HomeMy WebLinkAbout025115 RES - 11/19/2002A RESOLUTION
ADOPTING THE CITY OF CORPUS CHRISTI'S LEGISLATIVE PROGRAM
FOR THE SEVENTY-EIGHTH SESSION OF THE TEXAS LEGISLATURE
AND FOR THE UNITED STATES CONGRESS.
WHEREAS, the 78th Texas Legislature convenes in January 2003; and
WHEREAS, the Texas Legislature and the United States Congress will consider
many measures that may affect the City of Corpus Christi; and
WHEREAS, it is necessary to provide guidance for City officers and representatives
in conducting the City's legislative efforts and relations.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF
THE CITY OF CORPUS CHRISTI, TEXAS:
SECTION 1. The City Council adopts the Legislative Program, which is attached to and
incorporated into this resolution.
SECTION 2. This Legislative Program remains in effect until amended by the City
Council.
SECTION 3. The City Manager is directed to distribute this Legislative Program to the
local legislative delegation and solicit their advice and support.
ATTEST:
THE CITY OF CORPUS CHRISTI
Armando Chapa
City Secretary
APPROVED: (/~ day of
S~muel L. I~al Jr.
Mayor
2002.
Corpus Christi, Texas
,2002
The above resolution was passed by the following vote:
Samuel L. Neal Jr.
Brent Chesney
Javier D. Colmenero
Henry Garrett
William Kelly
Rex A. Kinnison
John Longoria
Jesse Noyola
Mark Scott
CITY OF CORPUS CHRISTI
Legislative Program
78th Legislative Session
including Federal Legislation
November 19, 2002
INTRODUCTION
Prior to the commencement of each legislative session, the City of Corpus Christi staff,
working with input from the City Council, other local interests, Texas Municipal League, and
other cities, prepares a recommended legislative program for City Council consideration
and approval.
The legislative program, after consideration and approval by the City Council, is then
transmitted to our local legislative delegation and forms the basis for the City's activities
during the 140 days of the session. In each legislative session, the number of bills that are
introduced is massive. For example in 2001, 5,712 bills were introduced, over 1600
actually passed, with approximately 1,200 of the bills City-related, of which slightly more
than 150 passed. Unfortunately a large percentage of the efforts by cities are necessarily
directed at simply stopping bad pieces of legislation which would negatively affect cities.
Over the past few legislative sessions, the City of Corpus Christi, with the tremendous
support and action of our local legislative delegation, has had very good success in
not only stopping bad bills which would negatively impact us, but also in the passage of
legislation which very positively affects us. For example, in the 1999 legislative session,
a serious assault on cities' annexation powers was successfully defeated, while at the
same time, the City, through our local legislative delegation, was able to fund expansion
and renovation of the Convention Center, provide liability protection for our Latchkey
Program, acquired the official designation of the Museum of Science and History as the
Texas Maritime Repository, and funding of the local Estuary Program, among a number
of other issues.
In the last session (2001), the City had a number of wins. Legislation was passed that:
1) allows cities to use design build
2) allows creation of Fire Control and Prevention Districts
3) desalinated water was exempted from interbasin regulations
4) water development grants to cities allowable for desal efforts
In addition, virtually all harmful bills were defeated.
The upcoming 78th legislative session will undoubtedly consider many issues that are
detrimental to cities, and will be extremely complex because many of the long-term
committee chairmen chose not to run for reelection, and the State's financial position
appears bleak.
As in the past, the City anticipates working very closely with our local legislative delegation.
In addition, we will work with the Texas Municipal League as well as the very active
legislative lobbying group of the eight largest cities (this latter group meets once a week
during the legislative session with TML staff to coordinate action.) The following legislative
program is broken down into sections each representing a major part of municipal
government beginning with a general statement of policies and procedures.
1
A separate section of Federal legislation issues is included at the end of the program and
is considered to be a part of our overall legislative effort.
The communication of this legislative program is carried out on a day to day basis by the
Special Assistant to the City Manager, with substantial assistance from the City Attorney
and his staff under the general direction of the City Manager after approval of the program
by the City Council. The Mayor and City Council Members, as well as City staff including
the Police and Fire Chiefs, members of the City Attorney's Office, and departments heads
are called upon to testify in Austin and in Washington, on a case by case basis.
