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Ordinance 33030006.900000 WSS /gjz 4/18/00 ORDINANCE NO. 3303 AN ORDINANCE OF THE CITY OF EDMONDS, WASHINGTON, AMENDING THE PROVISIONS OF THE EDMONDS CITY CODE BY THE REPEAL OF CHAPTER 2.80, ADOPTING A NEW PURCHASING POLICY IN THE FORM SET FORTH IN THE ATTACHED EXHIBIT A, AND FIXING A TIME WHEN THE SAME SHALL BECOME EFFECTIVE. WHEREAS, the City of Edmonds has previously adopted an ordinance establishing a process for the selection of professional consultants, and WHEREAS, the City Council finds that the provisions of state law provide adequate direction, protections and limitations on the selection of professional consultants and that the City ordinance is therefore redundant as well as unnecessarily limiting the selection process, and WHEREAS, the City Council finds it to be in the public interest to adopt a policy by reference in order to provide greater flexibility in the administration of its purchasing and consultant selection processes, NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF EDMONDS, WASHINGTON, DO ORDAIN AS FOLLOWS: Section 1. The Edmonds City Code is hereby amended by the repeal of Chapter 2.80 Professional Consultants. Section 2. A purchasing policy in the format established by the attached Exhibit A is hereby adopted, such Exhibit being incorporated by reference as fully as if herein set forth. The City Council reserves the right to approve deviations from said policy when, in its sole {WSS433885.D0C;1/00006.900000/} - 1 - discretion, the City Council deems it appropriate or, in such emergency situations or other circumstances as authorized by state law, when the Mayor or his designee deems it appropriate. In the event of deviation by the Mayor in an emergency or other statutorily authorized circumstance, the Mayor or his designee shall promptly report to the City Council regarding such deviations. Section 3. Effective Date. This ordinance, being an exercise of a power specifi- cally delegated to the City legislative body, is not subject to referendum, and shall take effect five (5) days after passage and publication of an approved summary thereof consisting of the title. APPROVED: MA;00R, G HAAKENSON ATTEST /AUTHENTICATED: CITY CLERK, SANDRA S. CHASE APPROVED AS TO FORM: OFFICE OF Y AT Y: BY �?!— W. SCOTT SNYDER FILED WITH THE CITY CLERK: 04/21/2000 PASSED BY THE CITY COUNCIL: 04/25/2000 PUBLISHED: 04/30/2000 EFFECTIVE DATE: 05/05/2000 ORDINANCE NO. 3303 (WSS433885.DOC;1/00006.900000/) - 2 - SUMMARY OF ORDINANCE NO. 3303 of the City of Edmonds, Washington On the 25th day of April, 2000, the City Council of the City of Edmonds, passed Ordinance No. 3303. A summary of the content of said ordinance, consisting of the title, provides as follows: AN ORDINANCE OF THE CITY OF EDMONDS, WASHINGTON, AMENDING THE PROVISIONS OF THE EDMONDS CITY CODE BY THE REPEAL OF CHAPTER 2.80, ADOPTING A NEW PURCHASING POLICY IN THE FORM SET FORTH IN THE ATTACHED EXHIBIT A, AND FIXING A TIME WHEN THE SAME SHALL BECOME EFFECTIVE. The full text of this Ordinance will be mailed upon request. DATED this 26th day of April, 2000. CITY CLERK, SANDRA S. CHASE { WSS433885.DOC;1/00006.900000/ }- 3 - EXHIBIT A Table of Contents Page Policy............................................................................... ..............................2 Purpose............................................................................. ..............................2 Authority............................................................................ ..............................2 Procurement of Goods & Services ......................................... ..............................2 Purchasing Parameters ..................................................... ..............................2 Conflicts of Interest .......................................................... ..............................3 Recyclables.................................................................... ..............................3 SurplusItems .................................................................. ..............................3 BiddingRequirements ......................................................... ..............................3 CompetitiveBid ... r .......................................................... ..............................4 BidProcedures .............................................................. ..............................4 Small Works Roster ......................................................... ..............................6 Purchase of Professional & Technical Services ........................ ..............................7 Interlocal Agreements ...................................................... ..............................8 Sole Source Procurement ................................................. ..............................8 Special Market Conditions .... ............................... ........................... ..........8 Emergencies.................................................................. ..............................8 Reimbursement of Expenses ................................................ ..............................8 Travel and Meeting Expenses ............................................... ..............................8 Advance Travel Requests ................................................... ..............................9 OtherIssues ...................................................................... ............................... Store - issued Charge Cards ............................................... ..............................9 BankCredit Cards .......................................................... ..............................9 Hand - Issued Checks ........................................................ ............................... PettyCash .................................................................... ............................... BudgetAdjustments ........................................................ .............................10 FinanceCommittee ........................................................... .............................10 Attachments 1. Purchasing Parameters 2. Purchase Quotation Sheet 3. Statement of Bidder's Qualifications 4. Claim for Expenses 5. Advance Travel Fund Request 6. Budget Adjustment Request P:ReportsTurPol Policy The City of Edmonds will acquire equipment, materials, and services in a manner that results in the most efficient delivery of services considering cost and value received. To avoid conflict of interest, procurement will be impartial. Procurement of goods and services will provide the City with the best quality for the best value. Purchases will be made within budget limits and to meet goals and objectives approved in the City's budget. Potential purchases that are not within budget limits will be pre- approved through a budget amendment process. All City purchases will ultimately be approved by the City Council through the voucher approval process. Purpose This administrative manual establishes City responsibilities and policies, procedures, and practices to follow to purchase equipment, materials, and services. All employees must follow established policies and procedures. Adherence to policies and procedures will ensure that public purchases and contracts are open, fair, and at the least cost to the public. Policies and procedures are divided into four major areas: 1) Procurement of Goods and Services, 2) Bidding Requirements, 3) Reimbursement of Expenses, and 4) Other Issues. Authority A department director (or designee), acting within their department budget, is authorized to provide for supplies and services purchases. To ensure the City's fiscal responsibility, purchases are coordinated through the Administrative Services Department. The City's procurement procedures are based on Revised Code of Washington guidelines, Edmonds City Council adopted resolutions and ordinances, the State Auditor's Office, and the Municipal Research Services Center. Procurement of Goods and Services Purchasing Parameters (Attachment 1) Purchases costing less than $5,000 may be made by the department director or designee. 2. Purchases costing more than $5,000 and less than $15,000 require at least three telephone quotes, unless the item(s) are from a sole source vendor. Purchases in this price range require the requesting department director's (or designee's) pre - approval and completion of the vendor quote form. Vendor quote forms may be obtained from the Financial Services Division (Attachment 2). 2 P: Reports:PurPol 3. Purchases costing more than $15,000 and less than $30,000 require written quotations from a minimum of three vendors, unless the item(s) are from a sole source vendor. In addition, the Mayor or Finance Director and requesting department director must approve purchase orders in this range prior to the purchase transaction. At the time of solicitation, the City will not inform a vendor of other vendors' quotes. Purchases in excess of $30,000 and less than $50,000 must satisfy the requirements of Item 3, above. Also, these items must be placed on the Council consent agenda. 4. A sole source vendor is characterized as the one and only source for the product or service. Purchases in excess of $5,000 from a sole source vendor require prior approval of the Administrative Services Department Director or designee. 