10-163 Formation of Spokane Regional Transportation Council silk 1 4 200
Sfi,C
' Return To:
Spokane Regional Transportation Council
221 W. First Avenue, Suite 310
Spokane, WA 99201
AN INTERLOCAL AGREEMENT AMONG SPOKANE COUNTY,
CITY OF SPOKANE, CITY OF SPOKANE VALLEY,
WASHINGTON STATE DEPARTMENT OF TRANSPORTATION,
SPOKANE TRANSIT AUTHORITY, AND OTHER CITIES AND
TOWNS WITHIN SPOKANE COUNTY, TO FORM THE
SPOKANE REGIONAL TRANSPORTATION COUNCIL, DEFINE
ITS ORGANIZATION AND POWERS, AND ITS
JURISDICTIONAL AREA.
THIS AGREEMENT, is made and entered into among the County of
Spokane, a political subdivision of the State of Washington, hereinafter referred
to as the "County," the City of Spokane, a municipal corporation of the State of
Washington, the City of Spokane Valley, a non-charter code city of the State of
Washington, the Washington State Department of Transportation, an agency of
........_..... . . .
the State of Washington, hereinafter referred to as "WSDOT," the Washington
State Transportation Commission, hereinafter referred to as '°WSTC", the
Spokane Transit Authority, a municipal corporation of the State of Washington,
hereinafter referred to as "STA," and other incorporated towns and cities
located within Spokane County, hereinafter referred to as "Other Members,"
jointly, along with the County, City of Spokane, STA and WSDOT are
collectively referred to as the "Members."
VVITNESSETH:
WHEREAS, pursuant to the provisions of chapter 39.34 RCW, two or
more public entities may jointly cooperate to perform functions which each may
individually perform; and
WHEREAS, on August 10, 2005, the President of the United States
signed the Safe, Accountable, Flexible, Efficient, Transportation Efficiency Act:
a Legacy for Users (SAFETEA-LU), which provided authorization for highways,
highway safety, and mass transportation and enunciated a policy "[t]o develop a
National Intermodal Transportation System that is economically efficient,
environmentally sound, provide the foundation for the nation to compete in the
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global economy and will move people and goods in an energy efficient manner;"
and
WHEREAS, in 1962, Federal transportation legislation required the
establishment, by agreement between the Governor of the State of Washington
and units of general purpose local government, of a Metropolitan Planning
Organization (MPO), which in cooperation with the State of Washington, shall
develop transportation plans and programs for urbanized areas of Washington
State; and
WHEREAS, Ch. 47.80 RCW authorizes the formation of a Regional
Transportation Planning Organization (RTPO) by voluntary association of local
governments within a county; provided each RTPO shall have as members the
county and at least sixty percent of the cities and towns within the RTPO's
boundaries, representing a minimum of seventy-five percent of the cities' and
towns' population; and
WHEREAS, each RTPO formed by local governments shall create a
transportation policy board to provide policy advice to the RTPO and shall allow
representatives of major employers within the region, the department of
transportation, transit districts, port districts, and member cities, towns, and
counties within the region to participate in policy making; and
WHEREAS, among other duties, each RTPO shall: (i) develop and
periodically update a regional transportation plan in cooperation with the State
department of transportation, providers of public transportation and high
capacity transportation, ports, and local governments within the region and shall
(ii) designate a lead planning agency to coordinate preparation of said regional
transportation plan and carry out the other responsibilities of the organization;
and
WHEREAS, RCW 47.80.020 provides that the RTPO in an urbanized
area shall be the same as the MPO designated for federal transportation
planning purposes; and
WHEREAS, pursuant to the above referenced state and federal laws, the
Members are desirous of establishing a regional transportation council
("Council") to carry out those responsibilities of the MPO as provided for in
Federal Transportation legislation as well as other responsibilities determined
by the Council.
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NOW, THEREFORE, in consideration of the following terms and conditions, to
include the above recitals, which are incorporated herein as a part of this
Agreement, it is agreed among the Members:
Section 1: NAME/ORGANIZATION
A voluntary association and joint board, comprising representatives of
the County, City of Spokane, City of Spokane Valley, Washington State
Department of Transportation (WSDOT), Washington State Transportation
Commission (WSTC), Spokane Transit Authority (STA), and Other Members is
hereby created and shall be known as the Spokane Regional Transportation
Council, referred to hereinafter as the "Council."
