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CC - Agenda - 06-09-15Public Comment from the Audience • If you wish to address the City Council, please complete a Speaker Request Card, as it must be handed to the City Clerk before the start of the meeting. • The City Council will hear public comments on matters not listed on the agenda during the Public Comments from the Audience period. • Opportunity to address the City Council (on non - agenda items) is limited to 3 minutes per speaker. • The City Council will hear public comments on items listed on the agenda during discussion of the matter and prior to a vote. Brown Act Pursuant to provisions of the Brown Act, no action may be taken on a matter unless it is listed on the agenda, or unless certain emergency or special circumstances exist. The City Council may direct staff to investigate and /or schedule certain matters for consideration at a future City Council meeting. Rules of Decorum Persons attending the meeting shall observe rules of propriety, decorum, good conduct, and refrain from impertinent or slanderous remarks. Violation of this rule shall result in such persons being barred from further audience before the governing body. Pursuant to Gov. Code Sect. 54954.3(c), any person who engages in unlawful interference shall be removed from chambers. Americans with Disabilities Act In compliance with the ADA, if you need special assistance to participate in this meeting, please contact the City Clerk's office at least 48 hours prior to the meeting to allow the City to make reasonable arrangements to ensure accessibility to the meeting or service. This agenda was posted 72 hours in advance of the meeting at the City Hall, 8838 E Valley Boulevard, Rosemead; the L.A. County Library, Rosemead Branch, 8800 E. Valley Boulevard, Rosemead; and other locations pursuant to RMC Sec. 1.08.020. Any writings or documents provided to a majority of the Rosemead City Council regarding any item on this agenda will be made available for public inspection in the City Clerk's office during normal business hours. Rosemead City Council, Housing Development Corporation and the Successor Agency of the Rosemead Community Development Commission JOINT MEETING AGENDA June 9, 2015 • 11' City Hall Council Chamber 8838 E. Valley Boulevard Rosemead, CA 91770 www.citvofrosemead.org Hilton Fort Wayne Lobby 1020 S. Calhoun Street Margaret Clark, Mayor Sandra Armenta, Mayor Pro Tem William Alarcon, Council Member Polly Low, Council Member Steven Ly, Council Member Fort Wayne, Indiana 46802 ROSEMEAD CITY COUNCIL, HOUSING DEVELOPMENT CORPORATION AND THE SUCCESSOR AGENCY OF THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION JOINT MEETING AGENDA JUNE 9, 2015 Regular Meeting 6:00 p.m. • CALL TO ORDER— 6:00 p.m. • PLEDGE OF ALLEGIANCE —Council Member Ly • INVOCATION — Mayor Clark • ROLL CALL: • City Council — Mayor Clark, Mayor Pro Tern Armenta, Council Members Alarcon, Low, Ly • Successor Agency —Chair Clark, Vice -Chair Armenta, Members Alarcon, Low, Ly • Housing Development Corporation —President Clark, Vice President Armenta, Board Members Alarcon, Low, Ly CLOSED SESSION A. Conference with Legal Counsel — Existing Litigation City of Rosemead v. Beneficial Patient Group, Inc. et al.; Los Angeles County Superior Court Case EC 063589 Pursuant to Government Code Section 65956.9 (d)(1) Regular Business 7:00 p.m. 2. PUBLIC COMMENTS FROM THE AUDIENCE The City Council will receive public comments on matters not listed on the agenda. 3. PRESENTATIONS • Muscatel Science Olympiad Team • Scholarship Recipients -- Rosemead Residents Page 2 of 12 ROSEMEAD CITY COUNCIL, HOUSING DEVELOPMENT CORPORATION AND THE SUCCESSOR AGENCY OF THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION JOINT MEETING AGENDA JUNE 9, 2015 4. PUBLIC HEARINGS A. Municipal Code Amendment 15.02 Amending Chapters 17.04 and 17.72 of Title 17 of the City of Rosemead Municipal Code Relating to Regulations for Nonconforming Uses, Structures, Lots, and Parking Facilities MCA 15 -02 is a City initiated amendment to revise Title 17 (Zoning) of the Rosemead Municipal Code to modify several regulations for nonconforming uses, structures, lots, and parking facilities. It was originally drafted for the purpose of allowing the addition of new residential structures on R -1 and R -2 lots that include existing legal nonconforming structures. However, upon hearing written and oral testimony at the public hearing on April 6, 2015, the Planning Commission directed staff to eliminate the proposed standards regarding residential expansions on properties with existing legal nonconforming structures, and the item was continued to the meeting of May 18, 2015. After