City Council Item Report

City of Surprise — Special (2026-02-05)

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City Council Work Session
October 5, 2021
Land Development Ordinance 
Zoning Text Amendment
FS21-413

ARTICLE 2 – PROCEDURE TYPES AND 
SUBMITTALS
102-2.1
Procedure Types
B.
The following Table 102-2a describes the 
level of public outreach required, decision-
making authority, and the appeal authority 
for the applications processed and the 
approvals that may be granted under this 
Ordinance.
CHAPTER 102 - REVIEW PROCESS AND APPLICATIONS

ARTICLE 3 – PUBLIC OUTREACH AND PUBLIC NOTIFICATION
102-3.2
Neighborhood Meetings 
A.
This is conducted by the applicant and/or developer.
1.
A Neighborhood Meeting is required for all Type 3 Applications that require a 
public hearing, Preliminary plats, and other applications as determined during the 
Concept Review Meeting. All neighborhood meetings shall be scheduled at a time 
and publically accessible location near the project that provides reasonable 
opportunity for assemblage of adjacent landowners, other affected publics, and 
the applicant to discuss and express their respective views upon the development 
request. The applicant shall secure a time and location near the proposed project 
according to the following requirements:
CHAPTER 102 - REVIEW PROCESS AND APPLICATIONS

ARTICLE 6 – TYPE 3 APPLICATION AND REQUESTS
102-6.3 Conditional Use Permits
J.  THE DECISION BY THE PLANNING AND ZONING COMMISSION TO APPROVE 
OR DENY A CUP MAY BE APPEALED BY ANY PERSON AGGRIEVED TO THE CITY 
COUNCIL AS SET FORTH IN SECTION 2-301(f) OF THE SURPRISE CITY CODE.
CHAPTER 102 - REVIEW PROCESS AND APPLICATIONS

CHAPTER 105 – BUILDING AND BUILDING REGULATIONS
ARTICLE 2 – TECHNICAL CODES  
A.
2018 2012 International Building Code. 
B.
2018 2012 International Residential Code. 
C.
2012 International 2017 NATIONAL Electrical Code. 
D.
2018 2012 International Mechanical Code. 
E.
2018 2012 International Plumbing Code. 
F.
2018 2012 International Fuel Gas Code. 
G.
2018 2012 International Energy Conservation Code. 
H.
2006 International Property Maintenance Code. 
I.
2018 2012 International Existing Building Code. 
J.
2018 2012 International Fire Code. 
K.
2018 INTERNATIONAL GREEN CONSTRUCTION CODE
A certain public record entitled "2016 Amendments to the 2012 International Codes," dated September 20, 2016, 
specifically amends the 2012 building code, residential code, mechanical code, plumbing code, fuel gas code, energy 
conservation code, existing building code, and fire code. 
ORDINANCE 2019-31 INCLUDES A CERTAIN PUBLIC RECORD ENTITLED “LOCAL AMENDMENTS TO THE 2018 
INTERNATIONAL CODES AND THE 2017 NATIONAL ELECTRICAL CODE,” DATED NOVEMBER 14, 2019, WHICH 
SPECIFICALLY AMENDS THE 2018 BUILDING CODE, RESIDENTIAL CODE, FIRE CODE, PLUMBING CODE, MECHANICAL 
CODE, FUEL GAS CODE, ENERGY CONSERVATION CODE, EXISTING BUILDINGS CODE, GREEN CONSTRUCTION CODE, 
AND THE 2017 NATIONAL ELECTRICAL CODE. 
State Law reference — Adoption by reference, A.R.S. § 9-801 et seq.; state plumbing code, A.R.S. § 41-619.

CHAPTER 106 - ZONING AND USE STANDARDS
ARTICLE 1 – IN GENERAL 
106-1.7
Development Standards and Encroachments
C.
Lot coverage. Measured by the total square footage of structures used for protection or 
shielding from the elements or weather divided by the square footage of the lot.   THE 
PERCENTAGE OF THE LOT AREA COVERED BY A BUILDING AND/OR OTHER ALLOWED 
ROOFED STRUCTURE USED FOR PROTECTION OR SHEILDING FROM THE ELEMENTS OR 
WEATHER.