5. Purchases in excess of $50,000 must be bid competitively per RCW 35.23.352. See Competitive Bid, Item 3, below. Conflicts of Interest The City will not accept donations of materials or services in return for a commitment to continue or initiate a purchasing agreement. No employee will participate in a procurement when they are aware of a conflict of interest, or accept gifts or gratuities from existing or potential vendors in return for a commitment to continue or initiate a purchasing relationship. Recyclables Every effort will be made to use prbducts.made from recycled materials if such products are available, of acceptable quality, and generally priced the same as similar, non - recycled products (Resolution 766). Surplus Items The City may acquire surplus property from another government without the use of bids (RCW 39.33.010). Bidding Requirements The bid process is generally (although not exclusively) used for public works projects. RCW 39.04.010 defines public works to include all work, construction, alteration, repair or improvement other than ordinary maintenance, executed at the cost of the tax payers. (Most public works projects are multiple craft, defined as more than one type of work being executed.) 3 P: Reports:PurPol Competitive Bid As authorized by City Council, the bid process will also be used under the following circumstances: 1. Projects costing less than $15,000 should use the procurement procedures defined in "Procurement of Goods and Services" above. 2. Projects costing between $15,000 and $30,000 require a pre- approved Purchase Order and short -form contract approved by the Mayor or designee. Projects between $30,000 and $50,000 must satisfy requirements of Item 2, and be placed on Council consent agenda. 3. Projects /purchases /professional services costing over $50,000 must be competitively bid, coordinated through the Administrative Services Department to ensure RCW compliance, and require bid award by City Council. 4. Public works projects valued over $20,000 but under $200,000 for a single craft public work, or over $35,000 for a multiple craft public works project for which an existing small works roster does not exist. 5. All public works projects valued over $200,000. Public works projects are governed by prevailing wage requirements, regardless of contract amount. Dollar -value ranges indicated above pertain to each purchase (including tax, if applicable). Purchases cannot be broken into multiple purchases to avoid compliance with State statutes and City policies. Bid Procedures 1. Request to City Council for authorization to call for bids. 2. Publication of Notice After Council authorization, the requesting department director (or designee) will publish the Call for Bids in the official newspaper or a newspaper of general circulation most likely to bring responsive bids, at least 13 days prior to bid submittal deadline. 3. Notice Contents Notice (or advertisement) for bids should contain definite specifications and procedures for bidders to use to estimate their bids. At a minimum, a bid notice for public work should include: - project title, - nature and scope of work, - where contract documents (plans and specifications) can be reviewed or obtained, - cost to obtain a set of contract documents, - place, date, and time that bids are due, 4 P: Reports:PurPol statement that a bid bond must accompany the bid, and a statement that the City retains the right to reject any and all bids and to waive minor irregularities in the bidding process. In addition, providing evaluation criteria; minimum qualifications; date, time, and location of pre -bid conference (if applicable); name, address, and telephone number of the project contact; and number of required copies will help bidders prepare responsive submittals. 4. Bid Opening Bids are submitted to the City Clerk's Office, where they are time and date stamped and processed. 5. Report on Bids The requesting department director will report to the Council or Council subcommittee on all bids received. 6. Council Approval The City Council will make a recommendation for final bid award. The following shall apply to bid solicitations: • Selection of a winning offer is based primarily on low bid. Quality and expertise, however, are a consideration. • To ensure consistency and fair process, the City will use standard forms, documents, contracts, and terms and conditions, when practical. The Administrative Services Department will maintain templates for bid - related documents for use by departments. The City will use an evaluation selection committee to promote an open, proper selection. The requesting department director will appoint committee members to act in an advisory capacity. • Minimum qualifications are stated to ensure respondents are reasonably qualified (Attachment 3). Minimum qualifications cannot be used to eliminate qualified offerors. Minimum qualifications should be tested against the marketplace to ensure they aren't overly restrictive. • When practical, the City will conduct a pre -bid conference to allow a thorough discussion of the City's intent, scope, specifications, and terms. Interested companies should be encouraged to attend. 