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Agenda 04/13/2006 W ,- Board of County COInInission Housing Workshop ~- COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS -. ;} AGENDA April 13, 2006 5:30 p.m. BCC Immokalee Housing Workshop Immokalee Sports Complex 505 Escambia Street, Immokalee, FL 34142 Frank Halas, Chairman, District 2 Jim Coletta, Vice-Chairman, District 5 Donna Fiala, Commissioner, District 1 Tom Henning, Commissioner, District 3 Fred W. Coyle, Commissioner, District 4 - NOTICE: ALL PERSONS WISHING TO SPEAK ON ANY AGENDA ITEM MUST REGISTER PRIOR TO SPEAKING. SPEAKERS MUST REGISTER WITH THE COUNTY MANAGER PRIOR TO THE PRESENTATION OF THE AGENDA ITEM TO BE ADDRESSED. COLLIER COUNTY ORDINANCE NO. 2004-05, AS AMENDED, REQUIRES THAT ALL LOBBYISTS SHALL, BEFORE ENGAGING IN ANY LOBBYING ACTIVITIES (INCLUDING, BUT NOT LIMITED TO, ADDRESSING THE BOARD OF COUNTY COMMISSIONERS), REGISTER WITH THE CLERK TO THE BOARD AT THE BOARD MINUTES AND RECORDS DEPARTMENT. IF YOU ARE A PERSON WITH A DISABILITY WHO NEEDS ANY ACCOMMODATION IN ORDER TO PARTICIPATE IN THIS PROCEEDING, YOU ARE ENTITLED, AT NO COST TO YOU, TO THE PROVISION OF CERTAIN ASSISTANCE. PLEASE CONTACT THE COLLIER COUNTY FACILITIES MANAGEMENT DEPARTMENT LOCATED AT 3301 EAST TAMIAMI TRAIL, NAPLES, FLORIDA, 34112, (239) 774-8380; ASSISTED LISTENING DEVICES FOR THE HEARING IMPAIRED ARE AVAILABLE IN THE COUNTY COMMISSIONERS' OFFICE. 1. Invocation Rev. Daniel Hernandez Pastor of Iglesia Bautista de Jesus Cristo 2. Pledge of Allegiance 3. Review of Past Housing Conditions Studies Michelle Arnold 4. Enforcement Challenges A. HealthDepartmentRegulations B. Application of the Codes Dr. Joan Colfer Michelle Arnold/Bill Hammond 5. Housing Programs & Incentives Cormac Giblin - 6. Solutions I Alternatives . Statewide Initiatives Nancy Muller -. - - . Construction Alternatives . Agricultural Industry Input 7. Public Participation Steve Kirk Jay Taylor 8. Questions and Answers 9. Adjourn INQUIRIES CONCERNING CHANGES TO THE BOARD'S AGENDA SHOULD BE MADE TO THE COUNTY MANAGER'S OFFICE AT 774-8383. - EXECUTIVE SUMMARY Workshop discussion regarding enfol'cement of the county-wide Minimum Housing Standard Ordinance and the Florida Building Code as they relate to safe structures within the Immokalee area OBJECTIVE: To discuss enforcement of Collier County's Minimum Housing Standards as defined in the Property Maintenance Ordinance Number 2004-58 and the Florida Building Code as they relate to residences within the Immokalee Community and to seek guidance from the Board of County Commissioners (BCC) relative to the degree and timing of enforcement required to ensure all Immokalee residences are habitable and in compliance with governing law. - CONSIDERATIONS: During 2002 the BCC directed the Code Enforcement staff to begin the "Immokalee Housing Initiative" with the objective of updating substandard and nonconforming mobile parks to minimum site development standards as defined in the Land Development Code and to condemn and have removed those mobile homes that were assessed to be unsafe for habitation. The initiative allowed owners 30 months to submit Site Improvement Plans for review at no cost to the park owner, to complete the associated construction of mobile home park improvements and to remove condemned trailers with disposal tipping feed funded by the county. The intent of the overlay initiative was to for the first time conduct a review of mobile home parks that were established without authorization from the County and bring parks closer into conformance with current codes. This process was also intended to address those units that posed health, safety and welfare concerns, as well as provide internal improvements in conjunction with the removal of unsafe units, This project lasted for 2 years and resulted in 76 mobile homes being removed and taken to the dump with the condition that dumping fees would be waived. During Phase I of the Immokalee Housing Initiative, 72 mobile home parks were identified as requiring compliance with the Mobile Home Park Overlay for Immokalee. At the conclusion of Phase I 43 :MH parks submitted SIPs but only 28 completed the process, 4 :MH parks were determined to be legally conforming uses, 8 mobile home parks abated their respective violations and 17 mobile home parks chose not to participate in the volunteer program. Those 17 mobile home parks were subsequently referred to Code Enforcement for prosecution before the Code Enforcement Board. Phase II of the lmmokalee Housing Initiative consisted of an overall assessment of the condition of the entire housing stock in