Section 2: PURPOSE
Recognizing that coordinated transportation planning of the County,
Cities and Towns, WSDOT, WSTC, STA and Other Members are necessarily
interwoven and interdependent and that the interests of all citizens will best be
served by coordinated, cooperative, and comprehensive transportation
planning, this Council is established to facilitate such appropriate coordination
and cooperation and provide for continuing area wide transportation planning
program in accordance with Section 3, herein.
The Council is not authorized to in any way supersede the authority
vested in the County, Cities and Towns, WSDOT, WSTC, STA or Other
Members, but is intended to meet the prerequisites of United States Code Titles
23 and 49, and RCW Chapter 47.80.
Section 3: POWERS AND FUNCTIONS
The functions, responsibilities, and powers of Council shall be as follows:
(a) To perform the functions of a Transportation Management Area (TMA) for
the metropolitan area, which includes those functions set forth in the
SAFETEA-LU legislation of August 10, 2005, and related rules, as amended
to implement SAFETEA-LU as well as those functions, which may be
required hereinafter by subsequent Federal Transportation legislation.
(b) To perform the functions of a Metropolitan Planning Organization (MPO) as
set forth in Title 23 United States Code and.Title 49 United States Code as
currently adopted or as amended, and 23 CFR Parts 450 and 500 and 40
CFR Part 613, as currently adopted or as amended.
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(c) To perform the functions of a Regional Transportation Planning Organization
(RTPO) as set forth in Ch. 47.80 RCW and Ch. 468-86 WAC, as currently
adopted or as amended.
(d) To prepare and update a Metropolitan Transportation Plan pursuant to 23
CFR Parts 450 and 500 and 49 CFR Part 613.
(e) To engage in regional transportation planning.
(f) To administer regional transportation funding programs and consider those.
projects which have been approved by the governing bodies of the Members
and which are incorporated within the adopted Metropolitan Transportation
Plan.
(g) To participate in the development and maintenance of transportation related
information necessary to support the functions and responsibilities of the
Council.
(h) To promote the regional transportation interests, plans and projects to local,
state and federal public and private entities.
(i) To contract with the WSDOT or other appropriate entities in order to meet
requirements of State and/or Federal Transportation legislation.
(j) To create committees as necessary, to advise the Board on regional
transportation related matters. At a minimum this shall include:
a. the Transportation Advisory Council (TAC) whose composition and
responsibilities shall be defined by the Board.
b. the Transportation Technical Committee (TTC) whose composition and
responsibilities shall be defined by the Board.
(k) To comply with the Transportation Planning requirements set forth in the
Washington State Growth Management Act, and Ch. 47.80 RCW, consistent
with Spokane County County-wide Planning Policies.
(I) To perform such other transportation planning and program related functions
as the Board may hereinafter determine to be in the best interests of the
Council and the members thereof, which are consistent with the terms of this
Agreement and related federal and state law.
The Council, or any of the Members hereto, may receive grants-in-aid
from the State or Federal Government or any other department or agency and
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may accept gifts from public or private entities for the purposes authorized in
this Agreement.
Section 4: JURISDICTIONAL AND METROPOLITAN AREA DEFINED
The Council's jurisdictional area shall consist of all incorporated and
unincorporated areas of Spokane County, Washington, and may include
contiguous areas across county or state boundaries as deemed appropriate
and which meet the criteria of State and/or Federal Transportation legislation.
Section 5: GOVERNING BODY AND OFFICERS
The governing body (the "Board") of the Council, consisting of twelve
voting (12) persons, shall be established by the following thresholds:
(a) Jurisdictions under 50,000 people - One (1) person jointly selected by
jurisdictions with populations between 50,000 and 5,000 people plus one (1)
person jointly selected by jurisdictions with populations fewer than 5,000
people. The person selected shall be an elected official from a small town/city;
(b) Jurisdictions between 50,001 to 100,000 people — one (1) person
appointed by each respective governing body, who shall be an elected official;
(c) Jurisdictions over 100,001 people— two (2) persons appointed by each
respective governing body, who shall be elected officials; (The population of
Spokane County includes the population of its cities and towns);
(d) One (1) Board Member of STA, who shall be appointed by the STA
Board;
(e) Two (2) State Transportation representatives, one (1) from the
Washington State Department of Transportation and appointed by the
Secretary of Transportation, and one (1) from the Washington State
Transportation Commission appointed by the Chair of the Commission;
(f) One (1) person who represents a major employer, with preference for a
provider of private sector transportation services within the region who shall be
appointed by a majority vote of the Board; and
(g) One (1) person who is Chair of the Transportation Advisory Council,
provided such person resides within the jurisdiction of the MPO.