5 P: Reports:PurPol Small Works Roster The Small Works Roster allows the City to evaluate the professional qualifications it has on file when a proposed project is scheduled. It may be used for public works projects valued over $20,000 and below $200,000 for a single craft public work, or over $35,000 for a multiple craft public works project. Use of.the Small Works Roster allows the City to preclude the advertisement requirements of the formal competitive process. All other bidding requirements are the same. The following steps outline the process to form a Small Works Roster: • Twice yearly the City will publish in a general circulation newspaper the existence of the Small Works Roster. • All qualified, licensed, or registered contractors will be invited to be on the Roster. • The Roster may be either a single list or several lists of contractors based on construction discipline or project type. • For each project, The City will develop a procedure to secure telephone or written quotations from (whenever possible) at least five appropriate contractors on the Roster. Whenever possible, at least one of the contractors invited to submit a proposal will be a minority- or woman -owned firm. The City may invite proposals from more than five or all appropriate contractors on the Roster. • The contract must be awarded to the contractor submitting the lowest responsible quote. • Once a contractor has been invited to submit a proposal, that contractor will not be offered another opportunity until all other appropriate contractors on the Roster have been given the opportunity to submit a proposal on a project. A list of contracts awarded through the Small Works Roster process will be posted at least bi- monthly. The list will contain the contractor's name, contract amount, brief description of the work awarded, date awarded, and where the contract is available for public inspection. Vendors /contractors selected off the Small Works Roster are not relieved from observing applicable legal requirements such as Performance Bond, Prevailing Wage, Labor and Material Bonding, etc. 6 P:Reports:PurPol Purchase of Professional and Technical Services A. Non - Architectural and Engineering Services 1. Professional and technical services include disciplines such as attorneys, computer programmers, financial analysts, bond counsels, artists, planners, and real estate appraisers. 2. Purchase of professional services require completion of a City professional service contract that describes services to be performed and purchase price. 3. The Mayor or designee must pre- approve purchases of professional services in excess of $15,000. Contracts between $30,000 and $50,000 must satisfy requirements of Item 3 and be placed on Council consent agenda. 4. The Edmonds City Council must pre- approve professional service contracts in excess of $50,000. 5. Prior experience with the City, timeframe for completing projects, and the value of a negotiated agreement (versus the procurement process authorized for securing architectural /engineering services in RCW 39.80.010.60 and /or RCW 39.29) will be considered when choosing a consultant/firm to perform professional services, as defined in this section. B. Architectural and Engineering WE) Services Procurement of A/E services will be in accordance with RCW 39.80.010.60. The statute requires advance notice of the requirement for professional services (39.80.030), evaluation of firms' qualifications and performance (39.80.040), and negotiation with firms in accordance with adjudged qualifications (39.80.050). A/E purchases will be coordinated through the Financial Services Division to ensure RCW compliance. 2. The Mayor or designee must pre- approve purchase of A/E services. In addition, contracts between $30,000 and $50,000 must be placed on the Council consent agenda. 3. Purchase of A/E services require completion of a City professional service contract that describes services to be performed and purchase price. 4. The Edmonds City Council must pre - approve A/E service contracts in excess of $50,000. Contracts for services cannot be broken into multiple agreements to avoid compliance with this policy or State statutes. 7 RReportsTurPol Interlocal Aareements Bidding by City departments is not required when purchases of materials, supplies, or equipment are made under State standard contracts or similar contracts executed by and through other local governments which have complied with state bidding requirements. The City must have an interlocal agreement with the city, state, or other government prior to the bid. All other procurement approval requirements must be maintained. Sole Source Procurement If, after conducting a good faith review of available resources, the requesting department director determines that there is only one source of the required materials, supplies, or equipment, a purchase contract may be awarded without complying with established bid requirements. The requesting department director will submit a written request for sole source procurement to the Administrative Services Director for approval, and conduct price, terms, and delivery negotiations, as appropriate. The vendor must certify that the City is getting the lowest offered price. Special Market Conditions The Mayor (or designee) will consider waiving established bidding requirements if an opportunity