CHAPTER 106 - ZONING AND USE STANDARDS
ARTICLE 1 – IN GENERAL

CHAPTER 106 - ZONING AND USE STANDARDS
ARTICLE 3 – SURPRISE HERITAGE DISTRICT 
(SHD) ZONING DISTRICTS
106-3.2
Design 
and 
Development 
Standards in the SHD Zoning district. 
B.
Development Standards. 
1.
The development standards 
shown in Table 106-3a and 
Table 106-3b below are 
applicable to all properties 
within the SHD.  These 
tables identify the 
development standards for 
properties zoned into one 
(1) of the overlay zones.

CHAPTER 106 - ZONING AND USE STANDARDS
ARTICLE 10 – USE SPECIFIC STANDARDS
106-10.3
Accessory Uses and Structures.
Development Standards. Table 106-10b below identifies 
the dimensional standards required for an 
accessory structure.
Note 3. The height of an accessory structure shall not exceed nine feet (9’) as 
measured at the five-foot (5’) setback line.  The height of the accessory 
structure may increase at a ratio of one foot vertical for every one foot 
horizontal (1’:1’) as measured relative to the property line to a maximum 
height of fifteen feet (15’) (See Figures 106-10a 106-10b)
K.
Accessory structures 
for multi-family, mixed 
use, 
commercial, and employment projects shall be included as 
part of an approved site plan and comply with setbacks of 
the zoning district.

CHAPTER 106 - ZONING AND USE STANDARDS
ARTICLE 10 – USE SPECIFIC STANDARDS
106-10.23
Home Occupation.
C.
The following uses have a pronounced tendency, once started, to rapidly increase beyond the limits 
permitted for home occupations and thereby impair the use and value of a residentially zoned area 
for residential purposes.  Therefore, the following uses shall not be permitted as home occupations: 
(this list is not all inclusive)
11.
Sales of weapons or ammunition, retail sales in general, banks, credit unions or payday 
lending 
106-10.31
Outdoor Display and Sales Areas.
Other retail businesses may be permitted outdoor display areas as an accessory use provided:
6.
Permanent outdoor display areas may be permitted as part of an approved site plan for C-3, I-
1 AND I-2 Zoning districts.

CHAPTER 106 - ZONING AND USE STANDARDS
ARTICLE 10 – USE SPECIFIC STANDARDS
106-10.40
Self-storage Facilities.
A.
Self-storage facilities may be appropriate in the Neighborhood, Commerce and Office, and 
Employment Character Areas of the General Plan, except expect may be considered incompatible in 
areas within the Transit-Oriented Development (TOD) Strategic Plan and Scenic Lands Sub Area.  
B.
There are four THREE different “types” of self-storage facilities; each with different land use needs 
and varying degrees of regulations.
1.
“Garage style” with single story buildings that allow customers to drive directly up to the front 
of each individual roll-up door storage unit/bay.
2.
“Multi-story/climate controlled” in a single building providing access to the individual units 
from an interior hallway within the building.
3.
“Parking style” allows outdoor storage of vehicles, boats, RV’s, and trailers.  This type can be a 
standalone facility or combined with either the garage style or multi-story climate controlled 
facility. 
4.
“Portable container” is the remote facility where small roll-off containers are stored after they 
have been delivered to and picked up from the customer’s location; with no public or 
customer access to the storage facility.

CHAPTER 106 - ZONING AND USE STANDARDS
ARTICLE 10 – USE SPECIFIC STANDARDS
106-10.40
Self-storage Facilities. (Continued)
D.
Regardless of the “type” the minimum size of any storage facility site shall be one acre (1 ac).  The 
site should be limited to a maximum of two acres (2 ac) when adjacent to a residential zoning 
district or a residential use. 
H.
Outdoor storage shall be limited to boats, trailers, or recreational vehicles.  The storage of these 
vehicles in conjunction with either the garage style or the “multi-story/climate controlled” storage 
facility shall be limited to a maximum fifteen percent (15%) of the net site area.  All outdoor vehicle 
storage shall be located in the interior of the site and shall be screened from view from surrounding 
properties.  Parking style and Garage style storage facilities shall provide an eight foot (8’) 
decorative view-obscuring wall to screen the entire storage area.  There shall be no storage of 
abandon, damaged, or junked boats, trailers or recreational vehicles in any storage facility.
106-10.47
Vehicle fueling stations
O.