Immokalee. Housing Units were classified as Standard, Standard M, Substandard, Deteriorated or Dilapidated/Demolition. The purposes was to set a base line for housing conditions in Immokalee, identifying potential units for future rehabilitation, and identify housing units that have immediate health, safety and welfare issues will be identified for immediate remedial action. - During the November 15, 2005 BCC regularly scheduled meeting there was a discussion under agenda item 15D regarding the living conditions in the lmmokalee community following Executive Summary Higher Regulatory Standards Workshop 3-20-06 Page 20f3 - Hurricane Wilma. Dr. Joan Colfer, Collier County's Health Department Director, addressed the board regarding the issue of mobile homes severely damaged by Wilma. She spoke of the large number of migrant housing units (133) that became uninhabitable and her concern regarding mobile home parks and housing in general, especially the increased possibilities of fires and other safety risks. There was board discussion of the deteriorated living conditions within the Immokalee area and possible actions to improve them. The Chairman stated that this issue is a serious problem and suggested that a workshop be scheduled to address it and provide guidance to staff within an advertised public meeting. The purpose of this workshop is as follows, to: . Familiarize the BCC to the present condition of housing in general within Immokalee . Discuss the estimated number of units, migrant and permanent residency, failing to meet: the minimum housing standards as codified in our ordinance, the safety standards as required by our Florida Building Code, and the minimum health standards as dictated by the State Migrant Housing Law. . Provide guidance to staff relative to enforcement of existing ordinances, including zoning, or to create a new ordinance with more demanding conditions and more draconian consequences for failure to comply . Provide guidance to staff to deal with the consequential displaced people FISCAL IMPACT: Not determinable at this time. -- GROWTH MANAGEMENT IMPACT: The elimination of substandard housing fulfils the Goals, Objectives and Policies, of the Housing Element of the County's Growth management Plan, specifically: Obiective 4: By 2000, the County and City will conduct a comprehensive housing survey to identify substandard dwelling units. Through continued enforcement of each jurisdictions housing codes, and the provision of housing programs, the number of substandard units associated with a lack of plumbing and/or kitchen facilities throughout the County shall be reduced by 5% per year through rehabilitation or demolition. Policy 4.1: By 2001, use the comprehensive housing inventory to develop and implement new programs to reduce substandard housing employing existing methods such as housing code inspections, rehabilitation, and demolition with new construction and develop new programs as needed. Policy 4.2: Require the demolition of dilapidated, unsafe or unsanitary housing that does not meet housing code or cannot economically be rehabilitated. - Executive Summary Higher Regulatory Standards Workshop 3-20-06 Page 3 of3 -. POliCY 4.5: Dwelling units will be maintained in a safe and sanitary condition, including adequate light, ventilation, sanitation and other provisions as required by the County and the City minimum housing codes. This will be accomplished through housing code inspections and enforcement, and housing rehabilitation programs using State, Federal, local and/or private resources. RECOMMENDA nON: That the BCC direct staff to require the rehabilitation and/or removal of substandard housing within the lmmokalee community. Prepared by: Denny Baker, Operations Support and Housing Director Michelle Edwards Arnold, Code Enforcement Director - - - Agenda Item #15D J,____- MR, MUDD: The next item I'd like to talk about and I gave you yesterday -- and -- and I'm sorry for the short turnaround, but I wanted to make sure that Mr, Dan Summers gave you an opportunity to at least brief you on -- on some of the -- the things that are still outstanding in Collier County, One of which has to do with -- with temporary housing, And it's significant enough that in my personal opinion, I would have liked to see those trailers in here a little bit sooner, And I'm not too sure they're here yet. But I do lmow that we still have families that are -- that are living in one shelter in our community center in -- in Immokalee, And we still have, what, eleven or a dozen -- a dozen or so families that are still there in a shelter run by the -- Red Cross, And I don't want you to lose visibility on that until those people have moved into adequate quarters and gotten some help from the Federal Government. So Mr, Summers, please, - .' ./ ./~ /' -/ / I - t_ . .