HomeMy WebLinkAboutPacket (Group Homes) for CC 10-19-202020-1019; Z-658-20; Council Report
MEMORANDUM
TO: Carmel City Council
FROM: Adrienne Keeling
Department of Community Services
SUBJECT: Z-658-20
DATE: October 9, 2020
Please find information on an item forwarded by the Plan Commission. This will appear on your October 19th agenda.
Forwarded with a favorable recommendation:
Ordinance Z-658-20 (Docket No. 19090013a OA): Group Home Ordinance Standards.
The applicant seeks to amend the Unified Development Ordinance in order to establish standards and an approval
process and to amend definitions for Group Homes. Filed by the Department of Community Services on behalf of
the Carmel Plan Commission.
Proposed Amendment Summary:
Attached is a proposed UDO amendment which establishes standards and an approval process for Group Homes. Over the
last year there have been two proposals to construct a Group Home in Carmel. The review of those recent proposals led to
a review of the UDO’s existing definitions and additional research regarding federal and state statutes, including the Fair
Housing Amendments Act (FHAA). An approval process specific to Group Homes will provide needed guidance to
applicants, neighbors and staff. Additionally, the proposed process would allow a more site-specific analysis to provide
residents who would be provided services at a Group Home access to housing that is equal to that of residents who are not
in need of such services.
The proposed UDO amendment recommends the following:
1. Require Special Exception approval of Group Homes by a BZA Hearing Officer.
a. Establish filing fee in Article 1, Line 40.
b. Add “Group Home” as a type of Residential Special Exception in S1, S2, R1, R2, R3, R4, R5, UR, B3, B5,
B6, B7 Districts. Appears throughout Article 2, starting on Line 49.
2. Establish Use-Specific Standards for Group Homes in Article 5, starting on Line 86.
3. Revise the existing Special Exception process specifically for Group Homes in Article 9, starting on Line 144.
4. Revise definitions for Dwelling, Single-Family, Family and Group Home in Article 11, starting on Line 281.
a. Note that Group Homes would be defined as six (6) or more persons in need of care, support or supervision –
AND would require Special Exception approval from the BZA. Five (5) or fewer unrelated persons in need
of care would fall under the definition of “Family” and would not require Special Exception approval.
5. Delays the effective date to January 1, 2021.
To aide in review, UDO page numbers are referenced in the ordinance document. You may view the Unified
Development Ordinance in its entirety online by clicking on Codes & Ordinances in the Department of Community
Services’ website: www.carmeldocs.com.
2020-1019; Z-658-20; Council Report
Plan Commission Overview:
The Department presented a proposal which initially amended a handful of residential-related definitions regarding Group
Homes. The purpose of the amendments was to ensure compliance with the Fair Housing Amendments Act (FHAA) by
removing references to outdated Indiana Status and establishing clear limits on the number of occupants. However, after
further discussion and review of federal court decisions it was decided to also establish standards and a BZA approval
process specifically related to Group Homes. Throughout review the Plan Commission and members of the public had
questions related to number of occupants and potential non-residential character of Group Homes. The Plan Commission
forwarded this item to the Carmel City Council with a favorable recommendation.
The information in this packet is arranged in the following order:
1. Memo from John Molitor to the Plan Commission summarizing the limitations imposed by the Fair Housing
Amendments Act (FHAA) and relevant Federal and State court decisions.
2. Proposed Ordinance Z-658-20
3. Plan Commission Certification (expires December 21, 2020).
MEMORANDUM
To: Members, Carmel Plan Commission
From: John R. Molitor, Counsel to the Plan Commission
Date: September 9, 2020
Re: Federal and State Laws Governing Group Home Regulations
The proposed ordinance dealing with group homes (now Docket No. 19090013 OA) is designed
to allow the City to regulate these uses within the strict limitations imposed by state and federal
statutes – primarily the Fair Housing Amendments Act (FHAA). Enacted by Congress in 1988
and liberally construed since then by federal appellate courts, the FHAA makes it a
discriminatory housing practice for a local government to “make unavailable or deny, a
dwelling to any buyer or renter because of a handicap….” According to several federal court
decisions, plaintiffs may prove that a City violated the FHAA by showing either (1) disparate
treatment, (2) disparate impact, or (3) a refusal to make a reasonable accommodation for
disabled persons.