2
I. GENERAL POLICY AND PROCEDURES
a. The City will support legislation and administrative actions that:
1. Will protect and enhance City revenues.
2. Reduce costs to the City.
3. Provide for more local control.
4. Protect those policies previously established through the Charter, ordinances,
resolutions, and master plans.
5. Provide increased educational opportunities for the citizens of Corpus Christi
and the region.
b. The City will oppose legislation or administrative actions that:
1. Undermine the principle of home rule and local self-government.
2. Result in the loss of revenue growth to the City.
3. Diminish the authority of cities to regulate and manage their growth and
development.
4. Nullify or undermine the City's policies contained in existing provisions of the
Charter, ordinances, resolutions, and master plans, unless such changes
expand the City's ability to manage its own affairs.
5. Diminish any existing authority of cities.
6. Impose mandates that require any expenditure by the City unless all costs
of same, including administrative as well as direct out-of-pocket costs, are
fully reimbursed by the mandating government.
c. The City Council will determine the City position on all legislative issues,
d. The City's Boards, Commissions, and Advisory Groups may not represent in oral
testimony or in writing a position on proposed legislation or administrative action
unless that position is first approved by the City Council.
e. Positions on legislative or administrative matters originating outside of the City
Council, but within the City's governmental framework shall be submitted to the City
Manager for review prior to consideration by the City Council.
3
The legislative or administrative positions herein approved, and others separately
approved by the City Council, shall be communicated to the legislative and
congressional delegations, to the Legislature and Congress, in general, and/or to
the appropriate legislative committees, committee members, and administrative
agencies or to others by members of the City Council, the City Manager, staff
persons, and consultants and others designated by the City Manager.
Where possible and where there is a commonality of interest, the City will coordinate
its legislative and administrative program with other political jurisdictions and provide
assistance to those political jurisdictions.
The city will support the legislative program of the Texas Municipal League, except
to the extent it conflicts with any policy herein.
It is recognized that this policy will often be implemented in the context of great
numbers of voluminous proposals being considered within short time periods. City
representatives, under the direction of the City Manager, shall be authorized to act
on behalf of the City consistent with the necessarily broad policy concerns set forth
in this policy.
In this policy, items are classified under three levels of importance, Priority, Actively
Support, and Endorse, as follows:
Priority means that the City will actively pursue and support (or oppose, as
specified) the policy including, if necessary, seeking introduction and
passage of legislation. This would include purely local Corpus Christi bills,
as well as very important legislation of statewide application.
2,
Actively Support means the City will aggressively attempt to obtain passage
of a measure if it is introduced by some other entity (or actively oppose, as
specified).
Endorse means that the City will make its (support or opposition) known, but
will not actively pursue the issue.
4
II. FINANCIAL INTEGRITY
PRIORITY
Franchise Fees. The City unalterably opposes any measure which would reduce
the City's existing franchise fees, the growth of those franchise fees, or its ability to
charge franchise fees, and any measure which would prevent the City from requiring
utilities to bear 100% of costs associated with relocations of utilities required by the
City or which would impair City regulation of use of rights-of-way. Franchise fees are
essential to continuation of basic services. A vote to reduce franchise fees would
be a vote to increase local ad valorem taxes or reduce basic local services such as
police, fire, roads, and parks, and would constitute a gift of public property for
private purposes. The City also advocates legislation which would effectively hold
the City harmless from any fluctuations in franchise fees.
State Hotel Tax for Beach Maintenance. The City supports legislation which
would provide State hotel tax funding of 1% for beach maintenance.
Street Accessibility Improvements. The City supports legislation which would
authorize a street use fee or other funding source to construct facilities to enhance
disabled access.
Clarification of Hotel Tax for Beaches. In 1999, the legislature authorized Corpus
Christi to use tax revenues from hotels previously subject to a county hotel
occupancy tax to clean and maintain public beaches in the municipality. The intent
was to use taxes from hotels in beach areas annexed for beaches. However, this
could be construed as only applying to existing hotels, which would be inequitable.
This needs to be changed.
ACTIVELY SUPPORT
Delinquent Ambulance Bill Collection. Allow delinquent ambulance bills to be
billed on a City's utility bill, to be paid out over time, not exceeding 10% of any
monthly bill.
Liability Law. The City supports legislation to reduce potential liability of
municipalities and municipal employees for torts and other actions and opposes
legislation which would increase such liability.