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(h) There shall be four (4) ex officio, non-voting members serving on the
Board representing different modes of transportation, which shall include:
(1) One (1) person representing STA, who shall be appointed by the
STA Board;
(2) One (1) person representing Rail; who shall be appointed by the
Members ;
(3) One (1) person representing Airports; who shall be appointed by
the Airport Board; and
(4) The Chair of the TTC
(i) Pursuant to RCW 47.80.040 all legislators whose districts are wholly or
partly within the designated boundaries of the Council, are considered ex officio
(non-voting) members of the Board.
(j) All Board appointments shall be for a term of three (3) years or the
tenure of office of the representative in his/her respective jurisdiction, whichever
is the lesser time. Alternate Board representatives may serve in the absence of
the designated representative so long as the alternate representative is an
elected or appointed official of the appointing Member's parent agency (or
governing body, as appropriate) and whose name has been placed on record
with the Council. All alternate Board representatives must serve in the same
capacity as the regularly designated representative as defined hereinabove.
(k) The Board shall elect a Chair and Vice-Chair ("Officers") by majority vote
of the Board. Only representatives who are elected officials may be Officers.
To be eligible for the Chair position, the Board Member shall have served on
the Board for at least one year. The term for Officers may be up to two (2)
years in each office. Ex officio members may not serve as Officers.
(j) A Board Member who, during a calendar year, has three (3) unexcused
absences from regular Board meetings shall be automatically removed from the
Board, without further action.
Section 6: MEETINGS
The Council shall hold regular monthly Board meetings. The Chair may
call a special meeting or executive session or shall call a special meeting at the
request of a majority of the Board.
The Board shall adopt rules for the conduct of its business consistent
with this Agreement and such rules shall prescribe the place of meetings, the
method of providing reasonable notice to Members thereof, the form of the
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agenda, the regular meeting date and such other matters that relate to the
conduct of the Council's business. Such rules shall be adopted and may be
amended by a seventy-five percent (75%) positive vote of the Board, or by
amendment to this Agreement as provided herein.
All meetings of the Board shall be open to the public as required by
chapter 42.30 RCW. A quorum for the purpose of transacting business shall
consist of a simple majority of the Board. All recommendations, motions, or
other actions of the Board shall be adopted by a favorable vote of a majority of
those present. Voting Board members shall be entitled to one vote. Provided,
however, that the following enumerated actions shall take an affirmative vote of
a majority of the voting membership of the Board:
(a) Appointment or dismissal of the Executive Director;
(b) Approval of the annual budget expenditure division among the
Members;
(c) Purchase, sale or disposition of real property; and
(d) Addition of new members.
Section 7: STAFF AND SUPPORT
The Board shall determine the positions, duties and working conditions
of employees as necessary to conduct the work programs of the Council
consistent with this Agreement. An Executive Director shall be appointed by
and serve solely at the pleasure of the Board. The Board shall adopt policies
and procedures to establish the duties and authorizes of the Executive Director,
including authority to make financial expenditures on behalf of the Board. The
Board shall approve application(s) for or acceptance of any grants to carry out
those functions set forth in Section 3 hereinabove. Provided, however, in
instances where a grant application must be submitted prior to the next
regularly scheduled meeting of the Board so that timely Board approval cannot
be obtained, the grant application may still be submitted with mutual approval of
the Chair and Vice-Chair.
Unless otherwise determined by the Board, employees are at-will and
shall be hired and discharged by and work under the direction of the Executive
Director.
The Board may arrange for support services such as requisitioning and
purchasing, payment of expenditures, accounting, payroll, computer
processing, legal counsel, and others as deemed necessary.
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Pay schedules shall be set by the Board consistent with responsibilities
performed and the demand for such personnel in public and private industry,
with due consideration to pay schedules for like positions in Member agencies.