The controlling decision in our federal judicial circuit (the 7th, which includes Illinois and
Wisconsin along with Indiana) was issued just two years ago. The case involved the zoning
ordinance of the City of Springfield, Illinois, which has a population similar to Carmel’s. Instead
of requiring a petitioner to demonstrate that it has a “hardship” justifying a variance, this decision
virtually places the burden of proof on a city to show that a petitioner’s “requested
accommodation” for a group home is unreasonable – that is, “if it imposes undue financial or
administrative burdens or requires a fundamental alteration in the nature of the [city’s
comprehensive plan] program.” Valencia v. City of Springfield, Illinois, 883 F.3d 959, 968-970
(7th Cir. 2018).
The Springfield decision also implies that cities shouldn’t preclude group homes from being
located near one another. The court had no problem with the clustering of two or three group
homes, but did note a report from an Illinois council stating that “clusters of four or five group
homes on a single block could … undermine the ability of neighboring group homes to function
properly”.
Finally, a footnote to the decision discusses the issue as to how many unrelated persons may
occupy a single-family home before it is subject to regulation as a group home or boarding
house. Springfield’s ordinance allowed for up to five unrelated persons – the federal court did
not find this provision objectionable. While Carmel’s current UDO definition does not specify a
limit, the proposed ordinance would also allow for up to five. However, a 2003 Indiana Supreme
Court decision previously ruled that a college town’s code limit of three unrelated adults did not
violate the State Constitution. See Dvorak v. City of Bloomington, 796 N.E.2d 236 (Ind. 2003).
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Ordinance Z-658-20
1
Sponsor: Councilor Rider 1
2
ORDINANCE Z-658-20 3
AN ORDINANCE OF THE COMMON COUNCIL OF THE 4
CITY OF CARMEL, INDIANA 5
___________________________________________________ 6
An Ordinance establishing standards and approval process for Group Homes 7
in the Unified Development Ordinance. 8
9
Synopsis: 10
This ordinance amends the Unified Development Ordinance in order to amend definitions and to establish 11
standards and approval requirements for Group Homes. 12
13
WHEREAS, the term “group home” includes residential facilities designed to house or accommodate 14
the needs of various groups of individuals, particularly persons who are considered disabled or otherwise in 15
need of specialized services. 16
WHEREAS, state and federal statutes, primarily the Fair Housing Amendments Act (FHAA), which 17
was enacted by Congress in 1988, have made it unlawful for local governments to “make unavailable or deny, 18
a dwelling to any buyer or renter because of a handicap.” 19
WHEREAS, according to federal court decisions, plaintiffs may prove that a city violated the FHAA 20
by showing either (1) disparate treatment, (2) disparate impact, or (3) a refusal to make a reasonable 21
accommodation for disabled persons. 22
WHEREAS, pursuant to Indiana Code 36-7-4-602 the Common Council is authorized to amend the 23
text of the unified development ordinance; and 24
WHEREAS, pursuant to Indiana Code 36-7-4-610 and City of Carmel Ordinance D-2391-17, the 25
Carmel Unified Development Ordinance is incorporated by reference into the Carmel City Code; 26
NOW, THEREFORE, BE IT ORDAINED by the Common Council of the City of Carmel, Indiana, 27
that, pursuant to IC 36-7-4-600 et seq. and after Docket No. 19090013a OA having received a favorable 28
recommendation from the Carmel Advisory Plan Commission on Tuesday, September 15, 2020, it hereby 29
adopts this Ordinance to amend the Carmel Unified Development Ordinance (Ordinance Z-625-17, as 30
amended), to read as follows: 31
32
Section I: Amend Article 1: Administration by adding BZA Hearing Officer filing fees for Group Home 33
review. 34
35
1.29 Filing Fees UDO Page 1-11 36
BZA Hearing Officer 37
• Residential $184 plus $107 for each additional 38
• Commercial petition $749.00 plus $371.00 for each additional 39
• Special Exception, Group Home $104 plus $104 per bedroom 40
• Special Exception, Short Term Rental $104.00 41
• Renewal of Special Exception $52.00 42
43
44
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Section II: Amend Article 2 by adding Group Home either as a Residential Special Exception or Permitted 45
Use for the following Districts: 46
47
2.03 S1 District Intent, Permitted Uses, Special Uses and Special Exceptions UDO Page 2-4 48
Residential Special Exception – Group Home 49
50
2.05 S2 District Intent, Permitted Uses, Special Uses and Special Exceptions UDO Page 2-6 51
Residential Special Exception – Group Home 52
53