~. \ - // '" I .:~, L _. - OFFICE OF THE COUNTY ATTORNEY INTEROFFICE MEMORANDUM TO: Commissioner Frank. Halas, Chairman, District 2 Commissioner James N. Coletta, Vice-Chair, District 5 Commissioner Fred W, Coyle, District 4 Commissioner Donna Fiala, District 1 Commissioner Tom Henning, District 3 FROM: Michael W, Pettit, Chief Assistant County Attorney DATE: April 4, 2006 RE: Immokalee Initiative Workshop - April 13, 2006/Sunshine Law Guidelines In anticipation of the publicly noticed Immokalee Initiative Workshop scheduled for April 13,2006 and the tour that will take place prior to the workshop, we are providing some guidelines to assist in view of the Sunshine Law, These guidelines for the tour are as follows: 1, Although it would be a good idea for Commissioners to arrive separately and meet at the location, if the plan is already set to arrive together on a bus, then please remember that Commissioners must not discuss any items that may relate in any way to business that may foreseeably come before the BCC. They must also refrain from such discussion during the tour. 2. Staff may make presentations to the Commissioners during the tour, but questions by the Commissioners should be held until the publicly noticed workshop is in progress, In this regard, as you know, staff may not facilitate communication between or among Commissioners except in the "sunshine". Please call me if I may be of further assistance. MWP/nfb cc: David C. Weigel, County Attorney James V, Mudd, County Manager Leo Ochs, Deputy County Manager Joseph Schmitt, Administrator, Community Development & Environmental Services Denny Baker, Director, Financial Administration & Housing Department 04-bcc-Oll99/461 ,- (l) OJ) ..:::! :;u ~ '" (l) .~ ~ .5 ~..c: ~~ ";3 o:::t :'ES (l) :> -< c: o (l) ~ o..~ (/:; ~ ~ (E UE~~ ": 3 5 t5 'u o::l 0::: ~ ~"':::::l"~tJ') ,,...,0 ~-:5 '_-"D ex: 0-- N ~ = o ~ ~ =~ 0= ~= OJ:iN = "' ._ ..c \1),..... =~ o'l""'i ~.~= == ~ ~ Q., ~< ~ o = = ~ . .,' -~ ~c: ~.- liO, -.Q. ::l ' 'e. ro :e' i,~ is-~-~'''' ~41' ! * '. 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CS ~... u V'l !i: ..c '" = ~- ~ BOoker - Blvd' U ~. -1 ~.. u Jd ;I~W ~ -~ U'. :). -< S 9ttl St J 0:> :n 2 "'3~ C ~ .~ .~ <ilCll ~~ rS:f: r--: ~ qG.S j- ..: ~ t 'I .. ~' II!~ i .it 8 .i ! ,: ... t .1 8 a ,,- IMMOKALEE HOUSING INITIATIVE, PHASE II: IMMOKALEE HOUSING CONDITION INVENTORY The lmmokalee Housing Condition Inventory is an assessment of the condition of housing in the lmmokalee Urban Area, other than mobile home parks. It is based on observations of the exterior aspects of these dwelling units between May and August, 2004. These aspects include the physical condition of each dwelling unit, its visible infrastructure and surrounding conditions. The information derived from this inventory will be used to develop neighborhood revitalization strategies and to identify needs in the area of code enforcement. BACKROUND: Objective 3 of the Housing Element, Collier County Growth Management Plan, requires an increase in housing programs countywide to assist in rehabilitation efforts. Objective 4 requires a comprehensive survey to identify substandard units. - With specific reference to the Immokalee area, Policy 8.2 states: "The County will prepare a housing assessment of single family, multi-family, and mobile home units and mobile home parks in the Immokalee Urban Area to determine the number of units that do not meet health and safety codes and the minimum housing code and target affordable housing and code enforcement programs to correct the conditions." Finally, Policy 3.4 of the Immokalee Area Master Plan directs Code Enforcement to prioritize enforcement related to substandard housing where serious threats to health and safety exist, including demolition. By direction of the Board of County Commissioners in September, 1999, Community Development and Environmental Services (CDES) embarked on a program specifically targeting mobile home parks in the Immokalee Urban Area. The Immokalee Housing Initiative, Phase 1 (Mobile Home Park Initiative) has been an ongoing program since that time. In 2003, Phase II of the Immokalee Housing Initiative began. This program is the Immokalee Housing Conditions Inventory (hereafter "inventory" or "survey"), which is the subject of this report. The inventory is intended to document the exterior conditions of existing housing in Immokalee at a specific point in time. It is intended to produce data that can be used in a number of ways. The Financial Administration and Housing Department (FAHD) will use the data as tool in the research, design and implementation of affordable housing programs. This may aid in the refinement of an overall strategy for affordable housing in Immokalee, as well as more specific uses such as grant applications. - The Code Enforcement Department (CED) will respond to matters of immediate concern and will also use the data to identify needs and priorities in Immokalee. In addition, this data will be available to various Departments, the BCC and outside agencies as needed. 