Section 8: WORK PROGRAM AND ANNUAL BUDGET
The Board shall prepare and adopt a proposed work program and
budget for each calendar year The detailed annual work program shall list
specific work projects to be undertaken by the Council. The Executive Director
or designee shall confer with and inform Members concerning the preparation
of and progress on the technical areas of work programs and projects. The
proposed annual budget shall set forth the methodology for determining the
allocation of costs, appropriations and expenditures to each member.
The Board shall submit the proposed work program and budget to the
Members by August 1 of the preceding year. Approval or rejection of such
budget by each Member shall be submitted to the Council by November 1 of
each year Members from jurisdictions identified in Section 5(a) that have not
previously been required to contribute funds toward the annual budget and
Members who have annual assessments increased by more than fifteen
percent (15%) shall be given written notice one (1) year in advance of a
proposed budget assessment.
Following a request from a Member to perform services on a specific
project, not identified in the work program, the Board may impose a special
assessment on the requesting Member. The special assessment shall be: (a)
reasonably determined by the Board and (b) reimburse the costs and expenses
associated with the specific project.
The annual budget and/or work program of the Council may be amended
by vote of the Board, provided such amendment does not require additional
budget appropriation in excess of the amounts established in the second
paragraph of this Section 8, by the Members. After approval of the Council
budget, no Member may terminate or withhold its share during the year for
which it was allocated.
Section 9: ALLOCATION OF COSTS, APPROPRIATIONS,
EXPENDITURES
It is anticipated that most projects and programs of the Council will
involve mutual benefit to its Members. Costs of the annual budget expenditures
shall be divided among the Members as recommended by the Board and
approved by the Members in the budget approval process. Any additional
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agency joining the Council as a Member, shall contribute as agreed with the
Board. Additional contributions to the Council budget may be made to
accomplish projects and programs deemed to be of particular pertinence or
benefit to one or more of the Member agencies.
Each funding Member approving the proposed Council budget shall
submit its payment on or before January 20 of the budget year that it has
approved. The funds of such joint operation shall be deposited in the public
treasury of the City of Spokane or the public treasury of any other Member as
so agreed upon by the Members; and such deposit shall be subject to the same
audit and fiscal controls as the public treasury where the funds are so
deposited. The funds shall be used in accordance with the adopted budget and
work plan.
The Executive Director may make expenditures in accordance with the
approved Council budget, work plan and approved policies and procedures,
and shall maintain records of expenditures and report monthly.to the Board on
budget activity.
Payment of all claims shall be signed by the Executive Director or
designee, and approved monthly by the Board. Such claims, with proper
affidavits required by law, shall then be certified for payment by the City of
Spokane or as arranged by the Board.
Section 10: REAL AND PERSONAL PROPERTY
The Council may, through gift, devise, purchase, lease or other form of
conveyance, acquire, hold, manage, use and dispose of real and personal
property necessary for the joint undertaking set forth herein with such property
acquisition upon such terms and conditions as agreed by the Board. It is
recognized that any public or private entity may appropriate funds and may sell,
lease, give or otherwise supply real and personal property, personnel and
services to the Council or other legal or administrative entity for the purpose of
operating the joint or cooperative undertaking.
The Council may not acquire or use real property to operate a
transportation system.
Section 11: INSURANCE
The Council shall obtain property and liability insurance for the matters
set forth in this Agreement with coverages and limits reasonably determined by
the Council, provided, insurance coverage for comprehensive general liability,
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auto liability, employment practices liability, public officials errors and omissions
liability, shall not be less than $10,000,000 in the aggregate.
Section 12: INTER-RELATIONSHIP BETWEEN COUNCIL, CITIES AND
COUNTY PLANNING COMMISSIONS
Cities and County Planning Commissions shall continue their respective
functions as provided by charter and/or State law, including preparation of
Cities' and County Comprehensive Plans, to which the Metropolitan
Transportation Plan and Regional Transportation Improvement Plan shall be
coordinated, and administering the zoning, subdivision and similar
implementing controls as may be assigned them by their respective legislative
bodies.
The successful execution of Council duties and responsibilities in
preparing a Metropolitan Transportation Plan and Regional Transportation
Improvement Plan, in coordination with state and local plans, , requires
comprehensive plans be prepared and kept up-to-date by the City, County, and
Other Members for their respective jurisdictions.