2.07 R1 District Intent, Permitted Uses, Special Uses and Special Exceptions UDO Page 2-8 54
Residential Special Exception – Group Home 55
56
2.09 R2 District Intent, Permitted Uses, Special Uses and Special Exceptions UDO Page 2-10 57
Residential Special Exception – Group Home 58
59
2.11 R3 District Intent, Permitted Uses, Special Uses and Special Exceptions UDO Page 2-12 60
Residential Special Exception – Group Home 61
62
2.13 R4 District Intent, Permitted Uses, Special Uses and Special Exceptions UDO Page 2-14 63
Residential Special Exception – Group Home 64
65
2.15 R5 District Intent, Permitted Uses, Special Uses and Special Exceptions UDO Page 2-16 66
Residential Special Exception – Group Home 67
68
2.17 UR District Intent, Permitted Uses, Special Uses and Special Exceptions UDO Page 2-18 69
Residential Special Exception – Group Home 70
71
2.23 B3 District Intent, Permitted Uses, Special Uses UDO Page 2-24 72
Residential Permitted Use – Group Home 73
74
2.25 B5 District Intent, Permitted Uses, Special Uses UDO Page 2-26 75
Residential Permitted Use – Group Home 76
77
2.27 B6 District Intent, Permitted Uses, Special Uses UDO Page 2-28 78
Residential Permitted Use – Group Home 79
80
2.29 B7 District Intent, Permitted Uses, Special Uses UDO Page 2-30 81
Residential Permitted Use – Group Home 82
83
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Section III: Amend Article 5: Development Standards to add standards for Group Homes as follows: 84
85
5.72 US-26: Group Home Use-Specific Standards 86
These Use-Specific Standards for Group Homes apply to the following districts: 87
[INSERT ICONS FOR S1, S2, R1, R2, R3, R4, R5, UR] 88
A. Purpose: It is the purpose of this Section to benefit the general public by minimizing adverse 89
impacts on established residential neighborhoods in the City and the owners and residents of 90
properties in these neighborhoods which may result from the conversion of residential 91
properties to business or institutional uses. However, it is also the purpose of this Section to 92
provide that the City may not refuse to make a reasonable accommodation for a Group Home 93
whenever such an accommodation would not impose undue financial or administrative burdens 94
on the City or require a fundamental alteration in the Comprehensive Plan. 95
96
B. Special Exception Eligibility: A Dwelling located in a Residential District may be used as a 97
Group Home only if the owner or occupant applies for and is granted a Special Exception, 98
pursuant to Section 9.08 hereof. 99
100
C. Required Information for Application: Both the initial application and any renewal application 101
for a Special Exception or Improvement Location Permit for a Group Home shall contain 102
primary and secondary emergency contact information, including mailing address, phone 103
number or email address. Upon approval of a Special Exception, emergency contact 104
information shall be shared with the Carmel Police Department. 105
106
D. Limitations: The term of a Special Exception permit granted to a Group Home shall be twenty 107
(20) years. The grant of a Special Exception permit provides an exception only to the other 108
requirements of this Ordinance. It does not confer a right to lease, sublease, or otherwise use a 109
Dwelling as a Group Home where such use is not otherwise allowed by law, a homeowners 110
association agreement or requirements, any applicable covenant, condition, and restriction, a 111
rental agreement, or any other restriction, requirement, or enforceable agreement. Nothing in 112
this Section shall relieve any person of the obligations imposed by any and all applicable 113
provisions of Federal and State laws and the Carmel City Code, including but not limited to 114
those obligations imposed by Indiana tax laws and rules. Further, nothing in this Section shall 115
be construed to limit any remedies available under any and all applicable provisions of Federal 116
or State law and the Carmel City Code. 117
118
E. Reasonable Accommodation: After formal acceptance of an application for a Special 119
Exception for a Group Home, the Director of Community Services shall review the application 120
for the purpose of determining whether it would be a reasonable accommodation for the City to 121
grant the Special Exception in order to provide the residents who would be provided services at 122
the Group Home with access to housing that is equal to that of residents who are not in need of 123
such services. In addition to the items listed in Section 9.08(C) hereof, the Director of 124
Community Services shall consider the following: 125
1. If there are other Group Homes clustered within a block of the site; 126
2. The number of unrelated persons who will be living in the Group Home, and whether 127
any professional support staff will also be residing there; 128
