Ordinance 27-23RECORD OF ORDINANCES
Dayton Legal Blank, Inc. Form No. 30043
20. Ordinance No. 27-23 Passed
AUTHORIZING THE CITY MANAGER TO
ENTER INTO A NEW SANITARY SEWER SERVICE AGREEMENT
WITH THE CITY OF COLUMBUS, OHIO
| WHEREAS, the City of Columbus and City of Dublin entered into an agreement
for sanitary sewer service on April 13, 1993, pursuant to Ordinance No. 136-92
passed by the City of Dublin on December 21, 1992, and pursuant to Ordinance
No. 2692-92 passed by the City of Columbus on December 14, 1992 (the “Sanitary
Sewer Service Contract”); and
WHEREAS, Columbus and Dublin previously amended pursuant to Columbus City
Ordinance No. 0454-2009, passed by its City Council on July 13, 2009 and by
Dublin, duly authorized by City Ordinance No. 43-09, passed by its City Council on
August 17, 2009, the Sanitary Sewer Service Contract to provide for the
modification of the Exclusive Dublin Expansion Area by expanding that area into
the Exclusive Columbus Expansion Area and Negotiated Expansion Area; and
WHEREAS, Columbus and Dublin are entering into a new Economic Development
Agreement to expand the previous Agreement’s revenue sharing area; and
WHEREAS, in order to service the additional revenue sharing area and to reflect
updated Columbus model agreements, new water and sanitary sewer service
agreements with Columbus are required.
NOW, THEREFORE, BE IT ORDAINED by the Council of the City of Dublin,
Delaware, Franklin and Union Counties, State of Ohio, ‘1_ of the elected
members concurring that:
Section 1. The City Manager is hereby authorized to enter into a new Sanitary
Sewer Service Agreement with the City of Columbus, Ohio.
Section 2. This Council further hereby authorizes and directs the City Manager,
the Director of Law, the Director of Finance, the Clerk of Council or other
appropriate officers of the City to prepare and sign all other agreements and
instruments and to take any other actions as may be necessary to implement this
Ordinance.
Section 3.This Ordinance shall be effective on the earliest date permitted by law.
ae :
Passed this Sl day of Jul, , 2023
| Hane DAL.
Mayet Presidirle Office?
ATTEST:
Clef of CoyAcil 0
To: Members of Dublin City Council
From: Megan D. O’Callaghan, P.E., City Manager
Date: June 20, 2023
Initiated By: Paul A. Hammersmith, P.E., Director of Engineering/City Engineer
Re: Ordinance 26-23 and Ordinance 27-23 – Authorizing the City Manager to Enter
into New Water and Sanitary Sewer Service Agreements with the City of
Columbus, Ohio
Background
The City of Columbus (Columbus) has provided water and sanitary sewer service to the City of Dublin
(Dublin) when it was first a village and thereafter when it became a City in 1987. For just over thirty
years, water and sanitary sewer services have been provided through agreements between Dublin
and Columbus. Dublin and Columbus entered into an agreement for water service on April 13, 1993,
pursuant to Ordinance No. 135-92 passed by Dublin on January 4, 1993, and pursuant to Ordinance
No. 2693-92 passed by Columbus on December 14, 1992 (Water Service Contract). Similarly, Dublin
and Columbus entered into an agreement for sanitary sewer service on April 13, 1993, pursuant to
Ordinance No. 136-92 passed by Dublin on December 21, 1992, and pursuant to Ordinance No. 2692-
92 passed by Columbus on December 14, 1992 (Sanitary Sewer Service Contract). Both Contracts
included an Exhibit A titled “Dublin/Columbus Sanitary Sewer and Water Contract Service Area” (as
attached) which delineated areas to be annexed by Dublin and Columbus whereby water and sanitary
sewer services could then be provided by each entity. The term of both Contracts is 50 years.
Dublin and Columbus previously amended the Contracts pursuant to Columbus Ordinance No. 0454-
2009, passed by its City Council on July 13, 2009 and by Dublin, duly authorized by City Ordinance
No. 43-09, passed by its City Council on August 17, 2009. The Contract amendments provided for the
modification of the Exclusive Dublin Expansion Area by expanding that area with the addition of a
277-acre area located in the Negotiated Expansion Area. The 277-acres constituted approximately six
percent of the Negotiated Expansion Area and was located just north of State Route 161, at its
intersection with US Route 33.