final discussion at the May 18, 2015 meeting, the Commission adopted Planning Commission Resolution No. 15- 04, recommending that the City Council ADOPT Ordinance 951, approving revised MCA 15- 02 without the proposed standards allowing the addition of new residential structures on properties with existing legal nonconforming structures. Ordinance 951 maintains all other proposed text in the amendment that is intended to improve the clarity and intent of the existing nonconforming standards. Ordinance 951 also proposes to eliminate the term and definition of "bachelor apartment' from Chapter 17.04, as the term is no longer accepted by the California Department of Housing and Community Development. Recommendation: That the City Council: 1. Conduct the noticed public hearing and receive public comment; 2. Approve the Negative Declaration of Environmental Impacts finding that the project will not have a significant adverse effect on the environment; and 3. Move to INTRODUCE FIRST READING, by title only Ordinance No. 951, entitled: AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA, APPROVING MUNICIPAL CODE AMENDMENT 15.02, AMENDING CHAPTERS 17.04 AND 17.72 OF TITLE 17 OF THE CITY OF ROSEMEAD MUNICIPAL CODE RELATING TO REGULATIONS FOR NONCONFORMING USES, STRUCTURES, LOTS, AND PARKING FACILITIES Page 3 of 12 ROSEMEAD CITY COUNCIL, HOUSING DEVELOPMENT CORPORATION AND THE SUCCESSOR AGENCY OF THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION JOINT MEETING AGENDA JUNE 9, 2015 B. Design Review 14.03: Garvey Garden Plaza Mixed Use Project 8408 Garvey Avenue Garvey Garden Plaza, LLC has submitted a Design Review application requesting to develop a new residential /commercial mixed use development totaling 11,860 of retail /office space on the first floor and 46 apartments on the second through fourth floors. Parking is proposed as a combination of surface and one level of subterranean basement parking. Access to the proposed project will be provided by two driveways from Delta Avenue that extends along the west project boundary. The project includes a density bonus application under Senate Bill (SB) 1818, which amended the state bonus law to allow density bonuses up to 35 %. The property is located at the southeast corner of Delta Avenue and Garvey Avenue in the C -3 MUDO -D (Medium Commercial with a Mixed Use and Design Overlay) zone. This item was presented to the Planning Commission for consideration on May 18, 2015. At the conclusion of the hearing, the Planning Commission removed condition of approval number 47, since the project does not involve a tentative map, and added two conditions of approval. The first condition required a post traffic study. The second condition prohibited restaurant use in the building due to parking restrictions. Once these changes were noted, the Planning Commission adopted Planning Commission Resolution No. 15 -07, recommending that the City Council ADOPT Resolution 2015 -29. Recommendation: That the City Council: 1. Conduct the noticed public hearing and receive public comment; 2. The City Council approve Resolution NO. 2015-29, entitled: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD APPROVING DESIGN REVIEW 14.03 FOR THE CONSTRUCTION OF A NEW RESIDENTIALICOMMERCIAL MIXED USE DEVELOPMENT TOTALING 11,860 SQUARE FEET OF RETAILIOFFICE SPACE AND 46 APARTMENTS. THE PROJECT INCUDES A DENSITY BONUS APPLICATION. THE SUBJECT SITE IS LOCATED AT 8408 GARVEY AVENUE IN THE C -3 MUDO -D (MEDIUM COMMERCIAL WITH A MIXED USE AND DESIGN OVERLAY) ZONE (APN:5283. 005.028) 3. The City Council adopt the Mitigation Negative Declaration and file the Notice of Determination for the project. Page 4 of 12 ROSEMEAD CITY COUNCIL, HOUSING DEVELOPMENT CORPORATION AND THE SUCCESSOR AGENCY OF THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION JOINT MEETING AGENDA JUNE 9, 2015 C. Resolution No. 201528 — A Resolution of the City Council of the City of Rosemead Ordering the Vacation of the Alley between Brighton Street and Del Mar Avenue On May 12, 2015, the City Council adopted Resolution No. 2015 -21, declaring its intention to vacate the Alley between Brighton Street and Del Mar Avenue, and setting June 9, 2015, as the date for a public hearing on this matter. Recommendation: That the City Council approve Resolution No. 2015 -28, entitled: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD ORDERING THE VACATION OF THE ALLEY BETWEEN BRIGHTON STREET AND DEL MAR AVENUE 5. CONSENT CALENDAR A. Claims and Demands • ResolutionNo.2015 -37 Recommendation: to approve Resolution No. 2015 — 37, entitled: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD ALLOWING CERTAIN CLAIMS AND DEMANDS IN THE SUM OF $630,846.28 NUMBERED 88866 