Section 13: AMENDMENTS AND NEW MEMBERS
This Agreement may be amended by unanimous consent of the
Members' governing bodies, except WSDOT may take action through its
Secretary. Upon majority consent of the voting Members, new members may
join the Council upon written acceptance of the terms of this Agreement.
Section 14: TERMINATION OF MEMBERSHIP
The Cities, County, STA, WSDOT, WSTC, or Other Members of the
Council may terminate membership in the Council by giving written notice to the
Council prior to August 1 of any year for the following year.
Section 15: PRIOR WRITTEN AGREEMENTS
This Agreement shall supersede the following Agreements:
Agreement creating the Spokane Regional Planning Conference,
Spokane, Washington, dated December 15, 1966.
An Amended Agreement between Spokane County, Washington, and
City of Spokane, Washington, to form a Spokane Regional Planning
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}
Conference, Define its Organization and Powers, and Establish its Regional
Planning District, dated August 31, 1972.
An Amended Agreement between Spokane County, Washington, and
the City of Spokane, Washington, and other municipalities, to form Spokane
Regional Council, Define its Organization and Powers, and Establish Regional
Council Jurisdiction Area, dated August 15, 1984.
An Interlocal Agreement among Spokane County, City of Spokane,
Washington State Department of Transportation, Spokane Transit Authority,
and Other Cities and Towns within Spokane County, to form a Regional
Transportation Council, Define its Organization and Powers, and Establish a
Regional Council Jurisdictional Area dated October 12, 1993.
An Interlocal Agreement among Spokane County, City of Spokane,
Washington State Department of Transportation, Spokane Transit Authority,
and other Cities and Towns within Spokane County to form a Spokane Regional
Transportation Council, Define its Organization and Powers, and Establish a
Regional Council Jurisdictional Area dated April 28, 2003.
Section 16: EFFECTIVE DATE and Binding Agreement
The effective date of this Agreement shall be upon ratification of this
Agreement by the County and, at least, sixty percent (60%) of the cities and
towns within the council area that represent seventy- five percent (75%) of the
cities' and towns' population. This Agreement shall be binding upon the
Members who have executed this Agreement, their successors and assigns.
Section 17: METROPOLITAN PLANNING ORGANIZATION (MPO)
DESIGNATION
The execution of this Agreement by the Members is not intended to act
as a revocation of the MPO or constitute a substantial change in authority or
responsibility of the MPO and shall not be interpreted to require the
redesignation of the MPO under 23 CFR § 450.310.
Section 18: SUCCESSOR IN INTEREST
The Council, as provided for herein, shall be the successor in interest to
all grants, contracts, and other documents entered into by the Council's
predecessor, the Spokane Regional Council.
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Section 19: DEFAULT
Failure by any Member to perform, observe or comply with the
covenants, agreements or conditions on its part contained in this Agreement
where that failure continues for a period of thirty (30) days after written notice
from the Council to the defaulting Member shall constitute an "Event of Default."
Section 20: REMEDIES
In the event of any Event of Default, the Council may at any time, without
waiving or limiting any other right or remedy, pursue any remedy allowed by law
including, by way of example and without limitation, specific performance,
declaratory judgment and other equitable remedies, and recovery of attorney's
fees and other costs for such enforcement action.
Section 21: GENERAL TERMS
This Agreement contains terms and conditions agreed upon by the
Members. The Members agree that there are not other understandings, oral or
otherwise, regarding the subject matter of this Agreement.
In the event any portion of this Agreement should become invalid or
unenforceable, the rest of the Agreement shall remain in full force and effect.
This Agreement shall be construed under the laws of Washington State.
Any action at law, suit in equity or judicial proceeding regarding this Agreement
or any provision hereto shall be instituted only in courts of competent
jurisdiction within Spokane County, Washington.
This Agreement may be executed in any number of counterparts, each of
which, when so executed and delivered, shall be an original, but such
counterparts shall together constitute but one and the same.
Nothing in this Agreement is intended to give, or shall give, whether
directly or indirectly, any benefit or right, greater than that enjoyed by the
general public, to third persons.
The section headings in this Agreement have been inserted solely for the
purpose of convenience and ready reference. In no way do they purport to and
shall not be deemed to define, limit or extend the scope or intent of the sections
to which they pertain.
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Section 22: RCW CHAPTER 39.34 REQUIRED CLAUSES
A. PURPOSE
See Section No. 2 above.