3. In addition to any residents’ cars, if more than two (2) staff cars will be parked at the 129
Group Home, and whether they will be marked; 130
4. If the Dwelling, existing, modified or new, is similar in design, materials and 131
landscaping as other adjacent and nearby Dwellings; 132
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5. Any other exterior indication that the Dwelling will be inhabited by Group Home 133
residents; 134
6. Any undue financial or administrative burdens that would be imposed on the City; and 135
7. If a fundamental alteration in the Comprehensive Plan would be required. 136
137
Based upon this review, the Director of Community Services may support or oppose the 138
granting of the Special Exception. 139
140
141
Section IV: Amend Article 9: Processes to add Group Homes to the Special Exception Process as follows: 142
143
9.08 Special Exception (Only Applicable to Group Homes and Short Term Residential Rentals) 144
145
A. General Information: Special Exception approval by a Hearing Officer of the Board of Zoning 146
Appeals shall be necessary prior to the establishment of a Special Exception, so cited by the 147
district regulations herein, or the issuance of an Improvement Location Permit for said Special 148
Exception. A Special Exception shall be considered as an exception to the uses allowed under 149
the Unified Development Ordinance, and thus the original application for a Special Exception 150
shall not generally be entitled to favorable consideration, except as follows: 151
152
1. A proposed Group Home where not more than eight (8) unrelated persons will be 153
residents shall generally be entitled to favorable consideration; 154
2. A proposed Group Home where not less than nine (9) nor more than twelve (12) 155
unrelated persons will be residents shall generally be entitled to favorable 156
consideration, so long as the application is not opposed by the Director of Community 157
Services; and 158
3. A proposed Group Home where thirteen (13) or more unrelated persons will be 159
residents shall be entitled to favorable consideration only if the application is supported 160
by the Director of Community Services. 161
162
; however, an Any application for the renewal of a Special Exception shall generally be entitled 163
to favorable consideration, so long as it is not opposed by the Director of Community Services. 164
A Hearing Officer shall have discretion whether to approve or deny each Special Exception 165
application, with his or her decision to be based on the special and unique conditions pertinent 166
to the site, determined as a result of the review procedure established herein. 167
168
B. Procedure: 169
1. Procedure Generally: Whenever an application for a Special Exception within the 170
planning jurisdiction is made, it shall follow the procedure set forth herein and shall 171
conform to the regulations and requirements of the Unified Development Ordinance. 172
2. Consultation with the Director of Community Services and Application: Applicants 173
shall meet with the Director of Community Services to review the zoning classification 174
of their site, review copies of the regulatory ordinances and materials, review the 175
Special Exception procedures, and examine the proposed exception and development of 176
the property. The Director of Community Services shall aid and advise the applicant in 177
preparing the application and supporting documents as necessary. The applicant shall 178
then submit two (2) copies of the written application form and all necessary supporting 179
documents and materials. 180
3. Initial Review by the Director of Community Services: Docketing on Hearing Officer 181
Agenda: Following the receipt of the written application and necessary supporting 182
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documents and materials by the Director of Community Services, the Director shall 183
then review the materials solely for the purpose of determining whether the application 184
is complete and in technical compliance with all applicable ordinances, laws, and 185
regulations, and therefore entitled to be forwarded to the Board of Zoning Appeals. If 186
the materials submitted by the applicant are not complete or do not comply with the 187
necessary legal requirements, the Director of Community Services shall inform the 188
applicant of the deficiencies in said materials. Unless and until the Director of 189
Community Services formally accepts the Special Exception application as complete 190
and in legal compliance, it shall not be considered as formally filed for the purpose of 191
proceeding to succeeding steps toward Special Exception approval as hereinafter set 192
forth. Within thirty (30) days of the formal acceptance of the application by the 193
Director of Community Services, the Director shall formally file the application by 194
