SR-11-B (15)
1.
.
e
:2 0 tj--tPo 3
PPD:PJS:CSR:lw
Council Meeting of February 28, 1984
Santa Monica, California
11-13
fEB 2 8 \984
TO: Mayor and Clty Council
FROM: City Staff
SUBJECT: CIty'S Powers to Regulate Alcohol Outlets
IHTRODUCTIOH
At its November 29, 1983 meeting, the CIty Council requested
staff to research the City's options to regulate llquor stores
and to determIne the appropriateness of adopting
interim
restrIctions on opening new liquor stores prlor to adoption of
the City's Land Use and Circulatlon Elements and subsequent
zoning ordinance revisions.
Because the issue of liquor stores
is part of a larger issue of alcohol consumption and
avaIlability, thls report dlscusses all types of alcohol outlets
and recommends an interim control measure until the CIty'S Land
Use Element is adopted and more detailed, specIfic analysis is
completed.
Permanent control measures will require in-depth
study and should be tailored to the type of alcohol outlet and
characteristICS of the neIghborhood involved.
The potential
revenue and employment implications of outlet control should be
analyzed as well as the mechanics of administering and enforcing
the controls.
The information presented in this report
illustrates the variety of conditions that exist in the City and
WIth supplementary data, may be useful information in developing
revised ZonIng Code provisions.
l\ -:8
fEB 2 8 J9~
.
\
( -
Mayor and City Council
tit
February 28, 1984
This report presents background information about the problems
associated with alcohol availability, a brief review of City's
residents' concern regarding alcohol outlets, a summary of
current state and City regulations of outlets, a descrlption of
varlous local options for outlet regu1atlon, a brief overview of
the City's POlICY regarding alcohol outlets on Main Street, and
presents recommendatIons for both interim control of alcohol
outlets and an appropriate policy for MaIn Street liquor licenses
protests WhICh is based on additional dIScussion with Ocean Park
residents.
BACKGROUND
Recent empirIcal studies indicate there is a complex array of
interrelationships between the availabilIty of alcohol. the
consumptIon of alcohol, and resulting community problems.
Research findIngs indicate that:
o there is a relatIonship between the availability of
alcohol and speCIfic alcohol-related problems. For
example, the number of beer bars IS significantly
related to public drunkeness and drunk driving;
o there is a relatIonship between the availabIlity and
dlstribution of beer and the total accident rate,
tra ffl c ace ident mortal i ty, and accidental deaths in
the workplace;
o ('onsumption of alcohol is related to a number of
fa('tors including availability, per('eived
availability, social norms regarding drinking, and
affordabillty;
o when the other fa('tors leading to alcohol consumption
are high, reducing or restricting the number of
alcohol outlets tends only to shift the geographi('al
locatIon of purchase;
2
-
Mayor and City Council
e
February 28, 1984
o substantial increases in availability have been shown
to lead to increases in consumption, but small
changes in availability generally fail to produce
demonstrable effects on drinking and drinking
problems;
o local regulatIon has little effect on decreasIng
consumption rates but can hold availability
artIfIcally low. restricting future Increases in
consumptIon;
o zoning that controls alcohol outlets has greater
potentIal for producing overall community benefits
(reduction of alcohol-related crimes in "sensitive"
areas) than for achieVing direct control over an
Ind 1 v Idua!' s use of alcohol;
o acute problems of alcohol use (alcohol related
accldents and InjurIes) appear to be susceptible to
local regulation through the restrictIon of outlets
selll ng alcohol for consumption on the pr em i s es near
sensitIve areas such as parks, beaches. transportation
routes, and freeway on-ramps than are chronic alcohol-
related health problems (alcoholIsm, cirrhosis);
o chronic problems such as alcoholIsm and other alcohol-
related Illnesses are not signlflcantly impacted by
restrIctIons placed on alcohol sale by one community
located within a metropolItan area where alcohol is
readIly avaIlable elsewhere.
o Permanent measures to control alcohol outlets will be
more effectIve if they are used to delineate tho~e
locatIons or areas where alcohol sale would be least
senSItIve to potential alcohol-related problems and
less effective if they are used to control alcohol
consumptIon in general.
LOCAL CONCERN AID STATISTICS
In Recent years, Santa MonIca residents and communIty groups have
become increasingly concerned about problems associated WIth
alcohol outlets throughout the City. Residents and groups are
unwilling to overlook the increasing problems of the nOIse,
crime, and general nUIsance that may result from the alcohol
3
It
Mayor and CIty Council
e
February 28, 1984
outlets in their neighborhoods. Concern is increasing for both
the steady increase in the number of alcohol outlets in the CIty,
and the concentratIon of outlets In particular neighborhoods.
Concern is also increasing for the potential impacts of "new
types" of alcohol outlets that are beginnIng to appear, such as
mInI-markets, drug stores, and fast food restaurants.
Alcohol Outlets Citywide
Between 1980 and 1983, the number of active retail alcohol
lIcenses In Santa MonIca increased by 7.4$, from 312 licenses to
335 licenses. The number of licenses for restaurants increa~ed
by 13.3$ (165 licenses in 1980 to 187 licenses in 1983) and for
lIquor stores by 9.7$ (93 In 1980 and 102 in 1983). The number
of licenses for bars and club/other alcohol outlets decreased
over the three year period. (See Attachment 1: Number and Type
of Alcohol Outlets in the Ci ty of Santa Monica.)
In October 1983, there were 335 actIve retaIl alcohol licenses in
the City of Santa Monica. Most of these alcohol outlets (about
55.8$ or 187) were restaurants ~ith licenses to serve alcohol on
the premises (on-sale license); 30.4$ (102) were liquor stores
or other buslnesses WhICh were permltted to sell alcohol for
consumption off the premlses (off-sale license);
8.1$ (27) were
bars; and the remaining 5.7% (19) were clubs or other outlets
which were permltted to serve alcohol.
When developed, permanent control measures should consider not
only the steady increase in outlets but also the types of outlets
in the CIty.
LI
. e
Mayor and City Council
e
February 28, 1984
Alcohol Outlet Location and Concentration
Santa Monica may have an overconcentration of alcohol outlets
CItYWIde and many of these outlets appear to be concentrated
within particular areas of the C1ty as well. However, similar
concentrations of outlets in different neighborhoods do not
necessarily result in sim1lar problems.
The State Department of Alcoholic Beverage Control (ABC) has a
general defin1tion for overconcentration of alcohol outlets i:;.
Los Angeles County.
