CITY OF ELK GROVE CITY COUNCIL STAFF REPORT

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1 CITY OF ELK GROVE CITY COUNCIL STAFF REPORT AGENDA ITEM NO. 9.1 AGENDA TITLE: A public hearing to consider a Determination of Public Convenience or Necessity for off-sale of beer and wine for Bruceville ARCO AM-PM (EG ) (CEQA Exempt) MEETING DATE: April 12, 2017 PREPARED BY: DEPARTMENT HEAD: Robby Thacker, Project Planner Darren Wilson, P.E., Development Services Director PROJECT DESCRIPTION: Location: Planner: Applicant: Property Owner: Southeast corner of Bruceville Road and Whitelock Parkway; APN: Robby Thacker, Assistant Planner Bruceville Enterprises Inc. Ken Dharni, (Representative) Taylor/Village Sacramento Investment Partners John Glikbarg (Representative) RECOMMENDED ACTION: Staff recommends the City Council adopt a resolution: 1) Finding the Bruceville ARCO AM-PM Project (EG ) exempt from the California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3) (General Rule Exemption) of the State CEQA Guidelines; and 2) Approving a Determination of Public Convenience or Necessity for a Type 20 alcohol license for the Bruceville ARCO AM-PM Project. 1

2 Elk Grove City Council April 12, 2017 Page 2 of 5 BACKGROUND INFORMATION: Bruceville Enterprises (Applicant) requests a Letter of Public Convenience or Necessity (PCN) from the City Council to allow the transfer of a Type 20 alcohol license from the Department of Alcohol Beverage Control (ABC) to the subject location. The site will accommodate a future ARCO AM-PM fueling station and convenience store as part of the Vineyard at Madeira Phase III project (EG ) which has not yet started construction. This development will also include a Taco Bell restaurant, Autozone retail store, and two additional commercial buildings. The center is located at the southeast corner of Whitelock Parkway and Bruceville Road (Figure 1). Figure 1 Project Location Map ANALYSIS: Chapter 4.54 of the Elk Grove Municipal Code establishes a protocol for the issuance and review of Determination of Public Convenience or Necessity. The protocol includes review by the Police Department, Planning Department, Code Enforcement Department, Business Licensing, and Building Department to determine compliance with any applicable 2 2

3 Elk Grove City Council April 12, 2017 Page 3 of 5 policy, regulation, or standard. In addition, the City Council is required to consider the following factors in making a Determination of Public Convenience or Necessity: 1. Proximity and number of other retail outlets selling alcohol; 2. Proximity of the retail outlets to schools, playgrounds, and other facilities serving young people; 3. Proximity of the retail outlet to residential neighborhoods; and 4. Whether the retail outlet provides: (a) a wide range of desirable goods and services; or (b) a unique type of goods or services. As previously mentioned, a variety of City departments and other agencies are required to review PCN applications in order to review past or current issues at the proposed store location. None of the reporting agencies noted any concerns with the ARCO AM-PM location. The proposed ARCO AM-PM convenience store is approximately 3,000 square feet in size, of which approximately 1,700 square feet is comprised of retail sales area. According to information provided by the applicant, ARCO AM-PM stores are designed using the principles of Crime Prevention Through Environmental Design. This approach relies on techniques that deter criminal activity by creating natural surveillance, providing access control, and implementing security measures. As part of the Vineyard at Madiera Phase III approval, the Project was conditioned to impose certain security measures and protocols related to the sale of alcohol and security functions of the convenience store to ensure proper safety and regulation of the business and to mitigate potential criminal impacts. Condition No. 17 requires that all alcoholic beverages be maintained in direct observation of the cashier, and coolers containing alcohol shall be locked between the hours of 2:00 A.M and 6:00 A.M (see Figure 2). Additionally, Condition No. 18 prohibits the sale of single containers of alcohol less than 750 ml and must be sold in factory pre-packaged units. In addition to these requirements, the Applicant indicates that staff members employed at the convenience store are required to go through on-going training for age-restricted sales. Stores are also equipped with security cameras, mirrors, and registers that contain features that assist in flagging under-age sales attempts. 3