1 - Finally, the inventory establishes a baseline of information. It can be used as a reference for comparisons with future surveys or studies of a similar nature. In this way, it preserves the historical record of existing housing conditions from May through August, 2004 for various potential studies. METHODOLOGY: The survey was designed by a committee of representatives from four Departments within CDES: Code Enforcement, Financial Administration and Housing, Comprehensive Planning and Addressing. The objectives stated by the committee include determining the numbers of parcels and dwelling units in the study, the number of vacant units, the number of units in each identified classification and the number of units in a dilapidated condition. The design was intended to quantify both structural and property considerations deemed most important to achieve the stated objectives. In view of the intention to inventory every dwelling unit in the study area, and given practical and legal considerations, this inventory was designed as a "windshield survey". Only exterior conditions were considered. Interior evaluations were not included in the survey. - Survey participants were selected from the Departments making up the committee. Fifteen (15) employees participated in the fieldwork. Participants attended two training sessions. A classroom session conveyed the purpose and background of the program, and introduced techniques in evaluating various criteria. A field training session was also held in which participants rated the same structures. The field training emphasized consistency in evaluation and safety in the field. Fieldwork commenced May 3, 2004 and concluded August 6, 2004. The inventory includes sixteen (16) fields or categories representing the condition of each dwelling unit as well as infrastructure (drainage and driveway) and overall property condition, Points are assigned according to the condition of each feature with a total tally indicating the overall condition of the property. Other important features of the inventory include the address fields, folio number, general comments and the option for immediate action. (See Appendix A). This design accommodates a total rating for each dwelling unit according to the following classifications and definitions (Table 1): - 2 - Table 1 DEFINITIONS AND AGGREGATED POINTS -. Condition Description Aggregated Poi nts Standard No visual defects 0-9 Standard M Slight defects that can be corrected during the 1 0-19 course of regular maintenance. The structure can still provide safe and adequate structure. Substandard Minor defects requiring more repair than would be 20-29 provided during regular maintenance. Structure still provides safe and adequate shelter. Deteriorated Major defects requiring extensive repairs. 30 or more Structure will not provide safe and adequate shelter unless repairs are made. Dilapidated/ Does not provide safe and adequate shelter in No points Demolition present condition and endangers health, safety, assigned and well being of occupants. Structure cannot be economically repaired, Repair costs would exceed 50% of the total value of the shelter. In an effort to include all dwelling units (other than mobile home parks) in the inventory, participants were provided with GIS maps of each quarter of each half section involved in the survey. Forty-six (46) such maps were distributed. The quadrants making up the study area were selected as the best representation of the urban area consistent with Township, Range and Section descriptions and the goals of the Inventory. (See Appendix B). Residential units within the Immokalee Urban Area not included within the study area are generally rural in character. On each mapped dwelling unit appeared an address and folio number to the extent available from the GIS database. All folios containing appropriate Land Use Code fields were included. These were derived from the Collier County Property Appraiser's 2004 Tax Parcel Database, using standard Florida Department of Revenue Land Use Field Codes 1-8 to identify appropriate residential properties. These did not include any commercial properties, or properties containing more than two (2) mobile home units (mobile home parks). - Along with rating the properties in 16 categories, participants noted any discrepancies between mapped and physical addresses and judged whether each unit was presently occupied. In addition, there was an opportunity to note health and safety issues of an immediate nature and to make additional comments. 