arises to purchase favorably - priced equipment at an auction, or supplies or used goods that will be sold before the City can conduct the bid process. Emergencies In case of an emergency that threatens City property or the safety of citizens and /or staff, the Mayor (or designee)-can waive bid requirements to purchase goods, materials, or services to stabilize the emergency condition. Purchase order(s) must be properly documented as an emergency as soon as possible following the event. Within two weeks of confirming the emergency existed, the City Council will adopt a resolution certifying the emergency situation existed. Reimbursement of Expenses Travel and Meetina Expenses Travel or training requires the requesting department director's prior approval. Expenses incurred on authorized travel will be reimbursed as submitted on the required, itemized, Claim for Expenses form (Attachment 4). Receipts must be submitted with the claim form for all expenses except meals. To qualify for reimbursement, submitted expenses must be within 90 days of incurrence, reasonable and prudent under the circumstances, and directly relate to the conduct of City business or service. Reimbursement for personal expenses is prohibited. Travel mileage by private vehicle is reimbursed at the City's established rate, which is the current IRS rate. Please see Ordinance 3214 and City Code 600.13 for more information. 8 PAeportsTurPol Advance Travel Reauests The Advance Travel Fund provides cash in advance of out -of -town travel. Advanced funds are used to defray necessary costs while performing official duties. Requests for advance travel funds are submitted on the Advance Travel Fund Request Form (Attachment 5), with pre - approval from the Human Resources Director. Funds are made payable to the applicant. Settlement of advanced funds will be made on or before the 1 oth day following return from travel by submitting a completed, director - approved Claim for Expenses form to the Financial Services Division. If the traveler's expenses were less than the advanced amount, the unspent portion of the advance must accompany the Claim for Expenses form. If the traveler's expenses were in excess of the amount advanced, the Claim for Expenses form must list the additional, approved expenses with two copies submitted to the Financial Services Division. A check for the difference will be processed. Other Issues Store - Issued Charge Cards It is sometimes necessary to use store - issued charge cards. The Financial Services Manager will set up the authorized account in such cases. Bank Credit Cards Bank credit cards can be issued with the approval of the Administrative Services Director. They are to be used solely for City- authorized business purposes. Please see Credit Card Policy. Hand - Issued Checks Checks may be hand - issued to avoid incurring penalties, interest, or late charges. Submit requests for hand - issued checks to the Financial Services Division. Manual checks will be approved by the Financial Services Manager. Departments should avoid requests for hand - issued warrants by informing vendors of invoice deadlines and payment schedules. Petty Cash Petty cash funds cover minor disbursements. Employees may be reimbursed from petty cash funds for authorized purchases that total less than the established, petty -cash limit. 9 RReportsTurPol Budaet Adiustments Each department's authorizing staff must ensure that purchases are initiated only when departmental appropriations are sufficient to cover the anticipated cost. Expenditures that exceed departmental appropriations require the Mayor's approval via the Budget Adjustment Request Form (Attachment 6). Finance Committee This committee, composed of two Council members and the Administrative Services Director, will review and update the City of Edmonds' purchasing and accounts payable policies and procedures, as necessary. 10 P:ReportsTurPol Attachments 1. Purchasing Parameters 2. Purchase Quotation Sheet 3. Statement of Bidder's Qualifications 4. Claim for Expenses 5. Advance Travel Fund Request 6. Budget Adjustment Request 11 P:ReportsTurPol O ry F- LLI G NQN � z V I LL D 0- W U_ L /ice U) 0 z Q O !O V LL O z CW G L.L U 0/ 0. 0— 0 O N V O U 0 U Cd 7 0. c O U o , Z LLI � me LU o L 21 V � m W m -a aa)) cn + �j c O U a) a) O cn O- 0 a)c C/) cn cn 0) '(D O = a) c O• U ) a) L�• ID i• V� � � LCi a) -p co O 0) a) =) O -2 a) Ef} w cuaUQ Waamo O N c _ > C U% co O Z L L O O 0 a) Q O O � _ a) Q Q _ O to p v a) L() L.% U (0 (6 T) E o _ O N O .> a) p a) iO O N .t- �� Q U N O. 4 O ) cn N N cn C N ca 0 - O Q ca otS c co a) N ca o O a) � , '5 0 O U O O a)� o o� �� cn .o to O C� a c�i « .- cn ) U O �� ���� QQ U) ��� ��� 69 Z> .0ooa0r CU � 0)L .. 