4 Elk Grove City Council April 12, 2017 Page 4 of 5 Figure 2 Building Floor Plan Since the area dedicated to alcohol sales is less than the City's standard that would trigger a conditional use permit (less than 50% of the shelving or gross floor area devoted to the public display and sale of alcoholic beverages), the City Council cannot impose conditions on the sale of alcohol other than the basic requirements of State law (which would be enforced by the State of California) and of the Elk Grove Zoning Code (sign area, lighting, and other standards common to all retail stores). Over-Concentration The State Department of Alcoholic Beverage Control requires an Applicant to obtain a PCN from the affected jurisdiction when the establishment is located within a census tract deemed over-concentrated with licenses by ABC s standards. The Project site is within Sacramento County census tract According to ABC, no more than two off-sale and four on-sale licenses are allowed in this census tract before it is considered to be overconcentrated. The census tract has three active Type 20 beer and wine offsale licenses and one active Type 21 general liquor off-sale license; therefore, the census tract is deemed to be over-concentrated by ABC. 4 4

5 Elk Grove City Council April 12, 2017 Page 5 of 5 Applicant's PCN Determination Justification As part of the request for a PCN, an Applicant must explain how the alcohol license will serve the public s convenience or necessity. In response, the Applicant notes that the ability to offer alcoholic beverages is an essential part of convenience store sales, making up approximately 35 percent of total sales. It would also offer customers the ability to purchase alcoholic beverages when only needing to purchase gasoline within the immediate area, and have no need to shop at a larger retailer (see Attachment 3). ENVIRONMENTAL ANALYSIS The California Environmental Quality Act (Section 21000, et seq., of the California Public Resources Code - hereafter CEQA) requires analysis of agency approvals of discretionary projects. A project, under CEQA, is defined as the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment. The proposed Project is a project under CEQA. Staff has reviewed the Project to determine the required level of review under CEQA. The proposed Project is exempt from CEQA under State CEQA Guidelines Section 15061(b)(3) (General Rule Exemption). Section 15061(b)(3) of the CEQA Guidelines states that an activity is covered by the general rule that CEQA only applies to projects which have the potential for causing a significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA review. Granting this Public Convenience or Necessity will not bring about any physical change to the environment and will not have any potential for causing a significant effect on the environment. FISCAL IMPACT: Approval of this Project will not impact the City s General Fund. ATTACHMENTS: 1. Resolution 2. Elk Grove Police Department Letter dated February 17, Applicant Justification Letter 5

6 ATTACHMENT 1 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ELK GROVE APPROVING A DETERMINATION OF PUBLIC CONVENIENCE OR NECESSITY FOR A TYPE 20 BEER AND WINE OFF-SALE LICENSE FOR BRUCEVILLE ARCO AM-PM LOCATED AT THE SOUTHEAST CORNER OF WHITELOCK PARKWAY AND BRUCEVILLE ROAD, ASSESSOR PARCEL NUMBER PROJECT NO. EG (CEQA EXEMPT) WHEREAS, the Planning Division of the City of Elk Grove received an application on January 31, 2017, requesting a Determination of Public Convenience or Necessity for Bruceville Enterprises Inc. to obtain a Type 20 (Off-Sale Beer and Wine) alcohol license from the Department of Alcoholic Beverage Control in order to sell beer and wine from a future convenience store location; and WHEREAS, the proposed project is located on real property in the incorporated portions of the City of Elk Grove more particularly described as Assessor Parcel Number ; and WHEREAS, Chapter 4.54, Article 5 of the Elk Grove Municipal Code establishes the City Council as the appropriate authority to hear and decide on all Determination of Public Convenience or Necessity requests; and WHEREAS, the City determined that the Project is exempt from the California Environmental Quality Act (CEQA) pursuant to State CEQA Guidelines Section 15061(b)(3), which exempts projects which, with certainty, will not have a significant effect on the environment from CEQA; and WHEREAS, the City Council held a duly noticed public hearing on April 12, 2017, as required by law to consider all of the information presented by staff, information presented by the project proponent, and public testimony presented in writing and at the meeting. NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Elk Grove, hereby finds the proposed Bruceville ARCO AM-PM Project, EG , exempt from the California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3) of the State CEQA Guidelines based upon the following finding: California Environmental Quality Act (CEQA) Finding: The project is exempt from CEQA review. Evidence: Pursuant to Section 15061(b)(3) of the CEQA Guidelines, an activity is covered by the general rule that CEQA only applies to projects that have the potential for causing a significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA review. Granting this Determination of Public Convenience or Necessity will not bring about any physical change to the environment. The PCN is only for the sale of alcohol and will not result in any physical changes to the existing setting. Therefore, the PCN will not have any potential for causing a significant effect on the environment. 6 6