In general, for off-sale outlets,
overconcentratlon may occur when there 15 more than one outlet
for each 1,039 residents and for on-sale outlets more than one
outlet for each BOO reSIdents. In 1983, there were 102 off-sale
outlets and 233 on-sale outlets In the C1ty of Santa Monica.
Using the ABC's overconcentration definitions and an estimated
populat1on of 89,000 for the City in 1983, Santa Monica could be
classif1ed as having had about 16 more off-sale outlets (llquor
and other stores sellIng alcohol) and 122 more on-sale outlets
(restaurants, bars, clubs, etc.) than the ABels threshold for
potential overconcentration.
Santa MonIca contalDs an "overconcentration" of on-sale alcohol
outlets because the City contains a greater concentration of
restaurants than is found in Los Angeles County as a whole, and
most restaurants serve alcohol. Accord1ng to the State Board of
Equalization, in 1983, Santa Monica contained about 3.8
restaurants per 1000 residents while Los Angeles County contained
about 2.2 restaurants per 1000 residents.
5
, Mayor and City eolC'il
e
February 28, 1984
Many of the City's alcohol outlets were concentrated in the
Downtown area WhICh contained the greatest number of outlets
(83). Most of the alcohol outlets outs1de of the Downtown area
were located on Wilshire (59), fico (31), Main Street (29), and
Santa Monica and Lincoln Boulevards (21 each). Fewer outlets
were located on Montana Avenue (18) and Ocean Park (10)
Boulevards. The remaining 63 alC'ohol outlets were located in
other commercial areas of the City. (See Attachment 2: Table 2
-- Location of Retail Alcohol Outlets 1983 and Attachment 3:
Maps)
Areas of the Clty d1ffered in the type of alcohol outlet
concentrated 1n the area. Most of the alcohol outlets in the
Do W::l tOW:l (74.7"), 0 n W II s hi r e Bo u leva r d ( 64.4 $), and 0 n M a i 1'1
Street (62.1%) were restaurants with on-sale llcenses. These
concentrations exceeded the Cltywide percentage of alcohol
outlets that were restaurants WI th lIquor licenses (55.8S). Most
of the outlets on Montana Avenue <17.8$) and Ocean Park Boulevard
(50.0%) were lIquor and other stores with off-sale licenses. The
concentratIon of llquor and other stores wIth off-sale licenses
on these streets and on Santa Monlca Boulevard (42.9%), fico
Boulevard (38.7%), and Lincoln Boulevard (33.3$) exceeded the
CitYWIde percentage of outlets that were liquor or other stores
wlth lIquor licenses (30.4%). The concentration of bars on Main
Street (17.2'.0, Santa Monica and Lincoln Boulevard s (14.3S each),
and Pico Boulevard (12.9S) exceeded the Citywide percentage of
outlets that were bar s (8.1 %). (See Attachment 2).
6
, It
Mayor and City Council
-
February 28, 1984
Since liquor stores may produce different neighborhood impacts
than restaurants that serve beer and wine, future Clty actions to
control alcohol outlets must consider the type of outlet
concentratIons that eXIsts in speciflc areas of the City.
Hew Types of Alcohol Outlets
New types of alcohol outlets are beginning to appear or are belng
proposed in Santa Monica and other communities. Santa Monica has
attacted a number of small, 24 hour, convenience "mini markets"
WhICh sell or propose to sell alcoholic beverages among other
goods. This type of market often replaces the former serv~ce
bays of serVlce stations and combine gasoline sales with the sale
of convenIence goods and alcohol.
In proposals for new food
markets in the CIty, it is sometimes dIffIcult to distinguIsh the
dIfference between a convenience food market that sells some
alcohol and a liquor store that sells some food. The owner of a
drug store on the Third Street Mall has recently inquired about
the posslbllity of selling alcohol and future outlets could
1 n c 1 u d e fa s t f 00 d res tau ran t s . ( The 0 w n e r 0 f a He Do n a 1 d's a t
Mammoth Lake recently requested a liquor license but withdrew the
applIcation due to public outcry.) It appears that the variety
of alcohol outlets is expanding from those more traditional
outlets such as bars, restaurants, liquor stores, and
supermarkets.
7
e
Mayor and CIty CouncIl
e
February 28, 1984
Recent Community Action
The increasIng concern about alcohol outlets and their negative
impacts on neIghborhoods and the community as a whole is evident
in recent plans and actions.
The concern of the business
community is illustrated by the formation by the Chamber of
Commerce of a Public Inebriate Task Force to study the issues
related to alcohol consumptlon and availabllity, among other
to pIC S .
Community resldents' concern is eVIdent in the features of
neighborhood plans. The 1980 Main Street Plan and subsequent
"CM" Main Street Special CommercIal District zonIng limited the
number of bars and restaurants and required the approval of a
condItIonal use permIt for liquor stores. WhIle the Main Street
Plan and "eM" zonIng do not address specifIcally the issuance of
liquor lIcenses,
they do attempt to lImIt the potential number
of outlets through density limlts to help control the
overconcentration of uses WhICh often result in excess noise,
trafflC, parking, and crime problems.
The Pico Neighborhood Community Plan prepared by Pico
Neighborhood residents in 1983 clearly stated the concerns of the
neIghborhood regarding the proliferation and concentration of
liquor stores in that Communiuty. The Plan asserts that many of
the more than 30 liquor outlets in the Pico Neighborhood were the
source of anti-social and criminal activity and that the
residents felt the number of liquor outlets exceeded a reasonable
8
e.
Mayor and CIty CouncIl
e
February 28, 1984
level for a healthy neighborhood.
One actlvity listed in the
Plan was to sponsor a Clty-wide workshop to consider the problems
of liquor stores and identify solutions.
Residentsl concerns are also reflected in the Draft Land Use and
Clrculation Elements which address the problem of
overconcentration of alcohol outlets by proposing a Cl ty pol icy
to limit or control the number of alcohol outlets in neighborhood
commercial districts. The Draft Elements suggest that the City's
Zoning Code provisions include a " use quota system" to limit
the number of any use such as liquor stores where an over-
concentratlon would have adverse impacts on surrounding areas.
The Draft Elements state that determIning the appropriate density
would require further analysis prIor to implementation if the
policy is adopted.
~TATE ,REGULATIOH OF ALCOHOL .OUTLE~S
Artlcle XX, Section 22 of the California Constltution gives the
California Deparment of Alcoholic Beverage Control (ABC) the
exclusive authority to lssue license for the sale of alcoholic
beverages for consumption on or off the premises.