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I- W W Z O H Q H O C1 W U) a C.) w D 0. s d r a' 0 X d 0 a 0 w a a 0 a w 0 E o o = o U- a C� o CY 0 a R 0 CD = L a, O 7 f0 ' 0 C 30 X J C� o �a F �i F 0 U) E- C) =3 C w cr C 3 C LO CU N 69� U) U) O O L O CU L- , la) O � w 0 d 0� ° C7 rn x cu U1 x 0 � p 3 CL m cu o W � 'L W p r �E_' O 7 �L W s d r a' 0 X Statement of Quoters /Bidder's Qualifications (Use for Purchases /Services over $50,000) Each bidder submitting a proposal shall prepare and submit as part of the bid, the data requested below: 1. Name of Quoter /Bidder 2. Business Address 3. Telephone 4. How many years has said quoter /bidder been in business under the present firm name? 5. Bank references. 6. Business License No. 7. Washington State Tax# Name of Bidder M Title DATE 0 y a a �o a a c E d a v c c m m 0 N m ` N N O. — f0 co U m v o � a m c d N U w 3 0 d o a '= L N � C d J @ O ( U) n N 3 @ N N C CO N O N U N @ y 2 ac rn :v a o 0 U) N W 0 � Z Z OW 2 X a W W w LL OLL U Q U N mE°� Z N L N C ❑ O Xt Q m a� c E Q U C Q N m W N Z W CL W W 2 F- 0 LL O J H W a N a) w qC c� 0 N E O N N n e O (0 C m TG N (6 m O d a Q N c ca C N I� IIII Ito W N Z W CL W W 2 F- 0 LL O J H W a N a) w qC c� 0 N E O N N n e O (0 C m TG N (6 m O d a Q N c ca C N �a5 o � i O � N � � O C � O U E O 'a > w 0 y O C _T O U a W m �C E Z C R R t4 O H c R 3 m is c d E T l0 a `o w O O. C. Q 01 C C 7 O V v a f`6 I� IIII �a5 o � i O � N � � O C � O U E O 'a > w 0 y O C _T O U a W m �C E Z C R R t4 O H c R 3 m is c d E T l0 a `o w O O. C. Q 01 C C 7 O V v a f`6 CITY OF EDMONDS AUTHORIZATION TO ATTEND / TRAVEL Employee Date: Department/Division: Employee #: Name of Program: ❑ Required Destination: ❑ Volunta ry Type of Program: El Educational F1 Conference E] Trainin Provider of Program: Automobile Costs: Miles @ $ / Mile = $ Acct #: Location: $ Other Transportation) Dates Attending from: Lodging Nights) to: Account #: Meals Days) Registration/Tuition Costs: $ Account #: $ Account #: Required Materials: $ Account #: TOTAL TRAINING COSTS $ Advance Requested: $ Salary Status During Pro ram: ❑ Paid Time ❑ Vacation ❑ Non -Paid Time Purpose & Benefit to City: Purpose: 7Date Destination: Leaving: Date Returning: Mode of Travel: Personal car Automobile Costs: Miles @ $ / Mile = $ Acct #: Other Transportation) $ Other Transportation) $ Lodging Nights) $ Account #: Meals Days) $ Other (specify): $ Account #: Advance Requested: $ Total Travel Costs: $ *Department Director will need to authorize if this is an unbudgeted expense. -1 OF ED y� Current Year Budget Adjustment Request 7. To: Administrative Services Director Dater Please transfer the following revenues and /or appropriations: Decrease from Increase to category acct. number amount category acct. number amount $ $ $ $ Reason Requested By Department Department Director Signature ADMINISTRATIVE SERVICES DIRECTOR: Comments: Approved Not Approved Signature 1 2. To: Mayor Date: Comments: Approved Not Approved Signature 1 3. To: Financial Services Division Date: I I Adjustment Recorded: SJ# Prepared By: Date: Approved By: Please see reverse side for instructions. D:Fomts:BudAdjmt STATE OF WASHINGTON, COUNTY OF SNOHODUSH, SUMMARYOFORDINANCE . f of the City ofETmonds, Washington i On the 25th day of April, 2000, the City Council of the City of j Edmonds, passed Ordinance No. '3303. A summary of the content of said ordinance, consisting of I tthe title, provides as follows: i ;AN ORDINANCE OF THE CITY OF EDMONDS, WASHINGTON, (AMENDING THE PROVISIONS iOF EDMONDS CITY CODE BY THE REPEAL OF CHAPTER 2.60, ADOPTING A NEW PUR- -CHASING POLICY IN THE ,FORM SET FORTH IN THE AT- TACHED EXHIBIT A, AND FIX - �ING A TIME WHEN THE SAME jSHALL BECOME EFFECTIVE. -4 i The full text of this Ordinance will be mailed upon request. DATED this 26th day of April, 2000. CITY CLERK, a SANDRA S. CHASE Published: April 30, 2000. 1 B -2 -t i - Affidavit of Publication The undersigned, being first duly sworn on oath deposes and says that she is Principal Clerk of THE HERALD, a daily newspaper printed and published in the City of Everett, County of Snohomish, and State of Washington; that said newspaper is a newspaper of general circulation in said County and State; that said newspaper has been approved as a legal newspaper by order of the Superior Court of Snohomish County and that the notice ......... ............................... Summary of Ordinance #3303 City of Edmonds ............................ ............................... ..... ............................... .............................. a printed copy of which is hereunto attached, was published in said newspaper proper and not in supplement form, in the regular and entire edition of said paper on the following days and times, namely: Published: April 30, 2000 ...................................................................................................... ......................... . . . . .. ............... .......................... ............................... a .------ ........................ and th t said n wspaper was regia dis ributed to its subscribers during al said period. .......................... incinal Clerk 1st Subscribed and sworn to before me this ................. CD P 0) m .� UBtlC s . a s O y 1'9[�e2�00`�`,�Q e � @6blP /bQ�bB��