Summary
Dublin and Columbus are proposing to enter into a new Economic Development Agreement to expand
the Exclusive Dublin Expansion Area by approximately 5,575-acres. The area consists of both the
Exclusive Columbus Expansion Area and the Negotiated Expansion Area, as defined within the 1993
Contracts. In the 1993 Contracts, both Dublin and Columbus agreed that the Negotiated Expansion
Area would constitute a shared future growth area for both entities. In order to provide services to
the expanded Dublin Expansion Area and update the existing agreements to reflect present
conditions, new water and sanitary sewer service agreements with Columbus are required.
The proposed new service agreements will replace the existing Contracts originally entered into in
1993. These new agreements are in Columbus’ updated format and are intended to be more
consistent with their current service agreements with other satellite suburbs to which Columbus
provides water and sanitary sewer services. The new service agreements include the expanded Dublin
Office of the City Manager
5555 Perimeter Drive • Dublin, OH 43017-1090
Phone: 614.410.4400 • Fax: 614.410.4490 Memo
Ordinance 26-23 and Ordinance 27-23 – Authorizing the City Manager to Enter Into New Water and
Sanitary Sewer Service Agreements with the City of Columbus, Ohio
June 20, 2023
Page 2 of 2
Expansion Area to align with the Revenue Sharing Area as established by the Economic Development
Agreement (EDA), and establish conditions and requirements for the provision of water and sanitary
sewer services to this expanded area. The term of the new agreements is twenty-five (25) years.
Additionally, the new service agreements maintain existing water and sanitary sewer service levels to
Dublin residents. Regarding the new Water Service Agreement, provisions are now included in terms
of temporary street closures and water shut offs. Columbus will use reasonable efforts to notify Dublin
at least forty-eight (48) hours in advance of when work on the Dublin water system is to be
performed, including street closures. The Columbus notification will include hours of work restrictions
and necessary detour routes, unless the work is an emergency in nature. Lastly, Columbus will give
Dublin reasonable notice and probable duration of temporary water shut offs, except in the case of
emergencies or serious water main breaks. In those situations, water service will be discontinued
immediately and notice will follow as soon as possible.
Recommendation
Staff recommends adoption of Ordinances 26-23 through 27-23 at the second reading/public hearing
on July 31, 2023, authorizing the City Manager to Enter into new Water and Sanitary Sewer Service
Agreements with Columbus.
EXHIBIT I
Depiction of Revenue Sharing Area
i
3
333
sa
1
5x
s
Cz
SH137S7413 7
3
e
f N
Proposed Dublin Columbus Revenue Sharing Area etr
t
II I Proposed Revenue Sharing Area il 27715 ac
Iliff Columbus Exclusive Expansion Area ti
v
Dublin Exclusive Expansion Area r
i City of Dublin Existing Incorporated Area r
10 r
L r
I 5C 1000 G
E clusNe Evenslon Ate We based on the 1993 DubinColumbus Water end Serer Corerecl SetmceSet 0 4
ir ettd In neceme 1 E hlb w NI un ncorocr ted lends nd loon by en MS a be t d 1
h
s
14080 ac
wFooNa r
eiVol V 1 4
e l 4031 ac
l1 trd l I1 1
d
r
I x i tad i o
r tJSID 1
9604 ac PosrtoJ ft
3 4 i l V R
e
er aufyoN CU
r
r
7
A
t
l pI16lM R0
i1 rT
1
SANITARY SEWER SERVICE AGREEMENT
CONTRACT
BETWEEN THE CITY OF COLUMBUS
AND
CITY OF DUBLIN
THIS AGREEMENT MADE AND ENTERED INTO THIS _____ DAY OF
_______________________, 2023, by and between the CITY OF COLUMBUS, OHIO,
(“Columbus”), and the CITY OF DUBLIN, OHIO (“Dublin”) (together the “Parties”) for the
discharge, transportation, pumping and treatment of sanitary sewage, industrial wastes,
water or other liquid wastes from the City of Dublin to and by the City of Columbus,
utilizing the Sewerage System and Sewage Treatment Works of the City of Columbus.