Local
jurisdictions are prohibited from taking action that would
infrInge on this authority.
The ABC can either approve,
conditionally approve, deny, suspend, or revoke any license for
good c-ause.
In addition to denYlng a license based on the
actions or crlmlnal record of the applicant, the ABC !!!ay also
deny a license when any of the following conditions or
9
r Mayor and City CO~Cil
e
February 28, 1984
characteristlcs occur at a particular location:
o the premises is located in a high cr1me area (20$
more reported crime per population than the city
average) and there is an overconcentration of alcohol
outlets (-Rule 61.3). The ABC 1s very cautious in
using this reason;
o the premises is located wi thin 200' (for an off-sale
llcense) and within 600' (for an on-sale license) of
a school, publIC playground, church, or hospital and
it can be shown that the issuance of a permit would
be contrary to pUblic welfare and morals;
o the premises are within 100' of a residence and the
appllcant is unable to establish that the operation
of the premises will not interfere with the Quiet
enjoyment of the property by residents.
Local Jurisdlctions can exercise some control through the
community's zoning ordlnance. Provisions of ABC eode Sections
23790 state that the ABC shall not issue licenses for any
premlses which are located In any area where the rights and
prlvlleges conferred by the license would be contrary to valld
local zonlng ordinances.
The ABC may regulate the condltions of alcohol sale by setting
restrIctlons regarding:
o the personal conduct and qualiflcations of the licensee;
o the conduct of business or condItIon of the premlses;
o the hours of operation;
o the display of signs;
o the employment of designated persons;
o the type and strength of alcoholic beverages to be sold or
served;
o the limItation of the off-sale priveledges associated with
on-sale licenses (unless restricted restaurants can sell beer
and wine to go);
10
e
Mayor and City Council
e
February 28, 1984
o the downgrading of a license from on-sale to off-sale;
o the forbIdding of video games in off-sale premises; and
o the monitoring of on-sale restaurants and off-sale food
stores by requiring these establishments to maintain records
in a way so it can be verified that these businesses sell
more food than alcohol.
The ABC II~ense application review process involves a number of
steps begInnIng with the submittal of the application to the ABC
DIstrIct offIce staff who investigates the applicant's
background. ThlS review includes an assessment to determine that
the appllcant has no ~rIminal history, an aceeptable source of
funds, and wlll be the only person dIrectly responsible for the
operatIon of the premises. During the investigation, the ABC
contacts the local zoning office to ascertaIn If the sIte is in a
sUItable area. Notification of the application occurs in the
following ways:
o posted notices on the premises for 30 days,
o notlce to all persons reSiding or doing business
wlthln 100 feet of the location,
o written notices to the local police department and
legislatlve body,
o notIces In newspapers for all on-sale licenses
(restaurants and bars)
In additlon to original licenses, applications are also processed
for transfer of licenses between persons but, in general, the
ABC ~hecks only the applicant's background since the premises has
already been found suitable for licensing. The ABC may process
applications for changes in the type of liquor license (ie. on-
sale restaurant to on-sale bar) in the same manner as a new
llcense.
11
e
Mayor and City Coun~il
e
February 28, 1984
If no ~omplaints are received and the ABC background evaluation
IS acceptable, the District Office recommendatlon is forwarded to
the State office for issuance of the license.
However, any
person may protest the issuance of a liquor license.
Local
agencIes may protest the issuance of lIcenses but must state
reasons for requesting a denial such as a possible increase in
crime or an aggravation of a parking shortage that would result
from issuance of the liquor license. A protest must be made
within 30 days from the first date that a notIce of application
to sell alcoholic beverages (or a notice of application for
ownership change) is posted on the premlses.
The appl icant may
wIthdraw hIS or her application In WhICh case he or she may not
file a new applicatlon for the same premises for one year If the
appl icatlon was wi thd r awn bee ause 0 f the protest.
All prote sts
remain valid for one year agaInst subsequent applications for the
premIses. If the applIcation is contested, the ABC determines if
the challenge is based on Department laws and regulatIons and
thus meets the requirements for a hearing before a California
AdminIstrative Law Judge. If the application does result in a
hearIng, the hearing findings are used at the ABC's discretion.
HearIng deCISIons may be appealed to the State ABC Appeals Board
(having the effect of a lower court finding), to the Appellate
DiviSIon of the State Court, to the State Supreme Court, and
finally the U.S. Supreme Court.
12
Mayor and CIty COU~il
e
February 28, 1984
Constraints and problems of this system include the following:
o Section 23790 of the ABC Code protects licensees
from zoning ordinances which take effect after the
outlet is operating as long as the outlet retains
the same type of retail license within a license
classification (on-sale or off-sale) and operates
continuously without substantial changes in .ode or
character of operation. The ABC would not revoke an
approved liquor licence due to newly adopted zoning
ordinances. However, Section 23790 does not effect
the right of a local juriSdiction to enact zoning
ordinances that classify certain alcohol outlets as
non-conformlng uses WhiCh are to be closed or
removed after a reasonable amortization period.
However, density reductions over the short term
would be difficult to aChleVej
o State regulation of alcohol retailing tends to
ignore the consequences of outlet location and
denSIty patterns. The licensIng declsions generally
involve only determInIng the competence and
character of the operators not the community-wide
effec ts of the av all ablll ty of alcohol ic bev er ages
In the area;
o ABC regulations include only one provision for
denial of licenses based on density (Rule 61.3) and
this is used lnfrequently;
o The ABC also has monitoring and enforcement
authority. However, the ABC has had staff and
budget cutbacks and has placed lowest prIorIty on
licensee monitoring and code enforcement, leavlng
thIS to local jurIsdictions with which it legally
shares responsibility.
o ReSldents are notIfIed only if they live within 100
feet of the proposed site;
o Public notice in a newspaper is only mandatory for
restaurant and bar liquor licenses; notices on
liquor and other retall store applications are only
pUblIshed for those located in high crime areasj
SANTA MOHICA REGULATION OF ALCOHOL OUTLETS
Santa Monica currently has few regulations regarding alcohol
outlets In the eity. The City's current Zonlng Code does not
contain any provIsions that regulate the number or location of
13
e
Mayor and City eouncil
e
February 28, 1984
alcohol outlets except in the "CMn Main Street zone. The Zoning
eode permlts lIquor stores, restaurants, bars, and/or other
potential alcohol outlet uses in all commercial and industrial
dlstricts of the City.
