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08-736Suspension 7/09/2008 Council File # /��- 7,3� Green Sheet # 3p56s �v� RESOLUTION Presented by OF -1 PAUL, MINNESOTA 1 WHEREAS, the Legislative Hearing Officer recommends that the application (I.D. # 20070000862) for 2 Second Hand Dealer — Motor Vehicle and Auto Repair Garage licenses for Jackson Ave Auto Sales LLC, 3 doing business as Jackson Auto Sales, 1202 Jackson Street, be approved with the following conditions: 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 1. The number of vehicles displayed "for sale" outdoors shall not exceed fifly (50). All display vehicles on site must be parked as shown on the approved site plan OS-157109, on file with DSI. (Any changes to the site plan must be approved by the Zoning Administrator) 2. The required pazking spaces for customers and employees is fifteen (15); there aze at least fifteen (15) additional spaces maintained for customer and employee use in the lot, all vehicles on the site must be parked as shown on the approved site plan on file with DSI, OS-157109. Employee vehicles may not be pazked or stored in the alley. 3. There sha11 be no exterior storage of vehicle parts, tires, oil ar any other similar materials associated with the business. Trash wili be stored in a covered dumpster. Storage of vehicle fluids, batteries, etc., shall be in accordance with the Ramsey County Hazardous Waste regulations. 4. At no time shall any vehicles be parked in the street, driveway or in the public right of way. This includes vehicles awaiting repair, vehicles awaiting sale or pick up or customer and employee vehicles. 5. The storage of vehicles for the purpose of salvaging parts is expressly forbidden. All vehicles parked outdoors must appear to be completely assembled with no major body parts missing. Vehicle salvage is not permitted. 6. No auto repair of vehicies may occur on the exterior of the lot or in the public right-of-way. Ali repair work must occur within an enclosed building. 7. Auto body repair and auto body spray painting is not permitted. 8. Customer vehicles may not be parked longer than 10 days on the premises. It shall be the responsibility of the licensee to ensure that any vehicle not claimed by its owner is removed from the lot as permitted by law. 9. Provide maneuvering space on the property to allow vehicles entering and exiting the site To proceed forward. Backing from the street or on to the street is prohibited. 10. Licensee must comply with all federal, state and local laws. 11. The Auto Repair Garage license is approved for a more limited service center (light mechanical only), and shall be limited to services such as the following: brake inspection, tire rotation, topping off fluids, changing of light bulbs, replacement of batteries, etc. No oil changes aze permitted, and any other types of auto repair shall be performed off-site by outside licensed vendors. Only vehicles owned and/or under the control of Jackson Auto Sales may be serviced, no work is permitted on vehicles owned by the general public. Any changes in operations relating to the Auto Repair Garage license require prior written approval by DSI. 12. Failure to remain in compliance with license conditions will result in adverse acUon against the licenses. Note: The Second Hand Dealer Motor Vehicle License is issued on the condition that the State of Minnesota Dealer Number is submitted to DSI upon issuance by the State of Minnesota Dealer Unit. d� 7�� 41 THEREFORE, BE IT RESOLVED that the Council of the City of Saint Paul hereby approved this license 42 application. Benanav Bostrom Thune Adopted by Council: Date Yeas � Nays � Absent �I Requested by Department of: � ✓ J Adoption Certified by C$�ncil Secretary BY� �«c. C_�i�X.Ld,/�' Approved by Mayor: Date � Form Approved by City Attomey By: Form Approved by Mayor for Submission to Council By: � � Green Sheet Green Sheet Green Sheet Green Sheet Green Sheet Green Sheet � �8= �.�G co ����;� Confact Person 8 Phone: Marcia Moermond 266-8570 MuSt Ce on GoUnQI A92ptla by (Date). 09JUL-08 Doc. Type: RESOLUTION E-Document Required: Y Document Contact: Jean Birkholz ConWCt Phone: 266-8673 o�,��-08 I Green Sheet NO: 3056538 � uepartmen[ aeni�orerson 0 oonN Assign 1 amcil De artmentDirector Number z ' Clerk CtiNClerk For Routing 3 Order 4 5 Total # of Signature Pages _(qip All Locations for Signature) Approving the license application with conditions, per the Legislative Heazing Officer, for Second Hand Dea]er - Motor Vehicle and Auto Repair Garage licenses for Jackson Ave Auto Sales LLC, doing business as Jackson Auto Sales, 1202 Jackson Street. ioanons: Hpprove (H) or n Planning Commission CIB Committee Civil Service Commission 1. Has this person/firm ever worked under a contrect for this department? Yes No 2. Has this person/firm ever been a ciry employee? Yes No 3. Does this person/firm possess a skill no[ normally possessed by any current city employee? Yes No Explain all yes answers on separete sheet and attach to green sheet Initiating Problem, Issues, Opportunity (Who, What, When, Where, Why): AdvanWges IfApproved: DisadvanWges IfApproved: Disativantages If Not Approved: Transaction: Funding Source: Financia l Infortnation: (F�cplain) CostlRevenue Budgeted: ActiviTy Number: July 8, 2008 4:09 PM Page 1 d�-��� CiTY OF SAINT PAUL Christopher B. Co!emaq Mayor DEPAR"MiENT OF SAFEN AND INSPECTIONS BoD icess'ar, Dira7w wc»nenya w..