Prompt Payment Statute. The City opposes legislation increasing the
requirements of the prompt payment statute.
Indemnity Provisions. The City opposes legislation limiting or prohibiting indemnity
provisions in public works contracts.
Mandated Fees. The City opposes legislation which would require a city to raise any
municipal fee and remit the revenue to the state, unless use of the monies would
be clearly dedicated for programs beneficial to the City.
Municipal Court Failure-to-Appear Fee. The City supports legislation that enables
a city to recover from municipal court defendants, who fail to appear as required by
citation or court process, the city's cost of collection and administration caused by
their failure to appear.
ENDORSE
Appraisal Appeals. The City supports legislation to allow cities to challenge the
appraisal or appeal of an appraisal of a specific property.
Municipal Court Costs. The City supports legislation which would consolidate all
State court costs collectible by municipal courts into one fee payable to the State,
and require that, in case of partial payments, a city and the state will split the
payments until both receive the proper amount of revenue. The City opposes
additional State or County fees or court costs on municipal courts.
Sale of Tax Liens. The City supports legislation to authorize cities to sell tax liens.
6
III. ESSENTIAL INFRASTRUCTURE
PRIORITY
a. Water.
Protection of Water Rights. As its highest priority, the City supports
legislation to protect the City's water supply and water rights, and to enable
the City to expand its water supply and rights, and strongly opposes
legislation which would diminish or challenge such water supply or water
rights or the City's ability to expand such.
Desal Projects. The City supports legislation to provide special set-aside
funding for desalination programs and projects.
Free Market in Water. The City strongly supports legislation that would
remove barriers to a free market between willing sellers and buyers of water
and water dghts, subject to applicable laws for protection of the environment,
and strongly opposes legislation that would create new barriers.
b=
Packery Channel. The City strongly supports State assistance/legislation/efforts
to facilitate the North Padre Island Storm Damage and Governmental Restoration
Project.
ACTIVELY SUPPORT
c. Transportation.
Resources. The City strongly supports legislation assuring the equitable
allocation of transportation resources from the State.
Funding for Construction and Maintenance. The City supports legislation
that would increase the level and availability of state transportation funding
for construction and maintenance.
Streamlining: The City supports legislation that would streamline the Texas
Department of Transportation to make it more effective and efficient.
City Streets/Maintenance. Maintenance of City streets throughout the State is
chronically under funded. The City strongly supports legislation which would allow
cities to have additional local revenue sources specifically earmarked for street
maintenance.
Supply of Surplus Materials. In 2001, the State legislation authorized TxDOT to
provide surplus materials such as salvaged passing to cities. The City supports
continuation of this position.
7
IV. COMMUNITY PROTECTION AND DEVELOPMENT
PRIORITY
Development. The City strongly opposes legislation which would erode municipal
authority to regulate development for the public safety, health and welfare,
including, but not limited to, locations of manufactured housing, annexation,
condemnation, platting, zoning, extraterritorial jurisdictions and building and housing
codes.
Marine Archeological Repository Funding. The City supports legislation which
at a minimum provides equitable funding to the City's Museum from any state
allocation of funds for marine archeological repositories.
Regulation of Location of Manufactured Housing. The City opposes legislation
that would erode the authority of cities to regulate the location of manufactured
housing.
Annexation Authority. The City opposes legislation that would erode current
annexation authority.
ACTIVELY SUPPORT
e=
Affordable Housing. The City supports affordable housing initiatives which do not
undermine the City's regulatory authority to 3rotect the public health, safety, and
welfare.
Building Codes. The City supports maintaining and expanding municipal authority
to select building codes and make local amendments as determined by local city
councils, and opposes legislation eroding such authority such as by mandating
adoption of particular codes.
Historic Courthouse Preservation. The City supports full State funding for
preservation of historic courthouses for which preservation is feasible.
Nuisance. The City supports legislation to strengthen municipal enforcement
authority with respect to nuisances.
Condemnation Authority. The City opposes legislation that would erode
condemnation authority.
Dune Protection. The City supports city administered dune protection within city
limits and cities' ETJ.
8
ENDORSE
Electrical Licensing. The City opposes legislation which would impose a statewide
electrical licensing law.