The nCM" zone on MaIn Street between
PICO Boulevard and the southern clty limit permits liquor stores
(stores in whi~h more than 50S of the display area is devoted to
alcoholic beverages), bars, and restaurants wIth 50 or more seats
only wlth the approval of a condltion~1 use permIt. There are no
density limltations for liquor stores but there can be no more
than 12 bars on Main Street (no more than 3 new bars south of
Ocean Park Boulevard and 4 north of Ocean Park Boulevard). The
"eM" Main Street zonIng provISlons permit up to 22 restaurants on
Main Street WIth no more than two per block. All restaurants
that existed prior to adoption of the zoning provlsions are
permItted to remaIn so some blocks exceed the density limIts.
UntIl adoption of the City's Land Use and Circulation Elements,
most new development or changes of use require the approval of an
Interlm Development Permit. The Plannlng Commission (or CIty
Council on appeal) in approving a permit must find that the
proposed proJect, among other flndings, wIll not preJudice the
abilIty of the City to adopt a revised Land Use Element. The
CItylS guidellnes for proJects that WIll not preJudIce the City's
ability to adopt a Land Use Element (Resolution 6385) contains no
standards for alcohol outlet~ other than recommending that liquor
stores and bars require a conditional use permit.
14
.
e
Mayor and City Council
-
February 28, 1984
Provisions in other sections of the Municipal Code control and
regulate the operation of businesses selling alcohol, but these
are limited to the business licensing and healthy operation of
the business.
LOCAL ZONING OPTIONS
Slnce the State has exclusive authority to issue liquor licenses,
local optIons for controlling alcohol outlets are somewhat
limited.
CIties and countles can establlsh reasonable
condItIons, standards, and density threshold for alcohol outlets
but these actIons may not have the effect of restricting the
State's authority to Issue liquor llcenses.
A review of how other California clties exercise control over
alcohol outlets as well as discussions with planners in these
communities reveal a number of measures which can be undertaken
In addressing this Issue:
o Temporary moratorium can be enacted to prevent over-
concentration of outlets whlle providing time to
assess local needs and posslble actions, partIcularly
in rapidly developing or decllning areas;
o Conditional use zonins WhICh distinguishes between
alcohol outlets and other commerCIal enterprises can
be Instituted. The burden of proof is on operators to
provlde assurances that the operatIon will achIeve
compllance with conditlons. This is an incremental
approach which deals with each case as it arises. Los
Angeles Clty has developed an ordinance for the South
Central area of the City that would require
conditional use permits for all new liquor stores and
all existing liquor stores where the owner applies for
a new type of llquor license, where the existing
premlses is considered to have been abandoned, and
where there has been a substantial change in the mode
or character of the operation of the establishment.
Culver Ci ty requires condl tional use permi ts for all
new outlets within 300 feet of residential areas.
15
Mayor and Clty C~Cil
e
February 28, 1984
Burbank requires conditional use permIts for all
new restaurants and bars for which the owner applies
for an on-sale liquor license and for all existing
restaurants and bars for which there is a change in
the ownership or transfer of the liquor license.
The condltional use permit process allows for greater
public notice/public hearing requirements than
standard ABC noticing requirements and results in
community input which might not otherwise be available
to loc al offlC i al s. In add 1 tion, the cond i tional use
permIt can require certaln conditions such as,
regulatIng the hours of operation or restrictIng the
type of alcohol to be sold to help satisfy neighbors'
concerns about the alcohol outlet.
o Threshold zonln6 which creates special districts that
est a b II s h d en sit Y t h res h 0 Ids b you tIe t t y p e . On c e a
threshold ~s reached for an area, a speclal permit is
required. San Francisco has developed such a process
and has found that ~t has had lIttle regulatory
effect. The City's "CM" Main Street zone also sets
densities for uses most likely to sell alcohol. If
strictly applied, thresholdexclusionary zoning
develops consistency in planning and zoning by
establishlng predetermined and consistent standards.
This method differs from conditional use zoning in
that threshold zon Ing impl ies that no spec ial perm i t
(such as a conditional use permlt) is requIred unless
the threshold limit is proposed to be exceeded.
o Cooperation can be established between State ABC and
1 oc al Jur i sd i ct Ion thro ugh (1) encour agi ng the ABe
to provide immediate notice of applications for on-
sale and off-sale llcenses to provide the CIty WIth
more tIme to evaluate and respond to applications,
(2) monltoring of licensees by the City and
exercising the right to initiate publIC license
revocation hearings showing violatlons of specifIc
ABe codes and standards, (3) urging ABC deference to
local concerns about license application review and
revocation of lIcenses and inclusion of community
"health, safety, morals and welfare concernsft in ABC
monltoring activity.
~AIN STREET LIQUOR LICENSE PROTEST POLICY
The Main Street liquor license protest policy is one of many
issues related to alcohol outlets in the City. On November 29,
1983, the City Council discussed the appropriateness of
16
e
Mayor and City eouncil
e
February 28, 1984
continuing to protest all applications for liquor licenses on
Maln Street. The Council initiated the current protest policy in
November 1979 pending development and approval of the Main Street
PI an.
Staff recommended that the City not protest licenses for
businesses permltted by the Main Street Plan and the "eM" Main
Street zoning and for outlets approved by the C1ty wIth
conditional use permits. Staff also recommended that the City
continue to protest all other retaIl liquor outlets until a
Citywide policy for these types of outlets could be developed
after adoptIon of the Cl ty's Land Use and Circulation Elements.
At the Counc il meeting, re~ndents of the area expressed concern
about the proposed change In the CIty'S protest policy. The
residents felt that the protests provided the only mechanism to
adequately notIfy the neIghborhood of pendIng new alcohol
outlets, that the protests resulted in some applicants
WIthdrawIng their applicatIons thus reducing the number of
potential alcohol outlets in the area, and the protests prOVIded
the CIty with the opportunity to express to the ABC the City'S
desire to reduce alcohol outlets in Santa Monica. The City staff
was concerned that the universal protest of all licenses on Main
Street regardless of whether or not they were permitted by the
MaID Street Plan and "eM" zoning and whether or not they were for
liquor stores approved by the City with a conditional use permit
could be construed by the ABC as an inconsistent City policy on
such protests. Thi:s could resul t in the City losing ered i bill ty
WIth the ABC with a resulting disregard for comments the City
11
. Mayor and Cl ty cote il
II
February 28, 1984
might make on future issues. Council members determined that a
decision on the matter should be delayed until after City staff
was able to meet with the neighborhood residents to clarlfy the
staff recommendation or refine the proposal.