CHAPTER 107 DESIGN AND DEVELOPMENT REGULATIONS
ARTICLE 2 – LANDSCAPE AND SCREENING REGULATIONS
107-2.2
REPAIR AND Maintenance RESPONSIBILITIES 
A.
The REPAIR AND maintenance of all landscaping on the property or abutting right-of-way, landscape 
strip, open space, buffer areas, setbacks, parks, retention basins, or pathways shall be the 
responsibility of the property owner. THE CITY OF SURPRISE SHALL NOT HAVE ANY REPAIR OR 
MAINTENANCE RESPONSIBILITIES ON PRIVATELY OWNED LANDSCAPING, UNLESS BY SEPARATE 
AGREEMENT.; unless otherwise accepted by the City for maintenance purpose. Maintenance of 
medians and median landscaping on arterial roads, or on parkways, shall be the responsibility of the 
city after acceptance.

CHAPTER 107 DESIGN AND DEVELOPMENT REGULATIONS
ARTICLE 2 – LANDSCAPE AND SCREENING REGULATIONS
107-2.2
REPAIR AND Maintenance RESPONSIBILITIES 
M.
Sidewalks, medians, and landscape strip construction and the landscaping within these areas shall adhere to the 
Property Maintenance regulations as referred to in Chapter 105 of the LDO AND THE NEIGHBORHOOD 
PRESERVATION ORDINANCE. THE OWNER OF A PARCEL OF REAL PROPERTY OR RESPONSIBLE PARTY IN CONTROL OF 
ANY LAND ABUTTING A COLLECTOR OR LOCAL STREET RIGHTS-OF-WAY, MEDIANS, SIDEWALKS, OR ALLEYS SHALL BE 
RESPONSIBLE FOR THE LANDSCAPING AND MAINTENANCE IN THESE AREAS. THE AREAS REQUIRED TO BE 
MAINTAINED PURSUANT TO THIS SUBSECTION ARE AS FOLLOWS: 
1.
ANY PORTION OF A STREET, WHICH HAS BEEN OPENED FOR PUBLIC USE, BETWEEN THE CURB LINE, OR IF 
THERE IS NO CURB LINE THE EDGE OF PAVEMENT, AND THE ABUTTING PROPERTY LINE INCLUDING 
LANDSCAPING STRIPS AND SIDEWALKS. 
a.
THE CITY SHALL NOTIFY THE OWNER WHEN LANDSCAPING IS FOUND IN VIOLATION OR A SIDEWALK IS 
FOUND TO BE DEFECTIVE, UNSAFE OR HAZARDOUS, AS DETERMINED BY THE CODE ENFORCEMENT 
DIVISION OF THE COMMUNITY DEVELOPMENT DEPARTMENT.
b.
WHENEVER ANY OWNER HAS BEEN NOTIFIED TO CORRECT A LANDSCAPE VIOLATION OR 
RECONSTRUCT OR REPAIR ANY SIDEWALK, THE CITY MAY PROCEED TO MAINTAIN, RECONSTRUCT, OR 
REPAIR THE ISSUE THREE (3) DAYS AFTER SUCH NOTICE EXPIRATION, AND THE COST OF SUCH 
MAINTENANCE, RECONSTRUCTION OR REPLACEMENT SHALL BE PAID BY THE OWNER OF SUCH 
ABUTTING PROPERTY. 
c.
THE CITY SHALL NOTIFY THE OWNER OF SUCH ABUTTING PROPERTY OF THE AMOUNT DUE FOR THE 
MAINTENANCE, RECONSTRUCTION, OR REPLACEMENT OF SUCH LANDSCAPING OR SIDEWALK AND 
THE OWNER SHALL THEREAFTER PAY TO THE CITY.