7 AND, BE IT FURTHER RESOLVED that the City Council of the City of Elk Grove hereby approves the Determination of Public Convenience or Necessity for Bruceville ARCO AM-PM Project located at the southeast corner of Whitelock Parkway and Bruceville Road based on the following findings: Public Convenience or Necessity Finding: The proposed use is compatible with neighborhood character. Evidence: The application was routed to the Elk Grove Police Department, the Code Enforcement Department, and the Building Department. No violations against the property or Applicant were identified that would discourage the issuance of a Type 20 alcohol license for Bruceville Enterprises Inc. The future ARCO AM-PM fuel station and convenience store is located in a SC - Shopping Center zone district and is generally surrounded by other commercially-zoned properties and uses with an existing shopping center. Therefore, the sale of alcohol for off-site consumption at this location is compatible with the uses in the surrounding area. The nearest school is Arlene Hein Elementary School, which is located approximately 0.5 miles north-west of the shopping center. The nearest park is Promenade Park, which is located approximately 1,000 feet to the north. The nearest residence is located on Chappelle Way, which is located approximately 300 feet to the east. The fuel station and convenience store would be surrounded by other commercial buildings and would not directly interface with the nearest residential area. Finding: The proposed use will be of benefit to the neighborhood. Evidence: As the sale of alcoholic beverages is ancillary to the sale of general fuel and grocery sales, the PCN determination will increase convenience to local shoppers. By including the sale of alcoholic beverages with the existing inventory, ARCO AM-PM will offer customers convenience with the ability to purchase alcohol when only needing to purchase gasoline without having the need to patronize larger scale retail centers. PASSED AND ADOPTED by the City Council of the City of Elk Grove this 12 th day of April STEVE LY, MAYOR of the CITY OF ELK GROVE ATTEST: APPROVED AS TO FORM: JASON LINDGREN, CITY CLERK JONATHAN P. HOBBS, CITY ATTORNEY 7

8 ATTACHMENT 2 City of Elk Grove Police Department February 17, 2017 Robby Thacker, Project Planner Elk Grove Planning Department 8401 Laguna Springs Way Elk Grove, CA Re: PCN Bruceville ARCO AM/PM Dear Mr. Thacker: This letter is a response to your request for review of a finding of Public Convenience or Necessity (PCN) for the Bruceville ARCO AM/PM (SEC Bruceville and Whitelock). Per your request, I have reviewed the application, and the crime statistics for the surrounding area. The most recent statistical data that we have compiled is from calendar year The data reflects that the area encompassing the applicant s site has moderately low criminal activity. Elk Grove is separated into 26 subsectors for crime reporting purposes. The applicant is located is subsector Annually, we compile the crime statistics in the following eight areas: Homicide Forcible Rape Robbery Larceny Burglary Arson Motor Vehicle Theft Aggravated Assault Per the attached chart, the 4102 subsector had 126 crimes reported in the year Of those, 73 were crimes related to larceny and 15 were related to burglary. According to our information, the census tract where the applicant is located (96.38) has three active Type 20 beer and wine off-sale licensed retail establishments and one active Type 21 general liquor off-sale licensed retail establishment. This census tract also has three active onsale licensed retail establishments (Types 41, 42, 47 and 86). The California Department of Alcohol Beverage Control views more than two off-sale licenses and more than four on-sale licenses in this census tract as over population. Based on the reviewed data, the Elk Grove Police Department has determined that there is no public safety reason to oppose a finding of Public Convenience and Necessity and the associated ABC license application. Please contact me at (916) or via at EMontgomery@ElkGrovePD.org if you have any further questions. Sincerely, Detective Erin Montgomery Problem Oriented Police Unit 8 REFER ALL CORRESPONDENCE TO: Elk Grove Police Department 8400 Laguna Palms Way Elk Grove, CA 95758

9 Page 2 of 2 HOMICIDE FORCIBLE RAPE ROBBERY AGGRAVATED ASSAULT BURGLARY LARCENY MOTOR VEHCILETHEFT ARSON TOTAL PART 1CRIME BYSUBSECTOR