WITNESSETH:
In consideration of the mutual covenants and promises herein contained, and in
accordance with the applicable provisions of Chapters 1145 and 1147, Columbus City
Codes, 1959 as amended and of Ordinance No. _________ passed _____________by
the Council of the City of Columbus, and Ordinance No. __________by the Council of the
City of Dublin, the Parties hereto agree as follows:
Section 1: That, subject at all times to Columbus’ right to sell surplus utility services,
under the provisions of Article XVIII, Section 6 of the Constitution of Ohio, Dublin shall
have the right and obligation, throughout the effective period of this Agreement, to
discharge all sewage, industrial wastes, water or other liquid wastes from its sanitary
sewers, either directly or indirectly, or both, into the Sewerage System of the City of
Columbus, Ohio, and into no other provider, and to have the same transported, pumped
and treated by the Sewerage System and Sewage Treatment Works of the Columbus,
provided, however:
(a) Dublin shall have adopted or passed such measures as may be necessary to
authorize the execution of this Agreement.
(b) Whenever, and to the extent that the Columbus City Codes prohibits or restricts
the direct or indirect discharge to the sanitary sewer of subfoundation building
drains from premises within Columbus, such prohibitions or restrictions shall apply
with equal force to premises within the City of Dublin as if same were a part of this
Agreement.
(c) Dublin agrees it will not at any time cause or permit storm water or roof water
leaders to be led into or connected with the separate, sanitary system of sewers,
or led into or connected with any soil pipe, house drain, or house sewer tributary
to the separate sanitary system of sewers.
Dublin agrees that it shall limit inflow and infiltration to its sewer system. The
limitations applying thereto shall be in accordance with a future mutually
acceptable modification to this Agreement.
2
(d) Dublin agrees that no person shall directly or indirectly use or discharge to any
sewer within the City of Dublin which is tributary to the Columbus Sewer System
in violation of any applicable provision of Columbus City Codes, Chapters 1145
and 1147.
(e) Dublin agrees it will not discharge, cause or permit to be discharged, directly or
indirectly into any sewer or into any water course, ditch, or drain leading into any
sewer, any acid, chemical, or other substance, which tends to, or does destroy, or
in any way injures the sewer or which in any way interferes with proper
maintenance of facilities and the transportation, treatment, or disposition of any
sewage carried or drained through any sewer in Columbus.
(f) Dublin agrees it will not discharge, cause or permit to be discharged, directly or
indirectly into any sewer, any kerosene, gasoline, benzene, naphtha or any
explosive or inflammable chemical, substance or thing.
(g) Dublin agrees the requirements set forth herein, together with any elaboration,
extension, definition or amendment of said requirements as such may be duly
elaborated, extended, defined or amended through rules and regulations issued
from time to time by the Columbus Director of Public Utilities, or by Legislative
processes of Columbus, shall be fully applicable to all premises in the City of
Dublin, which are or later become tributary, directly or indirectly, to the Columbus
Sewerage System, to the same extent and degree as they apply within the City of
Columbus and any violation of these provisions shall be corrected or caused to be
corrected at once by the Dublin.
(h) Subject to Sections 4 and 5 hereinafter, Dublin agrees that sewer services,
providing for the discharge of sewage, industrial wastes, water or other liquid
wastes into its sanitary sewers, shall be restricted to usage by properties within the
corporate limits of the City of Dublin, provided that such properties lie within the
boundaries of the Dublin Water and Sewer Service Area as such limits exist on the
date of execution of this Agreement, and to usage by any properties annexed to
the City of Dublin during the term of this Agreement provided that such properties
lie within the boundaries of the Dublin Water and Sewer Service Area as described
in Exhibit A and being hereby made by reference a part of this Agreement.
Reference to annexations as used in this Agreement does not include annexation
by merger pursuant to the Ohio Revised Code, Section 709.43 through 709.46,
inclusive, and as subsequently amended.
Dublin agrees that, should any properties within Dublin Sewer Service Area annex
to the City of Columbus, Columbus shall have the right to provide sewer service to
such properties the same as it would any other areas within its corporate limits
irrespective of this Agreement.
3
(h) Dublin agrees that the construction of all house sewers or service connections
within its boundaries shall comply with this Agreement, the then current minimum
requirements governing such work in Columbus, and conform Dublin’s rules and
regulations, whichever is more stringent.