�s's�.ao+rasi CCMMERCE BUILDING SuYe 2.V TeHpMx: (65l) 26�90.t0 BFwM54ee!ca# Fa^smd¢ (65!)2669099 Sa`KFtW.. ASt,feSUe "�v`101-:�< (651) 3669f3L I agree to the foilowing conditions beina placed on the following license(s): License #: 20080000862 Type of Business: Auto Repair Garage Secor:d Hand Dealer - Motor Vehicle Applied for by: JACKSON AVE AUTO SALES LLC Doing Business As. JACKSON AUTO SALES at: 1202 JACKSON ST ST PAUL MN 55117 � Conditions are as foliows: 1. The rumber of vehicles displayed "for sale" outdoors shall not exceed fifty (50). Ali dispiay vehicles on stte must be parked as shown on the approved site plan 05-157109, on file with DSI. (Any changes to the slie plan must be approved by the Zoning Administrator) 2 The reqwred parking spaces for customers and employees is fifteen (15), there are at least fifteen (15) additional spaces maintained far customer and employee use i� the lot, ali vehicles on the site must be parked as shown on the approved site plan on file with DSI, OS-157109. Employee vehicles may not be parked or stored in the ailey. 3. There shall be no exterior storage of vehicle parts, tires, oil or any other similar maferials associated with the business. Trash will be stored in a covered dumpster. Storage of vehicle fEuids, batteries, etc. shall be in accordance with the Ramsey County Hazardous Waste regulations. 4. At no time shali any vehides be parked in the street, driveway or in the public right of way. Thi9 inctudes vehicles awaiting repair, vehides awai#ing sale or pick up, or customer and employee vehictes. 5. The storage of vehides for the purpose of salvaging parts is expressiy forbidden. Aii vehictes parked outdoors must appear to be completely assembled with no major body parts misstng. Vehicie salvage is not permitted. 6 No auto repair of vehicles may occur on the eMerior of the lot or in the pubiic right-of-way. A(I repair work musf occur wifhin an enclosed building. 7. Auto body repair and auto body spray painting is not permitted. 8. Customer vehicles may not be parked longer than 10 days on the premises. It shall be the responsibitity of the licer.see io ensure that any vehicle not daimed by its owner is removed from the lot 2s permitted by law. 9. Provide manewering space on the properry to aliow vehicles entering and exfting fhe site to proceed forward. Backing from the street or on to the street is prohibifed. 10 Licensee must compiy with all federal, state and local laws. 11 The Auto Repair Garage license is approved for a more limited sen+ice center {light mechanical onlyj, and shall be limited to services such as the foliowing: brake insp'ection, tire rotation, topping off fluids, changing of light buibs, replacement of batteries, etc. No oiI changes are permitted. and any other types of auto repair shali be performed off-site by outside licensed vendors. Only vehicles owned and/or under the controi of Jackson Auto Sales may be serviced, no work is permit#ed on vehicles owned by the general pubiic. Any changes in operations reiating to the Auto Repair Garage license require prior written approval by DSI. . 12. Failure to remain in compiiance wifh license conditions wili result in adverse ac#ion against the Noke��.� �'he Se�nd�tand Dealer Motor Vehicle License is issued on the condition that the State of �(Njnn�s�ota De Number is submitted to DSI upon issuance by the State of Minnesota Dealer Unit. J t �� � � � � ;� � ,L� � � � � — � �J / / ��censee Date . �� ��� LICENSE HEARING MINUTES Jackson Auto Sales at 1202 Jackson Street Jackson Auto Sales at 1200 Jackson Street Monday, June 23, 2008, 1:00 p.m. 330 City Hall, 15 Kellogg Boulevard West Mazcia Moermond, Legislative Hearing Officer The hearing was called to order at 1:18 p.m. Staff Present: Jeffrey Fischbach and Jeff Hawkins, Department of Safety and Inspections (DSI); and Jean Birkholz, Council Research Others Present: Alan Crain, business and property owner; Peggy Mulligan, Office Manager; Kerry Antrim, District 6 Planning Council. 