Alcoholic Beverage Regulation. The City supports legislation to protect and
strengthen city authority to regulate alcoholic beverage sales and consumptions.
Group Homes. The City supports legislation to protect and strengthen city authority
to regulate group homes.
9
V. CHILDREN AND YOUTH
PRIORITY
Juvenile Crime. The City supports legislation to reduce crime and delinquency
among children and youth, to promote their development and well-being, and
continued funding of CYD programs.
10
VI. EDUCATION
PRIORITY
Higher Education. The City supports legislation to advance and obtain sufficient
support for education in this area, especially legislation to enable Texas A&M
University-Corpus Christi to operate as a strong and viable four-year university,
including special item funding; and legislation to insure adequate funding for the
operation and programs of the Del Mar Junior College District, including Full
Formula Funding.
Support of Local School Districts. In general, the City supports the legislative
programs of local school districts leading to enhancement of educational
opportunities for citizens of Corpus Christi.
ACTIVELY SUPPORT
South Texas/Border Initiative. The City supports continued funding of the South
Texas/Border Initiative.
11
VII. PUBLIC SAFETY AND HEALTH
PRIORITY
Fire Control and Prevention District. The City supports legislation permitting
1/8¢ over the 2¢ local Sales Tax cap for Fire Control and Prevention Districts.
Child Safety Registration Fee. The City supports legislation to amend current
law to increase the optional vehicle registration fee for child safety from $1.50 to
$3.00 and to allow cities to impose the fee.
CHIPS. The City strongly supports continuation and expansion of the Children's
Health Insurance Program and the simplification of enrollment and program
eligibility.
ACTIVELY SUPPORT
Pawnshops. The City supports legislation which would 1) require licensed
pawnshops to provide electronic access to local law enforcement agencies of all
pawn transactions, 2) and which would protect and strengthen cities' authority to
regulate pawnshops.
Liability Limit Outside of Jurisdiction. The City supports legislation that would
limit liability against City emergency service providers when requested to provide
service on an emergency basis in another jurisdiction.
Photographic Traffic Signal Enforcement: The City supports legislation that
would allow cities to effectively employ photographic traffic signal enforcement.
911 Emergency Service Systems. The City opposes legislation which would hinder
the City's operation of its 911 system, which would inequitably affect the Corpus
Christi area on 911 funding, or which would limit its ability to charge a fee for 911
services.
Crime and Fire Control and Prevention District. The City supports changing the
statute to use the City sales tax base for a City-created Crime or Fire Control and
Prevention district so that City sales taxes are administered consistently.
Animal Vaccinations at City Health Facilities. The City supports legislation that
would permit City employees to vaccinate animals at City animal shelter facilities.
12
ENDORSE
Community Service for Minors. The City supports legislation to eliminate the
requirement that mandatory community service imposed on a minor convicted of
certain alcohol or tobacco offenses be alcohol or tobacco-related.
Impoundment of Uninsured Vehicles. The City supports legislation to authorize
the impoundment of motor vehicles that are not covered by insurance.
Felony Forfeitures. The City opposes legislation which would detrimentally change
the existing felony forfeiture statute.
Peace Officers. The City opposes legislation to authorize additional entities to
employ and commission peace officers. The City opposes legislation that would
restrict its ability to maintain specialized peace officers outside the Police
Department and legislation applicable to the Police Department.
13
VIII. UTILITIES
PRIORITY
Electric Industry Deregulation. The City supports continued electric industry
deregulation legislation but only if it (1) fully preserves municipal authority over
rights-of-way or other public property and (2) fully preserves municipal authority to
impose a right-of-way fee that:
(a) equal to that received prior to competition (b) increases with growth; (c) ensures
that all citizens will benefit through lower rates; (d) assures that electric system
reliability and service quality will be maintained at standards equal to or better than
the reliability and service standards which exist today; (e) allows cities to serve as
aggregators; (t~ provides checks and balances against concentration of market
power through takeovers, mergers, acquisitions, or other means; (g) protects the
ability of a municipally owned utility (MOU) to operate profitably, continues to
exempt MOU's from regulation by the Public Utility Commission, and protects the
financial integrity of any city; (h) holds a city harmless over time vis-a-vis revenue.
Electric Franchise Base Date. The City supports changing the electric franchise
tax base to 2001, indexed for inflation, and flexible rules for negotiating above the
base.