On Fe b r u a r y 8, 1 9 8 4 , C i t Y s t a f f met wit hag r 0 u p 0 f s eve n
reSIdents who were most famlliar wlth Main Street development to
dlSCUSS the alcohol license protest policy issue. Two main
Issues were dIscussed: 1) notiflcation of residents near
potentlal alcohol outlets and 2) the excessive number of alcohol
outlets on the street. The general concensus of those persons at
the meetlng was that the ABC's publiC notification of llquor
license applIcations was inadequate and should be supplemented in
some way. I~ was felt that, at a minimum, resldents wlthin 300'
to 500' of the proposed outlet should be notlfled of the
application and that notification of the neighborhood
organlzatlon representing the area would be useful. Several
people attending the meeting felt that the Main Street Plan and
"CM" Main Street zoning may require some revision since the
Issue of alcohol outlets was not speciflcally addressed. The
people attending the meeting neither endorsed nor rejected City
staff's recommended Main Street liquor license protest policy.
CONCLUSIONS
Empirical studIes indIcate that there is a relationship between
alcohol availability, consumption, and community impact problems.
Review of alcohol license information from the ABC indicate that
18
.
.
e
Mayor and eity Council
February 28, 1984
there has been a steady increase in the number of alcohol outlets
in Santa Monica over the past three year5. An analysis of the
location of these outlets indicates that certain types of outlets
are concentrated In certain areas of the Clty. Based on recent
permit requests both within the City and in other communIties,
new types of alcohol outlets are beginning appear which could
expand the types of outlets located in the City in the future.
CommunIty concern about these issues has increased and is evident
In the formation of stUdy groups and the development of plans
which discuss the problems of alcohol outlets and suggest
solutions to the problems.
The issuance for liquor lIcenses is the exclusive authority of
the State and the rules and regulatIon of the Alcoholic Beverage
Control Department do not always consider loeal concerns or
aggregate problems. The State does permit local jurisdIctions to
extablish reasonable controls and conditions on the location of
alcohol outlet premises.
The City currently has few zoning regulations concerning alcohol
outlets but the Draft Land Use Element is proposing as City
policy that the number of alcohol outlets in the nelghborhood
commercial dlstricts be limited or controlled. The Draft Element
suggests one method that could be used to implement this policy
is a use density system in the Zoning Code which would limit the
number of uses where an over-concentration of the use would have
adverse impacts on surrounding areas.
The Draft Element states
that fur ther anal ysi s 15 requi r ed before spec i fie use den s i ti es
19
-
Mayor and City Council
e
February 28, 1984
are established.
ALTERNATIVES
As mentioned previously, there are a number of measures the City
may enact to control alcohol outlets in Santa Monica. The City
should consider several of these measures when preparing
permanent controls in the future. While it may be useful to
enact a temporary moratorium at this time to stop new alcohol
outlets from locating in the City prior to adopting permanent
control measures, this could cause hardshlps for businesses that
may not be affected by future alcohol outlet controls. It would
appear more approprIate to enact an interlm control measure that
would permit the City to reVIew and approve new outlets on a case
by case basis and to condItIon that approval based on the
specIfic type of alcohol outlet, neighborhood locatIon, and
potential problems involved.
BUDGET/FISCAL IMPACTS
The recommended interim action presented in this report does not
have a budget or fiscal impact.
Budget and fiscal Impacts
resulting from permanent alcohol outlet control measures will be
analyzed when they are developed.
RECOMMENDATIONS
Staff recommends that the City Council:
1) Approve staff's original recommendation regarding City
20
.
Kayor and City Council
e
February 28, 1984
protests of liquor license applications on Main Street, namely
that the eity not protest liquor license applications for:
a. eXIsting liquor stores and new liquor stores for which
the Ci ty has approved a cond i tional use permi t which is
required by the "eM" Maln Street zoning classificationj
b. existing bars and new bars which are permitted by the
"CM" MaIn Street zonIng classification and for which the
CIty has approved the requIred condltional use permit;
c. existing restaurants and new restaurants with 50 or more
seats which are permitted by the "eM" Main Street zoning
provisions and for which the City has approved the
requIred conditional use permit;
d. existlng restaurants and new restaurants under 50 seats
which are permitted by the "eMU Main Street zonIng
provIsions (these restaurants do not require condItional
use permi ts).
The Cl ty would contInue to protest liquor license applications
for retail stores (such as mini markets or gift shops) until the
eIty develops a Citywide policy and control mechanism for these
"new types" of alcohol outlets.
2} DIrect CIty staff to notify OPCO and Ocean Park residents and
property owners of new liquor license applications for businesses
on Main Street. The notice would be mailed to OPCD and residents
and property owners withIn 500' of the business and provide
lnformatlon about the type of license being requested and the ABC
regulations regarding an individual's protest of license
applications.
3) Direct the City Attorney in consultation with the COMmunity
and Economic Development Department to draft an ordinance that
would require the approval of a conditional use permit for all
21
-
Mayor and CIty Council
e
February 28, 1984
new premises from which alcohol is proposed to be sold or served
except on MaIn Street aDd to study the feasibility of requlring
conditional use permits for pre~ise5 for which a liquor license
15 proposed to be transferred or changed to a different
claSSIfIcation. This interim control measure should be in effect
until permanent outlet controls can be developed and approved In
conjunction with a revised Zoning Ordinance that implements the
adopted Land Use and eirculation Elements. Requirements for
approval of the Conditional Use Permit should be those deemed
necessary:
o to protect the public health, safety, and general
welfare;
o to secure the objectlves of the General Plan;
o and to promote the orderly development of the
community.
The Planni:1g eOmmiSSlOn and CIty Council on appeal should
consIder whether the proposed alcohol outlet:
o will adversely affect the welfare of neighborhood
residents;
o wIll contribute to an undue concentration of alCOhol
outlets in the area;
o and will detrimentally affect nearby reSIdentially
zoned areas after consIdering the distance of the
outlet to re:nd ential buildIngs, churches, schools,
hospitals, playgrounds, parks, and other existing
outlets.
ConditIons for approval of the conditional use permIt such as
hours of operation and type of alcohol sold would be decided on a
22
e
Mayor and City Council
e
February 28, 1984
case by case basis depending of the location and type of alcohol
outl et proposed.