1202 Jackson Street: Request for Second Hand Dealer – Motor Vehicle and Auto Repair Garage licenses 1200 Jackson Street: Request for Second Hand Dealer – Motor Vehicle license Ms. Moermond stated that this is an informal legislative hearing for a license application. This is a Class N notification which means that the neighborhood gets notified and has a chance to voice its concerns. If any one has a concern, it automatically triggers a hearing. Other Class N Licenses include: liquor sales, entertainment, cabaret, etc.—things that have an immediate impact on the neighborhood. The City received two (2) letters of concern regarding the issuance of these licenses. Ultimately, there are three (3) possible outcomes from this hearing: 1) Ms. Moermond can recommend to the City Council that they issue these licenses without any conditions; 2) she can recommend to the City Council that they issue these licenses with agreed upon conditions; ar 3) she can recommend to the City Council that they not issue these licenses but refer them to an administrative law judge for a further hearing and findings. Ms. Moermond will begin with a staff report. Staff will be asked to explain their review of the application and will also explain their recommendation. Then, she will ask the applicant to talk about the business plan. Next, if there are other people present, she will hear from those who are here in support of the issuance of the license and those with concerns about the issuance of the license; and, she will review the letters / emails that were sent regarding these applications. 1202 Jackson Street Mr. Jeff Fischbach, DSI, provided the staff report for 1202 Jackson Street. District 6 Planning Council has recommended approval subject to conditions stipulated in one of their letters. Regarding inspections, Building is not applicable; Environmental Health is not applicable; License has approved with conditions; Zoning has approved with conditions. The Department of Safety and Inspections recommends approval with the following conditions: 1. The number oF vehicles displayed "for sale" outdoors sha11 not exceed fifty (50). All display vehicles on site must be parked as shown on the approved site plan OS-157109, on file with the Department of Safety and Inspections (DSI). (Any changes to the site plan must be approved by the Zoning Administrator.) />��-�.3� 2. The required parking spaces for customers and employees is fifteen (15), there are at least fifteen (15) additional spaces maintained for customer and employee use in the lot, all vehicles on the site must be pazked as shown on the approved site plan on file with DSI, OS-157109. Employee vehicles may not be pazked or stored in the alley. 3. There shall be no exterior storage of vehicle parts, rires, oil or any other similar materials associated with the business. Trash will be stored in a covered dumpster. Storage of vehicle fluids, batteries, etc., sha11 be in accordance with the Ramsey County Hazardous Waste regulations. 4. At no time shall any vehicles be parked in the street, driveway or in the public right-of-way. This includes vehicles awaiting repair, vehicles awaiting sale or pick-up or customer and employee vehicles. 5. The storage of vehicles for the purpose of salvaging parts is expressly forbidden. All vehicles pazked outdoors must appeaz to be completely assembled with no major body parts missing. Vehicle salvage is not permitted. 6. No auto repair of vehicles may occur on the exterior of the lot or in the public right-of-way. All repair work must occur within an enclosed building. 7. Auto body repair and auto body spray painting is not permitted. 8. Customer vehicles may not be parked longer than ten (10) days on the premises. It shall be the responsibility of the licensee to ensure that any vehicle not claimed by its owner is removed from the lot as permitted by law. 9. Provide maneuvering space on the property to allow vehicles entering and exiting the site to proceed forward. Backing from the street or onto the street is prohibited. 10. Licensee must comply with all federal, state and locallaws. 11. The auto repair garage license is approved for a more limited service center (light mechanical only) and no oil changes. 12. Failure to remain in compliance with license conditions will result in adverse action against the license. Note: The Second Hand Dealer Motor Vehicle License is issued on the condition that the State of Minnesota Dealer Number is submitted to DSI upon issuance by the State of Minnesota Dealer Unit. Ms. Moermond asked Mr. Antrim if she has had a chance to look over the conditions. She replied that she had. The Land Use Task Force is a little concerned about condition #11. District 6 would like clearer language explaining "limited service center" and "light mechanical only." If there are going to be no oil changes, they are concerned as to why there are multiple hoists at the location. Mr. Hawkins explained that condition #11 was agreed to by the last licensee and this direct language had been requested by the