(i) Dublin agrees that the design, construction, operation, use and maintenance of all
sanitary sewers, house services and connections within its boundaries, including
all connections with the Columbus Sewerage System, shall be performed at the
entire expense of Dublin or its residents, and shall conform in all respects with or
exceed the corresponding standards and practice of Columbus. All main and
sanitary sewers and connections to serve areas within the Dublin shall be
constructed in accordance with detailed plans and specifications which have been
approved from an engineering standpoint by the Columbus Director of Public
Utilities, provided that such approval, from an engineering standpoint, or
disapproval supported by engineering reasons therefor, shall be made by the
Columbus Director of Public Utilities, within thirty (30) days after said plans and
specifications have been submitted for final approval by Dublin. Absent approval
or disapproval as set forth above, Dublin may proceed with construction in full
conformity with such plans and specifications and with such engineering
supervision and inspection as may be required by Columbus, and subject to all
other provisions of this Agreement and applicable references. Upon completion of
such work, and not later than sixty (60) days thereafter, accurate record drawings
showing the work as actually constructed shall be filed by Dublin, with Columbus,
having been approved and signed by Dublin and submitted to Columbus for final
approval. These record drawings shall show the area of each and every tributary
lot and tract computed in accordance with paragraph (l) of this Section. Dublin
agrees to notify Columbus at least forty-eight (48) hours prior to tapping any
Columbus sewers.
(j) Dublin agrees that for all structures and properties connected to the Columbus
Sewerage System, after the effective date of this Agreement, a system capacity
charge for main trunk sanitary sewer benefit, or such similar charges as may be
hereinafter established by Columbus, shall be applicable to any and all such
structures and properties which are located within the Dublin corporate limits,
wherever such property will be tributary directly or indirectly to the Columbus
Sewerage System, and provided that such charge(s) shall be determined and
collected before or upon the issuance of a permit to connect such structures to the
sewerage system. The charge so determined shall be computed on the size of the
domestic water service tap for either city water or well water usage for each
structure as computed by Columbus, for similar structures as established and
periodically amended by Columbus Ordinance. Dublin agrees to pay Columbus, at
three (3) month intervals, 100 percent of all such charges as collected.
(k) Dublin agrees to utilize the system of sewer service connection permits established
and issued by Columbus. Columbus shall keep and maintain an accurate record
of all permits issued, and will forward a copy of said permits to Dublin after
construction inspection is completed and the connection is accepted.
4
(l) Dublin agrees to furnish to the Columbus Director of Public Utilities all available
information and data as to all sources of water supply other than the Columbus
Division of Water, which may be in existence, or may later be developed to serve
Dublin. As to wells, this information shall include the location, size, capacity and
depth thereof. Further, Dublin agrees that where such water supply discharges
directly or indirectly into the sanitary sewer system, Dublin shall require metering
or other forms of measurement as agreed to by the Columbus Director of Public
Utilities.
(m) As soon as available, Dublin agrees to furnish to Columbus copies of its location
atlas maps showing the overall sanitary sewer system and furnish additional
copies as and when individual maps are changed or brought up-to-date.
Section 2:
(a) Columbus, through its Division of Water, shall have the rights and privilege,
beginning as of the effective date of this Agreement, of billing for sewerage service
charges directly against or of adding to water bills rendered against premises
within the Dublin by the Columbus Division of Water. Under the method
established above, for determination of the sewerage service charge or charges,
said charge or charges shall be computed by subjecting the water usage to the
applicable provisions and rates of Chapter 1147, Columbus City Code, 1959,
which applicable rates may be changed in accordance with such rate structure as
may be established from time to time for areas outside the Columbus corporate
limits by ordinances passed by the Columbus City Council; provided, however, and
subject to the provisions of Section 1 of this Agreement, that in the event of any
such subsequent change in the rates of charge, the rates of charge to Dublin, shall
not, in such case, exceed the rates of charge duly established and collected, at
such time, for any other political subdivision.
(b) Upon Dublin’s written request, Columbus agrees to include as a separate item
under the billing authorized above, such user surcharge for structures and
premises within the corporate limits of Dublin as may be established from time to
time by Dublin ordinance or regulation. Such surcharge shall be refunded to Dublin
monthly together with a verified report of the amount collected.