3 - RESULTS: field participants visited and evaluated 3,558 dwelling units on 2,898 parcels. On 363 parcels, 2 or more dwelling units were observed (including apartment complexes). No reports were made of 75 properties contained in the original database, either because of misclassification, change of use or inaccessibility. The density distribution of the observed dwelling units in the study area is shown on the map in Appendix C. The overall results for all properties covered by this inventory are as follows (Table 2): Table 2 OVERALL RESULTS- ALL CATAGORIES Classification: Number of Dwelling Units Standard Standard M Substandard Deteriorated Dilapidated* 2024 701 427 287 119 ,.....-.. Total Survey 3558 *These properties were specifically identified for further review by Building Department specialists. They were either identified verbally as possible demolitions, or received scores in the first 5 fields of at least 30 (of 35) points. This information is presented graphically in Figure 1. Figure 1 Overall Point Score Totals Categories 1 - 16 . Dilapidated (119 units) .0 to 19 Points (2725 units) Standard/ Standard M 020 to 29Points (427 units) Substandard a:la 30+ Points (287 units) Deteriorated - 4 -- Dilapidated units were identified as a first step in determining demolition. None of the participants were qualified as structural engineers or cost assessors. Accordingly, a portion of units shown as dilapidated (119) may ultimately be reclassified as deteriorated, capable of rehabilitation. The same data can also be mapped to show concentrations of substandard, deteriorated and dilapidated structures on a neighborhood scale. Maps produced for each quarter of each half section can be made available showing observed conditions on each folio. Larger scale maps will be provided to F AHD as an aid to planning and identifying programs for repair and rehabilitation. Geographic considerations in housing programs can be accommodated by various mapping techniques. For example, Appendix D shows concentrations of substandard conditions as described above. Appendix E shows concentrations of deteriorated housing. A more specific application might be concentrations of roof repair and replacement. Results in individual categories can be expressed as total numbers and percentages for each condition, as shown in Table 3, below: Table 3 Results for Each Category by Number and Percentage -... Point Number Percentage Category Value Condition of Units Totals 1 ROOFING/EAVES/SOFFITS 0 No repair needed 2636 74% 5 Needs patching 593 17% 10 Needs reolacement 310 9% 2SIDING 0 No repair needed 2537 71% 3 Needs painting 629 18% 5 Needs oatchinq/replacinq 377 11% 3WINDOWS 0 No repair needed 2800 79% 3 Needs repairing 382 11% 5 Needs replacinq 361 10% 4DOORS (HOUSE) 0 No repair needed 2980 84% 3 Needs repairing 259 7% 5 Needs replacinq 303 9% 5STRUCTURAL 0 No repair needed 3011 85% 5 Needs repairing 399 11% 10 Needs reolacing 135 4% 6MOLD 0 None visible 2457 69% 5 Visible 1085 31% 7DRIVEWAYIWALKWAY 0 No repair needed 2948 84% 2 Needs patching 142 4% 4 Needs replacing/structural repair or installation 436 12% - 5 ,- -- 8DRAINAGE/CUL VERT 0 Adequate 3317 94% 3 Inadeauate 208 6% 90VERGROWN VEGETATION 0 Very little/none 2993 85% 3 Moderate amount 348 10% 5 Siqnificant amount 184 5% 10RUBBISH/REFUSElDEBRIS 0 Very little/none 2661 76% 3 Moderate amount 578 16% 5 Siqnificant amount 285 8% 11TRASH CONTAINERS 0 None visible 3088 88% 3 Minor visual impact 389 11% 5 Maior visual imoact 46 1% 12SECONDARY BUILDINGS 0 None visible/no repair needed 3050 86% ON PROPERTY 3 Needs minor repair 236 7% 5 Needs maior repair/removal 236 7% 13GARAGElCARPORT 0 No repair needed 3407 97% CLOTHESLINES 1 Needs repairing 51 1% 3 Needs replacinq 66 2% 14FENCES 0 Good condition 3103 88% 3 Needs minor repair 324 9% 5 Needs maior repair 95 3% 15/161NOPERABLE VEHICLES & 0 None visible (1 condition) 2166 61% VEHICLES PARKED IN YARD 3 Visible (1 condition) 734 21% 6 Both conditions 621 18% Inventory Fields 9-16 deal primarily with Code related issues outside of the primary structure. Results in total points for these fields are shown in Figure 2. This information can also be displayed geographically. Figure 2 10 Point Increment Totals: Categories 9 -16 Overgrown Vegetation, Rubbish, Trash Containers, Secondary Buildings, Carports, Fences, Abandoned Vehicles, Vehicles Parked in Yard . 