District 6 Planning Council. The request came in on September 21, 2006. Ms. Antrim stated that the applicants were at the district meeting. The Land Use Committee was concerned about what type of repair work is going to be done there. They would like more of a clarification. Are the vehicles going to need an abundance of work done on them? Is that why there is a hoist? Mr. Hawkins stated that they certainly can change the language to something more specific, as long as the licensee is agreeable. Ms. Moermond asked if there is a definition of "light mechanicaP' in the Code. Mr. Hawkins replied that usually when you talk about "light mechanical," it includes oil changes, lube jobs, topping off fluids, changing fluids and filters, eta Services that are done by Jiffy Lubes, Quick Trips, etc; in and out services. The licensee isn't buying junk vehicles, so he isn't going to be ��-7�� putting in motors, transmissions, etc. An auto repair license would allow the general licensee to repair someone's vehicle, but in this case, that is not what the licensee intends to do. Mr. Crain needed to get a separate license because he wanted to expand across the street and the City couldn't vacate the street. The gazage will be used to put in headlights, top of fluids, detail, check tires, etc. Ms. Antrim asked if this was going to be a service station that is open to the public or is this going to be a service station to check out the vehicles prior to putting them up for sale. Mr. Fischbach added that Mr. Crain has signed a conditions affidavit agreeing to abide the conditions. Perhaps, he could explain his business operation at 1202 Jackson Street and then we could go from there to figure how to address condition #11. Mr. Crain stated that they are not going to be operating like a service station open to the publia The hoists will be used to inspect vehicies that are purchased at the auctions. They will be handling newer model cars. The things that will be done to service these vehicles are topping off fluids, changing some light bulbs, changing tires, detailing, etc. There will be no oil changes or handling any hazardous waste. The cars will be taken to Jiffy Lube or other service stations that handle other things. He added that he has three (3) other lots on which they do the same thing. They do not handle hazardous waste. Perhaps 70% - 80% of the vehicles wili still be under full factory warranty. Mr. Fischbach asked if he will have a mechanic on duty and will he offer warranties on the vehicles that are purchased, and if so, when something goes wrong, where does the customer take it for repair. Mr. Crain answered that they are required by the State of Minnesota to offer a warranty on cars that have 75,000 miles or fewer on certain years. If there's a problem with those vehicles, they come back and are sent out to be repaired; something thaYs covered under 30 or 60-day warranty. Mr. Crain noted that they will not have a mechanic on duty. They have a lot person, who is currently working at his Crystal lot, who will come to Saint Paul once the license is granted. Ms. Moermond said that she would like to have condition # 11 modified to clarify what "light mechanical only" means. Examples have been given; perhaps a few can be included in the condition. Mr. Fischbach suggested that perhaps Mr. Crain could provide a more detailed business plan in which the types of auto work that will be done are more clearly defined: stating exactly the types of repairs he proposes to do (dated and signed). With that, the condition could be modified including examples. Mr. Hawkins noted that auto detailing does not require a license. The auto repair license is an expansive license. In this case, we could eliminate the auto repair license, so there would be no temptation to do more. It wouldn't be so difficult to regulate. Ms. Antrim added that she is concerned that their hands would be tied when they needed to change a battery (under auto repair), etc. Ms. Mulligan added that the Fire Marshal was out to inspect on Friday. He said that their categories are repair, service and warehouse. The previous business had been categorized as "repair;" given the changes that have been made, Jackson Auto Sales will be categorized as "service" only. Mr. Fischbach noted that Fire Inspection's categories aze somewhat different from license's categories. Ms. Moermond stated that on that same condition, she would like to see language added to include, "no outside/public service." Ms. Antrim said that the only other thing that the Land Use Committee talked about is to provide more of a buffering, some landscaping and a holding pond. In 2005, the Capital Region Watershed District recommended adding an approved drainage basin at the southeast corner of the lot. District 6 would like them to go back and evaluate