10 ATTACHMENT 3 Proposed ARCO AM/PM Development SEC of Bruceville Road and Whitelock Parkway, Elk Grove, California License to Sell Alcoholic Beverages - Public Convenience or Necessity Letter Description of Age Restricted Sales Justification The development proposes a new ARCO AM/PM C-store with fuel facility. The ARCO AM/PM operation proposal includes the sale of age-restricted products including alcoholic beverages and tobacco. The ABC requires a finding of public convenience and necessity for the alcohol sales, which will consist of beer and wine as typically sold under a Type 20 Off-Premises alcohol license. Both product categories are essential to the viability of convenience stores, in some cases making up as much as 35% of sales. Inherent in the reasons for shopping at such stores is the expectation that a convenient location, not requiring travel to large regional shopping centers or large grocery store parking lots, is available for a quick stop on the way home from work. With this convenience comes a responsibility. ARCO AM/PM stores not only are designed using the principles of Crime Prevention Through Environmental Design, the operations conduct on-going staff training for age-restricted sales based on industry-proven materials, and have many operational features designed to ensure compliance with laws governing those sales, such as registers that contain features to assist in flagging under-age attempts at sales. The store feature security cameras and mirrors, prominently displayed with signage alerting customers that these features exist and are monitoring the premises. The premises in general will comply with the recommendations anticipated from staff and based on conditions of approval anticipated governing type of product, display of product and operation during restricted hours. Detective Montgomery of the Elk Grove Police Department reviewed the project previously. A copy of her letter to the ABC is attached to this application. Her comments were as follows: It should be noted that in Resolution No , for Phase 3 of the Vineyard at Madeira center, of which the ARCO is a part, approval was granted with conditions. Among those conditions were items 17 and 18, pertaining to liquor sales at the convenience store operation. The conditions contain the limitations that Detective Montgomery requested. The ARCO will be developed in accordance with all applicable conditions in Resolution No

11 Incorporated July 1, 2000 CITY OF ELK GROVE 8401 Laguna Palms Way Telephone: (916) Elk Grove, California Fax: (916) City of Elk Grove City Council NOTICE OF PUBLIC HEARING NOTICE IS HEREBY GIVEN that on Wednesday, April 12, 2017 at the hour of 6:00 p.m., or as soon thereafter as the matter may be heard, the Elk Grove City Council will conduct a continued public hearing at City Hall in the Council Chambers, 8400 Laguna Palms Way, Elk Grove, California, to consider the following matter: BRUCEVILLE ARCO AM-PM (EG ) DETERMINATION OF PUBLIC CONVENIENCE OR NECESSITY (PCN): The Applicant is requesting a Letter of Public Convenience or Necessity (PCN) from the City Council for Bruceville Enterprises Inc to obtain a Type 20 (Off-Sale Beer and Wine) alcohol license from the Department of Alcohol Beverage Control (ABC). The Type 20 license allows for the sale of beer and wine for off-site consumption. OWNER: Taylor/Village Sacramento Investment Partners John Glikbarg (Representative) 940 Emmett Street, Suite 200 Belmont, CA APPLICANT: Bruceville Enterprises Ken Dharni (Representative) 6698 Mack Road Sacramento, CA Agent: Barghausen Consulting Engineers Pete Tobin (Representative) 915 Highland Pointe Drive Roseville, CA LOCATION/APN: Southeast Corner of Whitelock Parkway and Bruceville Road / APN: ZONING: Shopping Center SC pursuant to the Laguna Ridge Specific Plan ENVIRONMENTAL Exempt from CEQA review pursuant to Section 15061(b)(3) of the State CEQA Guidelines. Information or questions regarding this item should be referred to Robby Thacker, (916) ; or to the Office of Development Services Planning, 8401 Laguna Palms Way, Elk Grove, CA, All interested persons are invited to present their views and comments on this matter. Written statements may be filed with the City Clerk at any time prior to the close of the hearing scheduled herein, and oral statements may be made at said hearing. 11