Right-of-Way Control. The City opposes legislation which would erode the authority
of cities to manage and control their rights-of-way and other public property.
ACTIVELY SUPPORT
Underground Facilities Notification. The City opposes legislation that would
amend the Underground Facilities Statute to 1) raise the $1.25 cap on the fee paid
by a facility operator, 2) levy a fee on an excavator, 3) raise the registration fee
unless the fee is determined on a more equitable basis, and 4) require mandatory
participation by cities as Class B operators.
Sections 401 and 404 Certifications. The City supports legislation that, with
regard to Sections 401 and 404 certifications (Clean Water Act), would prevent the
Texas Natural Resource Conservation Commission (TNRCC) from expanding the
scope of its activities beyond that required by law.
14
IX. ENVIRONMENT
PRIORITY
Air Quality. The City supports continued allocation of financial resources for near
non-attainment areas, which is essential for those communities striving to remain
within federal guidelines for air quality.
National Estuary Program. During the last legislative session, the City of Corpus
Christi actively supported State funding of the local National Estuary Program. It is
an important priority that the program continue to be funded, possibly at an elevated
level.
Regional Water Planning. The City supports continued funding of regional water
planning.
ACTIVELY SUPPORT
Parks and Recreation. The City supports additional funding for State grants to
cities for park acquisition and development.
Beach Cleaning. The City supports full State funding of the beach cleaning
program.
Oil Spill Response Program. The City supports continued and expanded State
support for the Oil Spill Response Program and the location of a major center in the
Corpus Christi area.
Drainage/Stormwater. The City opposes further unfunded mandates with respect
to drainage and stormwater, and supports increased State programs to assist in
solving such problems.
Solid Waste. The City supports legislation that would enhance its ability to maintain
adequate funding for the operation of its present and future landfills or that would
strengthen city authority over landfill operations, and the City opposes legislation
that would undermine adequate funding of city landfills, impose regulations more
stringent than federal law, or erode city authority over landfill operations.
Glass and Plastic Bottles. Several states have enacted State-wide container
deposit laws for both glass and plastic bottles. Such a deposit system would
substantially enhance litter removal from public rights-of-way in the City of Corpus
Christi. The City supports a statewide deposit statute.
X. PERSONNEL
ACTIVELY SUPPORT
Emergency Response. The City opposes legislation which would erode current
municipal authority to establish standards relating to response of non-resident
employees to civil emergencies or which would in any other way, erode current
municipal options regarding residency policies.
Collective Bargaining Law. The City opposes legislation which would broaden
current law regarding adoption of collective bargaining.
State Fire and Police Civil Service. The City supports amending the State Fire and
Police Civil Service law to: (1) remove age limits for hiring; (2) permit rehiring of
certified personnel within 18 months of severance without going through the full
selection process; (3) clarify how many applicants are required for a promotional
test to be deemed competitive; and (4) clarify information to be placed in the
personnel file and the departmental file. The City supports amendments beneficial
to the efficient administration of the service, and opposes amendments detrimental
to the efficient administration of the service.
ENDORSE
Internal Investigations. The City opposes legislation which would create special
employment rights for any group of public employees who may be the subject of
internal investigations.
Mandated Job Protection. The City opposes legislation that would erode the
employment-at-will doctrine.
16
Xl. ECONOMIC DEVELOPMENT
PRIORITY
Military. The City supports continued funding and legislative support of the Texas
Strategic Military Planning Commission and other efforts to preserve existing military
bases in Texas..
b. Spaceport. The City supports efforts to procure the Spaceport for South Texas.
Co
Insurance Rates. Local insurance rates for homeowners and automobile coverage
are some of the highest in the State. The City finds that these rates have a major
depressive influence on local economic development. The City supports State
legislation and/or other efforts to aggressively and innovatively reduce local rates.
Ballot Language for Economic Development Sales Tax. The City supports
amendment of Sections 4A and 4B of the Development Corporation Act to provide
greater local flexibility in presenting projects to the voters individually or combined.
ACTIVELY SUPPORT
Economic Development Authority. The City opposes legislation which would
erode municipal economic development authority.
f. Child Care. The City supports increased, sustained State funding for child care.
Texas Public Libraries. The City supports legislation that would increase support
of Texas public libraries through TexShare and the Library of Texas for improved
access to electronic information.