CHAPTER 107 DESIGN AND DEVELOPMENT REGULATIONS
ARTICLE 2 – LANDSCAPE AND SCREENING REGULATIONS
107-2.2
REPAIR AND Maintenance RESPONSIBILITIES (Continued)
2.
ONE-HALF (½) OF THE WIDTH OF ABUTTING ALLEYS FROM THE PROPERTY LINE TO THE CENTERLINE OF THE 
ALLEY. 
3.
ANY PORTION OF A STREET ABUTTING THE BOUNDARIES OF A PARCEL OF LAND, WHICH STREET HAS NOT 
BEEN OPENED FOR PUBLIC USE, SHALL BE MAINTAINED BY THOSE PERSONS WHO DEDICATED THE STREET OR 
THEIR SUCCESSORS IN INTEREST, INCLUDING LESSEES AND OTHER PERSONS IN CONTROL OF THE LAND 
ABUTTING THE STREET; PROVIDED THAT IF THE ABUTTING LAND ON EITHER SIDE OF SUCH STREET IS OWNED 
BY DIFFERENT PERSONS AND EACH PERSON HAS AN OBLIGATION TO MAINTAIN THE STREET. HEREUNDER, 
THEN THE RESPONSIBLE PARTY OR OTHER PERSON IN CONTROL OF THE LAND SHALL ONLY BE REQUIRED TO 
MAINTAIN ONE-HALF (½) OF THE WIDTH OF THE STREET ABUTTING THEIR LAND.
107-2.4
Quantity, Size, and Spacing Requirements.
C.
Parking Areas/Lots, MULTI-FAMILY and Non-residential Setbacks

CHAPTER 107 DESIGN AND DEVELOPMENT REGULATIONS
ARTICLE 3 – OUTDOOR LIGHTING REGULATIONS 
107-3.7
Outdoor Advertising Signs.
A.

CHAPTER 107 DESIGN AND DEVELOPMENT REGULATIONS
ARTICLE 3 – OUTDOOR LIGHTING REGULATIONS 
107-3.7
Outdoor Advertising Signs.
A.

CHAPTER 107 DESIGN AND DEVELOPMENT REGULATIONS
ARTICLE 4 – PARKING AND LOADING REGULATIONS
107-4.3
R-1 and R-2, AND SHD-RO Residential Provisions
A.
Required Off-street parking SPACES WITHIN THE FRONT YARD shall be utilized solely for the parking of licensed and 
operable passenger vehicles and in addition to Chapter 54, Article IV of the Municipal Code the regulations below 
shall apply:  
1.
The recreational vehicle or utility trailer stored in the rear or side yard shall be behind the front line of the 
primary structure.
2.
Placement of a recreational vehicle or utility trailer in other than the rear or side yard for loading and 
unloading purposes may be permitted for a period not to exceed seventy-two (72) hours up to two (2) times 
per month.
3.
No person shall park a truck on any lot, except while loading and unloading the truck, while services are being 
provided to the residence by the truck's occupant, or for a period of time to exceed twenty (24) hours.
B.
The required off-street parking spaces WITHIN THE FRONT YARD shall not be used for storage of commercial 
equipment.
C.
Residential parking and driveway areas shall be constructed and maintained, with the required parking space(s) being 
located on and accessed by a dust-proof surface. 
D.
DRIVEWAY ENTRANCES AND OFF-STREET PARKING SPACES WITHIN THE FRONT YARD SHALL NOT COMPRISE OF 
MORE THAN THIRTY PERCENT (30%) OF THE FRONT LOT LINE, EXCEPT THAT EACH LOT IS PERMITTED ONE DRIVEWAY 
UP TO EIGHTEEN FEET (18’) WIDE.

CHAPTER 107 DESIGN AND DEVELOPMENT REGULATIONS
ARTICLE 4 – PARKING AND LOADING REGULATIONS
107-4.5
Dimensions 
D.
Off-street loading spaces. The number of such required spaces is outlined in Table 107-4a and the 
dimensions, exclusive of access or maneuvering area, platform, and other appurtenances, are as 
follows:
1.
Each large space shall have an overhead clearance of at least fifteen feet (15’), shall be at 
least twelve feet wide and at least fifty feet (12’x50’) long. 
2.
Each small space shall have an overhead clearance of at least ten feet (10’), shall be at least 
eight feet wide and at least TWENTY feet long (8’x20’).