4) Direct City staff to study the issue of alcohol outlets in
greater detaIl. once the Land Use Element is adopted,work with
the various communIty and business interests Involved, and
prepare permanent control measures that refine the interim
measure and that are tailored to the area and the type of alcohol
outlet. These refInements should include density limitatIons in
some areas; locatIonal requirements such as dIstance from
schools, churches, parks, and other uses In some neIghborhoods;
reasonable prohibitIons of certain types of outlets from certain
areas; the lIfting of requirements from certain types of outlets;
and other refInements. Appropriate changes would be incorporated
into future changes to the City's Zoning Code.
Prepared by: Paul J. SIlvern, Manager
Christopher S. Rudd, Associate Planner
Program and Policy Development DiVIsion
Community and EconomIc Development Department
Attachments:
1) Table 1:
Number and Type of Alcohol Outlets in
the City of Santa Monica.
2) Table 2: Location of Retail Alcohol Outlets 1983
3) Maps: Location of Alcohol Outlets
23
~ - e e
Attachment 1
Table 1
NUMBER AND TYPE OF ALCOHOL OUTLETS
--
IN THE CITY OF SANTA MOHICA
Number 0 f Current Licenses
eh an g e "
Ty:pe of Outlet 1980-81. 1981-82. 1982-83** 1980-1983 Chane;e
Llquor and Retall Stores
Off-Sale Beer & WIne 44 47 56 +12 27%
Off-Sale General**. 49 47 46 - 3 - 6$
TOTAL 93 94 102 :... 9 + 9.7%
Restaurants
O~-Sale Beer & Wlne 100 108 111 +11 11$
On-Sale General 65 67 76 + 11 17$
TOTAL 165 175 187 +22 +13.3%
Bar
On-Sale Beer &. Wine 5 5 6 + 1 20%
On -Sale General 25 24 21 - 4 -16%
On-Sale Beer 1 1 0 - 1
TOTAL 31 30 27 4 -12.9%
Cl ubs/ Other
On-Sale Beer & Wine
(FIshing Boat) 2 2 0 - 2
On-Sal e Gener al (Cl ub) 8 7 6 - 2 -25%
Or.-Sal e Beer ( food) . If * I 13 12 13 0 0$
TOTAL 23 29 19 4 -17.4%
TOTAL
312
320
335
+ 23
+ 7.4'
· Data provided by Alcoholic Beverage Control, Technical Division,
Sacramento (November 1982).
*1 Actlve retail licenses as of October 7, 1983.
III
"General" IDcludes beer, wine and all other alcoholic beverages.
IIII Business must sell food (sandwlches) but is not required to provide
full restaurant service. Minors are permitted on the premlses.
, .
.
e
Attachment 2
Table 2
LOCATION OF RETAIL ALCOHOL OUTLETS 1983
Street
Liquor and Other
Stores Restaurants
Bars
Other-
Total
Downtown .. 15 (18.1$) 62 (74.71.) 4 ( 4.81.) , 2 (2.4$); 83 (100S)
1
I I
I I
Wilshire Blvd.... 16 ( 27 . a) 38 (64.4%) 3 ( 5.1%) I 2 (3.4%)1 59 (100%)
J
I I
t
Pico B1 v d . 12 (38.7~) 14 (45.2$.) 4 (12.9%) I 1 (3.2~) 31 (100%)
I
,
I
MaIn Street 6 (20.7'1) 18 (62.1$) 5 (17.2'1) I 0 29 (100'1)
I
I
I
Santa Monlca.*. 9 (42.9'1) 8 (38.1%) 3 (14.3%) t 1 (4.8'1) 21 (100'1)
I
I
I
LIncoln 61 vd. 7 (33.3'1) I 9 (42.9'1) 3 (14.3'1) I 2 (9.5$) 21 (1001,)
I
I
I
Montana Ave. 14 (77.8'1) 3 (16.7%) 1 ( 5.5%) , 0 I 18 (100%)
, I
I I
I I
Ocean Park Blvd. 5 (50.0f,) 4 (40.01.) 0 I (10.0'1)\ 10 ( 100%)
I
, ,
I I
Rest of Cl ty 18 (26.6$) 31 (49.21.) 4 ( 6.3$) 110 (15.9'1): 63 (100$)
CITY TOTAL 102 (30.4'1) 187 (55.8$) 27 ( 8.lf,) 19 (5.1'.t) 335 ( 100'1 )
* "Other" Includes clubs, and beer outlets required to serve
some food such as sandwiches but is not requIred to prov id e
full restaurant serVlces.
.. Downtown 1S bounded by Wilshire Boulevard, Seventh Street,
Colorado/, and Dc ear. Aver. ues .
.*. OutSIde the Downtown area east of Lincoln Boulevard.
, . >
.
e
liJ' 'rr:7::-7~"-~f::':"'_'-:,---:- -J
t . ~ ., ...~ - 1 j --.. .......-..--~~
Ii;. I I:' . .." ... "'" ...... { - -:;:.'~ -- ':.. 1
..,!. < i ,. !!... - - r.-~rif'""- - . - -
. r J;' fl. ~tj.~_!l \.0- 0W--:'-'~ -
..~ If" - ~ ,. t;').,'. , "--::.. '-- I I J -
. 1 ....-....... {:-'--.::...- J~J - ( ,I J" ........- I I I
, II ! f '-'~ :..j, '-'~7r II /\ ;;7-:.....17 ~ nN""'~ I. I r I 4 I ·