if some sort of storm water plan will be needed. Old Maryland Avenue ��s� ��� goes through the two properties down a hill, and there's a railroad track at the bottom of the gulley. Mr. Hawkins noted that in January 2006, Quinten Mencken went through site plan approval which recommended a proposed infiltration pond. Mr. Fischbach asked if that site plan review had been sent to the Watershed District. Mr. Hawkins replied that they aze invited to every site plan review the City has. Ms. Moermond asked the size of the site. Mr. Hawkins answered that it's under an acre: 34,000 squaze feet. Ms Moermond asked Mr. Crain if he's considered any landscaping ideas. Mr. Crain responded that they will be adding landscaping beautification once the licenses are approved. They plan on seal coating the lot and striping it this weekend; and, making both sites look very professional. 1200 Jackson Street Mr. Fischbach reported that regarding inspections, Building and Environmental Health aze not applicable; License approved it with conditions; Zoning approved it with conditions. The District 6 Planning Council sent a letter recommending approval subject to conditions. DSI recommends approval with the following conditions: 1. The number of vehicles displayed "for sale" outdoors shall not exceed twenty-nine (29) in the main lot (front) approved 10-19-95 and thirty-six (36) in the overflow lot (back) approved 5-9- 02, for a total of sixty-five (65). All display vehicles on the site must be parked as shown on the approved site plan on file in the Departrnent of Safety and Inspections (DSI). (Any changes to the site plan must be approved by the Zoning Administrator.). 2. The required number of pazking spaces for employees and customers is ten (10). There aze ten (10) spaces in addition to "for sale" vehicle display spaces mazked for customer and employee use in the front lot. Ail vehicles on the site must be pazked as shown on the approved site plan on file in DSI, dated 10-19-95. (Any changes to the site plan must be approved by the Zoning Administrator.). 3. Customer, employee or sale vehicles shall not be parked or stored on the street, a11ey or right-of- way. This includes cars which have been detailed and are awaiting pick-up by their owners. All display vehicles on the site must be parked as shown on the approved site plans on file in DSI, dated 10-19-95 and 5-09-02. At no time shall the total number of vehicles on the two lots exceed seventy-five (75). (Any changes to the site plan must be approved by the Zoning Administrator.) 4. There shall be no exterior storage of vehicle parts, tires, oil or other similar materials associated with the business. Trash will be stored in a covered dumpster which shall be enclosed with a wood obscuring fence at least six (6) feet high. 5. The license holder agrees to maintain the fencing, vehicle location and vehicle barriers in a manner consistent with the approved site plans. 6. All vehicles parked outdoors must appear to be completely assembled with no major body parts missing. 7. Vehicle salvage is not permitted. 8. Auto body repair and painting are not permitted. 9. Auto repair is not permitted. All detailing of vehicles must occur within an enclosed building. 10. Customer vehicles may not be parked longer than ten (10) days on the premises. It shall be the responsibility of the licensee to ensure that any vehicle not claimed by its owner is removed from the lot as permitted by law. 11. Provide maneuvering space on the property to allow vehicles entering and exiting the site to proceed forward as stipulated on the approved site plan. 12. Licensee must comply with all federal, state and local laws. � d� y� 13. Storage of vehicle fluids, batteries, etc., shail be in accordance with Ramsey County Hazardous Waste Regulations. 14. Failure to remain in compliance with license conditions wiil result in adverse action against the license. Note: The Second Hand Dealer Motor Vehicle License is issued on the condition that the State of Minnesota Dealer Number is submitted to DSI upon issuance by the State of Minnesota Dealer Unit. Ms. Moermond asked the difference in the conditions between the two (2) sites. Mr. Fischbach responded that there is an additional license at 1202. There's a difference in the number of vehicles permitted at each location; they both have sepazate site plans. 