A
15 Call applicant if it appears that portion of
bldg permit application missing
Already in Practice
(checklists are available on-
line and at the front
counter)
existing practice N/A N/A A
Attachment 3 Page 3 of 5
Item Number &
Status Advocacy Item Action to be Taken Action Resources Estimated Timeframe Priority
16
Salem uses Bldg Code "use" instead of
Planning code "use" to trigger Site Plan
Review - please don't do this
Already in practice / not a
process the City uses N/A N/A N/A A
17 Notification of Code Amendments
Quality Code (qcode)
maintains the city's
Development and
Municiple Code, while
there is CodeAlert and
Ordinance List links - is
there an email alert
process or list for
notifications?
Process Improvement staff time B
18
User friendly on-line copies of existing and
past applications. Place documents in
order as there are presented in the
application. Should be a structured format
and searchable
already in progress/Offer
Development Community
Training? (need to make
search tools more
accesable and look at
linking documents)
Practice/Process
Improvement
Staff Time / IT /
software?B
19 Open DIMs to more than 5 questions
Change to the Application
(note time restraints for
meeting and have
applicant priortize
questions or change to 5
areas)
Process Improvement staff time B
Attachment 3 Page 4 of 5
Item Number &
Status Advocacy Item Action to be Taken Action Resources Estimated Timeframe Priority
20 Salem only needs 2 sheets for planning
application instead of multiple
ongoing streamlining
process (look at Salem's
application)
Process Improvement Staff time B
21 Streamline annexation process
look at streamlining
process (meetings and
paperwork)
Process Improvement Medium Staff Time B
22 Building Board of Appeals status 2.550-
2.574
BBA is in the SMC and
needs to be evaluated by
council
Process Improvement medium to high staff
time B
23 Review policies and procedures of current
PIP insurance requirements
DAC made motion and
motion was approved for
Staff to look at process
with legal and executive
team to see if 3 party
contract could be
eliminated or modified to
improve review times.
(remove consulting
engineer from contract)
Policy
Medium to High Staff
Time (currently under
discussion)
C
24
Check code for conflicts/lack of clarity with
a long range goal of re-examing the code
structure
Staff keeps running list of
code conflicts, continue to
track items and update
codes.
Policy
Medium to High Staff
Time (city wide
initiative or select code
process and
procedures)
C
25 PIP requirement, deffered until needed,
utilize proportionate share
Staff to research, Look into
a phased PIP approach,
check into control strips
and late comers
agreements/payment
tracking.
policy medium to high staff
time (legal and code)C
Attachment 3 Page 5 of 5
Attachment 4 Page 1 of 1