._! f --' ~1r.La: ': ''::!f~ _,I ~.~i __~\p.(\.,-jf lu rR-:~ri.-..t d-~~"" --~. j I - -!,
~1 j -- .: i~:;::iL~ - j,:~--"JC~ ~ "~.}~~! /1T'jb3f,t:::: \ ~' ~ _), Llr-:-rrrr-r--:--:.. ~ I
~~ --~_ It ~:~ ~1'--:=- .I': Ie-' "', -/.:.;.~:_- -I r: ~~1 1I If . iIJL1c-.,.~'i ----
s' (1'1 -J'It.. ~r.':'--- :~.~-- i'~~ -~L--=l;~ . ::,~-,--lj~~~~~r "i -i~l---~'-l H ~~I-':-,
I~ ! ,.~I:-'-A3rif.:':;::::'~-.!L~.1--::.i, .::::.---8_ .-jJ - r.-----"~'r~3 -J-[~f='J1'or. "r' r
I I ., ''"Tf ,- lr-.,__. -L4L ,r~r -' J{. ,fj-~ -- J/' 'L I I"
~l~._, L . ~ ," y ;,' ! IC-:r-~~::!k-;JL.}H ~. ~f!D r -.: fJ) L'..; "
\' -~~-J . t ,1 I f l' I~l" t I..~..::_~.=:_l ...;r -' Il~~~_ Jr:'-:-:-:J~~.::f J :~1IJ""1'/'~(---11
\ ~ " : ( ; l' f . -- I r~ ~J L - J I r . -'--). ,.0; 'uu;; t. J I , ,1 I -- ,I
'--'lo. ~~- -- . f' ',. - ~ 1"1 r -- -- J l - 1. - 1 h ; I, . ' .It! [f 1-- '
~ -.,..,. ~ ., ~~:---=_ -: r I I ~ ~ : : I r=-= - J I I r'"'-~r~ l...-::t~ ~~r ""~11r1 ,', 1-r1r-1 '
.\....._, ~...~ ' 1 ' -. rJ:.J;_1I . ,~ ~Jo... ~r~'lr -':..-::::;:J.__Ji-rl;.c-ll~__~ 3.!!I)'"-' l' fl~
)..~,. -:......:~ ---- h ~l "_i: 1:-- ::--r.- ,---~~ -, ~"~lll J' ~ !I -ll jf:r
~~;:. C'1Ct",~f1H~ 'in ~r"'~:; ,-'J~~~~::tjE:;p:~jJJt~~;JtJL
i1<~" '~~~~Jiilifl;JI~, ~~rlj;~i'T~Y,'l~?Jt~iJ~~~:Vil'
i L~~~,>:-~.~.1 ~'n, !lill]lJ Jl.jlJ!- ~ ,~Ut,,(ji ],~r :. If! /'1nr-:..;r'
!1-'W~lJ1fi~~_~.T" - ~ -:;: f:l1;l: ~-;I"lf-ll--LH/'LO[:qll'-'f:~ ~I ~!I:J (( 'I j' -
II ~~_ ~JJ ' .~' I ~~~~~.I~:tjJ'!~'~~~:~J--~r~:~rl:,~,,"':h,"~nji~ ..!! IlirJ;-~
! : i ~J.wL_ C~iht~fl- i ~l~ .~: a ~ ~'1~fI~1 ~;:"'~jl~-J~~.j ;;.".
! :;- IfF{[. !.l_JJlllr~[JU][JIJ[!I]][1[]~CJlmJ~~ull~:' ,-
: ',' ~rn~~illllIilJlJtltmDJjl~I1J[Ji1IJ]]])tl1011:Jf~Y i
~l trJtTIf!jOO~rn~.~i!~fftrTii MlTlillli Iml 'r:W1IIII:,II':I'lmmmFlITIJ ilPl I ;
I __
. . =' -
e
.
G {' r~--~-:-:.._. -.
,-.....:.. -4t...... --:~:~ ,.
1" - I -! .'.If "--.-.-:-. - J
l' ( . '" ~". - I' ..... -------~ .
-.:.' I I: 1 J.. ,'" -~ ~~-;"'<t...t 0--.. _ '. "' t .
." , I I, & ~ - - !n-- - -,
~.. '- I f ~-'L--_ - J I .~ \t~ ~ ~ -.. _ __ -...
, n I f ~.... fr4'ttf:::<' "'~ .-.,...... ' I ...
, .. :.--., ........... fi ~ J 4 . ---.. -.. ...
. '- i 1 --- --If --". _Jr~J :< } I' J- :::::..- , " " .
J' II . " L~-J' ~.~ j' 'I..{~ '~~I~ - r--,~r '-1- .. , I, ,
I . -. I I 4 '" ~,'1i';:'-:,L~ J _ ",)?\. 'I I K 'Ir--l- ~ J!...____ ~~r-. ~I, - _: I
-~j . ---:f~)r: 1;'~_JC=~~'.i~}lffftJ~I~1~~_ fJr)fJri'~---; I
- -::~! ---::,- '"~b ~ ~I~"-/L;;:)C~-- ."~~r_:=JJtl-j'ro/l-J_---. tr I !lJ- l._~~'l;,---
I '11'11. r.,. ,:::----- -';~ ~ .J~~ ,>~{~I-.,-_1'-:o-;-::-~-~::~~,:.;~.-r!~~ I ;jaE~--~ J~4 r.'~f:' ~,
if 17 I '-, 01 r-".:"J,:,?- Jc__--1l If ~I~~~ it T~ " . -- JJ~ II~ I' r
-"-JU. . ~ .1/ [;' Ii '~-~IL-:if :.nr:--;r/: ~n i - 'i)' fl !I!J '
__ 1/ (nr'5iC:~~;' [- "I' ~"-i! ' j': '!( if-~- :~;:- J" ( I 'h'! rr'i;"~--~'- i
~' -e:::~ '-' ; If; -, .';- :;<--.:::.:::1 ":,' 'L-"'~j- - JI:-::;, ~:J D. : j I 1"'1 're. ~- i
\_~~~i;v:-~W!N.;Jt J' j i/ --),(~-lr-=-;[~r~~~j~~J")_.Ar1 i J~rt:: .;
~~f' ~~~\1~_ l:f~~c'l' i ~_-C1':'~:-:i'Jk-i'~-lUBri: illlf'
~~~ -. . ~ :~- ~Ct J~"'" J;3rl r~ r~-n--~ll:'-l~~t~ ~~; ~t~jl~~1 FiCi"lr I JI~i~-~J.f-jL
.... I "-~~-['-I '-OJ'' I . - 11" 1 ~ --J! i---'::::': _":.,..'1 tj W--- 1" -.'
".' -'_~~'~' Jill lJI ) ~:;i~jrl--!.~--~l.,-:' ~:--- I}.=-JeB'l.'r
~..~ -:.~ ~hi' lC. "=- - __tit Ll ,I) -. I' ~,. ~ ; ~~ ~J ! if]: ~ -'~_-~1il Jt.;i ril',
~ " -......... I 1L::ih . '[' It I' Ji ..~ I Ii I ~ I ij' ... I _. .
. '~~,~ ~,~ . - ~ !L,t, i I ~:. ~~]~:, .Jl.~ _f::)L: L.U~ 1 j i :_~ : I f '1'i~~r'
i . J "'I 0..' - - ': -; I -. ~It - -, ~ 1 I L.. ' l , . I I .
i I ~ r ': : de~r--. _ ._~ ... h _P -I"r_ tl ''-0.. I-I - --l~~ P I I ,-
~'- - ~:.?/ I~:tf;; Ill__'~-~-:I--~f--'i'I-i~' t!-)~fd~'-I-:~'~il~r:;:[-~J ~!ni~_"l~:'~_~; -:~t.1 ;L~-~:: ,.