CHAPTER 108 - LAND DIVISION AND SUBDIVISION REGULATIONS
ARTICLE 1 – GENERAL PROCESS AND OVERVIEW
108-1.8
MAINTENANCE OF MEDIANS AND MEDIAN LANDSCAPING.
A.
THE REPAIR AND MAINTENANCE OF ALL MEDIANS AND MEDIAN LANDSCAPING WITHIN ALL 
ARTERIAL AND PARKWAY RIGHTS-OF-WAY CLASSIFICATIONS WILL NOT BE THE RESPONSIBILITY OF 
THE CITY OF SURPRISE UNTIL ALL REQUIREMENTS ARE MET AS DESCRIBED HEREIN.
1.
PRIOR TO ACCEPTANCE OF THE MEDIAN AND/OR MEDIAN LANDSCAPING, IF A MEDIAN 
AND/OR MEDIAN LANDSCAPING IS FOUND TO BE DEFECTIVE, OVERGROWN, UNSAFE OR 
HAZARDOUS, THE CITY SHALL NOTIFY THE APPLICANT AND/OR ASSOCIATION FORMED BY THE 
APPLICANT OF THE ABUTTING PROPERTY TO RECONSTRUCT AND/OR REPAIR AND/OR 
REPLACE THE MEDIAN AND/OR MEDIAN LANDSCAPING WITHIN A TIME FRAME NOT TO 
EXCEED 45 DAYS FROM WRITTEN NOTICE.
2.
FAILURE TO REPAIR WITHIN THE TIME ALLOTTED WILL RESULT IN THE WITHHOLDING ON THE 
COMPANY'S BOND WHEN APPLICABLE. SECTION 42-44 II AND III SHALL APPLY AS DESCRIBED 
IN THE SURPRISE MUNICIPAL CODE.

CHAPTER 108 - LAND DIVISION AND SUBDIVISION REGULATIONS
ARTICLE 1 – GENERAL PROCESS AND OVERVIEW
108-1.8
MAINTENANCE OF MEDIANS AND MEDIAN LANDSCAPING.
B.
THE REPAIR AND MAINTENANCE OF ALL MEDIANS AND MEDIAN LANDSCAPING WITHIN ALL 
COLLECTOR AND LOCAL STREET RIGHTS-OF-WAY CLASSIFICATIONS SHALL BE THE RESPONSIBILITY OF 
THE APPLICANT AND/OR ASSOCIATION FORMED BY THE APPLICANT. THE CITY OF SURPRISE SHALL 
NOT HAVE ANY REPAIR OR MAINTENANCE RESPONSIBILITIES FOR MEDIANS LOCATED IN COLLECTOR 
AND LOCAL STREET RIGHTS-OF-WAY, UNLESS BY SEPARATE AGREEMENT.
1.
WHEN A MEDIAN AND/OR MEDIAN LANDSCAPING IS FOUND TO BE DEFECTIVE, OVERGROWN, 
UNSAFE OR HAZARDOUS, THE CITY SHALL NOTIFY THE OWNER OF THE ABUTTING PROPERTY 
TO RECONSTRUCT OR REPAIR THE MEDIAN AND/OR MEDIAN LANDSCAPING WITHIN A TIME 
FRAME NOT TO EXCEED FORTY-FIVE (45) DAYS FROM WRITTEN NOTICE.
2.
WHEN AN OWNER NOTIFIED TO REPAIR ANY MEDIAN AND/OR MEDIAN LANDSCAPING, AS 
PROVIDED IN THE PRECEDING SECTION, FAILS TO REPAIR SUCH MEDIAN AND/OR MEDIAN 
LANDSCAPING AS REQUIRED BY THE NOTICE AND ORDINANCES OF THE CITY, THE CITY MAY 
PROCEED TO REPAIR SUCH MEDIAN AND/OR MEDIAN LANDSCAPING THREE (3) DAYS AFTER 
SUCH NOTICE EXPIRATION TO SUCH OWNER, AND WHEN SO REPAIRED BY THE CITY, THE COST 
OF SUCH REPAIR SHALL BE PAID BY THE OWNER OF SUCH ABUTTING PROPERTY AND BE 
COLLECTED AS DESCRIBED HEREIN.

CHAPTER 109 - SIGNS
ARTICLE 1 – IN GENERAL PROCESS AND OVERVIEW
109-1.9
Sign classifications and types.  The following sign classifications and types as defined in section 109-
1.6 are permitted in the city as outlined in table 109-1a subject to the following "time, place and 
manner" restrictions. 
B.
Building-mounted signs. Building-mounted signs may only be placed on building elevations which 
face a street or primary parking lot. For purposes of this section, parking areas adjacent to service 
bays, access drives located behind a building, or alley ways are not considered primary parking 
areas. 
1.
Building wall signs. In other than residential zoning, building wall signs are permitted on any 
building elevation of any primary use building, subject to the following: 
a.
For single story, single-tenant AND MULTI-TENANT buildings, any number of building 
wall signs may be affixed to any building elevation, provided the aggregate sign area 
does not exceed one and one-half square foot per one linear foot of building elevation 
OF THE TENANT WIDTH on which the sign is mounted.