12 If you challenge the subject matter in court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice or in written correspondence delivered to the City Clerk, 8401 Laguna Palms Way, 1 st Floor, Elk Grove, CA, 95758, at or prior to the close of the public hearing. Dated / Published: March 29, 2017 JASON LINDGREN CITY CLERK, CITY OF ELK GROVE ADA COMPLIANCE STATEMENT In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please contact the Office of the City Clerk at (916) Notification 48 hours prior to the meeting will enable the City to make reasonable arrangements to ensure accessibility to this meeting. 1212

13 NOTICE OF CONTINUED HEARING CITY COUNCIL CITY OF ELK GROVE NOTICE IS HEREBY GIVEN that the March 22, 2017 public hearing of the City Council of the City of Elk Grove to consider the BRUCEVILLE ARCO AM-PM (EG ) DETERMINATION OF PUBLIC CONVENIENCE OR NECESSITY (PCN) has been continued to April 12, 2017 to be heard at the hour of 6:00 p.m., or as soon thereafter as the matter may be heard, at City Hall in the Council Chambers, 8400 Laguna Palms Way, Elk Grove, California, Posted: March 23, 2017 /s/ JASON LINDGREN CITY CLERK of the City of Elk Grove 13

14 Incorporated July 1, 2000 CITY OF ELK GROVE 8401 Laguna Palms Way Telephone: (916) Elk Grove, California Fax: (916) City of Elk Grove City Council NOTICE OF PUBLIC HEARING NOTICE IS HEREBY GIVEN that on Wednesday, March 22, 2017 at the hour of 6:00 p.m., or as soon thereafter as the matter may be heard, the Elk Grove City Council will conduct a public hearing at City Hall in the Council Chambers, 8400 Laguna Palms Way, Elk Grove, California, to consider the following matter: BRUCEVILLE ARCO AM-PM (EG ) DETERMINATION OF PUBLIC CONVENIENCE OR NECESSITY (PCN): The Applicant is requesting a Letter of Public Convenience or Necessity (PCN) from the City Council for Bruceville Enterprises Inc to obtain a Type 20 (Off-Sale Beer and Wine) alcohol license from the Department of Alcohol Beverage Control (ABC). The Type 20 license allows for the sale of beer and wine for off-site consumption. OWNER: Taylor/Village Sacramento Investment Partners John Glikbarg (Representative) 940 Emmett Street, Suite 200 Belmont, CA APPLICANT: Bruceville Enterprises Ken Dharni (Representative) 6698 Mack Road Sacramento, CA Agent: Barghausen Consulting Engineers Pete Tobin (Representative) 915 Highland Pointe Drive Roseville, CA LOCATION/APN: Southeast Corner of Whitelock Parkway and Bruceville Road / APN: ZONING: Shopping Center SC pursuant to the Laguna Ridge Specific Plan ENVIRONMENTAL Exempt from CEQA review pursuant to Section 15061(b)(3) of the State CEQA Guidelines. Information or questions regarding this item should be referred to Robby Thacker, (916) ; or to the Office of Development Services Planning, 8401 Laguna Palms Way, Elk Grove, CA, All interested persons are invited to present their views and comments on this matter. Written statements may be filed with the City Clerk at any time prior to the close of the hearing scheduled herein, and oral statements may be made at said hearing. 1414

15 If you challenge the subject matter in court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice or in written correspondence delivered to the City Clerk, 8401 Laguna Palms Way, 1 st Floor, Elk Grove, CA, 95758, at or prior to the close of the public hearing. Dated / Published: March 10, 2017 JASON LINDGREN CITY CLERK, CITY OF ELK GROVE ADA COMPLIANCE STATEMENT In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please contact the Office of the City Clerk at (916) Notification 48 hours prior to the meeting will enable the City to make reasonable arrangements to ensure accessibility to this meeting. 15