placing it upon the agenda of a Board of Zoning Appeals Hearing Officer, according to 195
the Rules of Procedure of the Board of Zoning Appeals. 196
4. Public Hearing: Once the Director of Community Services has accepted and filed the 197
application with a Hearing Officer, a docket number shall be assigned and a date and 198
time set for a public hearing by the Hearing Officer, according to the Rules of 199
Procedure of the Board of Zoning Appeals. The applicant shall be responsible for the 200
cost and publication of any required published legal notification of the public hearing. 201
The applicant shall also notify all interested parties and property owners as required by 202
the Rules of Procedure of the Board of Zoning Appeals; however, notice by publication 203
shall not be required for the renewal of a Special Exception. The conduct of the public 204
hearing shall be in accordance with the Board of Zoning Appeals Rules of Procedure. 205
5. Approval or Denial of the Special Exception Application: Upon approval of a Special 206
Exception, the Hearing Officer shall inform the applicant that the applicant may apply 207
to the Director of Community Services for Improvement Location Permits (if 208
necessary) or may commence the Special Exception if no permits are required. Failure 209
of the Hearing Officer to inform the applicant of the time limits set forth in Section 210
5.72(D) shall not relieve the applicant of complying with said Section. 211
6. Appeal of Hearing Officer Decision: A decision of a Hearing Officer shall not be a 212
basis for judicial review, but it may be appealed to the Board of Zoning Appeals. The 213
Board of Zoning Appeals shall conduct a new hearing on the matter and shall not be 214
bound by any Findings of Fact made by the Hearing Officer. A person who wishes to 215
appeal a decision of the Hearing Officer must file the appeal with the Board of Zoning 216
Appeals within five (5) days after the decision is made, as provided in I.C. 36-7-4-924. 217
7. Time Limit for Re-Application: A Special Exception application that is denied by a 218
Hearing Officer or the Board of Zoning Appeals is ineligible to be placed again on an 219
agenda for consideration until the legality of the decision is finally determined by a 220
court, pursuant to judicial review according to the Advisory Planning Law, or for a 221
period of twelve (12) months following the date of the denial, whichever is later. In 222
addition, whenever a Special Exception application is denied, the property involved in 223
the application shall not be the subject of a different Special Exception application, or 224
any use variance or rezone proposal, for a period of six (6) months following the date 225
of the denial. 226
227
C. Basis of Review: A Hearing Officer, in reviewing a Special Exception application, shall give 228
consideration to the particular needs and circumstances of each application and shall examine 229
the following items as they relate to the proposed Special Exception: 230
1. Surrounding zoning and land use; 231
2. Access to public streets; 232
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3. Driveway and curb cut locations in relation to other sites; 233
4. Parking location and arrangement; 234
5. Trash and material storage; 235
6. Necessary exterior lighting; and 236
7. Protective restrictions and/or covenants. 237
238
D. Basis of Approval or Rejection: A Hearing Officer, in approving or rejecting a Special 239
Exception application, shall base his or her decision upon the following factors as they relate to 240
the above listed items (Section 9.08 (C) concerning the proposed Special Exception: 241
1. The economic factors related to the proposed Special Exception, such as cost/benefit to 242
the community and its anticipated effect on surrounding property values; 243
2. The social/neighborhood factors related to the proposed Special Exception, such as 244
compatibility with existing uses in the vicinity of the premises under consideration and 245
how the proposed Special Exception will affect neighborhood integrity; and 246
3. The effects of the proposed Special Exception on vehicular and pedestrian traffic in and 247
around the premises upon which the Special Exception is proposed. 248
249
E. Special Exception Group Home Decisions; Commitment: Pursuant to IC 36-7-4-1015, a 250
Hearing Officer may, as a condition to any approval of an application for a Special Exception, 251
require or allow the owner to make any or all of the following commitments concerning the use 252
of the property: 253
1. That the Special Exception will fully comply with Section 5.72 Group Home Use 254
Standards. 255
2. That the Special Exception will be limited to five (5), ten (10), or fifteen (15) years, at 256
the discretion of the Hearing Officer. 257