0-9 pts 3016 D 10-19 Pts 473 [] 20-29 Pts 48 1130-39 Pts 21 1% 1% 6 - The lmmokalee Housing Condition Inventory database will be available to departments, boards and agencies as requested. Because nearly every residential property was included in the inventory, the database can be mined in different ways. For example, if Code Enforcement wants to determine the neighborhoods with the highest concentration of significant rubbish, this can be provided. (See Appendix F). If enforcement is by a priority such as simultaneous abandoned vehicles and significant rubbish, this information can be correlated and mapped. Occupancy as observed by participants was at 81 % of total dwelling units. The remaining 19 % were either judged unoccupied or "unable to determine". Of all observations, this one may be most subjective, because the observation relies on indirect evidence. As the inventory was taken between May and August, the percentage should reflect occupancy during low season. Participants indicated a need for immediate action on 131 units. Most of these were for obstructed windows (90), including bars or heavy screening on all windows that could not be easily removed in an emergency. Ironically, these obstructions are typically employed for reasons of personal safety. Of the remainder, 32 were indicated as Demolition and 9 had other health and safety concerns. All of these have been forwarded to the appropriate departments for review. ..---'~ Addressing discrepancies were an additional item of review. In total, 914 properties had addressing problems of some kind. In many cases, the Property Appraiser database either had no property address or had an incorrect one. In other cases, no address was posted at the location. Finally, some locations were missing a folio number. Field notations were compiled and forwarded to the Addressing Department. This compilation will be checked by the Addressing Department against their ongoing review of lmmokalee properties. Many of these discrepancies have already been corrected. All corrections made by Addressing will be reflected on the GIS database and ultimately in the Property Appraiser's records. SUMMARY: The Immokalee Housing Condition Inventory is a tool that can be used in a variety of ways. It will be used for housing assistance programs and code enforcement, as well as other public purposes. It also serves as a baseline of information that that can be used as a point of comparison by future studies of a similar nature. 7 Appendix A: Field Inventory Form - IMMOKALEE HOUSING CONDITION INVENTORY Falla: Map Address: No, of Units: Field Address: IA:_ Occupied: a Yes aNa ROOFING I EAVES I SOFFITS o No repair needed 5 Needs patdling 10 Needs replacement ~ o 3 5 No repair needed Needs painting Needs patching/repWcing OVERGROWN VEGETATION o Very little/none 3 Model1lte amount 5 Significant amount RUBBISH I REFUSE I DEBRIS o Very ltile/none 3 Modelllte amount 5 Significant amount WINDOWS o No repair needed 3 NeIld JePUing 5 Need replacing DOOR (HOUSE) o No repair needed 3 NeIld ntpairing 5 Need replacing TRASH CONTAINERS o None vilible 3 Minor visual Implld 5 Major visual impad SECONDARY BUILDINGS ON PROPERTY o None viaiblelno repair needed 3 Needs minor repair 5 needs major ntpair/llll1loval Occupied [J YES [J NO DRIVEWAY I~AY o No....... ~ 2 Needs P*Iling .. NMda ~ IllIl*I inslallllion DRAINAGE I CUlVERT o AdequB 3 IrlIIdequMe GARAGE! CARPORT I CLOTHESLINES o No repair IlMded 1 Need repairing 3 Need replIIcing ~ o Good condition 3 Needs minor repair 5 Needs major repair INOPERABLE VEHICLES o None visible 3 Visible ,~, STRUCTURAL o No repair .-ted 5 Need ..,.mg 10 Need IIIpIacing MQ!.Q o None visilIe 5 11'151* VEHIClES PARKED IN YARD Q None vii.. 3 VIsIble TOTAL POINTS Standard Standard M Substandard Deteriorated DllapidatedlDemo == COMMENTS: FOI1Tl cornpIeted by: DIlle: ,- 8 - 'Jl .... = I:': "" "t:l I:': = 01 I:': ~ "" < -- ~ "t:l .a r:J'J - .. ~ ~ ;a = ~ Q.; Q.; < d,~ 2l~ ..:.@ D ,lil ,@ ,~ '" m'f ~ ~ ~ ,... ~ /" ~ ,fiS D D ,fil D .""' ' '" ~ ,,,", '" , D , M~ ,.... on , - <D "'<D ,... -,... ~ ~ ~ ~ ~ " , ,g:: en '" '" ,/ ,gJ , ,N ,N ,N ~.;, "', <D , -' /~ ~,..'.. N<D ""'<D -,... ~ " " ~ ~ 1 '" .?:l ,~ ,~ 7 .fll ,[1.l ,N '" , ~' ~' ~, '" , N<D N' -,... N.... " ~ ~ " " v- / ID ,gj ,g:: ,l',l ,~ ,[1.l , N N' ~~ 1il;' -' c' U> . 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