B. DURATION
This Agreement is perpetual until the joint and comprehensive
undertaking is either voluntarily dissolved or discontinued
pursuant to RCW 47.80.020.
C. ORGANIZATION OF SEPARATE ENTITY AND ITS POWERS
The Board shall administer the joint and cooperative undertakings
set forth herein.
D. RESPONSIBILITIES OF THE PARTIES
See provisions above.
E. AGREEMENT TO BE FILED
This Agreement may be filed with the County Auditor or published
on the Members' websites, as available.
F. FINANCING
See Section Nos. 8 and 9 above.
G. TERMINATION
See Section No. 14 above.
H. PROPERTY UPON TERMINATION
Any Member terminating its membership in the Council as
provided for in Section 14 hereinabove shall forfeit any ownership
interest in any personal or real property owned or held by the
Council.
Personal property acquired by the Council in the performance of
this Agreement shall be disposed of by the Council upon
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termination of the Agreement. Unless otherwise required by law
or agreement, cash and cash proceeds from sale of personal
property shall be disbursed to the Members according to the
contribution made by the Member as set forth in this Agreement.
Real property shall be conveyed or disposed of as set forth in this
Agreement in the same manner as personal property except
where a separate instrument or deed reservation exists with
regard to any real property in which instance it shall control.
IN WITNESS WHEREOF, the Members hereto have entered into this
Agreement on the day and year of their respective signature.
."
COR3Agj\`i1 ADOPTED by the Board of County
4 of co Ssro `tEl Commissioners of Spokane County,
� Qom - oy���� 4P, Washington this '7fI day of
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: i c, Pt , 2010.
roe 1
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SEAL. WA/AZ)
caul , Mark Richard, Chair
ATTEST:
DANIELA ERICKSON Bonnie Mager, V ce-Chair
716.tej,4_,
LER OF THE BOARD
B 'ALAI �a� t o -a ,
Daniela Erickson. Todd Mielke, Commissioner
Clerk of the Board
ATTEST' CITY OF SPOKANE
CityCle' A ting By
Date: 8- 12- 20/0
Approved as to form:
Assistant City A orney
(S0165051;1 } Page 14 of 16
WASHINGTON STATE SPOKANE TRANSIT AUTHORITY
DEPARTMENT OF TRANSPORTATION
0)14 ��a-�•QSu
Secretary of Tr sport io By
Date: p�z 3//U Date: \'
WASHINGTON STATE
TRANSPORTATION COMMISSION
/10- .`
By -- /
Date:
CITY OF AIRWAY HTS., CITY OF CHENEY, WASHINGTON
WASHINGTON
Date: "-Z-/ - l Date: q - 1 0
CITY OF DEER PARK, WASHINGTON CITY OF FAIRFIELD, WASHINGTON
MetA.4.1c.2).),_w_
Date: il/i//id e Date: q' -
CITY OF LATAH, WASHINGTON CITY OF LIBERTY LK., WASHINGTON
VapLy0 U.)AgAnA-c/ Ce.,A. (),T\)/)A-44"-
By By
Date: II- 1Y- 2OID Date: � , 1,0
(50165051,1 ) Page 15 of 16
CITY OF MEDICAL LAKE, CITY OF MILLWOOD, WASHINGTON
WASHINGTO
, / /ati
Day t:: /e/2-3//0 Date: /07/ Z/ 10
ATTEST: PaArvka , CtS(oo-n,.
CITY OF ROCKFORD, WASHINGTON CITY OF SPANGLE, WASHINGTON
ielaitA1 Atiti
By By
Date: q/ia/i0 Date: 'T-t a-1(-)
CITY OF WAVERLY, WASHINGTON CITY OF SPOKANE VALLEY,
WASHINGTON
ii4L
By :y
Date: Date: i� I
{S0165051;1 } Page 16 of 16
CITY OF MEDICAL LAKE, CITY OF MILLWOOD, WASHINGTON
WASHINGTON
By By
Date: Date:
CITY OF ROCKFORD, WASHINGTON CITY OF SPANGLE, WASHINGTON
By By
Date: Date:
CITY OF WAVERLY, WASHINGTON CITY OF SPOKANE VALLEY,
WASHINGTON
By By
Date: Date:
(50165051;1 } Page 16 of 16