3. If the Hearing Officer determines that a homeowners association or similar entity has 258
established limitations or prohibitions that apply to the property, that the owner’s 259
implementation of the Special Exception will not result in the violation of any such 260
limitations or prohibitions. 261
262
E.F. Special Exception Short Term Residential Rental Decisions; Commitment: Pursuant to IC 36-263
7-4-1015, a Hearing Officer may, as a condition to any approval of an application for a Special 264
Exception, require or allow the owner to make any or all of the following commitments 265
concerning the use of the property: 266
1. That the Special Exception will fully comply with Section 5.725.73 Short Term 267
Residential Rental Standards. 268
2. That the Special Exception will be limited to thirty (30), sixty (60), or ninety (90) days 269
during a calendar year, at the discretion of the Hearing Officer. 270
3. If the Hearing Officer determines that a homeowners association or similar entity has 271
established limitations or prohibitions that apply to the property, that the owner’s 272
implementation of the Special Exception will not result in the violation of any such 273
limitations or prohibitions. 274
275
276
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Section V: Amend Article 11: Definitions as follows: 277
278
11.02 Definitions UDO Pages 11-4 through 11-22 279
280
Dwelling, Single-Family: A residential Building containing only one (1) Dwelling Unit and not 281
occupied by more than one (1) Family. Pursuant to IC 12-28-4-7, a Group Home for the mentally ill 282
shall be treated as if it were a Single-family Dwelling, unless the Group Home will be located within 283
3,000 feet of another Group Home for the mentally ill, as measured between lot lines. Pursuant to IC 284
12-28-4-8, a Group Home for not more than ten (10) developmentally disabled individuals which is 285
established under a program authorized by IC 12-11-1.1-1(e)(1) or IC 12-11-1.1-1(e)(2) shall be 286
treated as if it were a Single-family Dwelling. 287
288
Family: One or more persons living as a single housekeeping unit, including up to five (5) unrelated 289
persons, as distinguished from a group occupying a hotel, club, nursing home, fraternity or sorority 290
house, or Group Home. 291
292
Home, Group: A residential Structure or facility where six (6) or more unrelated persons who are in 293
need of care, support or supervision can live together, such as children or those who are elderly, 294
disabled or mentally ill.Any of The Following: 295
1. A residential Structure (licensed under IC 12-17.4) in which care is provided on a twenty-four 296
(24) hour basis for not more than ten (10) children; or 297
2. A facility (licensed under IC 12-28-4) that provides residential services for developmentally 298
disabled individuals in a program described in IC 12-11-1.1-1(e)(1) or IC 12-11-1.1-1(e)(2); or 299
3. A facility (licensed under IC 12-28-4) that provides residential services for mentally ill 300
individuals in a program described in IC 12-22-2-3. 301
302
Section VI: All prior Ordinances or parts thereof inconsistent with any provision of this Ordinance are hereby 303
repealed. 304
305
Section VII: This Ordinance shall be in full force and effect beginning January 1, 2021 after its passage and 306
signing by the Mayor. 307
308
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PASSED by the Common Council of the City of Carmel, Indiana, this ____ day of ________, 2020, by a vote of _____ ayes 309
and _____ nays. 310
311
312
COMMON COUNCIL FOR THE CITY OF CARMEL 313
314
___________________________________ 315
Laura D. Campbell, President Sue Finkam, Vice-President 316
317
318
___________________________________ ____________________________________ 319
H. Bruce Kimball Kevin D. Rider 320
321
322
___________________________________ ____________________________________ 323
Anthony Green Jeff Worrell 324
325
326
___________________________________ ___________________________________ 327
Tim Hannon Miles Nelson 328
329
330
___________________________________ 331
Adam Aasen 332
333
334
ATTEST: 335
336
__________________________________ 337
Sue Wolfgang, Clerk 338
339
340
Presented by me to the Mayor of the City of Carmel, Indiana this ____ day of _________________________ 20 20, at 341
_______ __.M. 342
343
____________________________________ 344
Sue Wolfgang, Clerk 345
346
347
Approved by me, Mayor of the City of Carmel, Indiana, this _____ day of ________________________ 2020, at _______ 348
__.M. 349
350
____________________________________ 351
James Brainard, Mayor 352
353
354
355
ATTEST: 356
___________________________________ 357
Sue Wolfgang, Clerk 358
359
360
Prepared by: 361
Adrienne Keeling, Planning Administrator, One Civic Square, Carmel, IN 46032 362