THROUGH 89000 INCLUSIVELY • ResolutionNo.2015 -12 Recommendation: to approve Resolution No. 2015 —12, entitled: A RESOLUTION OF THE CITY OF ROSEMEAD AS THE SUCCESSOR AGENCY OF THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION ALLOWING CERTAIN CLAIMS AND DEMANDS IN THE SUM OF $88,911.25 NUMBERED 10130 Page 5 of 12 ROSEMEAD CITY COUNCIL, HOUSING DEVELOPMENT CORPORATION AND THE SUCCESSOR AGENCY OF THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION JOINT MEETING AGENDA JUNE 9, 2015 B. Second Reading of Ordinance No. 949: Adoption of Development Impact Fees (DIF) and Resolution No. 2015.07, Approving the Final Draft DIF Study On May 26, 2015, the City Council introduced Ordinance No. 949, amending the Rosemead Municipal Code by repealing Section 12.44.020 (Park and Recreation Impact Fee) of Title 12, Chapter 12.44 and adding Article 7 (Development Fees), Chapter 17.170 (Development Impact Fees) to Title 17 to establish Development Impact Fees (DIF) for new residential and nonresidential development. The City Council further directed staff to reduce the proposed park fee for the single - family land use category from $5,900 to $4,318 and gave direction to lower the multi - family land use category by a proportionate amount. Therefore, the final proposed City Council Resolution No. 2015 -07 includes the reduced park impact fee of $4,318 for new single - family dwelling and $3,597 for multi - family dwellings. No other modifications were made to City Council Resolution No, 2015 -07 Recommendation: That the City Council: 1. Adopt Ordinance No. 949 at its second reading, entitled: AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA, AMENDING THE ROSEMEAD MUNICIPAL CODE BY REPEALING SECTION 12.44.020 (PARK AND RECREATION IMPACT FEE) OF TITLE 12, CHAPTER 12.44 AND ADDING ARTICLE 7 (DEVELOPMENT FEES), CHAPTER 17.170 (DEVELOPMENT IMPACT FEES) TO TITLE 17 TO ESTABLISH DEVELOPMENT IMPACT FEES FOR NEW RESIDENTIAL AND NONRESIDENTIAL DEVELOPMENT 2. Approve Resolution No. 2015 -07, entitled: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA, ADDING DEVELOPMENT IMPACT FEES TO THE CITY'S COMPREHENSIVE FEE SCHEDULE TO IMPLEMENT THE DEVELOPMENT FEE PROGRAM ESTABLISHED BY ORDINANCE NO. 949 C. Annual Salary and Benefits Resolutions The City Council will consider approval of four annual salary and benefits Resolutions: General Service Unit, Middle Management, Professional, and Confidential Service Unit, Management Service Unit, and City Council. The Resolution for the General Service Unit includes an amendment to an existing Memorandum of Understanding (MOU) with the Rosemead Employees Association (REA) covering all General Service employees. The other annual Resolutions detail the changes to the terms and conditions of employment for Page 6 of 12 ROSEMEAD CITY COUNCIL, HOUSING DEVELOPMENT CORPORATION AND THE SUCCESSOR AGENCY OF THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION JOINT MEETING AGENDA JUNE 9, 2015 other full -time employees. The purpose of the annual salary and benefits resolutions is to ensure transparency and to implement modifications to the City's compensation system. Amendments to the MOU and Resolutions also include salary range adjustments for various full -time classifications to maintain a competitive position in the local labor market in accordance with existing policies and procedures. Recommendation: That the City Council approve Resolution No. 2015 -31, Resolution No. 2015 -32, Resolution No. 2015 -34, and Resolution No. 2015 -35, respectively entitled: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA, ESTABLISHING ANNUAL SALARY RANGES AND BENEFITS FOR CLASSIFICATIONS IN THE GENERAL SERVICE UNIT OF THE CITY OF ROSEMEAD A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA, ESTABLISHING ANNUAL SALARY RANGES AND BENEFITS FOR CLASSIFICATIONS IN THE MIDDLE MANAGEMENT, PROFESSIONAL, AND CONFIDENTIAL SERVICE UNIT OF THE CITY OF ROSEMEAD A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA, ESTABLISHING ANNUAL SALARY RANGES AND BENEFITS FOR CLASSIFICATIONS IN THE MANAGEMENT SERVICE UNIT OF THE CITY OF ROSEMEAD A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA, ESTABLISHING ANNUAL SALARY RANGES AND BENEFITS FOR THE CITY COUNCIL OF THE CITY OF ROSEMEAD D. Resolution Authorizing the Release of Unclaimed Checks Pursuant to Government Code Section 50050 through 50056 On an annual basis, the City is required to review the outstanding check list for outdated checks pursuant to Government Code Section 50050 through 50056. Unclaimed checks which are held over three (3) years are published once a week for two successive weeks in a newspaper of general circulation published in the City of Rosemead. A