16 Bruceville ARCO AM-PM EG ft Radius for Owners COLLIE WAY WAY ALBACORE WAY OAKHAM WAY HATHERTON WAY IT O N TARZO WAY BO WAY SOLOMON D R C IR D RE C ALDON WAY T WAY KENNE ER WAY MINST BARNSLEY DR DEL WEBB BLVD CIR LA CE K FO R EST WAY YELLOWFIN WAY ASHBY WAY MA PE A R CI IR LI C NA DE Y WEST ABBEY DEAR NE WAY A DR AY DW IE L TERRAZ ZO H CT W SUNDERLAN D SH EFF FOXBURG DERBY WAY Y WA ROTHSCHILD CT WAY R CI MAISS WAY DE AN BLOOMSBURY ON ST EL R LG VA CORDIALLY ON GT IN RT PA SPIES S CT G IN GE R WIN CHATSWORTH CIR WAY K LE C IR CT WAY WAYANS WAY CT POPPY RIDGE RD ELVORA WAY PA RADA POMBAL CT OJELIO CT TU ZZA QUAIL RUN LN KNOTTS DR STI FEY R WAY L LER CT WAY FERRELL COSBY RD BRUCEVILLE CHAPPELLE WAY NEALON DR WHITELOCK PKWY Legend RIO TAMEGA DR MACHADO RANCH DR Project_Parcel DESERTAS CT Owner_Parcels Feet 590

17 1 APN ADDRESS CITY STATE ZIP CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA TH ST 210 OAKLAND CA CHATSWORTH CIR ELK GROVE CA JUDAH ST SAN FRANCISCO CA MSSN CTR RD SAN DIEGO CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA TAGART DR SAN JOSE CA CHATSWORTH CIR ELK GROVE CA PO BOX COLUMBUS OH CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA LOUVRE AV SAN JOSE CA CHATSWORTH CIR ELK GROVE CA DOUGLAS BL STE 100 GRANITE BAY CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA FOLKSTOVER CT ELK GROVE CA EMMETT ST. STE 200 BELMONT CA PO BOX 8050 BENTONVILLE AR CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA DONCASTER CT ELK GROVE CA COSBY WY ELK GROVE CA COSBY WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA COSBY WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHATSWORTH CIR ELK GROVE CA FERRELL WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHATSWORTH CIR ELK GROVE CA ITEM 9.01 PHN-3 MAILING LIST_Bruceville ARCO AM-PM EG

18 COSBY WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA COSBY WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA HIGHLAND POINTE DR ROSEVILLE CA MACK ROAD SACRAMENTO CA SCHULER RANCH RD ELK GROVE CA SCHULER RANCH RD ELK GROVE CA BRUCEVILLE RD # 108 ELK GROVE CA BRUCEVILLE RD # 120 ELK GROVE CA BRUCEVILLE RD # 140 ELK GROVE CA BRUCEVILLE RD # 160 ELK GROVE CA BRUCEVILLE RD # 100 ELK GROVE CA BRUCEVILLE RD # 110 ELK GROVE CA BRUCEVILLE RD # 120 ELK GROVE CA BRUCEVILLE RD # 130 ELK GROVE CA BRUCEVILLE RD # 140 ELK GROVE CA BRUCEVILLE RD # 150 ELK GROVE CA BRUCEVILLE RD # 160 ELK GROVE CA BRUCEVILLE RD # 170 ELK GROVE CA BRUCEVILLE RD # 180 ELK GROVE CA BRUCEVILLE RD ELK GROVE CA BRUCEVILLE RD ELK GROVE CA BRUCEVILLE RD # 100 ELK GROVE CA COSBY WY ELK GROVE CA BRUCEVILLE RD # 100 ELK GROVE CA BRUCEVILLE RD # 100 ELK GROVE CA BRUCEVILLE RD # 140 ELK GROVE CA COSBY WY ELK GROVE CA ROJELIO CT ELK GROVE CA ROJELIO CT ELK GROVE CA TUZZA CT ELK GROVE CA WEXTED WY ELK GROVE CA BRUCEVILLE RD ELK GROVE CA ROJELIO CT ELK GROVE CA WEXTED WY ELK GROVE CA WEXTED WY ELK GROVE CA WEXTED WY ELK GROVE CA WEXTED WY ELK GROVE CA WEXTED WY ELK GROVE CA WEXTED WY ELK GROVE CA WEXTED WY ELK GROVE CA CHATSWORTH CR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA ITEM 9.01 PHN-3 MAILING LIST_Bruceville ARCO AM-PM EG

19 CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHATSWORTH CIR ELK GROVE CA FERRELL WY ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHATSWORTH CIR ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA CHAPPELLE WY ELK GROVE CA OAKHAM WY ELK GROVE CA WESTMINSTER WY ELK GROVE CA WESTMINSTER WY ELK GROVE CA ITEM 9.01 PHN-3 MAILING LIST_Bruceville ARCO AM-PM EG