1200 Jackson stipulates some pazking requirements. The rest of the conditions aze similaz, except far "auto repair not permitted" at 1200 Jackson because they're not requesting an auto repair license. Regarding 1200 Jackson, Mr. Crain stated that the building had two (2) overhead doors. They intend to pull a permit and talce out the doors and turn that space into a greeting and customer space. They will put in show room glass and make it look much better. Mr. Crain stated that it's to their own advantage to beauty their space. He added that every week, people are dumping garbage on these sites. Last week, someone stole a whole section of a wooden fence. Mr. Crain is anxious to comply with everything the City wants, so that they can open up and provide security. He is looking for advice regarding types of landscaping. Ms. Antrim noted that the Land Use Committee could meet with Mr. Crain to discuss specifics. Mr. Hawkins is looking for a date certain to have all of these things done or he can enforce off the site plan. Mr. Fischbach added that a copy of site plan went out with his license notification letter. Ms. Moermond asked for a copy of the site plan for the file. If Mr. Crain comes up with a plan that's different from the site plan, Mr. Hawkins would be willing to re-evaluate. Mr. Fischbach asked when he can expect a signed statement from Mr. Crain, detailing the type of auto repairs that he's going to make at 1202 Jackson. Mr. Crain replied that they could FAX it to him this afternoon. Ms. Moermond summed up that one condition will be re-written to define "light mechanical only." There will also be language to explain that this is not a service for public use; only for the vehicles on the lot. After the conditions have been established, DSI will sent Mr. Crain an affidavit of conditions to sign and return to DSI. Today's hearing minutes will be written and a resolution will be drawn up for each address and requested licenses to be signed by the ward's councilmember, in this case, Councilmember Lee Helgen. It will then be put on the City Council agenda as quickly as possible. Ms. Antrim stated that both parties responsible for the letters from the Tri Area Block Club were present at the Land use Task Force meeting, and the District 6 Planning Council was unaware that there were any letters sent until just a week ago. Ms. Moermond noted that in reviewing the letters, it seems that most of the concerns center around the previous ownership and license holder; and there is some question as to what the relationship is between the current license applicant and the previous license holder having to do with business decisions, lease agreements and so on. On record, DSI staff has lease agreements, ownership information about the land — this is all maintained as a matter of course and is all public information. Mr. Fischbach replied that they have a purchase agreement between the previous owner and the current license applicant. Mr. Crain is shown as the property owner. Ms. Moermond asked if there has ever been any reason to investigate this. Mr. Fischbach answered that there has not. Ms. Moermond asked staff if they have 5 ��-�.�b ever had any complaints about signage at either 1200 or 1202 Jackson Street that needed to be investigated. Both Mr. Fischbach and Mr. Hawkins replied that they have not. Mr. Fischbach noted that he doesn't see any sign permit for the replaced signage. Mr. Crain responded that he had the signs professionally made. Mr. Fischbach said that normally the sign maker pulls the permit. Ms. Mulligan will send a copy of the invoice to DSI so that the permits can be investigated. Ms. Moermond added that the majority of the concems raised by the Tri Area Block Club aze not things that she can handle in this hearing. The other items have been handled by way of landscaping concems and what kind of work can be done at which site. To clarify, Mr. Crain explained that he pwchased this property in 1998. He was the sole owner of this business. In the eazly 2000s, he sold the business to Mr. Mencken who was the sole owner. Mr. Crain said that he had no decision making authority; he had nothing to do with it other than being the landowner. Everything that has taken place at the business during that time was solely Mr. Mencken's responsibility. Ms. Moermond asked staff how long the deparhnent would grant before compliance of the site plan is enforced. Mr. Hawkins responded that staff would inspect either in September or October, before it would be too late to plant anything, etc. Ms. Moermond asked Mr. Crain if he could have the landscaping finished by the end of November. Mr. Crain replied that he could. Ms. Moermond asked staff to put a six (6) month enforcement on the site plan. Mr. Crain asked Ms. Moermond and staff to expedite the process. The business has been shut down since February, 2008 and iYs been an extreme expense. Ms. Moermond replied that staff will do their best to get it on the City Council agenda by July 2, 2008. She encouraged Mr. Crain and District 6 to talk with the wazd office about expediting the resolution also. Ms. Moermond will recommend approval for both 1200 and 1202 Jackson Street with conditions as discussed and listed on the attached resolutions. The hearing was adjourned at 220 p.m. /jab