(c) Columbus agrees that in the computation of charges made to Dublin
Sewerage Service customers, the same credits or adjustments shall be applicable
to Sewerage Service customers in Columbus as are now, or may hereafter from
time to time, be applicable thereto, due to non-entry into the sanitary sewers of
water consumed by such users, shall be applicable to Dublin customers; provided
that any fee charged by Columbus to obtain such credits or adjustments may be
increased by fifty-cents ($0.50) for users within Dublin.
(d) Columbus agrees that Dublin shall have the right and privilege to make charges,
for structures and premises within the corporation limits of the City of Dublin,
5
independent of the requirements of Section 1.
(e) Columbus may administer and enforce Sections 1145.01 - 1145.99 of the
Columbus City Codes and all amendments thereto within the City of Dublin’s
corporate limits in order to prohibit or limit the discharge of toxic and other
substances into the sewerage system. It is also agreed that Columbus
representatives may enter industrial establishments, perform inspections, and
sample waste streams for the purpose of enforcing Sections 1145 and 1147 of the
Columbus City Code, as amended. Dublin agrees to adopt as a local regulation or
ordinance of Dublin, the requirements of Section 1145.01 - 1145.99 in order that
these requirements shall be applicable to all premises in the City of Dublin which
are, or later become, tributary directly or indirectly to the Columbus Sewage
System to the same extent as they apply to premises within the City of Columbus.
(f) Dublin agrees that all fees for administering and enforcing Chapter 1145 shall be
collected in accordance with Chapter 1147 of the Columbus City Codes, as
amended.
Section 3: Dublin agrees that during the effective period of this Agreement, Columbus
employees or agents shall have the right to enter into and within City of Dublin’s corporate
limits for all purposes of this Agreement, for the further purpose of construction within the
individual design-tributary area of any extensions to the Sewer System of Dublin and
constructing any other main sewers which, on the basis of sound engineering principles,
may be deemed necessary by the Columbus Director of Public Utilities to build up an
adequate sewer collector system in the entire area to be serviced by Columbus, including
but not being limited to the City of Dublin corporate limits.
The plans and specifications for the construction of sewers shall be submitted by
Columbus to Dublin for approval as to engineering and location. Such approval or
rejection supported by engineering reasons therefore, shall be made by Dublin within
thirty (30) days after said plans and specifications have been submitted by Columbus to
Dublin for final approval. In the case where no approval or disapproval is made by Dublin
within said thirty (30) days, Columbus may proceed with construction, without prejudice,
in full conformity with the plans and specifications so submitted and not acted upon by
Dublin, subject however to legal requirements governing the need for proper easements
where said sewers will be located on private property. In the case where said plans and
specifications are disapproved from an engineering or location standpoint by Dublin
within the said thirty (30) days, such disapproval shall be made in writing and the
engineering reasons set forth therein.
Columbus pledges itself to construct such sewer extensions at its own expense and,
insofar as possible, to restore disturbed areas to a reasonably equal condition in which
they were found prior to such construction. Columbus will and shall have the right to
preserve, maintain, operate, replace and repair any such sewers. During the life of this
Agreement Dublin shall have the right to connect any main sewers of its own collector
system to any such aforementioned sewers, subject to the requirement that the flow from
Dublin’s main sewers is not above that designed for and is not from areas outside the
individual tributary-design area of the said main sewers constructed by Columbus.
6
Further, subject to the requirement that such connections shall be made under Columbus’
supervision in such manner as approved by Columbus and in full conformity with all other
provisions of this Agreement.
Section 3.1: Dublin and Columbus both recognize the need for future growth in order for both communities to continue to prosper. In consideration of the foregoing, the Parties further agree as follows:
(a) Included within Exhibit "A" is an area delineated as "Dublin Expansion Area." The Parties agree that as to areas located within the "Dublin Expansion Area," sewer services shall be restricted to properties lying within the City of Dublin corporate limits. The Parties also acknowledge that unincorporated areas within Exhibit "A" will become eligible for sewer service pursuant to this Agreement upon annexation to Dublin during the period of this Agreement provided that such annexed properties lie within the aforementioned Dublin Water and Sewer Service Area established in Exhibit "A". It is also agreed that expansion, adjustment, or modification of the Dublin Water and Sewer Service Area shall be reviewed by both Parties at least every five (5) years, or sooner, upon a showing of good cause in writing delivered by either party to the other.
(b) Columbus agrees that it shall not accept any annexation of property situated within the aforementioned “Dublin Expansion Area”.