statement announcing that the money shall become the property of the City of Rosemead forty -five (45) days after the publication of the first notice is included in the Public Notice. Upon the close of business on the forty -fifth (45) day after publication of the first notice, the unclaimed checks shall become the property of the city of Rosemead and transferred to the General Fund. Page 7 of 12 ROSEMEAD CITY COUNCIL, HOUSING DEVELOPMENT CORPORATION AND THE SUCCESSOR AGENCY OF THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION JOINT MEETING AGENDA JUNE 9, 2015 Unclaimed checks that are less than $15 which remain unclaimed for a period of at least one year can be transferred to the General Fund after City Council approval without having to publish a notice in the newspaper. Recommendation: That the City Council approve Resolution No. 2015 -27, entitled: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA, AUTHORIZING THE RELEASE OF UNCLAIMED CHECKS PURSUANT TO GOVERNMENT CODE SECTION 50050 AND 50053 TO THE CITY OF ROSEMEAD E. Deputy Probation Officer Annual Contract Renewal The City currently contracts with the Los Angeles County Probation Department for one Deputy Probation Officer (DPO's) for juvenile prevention and intervention programs. The DPO works full -time with Rosemead youth who have been identified as at -risk or arrested for minor criminal offenses. These juveniles may have problems ranging from school performance and attendance to vandalism, theft and drug arrests. The DPO's authority allows him to work closely with the juveniles and their families to implement a variety of programs and services to help correct their behavior. Recommendation: That the City Council approve the agreement with the Los Angeles County Probation Department and authorize the City Manager to sign any necessary documentation. F. Used Oil Payment Program Grant Application The California Oil Recycling Enhancement Act of 1991 authorizes the Department of Resources Recycling and Recovery (CalRecycle), formerly known as the California Integrated Waste Management Board, to award grants to enhance the collection and recycling of used lubricating oil. Rosemead is eligible to apply under the Used Oil Payment Program for the July 1, 2015 — June 30, 2016 fiscal year. Recommendation: That the City Council approve Resolution No. 2015 -33, entitled: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA, AUTHORIZING THE SUBMITTAL OF AN USED OIL PAYMENT PROGRAM APPLICATION AND RELATED AUTHORIZATIONS Page 8 of 12 ROSEMEAD CITY COUNCIL, HOUSING DEVELOPMENT CORPORATION AND THE SUCCESSOR AGENCY OF THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION JOINT MEETING AGENDA JUNE 9, 2015 6. MATTERS FROM CITY MANAGER & STAFF A. Enhanced Watershed Management Program (EWMP) for Compliance with Federal and State Storm Water Regulations The California Regional Water Quality Control Board, Los Angeles Region (Board) adopted an updated National Pollutant Discharge Elimination System (NPDES), Municipal Separate Storm Sewer System (MS4) Permit, Order No. R4- 2012 -0175, effective December 28, 2012. This MS4 Permit is a set of regulations, control measures, and programs aimed at preventing the pollution of storm water and urban runoff within Los Angeles County. The Permit applies to municipalities who operate a storm sewer system within Los Angeles County and 84 of the 88 cities in the County are party to this Permit. Prior to the issuance of the MS4 Permit effective December 28, 2012, all agencies were operating under a Permit issued in 2001. By comparison, the newly updated MS4 Permit contains more stringent water quality regulations but enables a collective approach to compliance. In June 2013, the City Council approved the City's participation in a group, consisting of sixteen (16) other cities and Los Angeles County, to develop an Enhanced Watershed Management Program (EWMP) as the City's chosen mechanism of compliance with the MS4 Permit. The Enhanced Watershed Management Plan is a multifaceted approach to manage stormwater and improve water quality throughout the region. The draft plan, to was prepared by a team of consultants, is ready for submittal to the Board for approval. Attaining compliance with MS4 permit through the implementation of an EWMP requires jurisdictions to implement Green Streets Best Management Practices (BMPs) which divert stormwater runoff from gutters into retention mechanisms such as bio- swales or curb cuts that allow for soil infiltration. Recommendation: That the City Council; 1. Receive and file this report; and 2. Approve Resolution No. 2015 -38, entitled: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA, ADOPTING A POLICY OF IMPLEMENTING