E-Commerce Taxation. The City supports a level playing field for all businesses
whether they are locally operating or operating through e-commerce. The City
opposes any system of taxation which restricts a local government's ability to collect
sales tax on commerce over the internet.
ENDORSE
Waiver of Agricultural Rebate. The City supports legislation which would allow a
city the option of waiving the payment of three years of recalculated property taxes
when agricultural land is converted to a different use.
Workforce Development. The City supports local control over employment
training programs, continuation of Smart Job training grants and the Skills
Development Fund, and State funding for adult literacy programs.
17
Xll. EFFICIENT ADMINISTRATION
PRIORITY
City Election Date Statute. The Texas Election Code permits Corpus Christi to
have its general election in April of odd-numbered years. This was done to avoid
conflict with Buccaneer Days. The State uniform election date in the spring remains
the first Saturday in May, which in odd-numbered years, conflicts with Buccaneer
Days. It is not explicitly stated in the Corpus Christi Statute that this date cannot be
used by the City, which could create a problem based on timing of a petition. If the
date were held to be available, it could result in a general city election the first
Saturday in April, a runoff the third Saturday in April, and a referendum election the
first Saturday in May. It should be clarified that the May date is not available.
Effective Tax Rate Calculation. The City supports legislation that would allow a
city to adjust its effective tax rate calculation to account for mandated (statutorily-
imposed) reductions in general fund revenue.
ACTIVELY SUPPORT
Sales Tax Exemption. The City opposes legislation that would enact a sales tax
exemption that isn't a local option exemption.
Property Tax Exemption. The City opposes legislation that would enact a property
tax exemption that would shift the burden to other taxpayers and that would be a
substantial erosion of the tax base.
Delinquent Sale Tax. The City opposes legislation that would abolish the authority
of cities to sue for delinquent sales taxes or to join in an attorney general's suit.
Notification of Delinquent Amounts of Sales Taxes. The City opposes
legislation that would repeal the requirement that the comptroller notify cities of
delinquent amounts of sales taxes.
Rate Case and Complaint Dockets. The City supports legislation that would
establish the right of cities to recover expenses related to rate case and complaint
dockets within a reasonable time and require utilities to recover rate case expenses
out of stockholders' equity when a rate case is found to be unjustified.
Water or Wastewater Permittees Fees. The City opposes legislation that would
increase fees paid by water or wastewater permittees.
Sales Tax Pledge. The City supports allowing the pledge of sales tax for financial
obligations outside of economic development.
18
ENDORSE
Open Meetings Act. The City supports legislation clearly exempting from the Open
Meetings Act attendance by a quorum at public community events, and clarifying
restrictions on meetings in less than a quorum. The City opposes making the Act
more restrictive.
Open Records Act. The City supports legislation which would clearly exempt from
disclosure information on utility facilities, pipelines, and other facilities which could
compromise security.
Collective Bargaining Executive Sessions. State collective bargaining law for
Fire and Police does not allow closed sessions on bargaining issues, except legal
matters. This is detrimental to sound bargaining, and should be eliminated.
19
FEDERAL LEGISLATION/ACTION
Aw
Packery Channel. The City strongly supports legislation/action to continue the
North Padre Island Storm Damage Reduction and Environmental Retention Project
to its completion.
CDBGIHOME Funding. The City has found Federal funding of the CDBG and
HOME Program to be essential to the continued wellbeing and revitalization of the
City. Therefore, the City strongly supports continued and increased funding for the
programs.
Ct
Diversion to State. The City supports direct Federal funding of programs to cities
and generally opposes funding to cities being routed through State government.
Homeland Security. Due to greatly increased costs of local security activities, the
City supports continued and increased direct Federal funding of homeland security
to cities.
Et
Military. The city strongly supports legislation/funding/actions to maintain our local
areas' military facilities as one of the City's highest priorities.
Coordination with Local Agencies. Whenever possible and particularly where
there is a commonality of interest, the City will support local agencies or units such
as the County, RTA and the Port in their efforts to secure favorable legislation
and/or funding.
Protection of Right of Way Fees and Authority. The City strongly supports its
traditional authority to charge rental value to private companies for the use of
valuable public rights of way, and to reasonably regulate the rights of way for the
benefit of the public. The City strongly opposes any dilution of its traditional
authority.
2O