-- .-It' 'L.l A' I~ . ,: 1! ::1!. 'I~ ,II - ::.;llr:i'~' ': '"-(v: 1 3..
' I ___ I -L..' ~ -!. ,'1' ~, . I ...;::J Lll " I I .' - '!"1J:'
r: 0 'D L-' :,~ r--_1Ji:lJ~llJ[utJE1[j[Ii1CJ(~Duj[t-llit1[ir~l~ ",
.~~ wrnrn[T~tlJlliIIJ]]Er~ UHYln[rfIJII)CfRltDJj~IiQI_I!j i
'L .WJD~rn~~~Ji~!1[[-:n1 Drnmmrl;Jl,rJJm0[;[lmn')mmm ilml/j;
. . '
e
e
f,/~r~:-~-T;~.1- <~~ --:: j
, I ! J - ~..~
=:. Ii' - . .,.. -' "'t.~ -- ':.'" .
.." ,'_ ,i ", ~~ :,' .~ :["--0- .... ...;.
.' J; '.... -r~!l. >:.":.~ WJ;-- - .. - ' I
.' ~[ 'I ~~ ( ., , -...::. '-- I & -
_ 1 . !'"--~ 11:"__' _4 ,,,,,- I I .. :-'- I '.
" \I ! l f~~~(::'- r~11 -{\\o;Y--....m- J ~I r+-,~~:: J I I, I ·
. f -, , / -.4...... --'/,-- -:., L.:;. J '~+'~\. II, . fR=-l..,.:!~ ~~-~r-- -J . ; - _: ~
=LJ --.:t- . -:;.,:,;: ~''=.JC ~ ~ '!!,:.;.;>;.-,dlffji;;;;;J~' IJ tJr:-T~r..,."':--- - I
- ---':-'r-:!r-- _ ~f=--!i~';~_jD~h~--'~-:"~-~il~-J~I' '- lC~-=~/f'i(ILlr1~~---
! H f (i .. I r41 -~-- ~ h_.. :---:7b..;,: Ji__~_ r~I~, -==-r~-_.:.:~G~l(~ --J1GI:. E. l ~ ~r.'
I . -..... ~ ~ '1. --.. --- l( .......-- .&.1 _. J r I - ~
I; --.., ---. - !__ J' ~. -_ .<- ~ -;:,-~" 'I . '- -~ .. \Ie --ir-';r' '"
- '1- - "--::lr-- ' - J - -_.:.( f ~ ,,-.., --, I I . I
I ~LJ.~ l: ' j. 11. ,'f P ;r ;~~i";lp~~i][;jt~~" rl=- ~t:iJ ~I '
~. ' 'I 'I, ,"'::::'" L--.Jl ;;' r4' .,..../ 1 ' : 'I-ua.a ~- 1["_ H" " J' ~ /1 h' j -lr- ~ 'J-"-"=" I
1 ' ,. J, -I L t ' I I' ' I r - - '.'- 1 j l I !Jl ' I' 1
\, __~ . I : _.r "- :_..:-- ~ ' Il.:uo..Jl J'('~- r--.""'---E.iij 'f "I)ac--,
..... (....., , I ' ~ J ~~ '- ~I I ,--- -"il-i! c_J' I . I
\::~,-~~~;'-" -"l~ ~J /U/J.~ tJ'J. -5/:' i.' --II~~f--l~~ri,:;~lt-;J ~ : ,'ltlnJ~~~ ':
~~. '::I' Ir-'. r~ - J 'I'" I f-' r 1 t '- I j j Ill"-
-Vf : ~, ....: Cf t::c___-[~-~J(---J~,~I ;.-_ ~ ~:._ .~~--- ~'=~?/~i~cJ~ll :]i\ ~L~]I Jf;~
~\ ~ ~CLc-~ ~!~-H~ b I Y,1111: -r--II-.-:)l--:-..:..._Jl.. ~'~--.J.:- =_.-t.r=--='~(I=~~-.-.lr-i!....rl[--jlJl-jL
III .... - ~ - .-....~] - l'~. ~~u~ f; . n I 'I! . l(l J"j -. ~r~: .-Ii r >ar!-~.l1--K= -j ft < "
1 ' ~ . +......"~ l _ II I : l i 'r II . ~ i~ ~'~ il f 'l~ ' --.":. ]t --=rl 1- - I!- -=- 1 I 1,;,': , .1
I .... =-- ~'" l_~~_..:-,rll~l!-.1__..""".. ", I.t" ;lq::;11..'~-; _-=-''1IEJ.-Jr-.li ~,U
I ~ J - - . <.(.' i 1"1 !' 1 II I ~ 1 ~ I I. :1. . --'. ,- . .
I ",~~,( "" . , 0Jjl~[~n, il,'ll! :LJJLJI 1 L.huL LiJ:. II! jM+:~~~
I -...-----..........? ~- -:::-:~ J~ 1'- I -dl :-lr-:-ll'- .--'~--e-""'Tl[Tl'~F'1 ,'If :J'
'. -I~Mr- ~-............ <[ 'I~I! ..\. ..'JL-l-~"~~~I.-.';.U.l...L..r'~'r' iJii Ij ~
. .......... . ' ': . _ I! : I "- . .- - Ii' I J r-
,I t >J.1L)[~-'r-'"L~"l~,Jr"rr::l,-'" 11-=n"~'- -r::.._J:, , - ,-
J ~- J. - :lJ' -""'-1 ~l-ll- -lr-i!-'!~ :f~l~~~'-i l~; :~~-'l-::ri iH .-~..Ir": .,:1 l: - '.'.
i' ]'-. .l_~ ,,!: '~. ;'l~j!;1ll.!,'~i.',1 --::"'-'=::'Jl":--""'~' ,--1=
~ d L::J L- ._ I_JL __ JT~Ji. ----'~j~ ,.11, 'Ii ~ C-_~ _L._l J._ ,)-l:2:i t\ - iii'" U
!:~ WillJID! .-iJ__JllUmrrJWCleJl.lll[ JIJLlrJCJ\DliJ1]lilflITI r\~ ~, "'.~ ~-
~_" rnlngQ}~[JJITlliIllEI t]l)[IIi] rnr~-JI~~IJirITffilHJJJl!lflll \
iT. ,00J:l1~~8~lij Ii !llLJj III OJ UI[~CJ[J~] m [!J [8uJDIJI[fJ[U[1J[ll{ i1im :