GREEN STREETS BEST MANAGEMENT PRACTICES FOR STORMWATER MANAGEMENT Page 9 of 12 ROSEMEAD CITY COUNCIL, HOUSING DEVELOPMENT CORPORATION AND THE SUCCESSOR AGENCY OF THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION JOINT MEETING AGENDA JUNE 9, 2015 B. Adoption of the City of Rosemead Appropriations Limit Article XIIIB of the Constitution of the State of California was enacted by a vote of the people as Proposition 4 (the Gann Initiative) in November 1979. This law limits the level of most appropriations from tax sources that the state and most local government entities are permitted to make in any given year. It also requires that annually each government unit calculate its Appropriations Limit and adopt it by Resolution prior to the beginning of the fiscal year under consideration. Recommendation: That the City Council approve Resolution No. 2015 -36, entitled: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA, ADOPTING AN APPROPRIATION LIMIT FOR THE 2015.16 FISCAL YEAR C. Adoption of the 2015.16 Fiscal Year Budget The City Council will consider the adoption of the City's Budget for the 2015 -16 Fiscal Year, which provides for total appropriations of $31,014,300. The ongoing General Fund Operating Budget of $20,107,200 is balanced with a small surplus for the upcoming fiscal year. Consequently a full scope of services to residents will be continues without service reductions. A budget workshop with the City Council was held on May 12, 2015. Since the budget workshop was conducted, several adjustments to General Fund expenditures have been made to reflect better estimates of the FY 2015 -16 costs. After adjustments, the General Fund operating budget has a surplus of $345,800; however, the operating surplus will be transferred into the Capital Improvement Program (CIP) along with limited resources from the unallocated fund balance of the General Fund to pay for needed infrastructure projects. Recommendation: That the City Council: 1. Approve Resolution No. 2015 -30, entitled: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA, ADOPTING THE ANNUAL OPERATING AND CAPITAL IMPROVEMENT BUDGET FOR THE 2015.16 FISCAL YEAR 2, Approve Resolution No. 2015 -06, entitled: A RESOLUTION OF THE ROSEMEAD HOUSING DEVELOPMENT CORPORATION ADOPTING THE ANNUAL OPERATING AND CAPITAL IMPROVEMENT BUDGET FOR THE 2015.16 FISCAL YEAR Page 10 of 12 ROSEMEAD CITY COUNCIL, HOUSING DEVELOPMENT CORPORATION AND THE SUCCESSOR AGENCY OF THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION JOINT MEETING AGENDA JUNE 9, 2015 D. Adopt Urgency Ordinance No. 953 Amending Municipal Code Section 13.04 concerning Water Conservation On November 10, 2014 the City Council adopted Resolution 2014 -57 implementing Phase II water shortage conservation measures. Subsequently, on April 1, 2015 Governor Brown issued an executive order mandating additional water conservation of 25% statewide compared to 2013 usage figures. Based upon the additional mandates, the City's current Phase II restrictions are not sufficient and the City's current code section 13.04.060 regulating Phase III restrictions also are not sufficient. Therefore, Urgency Ordinance 953 is being presented to completely amend code sections 13.04.040, 13.04.050, 13.04.060 and 13.04.080 to ensure compliance with the Governor's mandate and the intended response of the six (6) water companies that supply water to Rosemead. Additionally, due to the Governor's executive order, the City Council needs to declare a Phase III water shortage with mandatory conservation measures. Recommendation: That the City Council: 1, Adopt Urgency Ordinance No. 953, entitled AN URGENCY ORDINANCE OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA, AMENDING CHAPTERS 13.04.040, 13.04.050, 13.04.060 AND 13.04.080 OF THE ROSEMEAD MUNICIPAL CODE CONCERNING WATER CONSERVATION 2. Approve Resolution No. 2015 -24, entitled: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD, CALIFORNIA DECLARING A PHASE III WATER SHORTAGE WITH MANDATORY WATER CONSERVATION MEASURES 7. MATTERS FROM CITY COUNCIL 8. ADJOURNMENT The next regular City Council meeting is scheduled to take place on June 23, 2015 at 7:00 p.m. in the Rosemead City Hall Council Chamber. Page 11 of 12 ROSEMEAD CITY COUNCIL, HOUSING DEVELOPMENT CORPORATION AND THE SUCCESSOR AGENCY OF THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION JOINT MEETING AGENDA JUNE 9, 2015 Upcoming City - Sponsored Community Events Rosemead Park Skate Plaza Design Workshop Wednesday, June 17` Rosemead Community Recreation Center 6:00 p.m. - 8:00 p.m. 3936 N. Muscatel Avenue Relay for Life Luminaria Ceremony Thursday, June 25" Zapopan Park 7:30 p.m, - 9:00 p.m. 8301 Garvey Avenue Page 12 of 12