Section 3.2: Dublin will take no action to initiate, approve, nor in any manner support a
merger with any adjacent township pursuant to Section 709.43 through 709.46, inclusive,
of the Ohio Revised Code or any revision or amendment thereto. All efforts by Dublin to
increase its geographic boundaries shall be through the annexation procedure. Dublin
agrees that it will not initiate, approve, nor support in any manner, annexation to Dublin
of properties located outside the Dublin Sewer Service Area designated on Exhibit A
attached to this Agreement.
Section 3.3: It is agreed by the Parties that in the event a merger between City of Dublin
and any Township should occur, Columbus shall incur no obligation to service areas other
than those specifically referred to in this Agreement. The Parties further agree that as of
the effective date of said merger, the rates chargeable hereunder shall become ten times
those set forth in Section 2 hereof. Dublin consents to the provisions set forth in this
section as related to the cost and expense of providing continued services under this
Agreement and not as an exaction, tax or penalty in the event the conditions imposing
this section occur. Further, Dublin consents and agrees that the provisions in this section
are not confiscatory nor unreasonable.
Section 3.4: If Columbus enters into any new Sewerage Service Agreement or modifies,
amends, extends or otherwise changes the terms of any Sewerage Service Agreement
with any political jurisdiction and the new, modified, amended, extended or otherwise
changed Agreement does not contain the same provisions regarding merger/annexation
as set forth in Section 3.2 and 3.3 of this Agreement, then Sections 3.2 and 3.3 are null
and void.
Section 4: This Agreement will commence on ___________________________, and
7
shall remain in effect for a period of twenty-five (25) years therefrom subject to earlier
termination or to revision, or to properly authorized modification or to renewal upon mutual
Agreement of the Parties hereto and shall supersede and cancel any and all previous
Agreements concerning sanitary sewage service between the Parties hereto for the
specific City of Dublin.
Section 5: Dublin further agrees that Columbus may connect any sewer to the sewerage
system of Dublin after submission of the plans and specifications therefore to Dublin in
accordance with the provisions of Section 3 and provided that such sewer connections
by Columbus do not serve areas outside the Dublin sewer system tributary-design areas,
and provided further that Dublin determines that there is available capacity within said
line to service Dublin’s planned tributary areas.
Columbus agrees that for all properties and premises within Columbus connected into
such sewers or connections, it shall reimburse Dublin for any sanitary sewer oversizing
of that section of the sewer system built by Dublin on the basis of an estimate of the
differential in cost of that section of the system involved, to be mutually agreed upon prior
to the approval of plans.
Section 6: If any portion of this Agreement proves to be invalid or unconstitutional, the
same shall not be held to invalidate or impair the validity, force or effect of any other
portion of this Agreement unless it clearly appears that such other portion is wholly or
necessarily dependent for its operation upon the portion so held invalid or
unconstitutional.
Section 7: That failure on the part of either party of this Agreement to faithfully discharge
its obligations and responsibilities hereunder, either in whole or in part, shall vest in the
other party to the Agreement the right to terminate same, effective sixty (60) days after
written notice of such failure and the intent to terminate is delivered to the offending party,
provided that the offending party shall have the right to cure or correct the said failure, to
faithfully discharge its obligations and responsibilities and upon demonstration thereof
such notice of cancellation shall not be effective and this Agreement shall remain in full
force and effect without prejudice to Columbus’ right to collect amounts due and owing to
Columbus arising under the terms of this Agreement prior to notice of termination.
Section 8: Dublin agrees that during the term of this Agreement, it will take no action whatsoever, including any funding, preliminary engineering, or other surveying necessary or incident to plan, design, construct, or operate any sanitary waste water treatment facility and that, except as herein provided or as may be subsequently authorized by the Columbus City Council, Columbus shall be the sole and exclusive provider to Dublin of such services as are provided by the terms of this Agreement within the designated contract service areas set forth on “Exhibit A”.
8
IN WITNESS WHEREOF, the Parties hereto have set their hands on this __________
day of ____________________, ____.
THE CITY OF COLUMBUS, OHIO
By______________________________
PUBLIC UTILITIES DIRECTOR
THE CITY OF DUBLIN, OHIO
By________________________________
CITY MANAGER
Approved as to form:
____________________________________
City Attorney
Columbus, Ohio
____________________________________
Law Director,
City of Dublin, Ohio