CHAPTER 110 - DEVELOPMENT IMPACT FEES 
ARTICLE 1 – IN GENERAL 
110-1.1
Definitions. 
A.
Unless otherwise defined in this chapter, terms used in this chapter have the same meaning as used 
in A.R.S. § 9-463.05. 
G
GROSS FLOOR AREA: FOR FEES ASSESSED ON THE BASIS OF SQUARE FEET, GROSS FLOOR AREA SHALL BE 
CALCULATED AS FOLLOWS. THE FLOOR AREA WITHIN THE INSIDE PERIMETER OF THE EXTERIOR WALLS OF THE 
BUILDING UNDER CONSTRUCTION, EXCLUSIVE OF THE VENT SHAFTS AND COURTS, WITHOUT DEDUCTION FOR 
CORRIDORS, STAIRWAYS, RAMPS, CLOSETS, THE THICKNESS OF THE INTERIOR WALLS, COLUMNS OR OTHER 
FEATURES. THE FLOOR AREA OF A BUILDING, OR PORTION THEREOF, NOT PROVIDED WITH SURROUNDING 
EXTERIOR WALLS SHALL BE THE USEABLE AREA UNDER THE HORIZONTAL PROJECTION OF THE ROOF OR FLOOR 
ABOVE. THE GROSS FLOOR AREA SHALL NOT INCLUDE SHAFTS WITH NO OPENINGS OR INTERIOR COURTS. THE 
USEABLE SPACE FOR A BUSINESS UNDER THE CANOPY FOR OUTDOOR DINING, GAS PUMPS, PARKING, DRIVE 
THROUGH, ETC. WILL BE COUNTED IN GROSS FLOOR AREA SQUARE FOOTAGE CALCULATION.

Sec. 2-301. - Planning and zoning commission. 
(d)  Powers, duties and responsibilities. The commission will: 
(8)  Make recommendations in all matters pertaining to the use of United States Department of Housing and Urban 
Development grant funding programs and other community support grant funding programs. REVIEW AND 
APPROVE OR DENY APPLICATIONS FOR SITE PLAN APPROVAL AND CONDITIONAL USE PERMITS, AS 
SET FORTH IN THE LAND DEVELOPMENT CODE, OR AS OTHERWISE SET FORTH IN THIS CODE.
(f)  Appeals. When sitting as either the board of adjustment or the board of construction review, only decisions of the 
planning and zoning commission may be appealed as set forth in section 2-303 or 2-304 as appropriate. Decisions by 
the Planning and Zoning Commission may be appealed as follows:
(1)
ANY PERSON AGGRIEVED BY THE DECISION OF THE PLANNING AND ZONING COMMISSION TO 
APPROVE OR DISAPPROVE AN APPLICATION FOR A CONDITIONAL USE PERMIT MAY APPEAL THE 
DECISION TO THE CITY COUNCIL WITHIN 15 CALENDAR DAYS AFTER THE COMMISSION HAS RENDERED 
ITS DECISION.  THE AGGRIEVED PERSON, OR ANY MUNICIPAL OFFICER OR OFFICIAL DEPARTMENT OF 
THE CITY, OR MEMBER OF CITY COUNCIL, MAY FILE AN APPEAL WHETHER OR NOT THEY WERE A 
PREVIOUS PARTY TO THE DECISION.  APPEALS SHALL BE FILED IN WRITING WITH THE OFFICE OF THE 
CITY CLERK AND SHALL SPECIFY THE GROUNDS FOR THE APPEAL. THE DECISION BY THE CITY COUNCIL 
SHALL BE FINAL.  
(2)
WHEN SITTING AS EITHER THE BOARD OF ADJUSTMENT OR THE BOARD OF 
CONSTRUCTION REVIEW, DECISIONS OF THE PLANNING AND ZONING COMMISSION MAY BE APPEALED AS 
SET FORTH IN SECTION 2-303 OR 2-304 AS APPROPRIATE.

QUESTIONS OR 
COMMENTS?
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