Loading...
HomeMy WebLinkAbout2012-03-13 City Council Item No. 5CITY OF L14KE L LSIl`IOI�E -�� DREAM EXTREMEn REPORT TO CITY COUNCIL TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: BARBARA LEIBOLD, CITY ATTORNEY DATE: MARCH 13, 2012 RE: SETTLEMENT AND IMPLEMENTATION AGREEMENT WITH K. HOVNANIAN AT LA LAGUNA Background In July, 1990, the City and the original developer of La Laguna Estates entered into a Development Agreement for the development of residential units on a 489 -acre project site. The following year, the City approved the La Laguna Estates Specific Plan ( "Specific Plan "), which proposes the development of 660 dwelling units. In 2001, the City and the original developer executed an amendment to the Development Agreement extending the term of the Original DA to July 18, 2010, and revising the schedule of development impact mitigation fees that were applicable to the project, including a $1,000 per unit development agreement fee ( "DAG Fee "). In connection with the development of the first four project tracts, the developer applied for 515 building permits and erroneously paid certain City development impact fees not listed in the Development Agreement in the amount of $566,284 and also erroneously paid MSHCP fees in the amount of $536,721. Of the $536,721 of MSHCP fees erroneously collected, $521,217 had been transmitted by the City to the Regional Conservation Authority ( "RCA "). The City currently holds the balance, $15,504. The developer has presented an analysis of the Project's vested rights and requested a refund of fees in the amount of overpayment. In order to avoid the time and expense of protracted litigation, the City and the developer have engaged in settlement discussions under the direction of the City Council. An agreement has been prepared consistent with those negotiations and is before the City Council this evening. Discussion A copy of the proposed Settlement and Implementation Agreement is attached. As structured, the agreement only imposes a cash payment by the City of the MSHCP fees currently retained by the City, that is, $15,504. The proposed agreement provides for the following additional key terms: AGENDA ITEM NO. 5 Page 1 of 13 Settlement and Implementation Agreement March 13, 2012 Page 2 • The City agrees to coordinate in good faith with developer to assist developer in seeking a reimbursement or credit from RCA for the amounts of MSHCP fees erroneously paid. The City also agrees to not impose further MSHCP fees on the remainder of the project. • The City shall retain the $566,284 in erroneously paid City impact fees but shall forego any claim to further DAG fees under the Development Agreement. • The City will continue to collect the library improvement fees of $150 per unit; plan -check and processing fees, a parkland dedication in -lieu fees for the remainder of the units as building permits are pulled as provided in the Development Agreement. Fiscal Impact None. Although the City will refund $15,504 of erroneously collected MSHCP fees, those fees would have otherwise been forwarded to RCA. Recommendation That the City Council approved the attached Settlement and Implementation Agreement and authorize the Mayor to execute the agreement, subject to any minor modifications as may be approved by the City Attorney. Prepared by: Barbara Leibold, City Attorney Attachment: Settlement and Implementation Agreement Page 2 of 13 SETTLEMENT AND IMPLEMENTATION AGREEMENT This SETTLEMENT AND IMPLEMENTATION AGREEMENT ( "Agreement ") is entered into as of this 13th day of March 2012, by and between THE CITY OF LAKE ELSINORE, a municipal corporation ( "City ") and K. HOVNANIAN AT LA LAGUNA LLC (the "Developer ") with respect to the facts set forth in the Recitals below. City and Developer shall hereinafter be referred to, collectively, as the "Parties" and, each, a "Parry." RECITALS A. On or about July 18, 1990, the City and La Lagmi 'Estates (the "Original Developer ") entered into a Development Agreement pursuant to Govesninent Code section 65964, et seq. (the "Original DA ") for the development of 600 residenfiai:iiwellfgg units on a 489 -acre site (the "Project ") located within the City's jurisdiction. B. Sections 3.5, 4.8, 4.8.1, and 4.8 DA set forth the exactions, dedications, and Section 3.5 of the Original DA outlines development of the 600 residential units, obligations the "Developer shall have fulfill impose nor assist any other entity in iprpo: exaction or other requirement against anyprc Original DA outlines a schedule of Develops " [o]ther than the Development: Agreement lV only those fees listediri Exhibit D "and/or exp with only those conditions and make only th Agreement or included asJ,a.condtrion apl o ,ttie Original DA and khibit D to the Original lther :; requirements for the Project in their entirety. the xDevelopei s; - mitigation 'obligations for the nd pro04es h if the Developer fulfills these i its entire b ligation" and "the City shall neither ng colle6 .any fee, charge, dedication, tax, lerty owned b"eyeloper...." Section 4.8 of the lent Agreement Mitigation Fees and provides that, tigatioii Fees;:Developer shall be obligated to pay esslypermitted.utider Section 4.8.1, and to comply s6 and improvements specified in this royal to the Tentative Map, which conditions and aeaicanons snasi oe nmuea ro -nose perm. 1 ea unaer:me Hppucaose Law 01 me rroject. 1ne Original:DA defines "ApplicAlo"Law of ihe'Proic& `to "mean all of the rules, regulations, and official polices governing, permit uses of 't13e land, density, design, improvement and construction ,standards and _specificd ibns in force as of the Effective Date [July 18, 1990] including, without limitation; chose goveming the issuance of permits and approvals for the Project. ." Section 4.8.1 provides: "[t]he City shall not (a) impose any fees, taxes, assessments, conditions, dedications, exactions, or other requirements not expressly provided herein ... or (b) increase existing fees, taxes, assessments, conditions, dedications, or other exactions or other requirements:" Section 4.8.2 provides that "[t]he fees applicable to the Project, as provided in Exhibit D, and any taxes, assessments, conditions, dedications, exactions, or other requirements applicable to the Project shall not be modified or renegotiated by the City as a condition of approval of the Tentative Map, or any final map, or as a result of the filing of any new subdivision or processing of any lot -line adjustment " Finally, Exhibit D to the Original DA limits "the fees applicable to the Project" to: (1) fees for the City's Master Entryway Sign Program in an amount to be determined by the Tentative Map conditions, (2) Library Capital Improvement Fees in the amount of $150 per unit; (3) planning application, plan- check, and processing fees for land -use approvals at the rate in effect at the time application is made for such approvals or permits; and (4) Parkland Dedication In -Lieu Fees in an amount to be determined by the Tentative Map conditions. 119/024740 -0001 Page 3 of 13 2543863.5 a03/08/12 9 C. In 1991, the Original Developer applied for approval of the La Laguna Estates Specific Plan ( "Specific Plan "), which proposes the development of 660 dwelling units on the 489 -acre Project site. Although the Specific Plan proposes 60 more units than were referenced in the Original DA, the City made a finding of "substantial conformance." After completing the environmental review required by the California Environmental Quality Act (Cal. Pub. Res. Code §§ 21000 — 21177) ( "CEQA ") and the CEQA Guidelines (14 C.F.R. §§ 15000 — 15387), the City approved the Specific Plan on November 10, 1998. D. As part of the environmental review required by CEQA, the City and the Original Developer created a Habitat Mitigation Plan in May 1994. The California Department of Fish and Game ( "CDFG ") endorsed the Habitat Mitigation Plan as providing adequate mitigation to offset impacts to biological resources caused by the implementation of the Specific Plan. In December 1996, the City and the Original Developer re- evaluated and revised the Habitat Mitigation Plan to ensure that it accurately mitigates impacts to sensitive biological resources on the Project site. The United States Fish and Wildlife Service ( "USFWS ") reviewed the Revised Habitat Mitigation Plan and concurred with the CDFG's determination that the Plan would mitigate impacts to biological resources to less than significant levels. E. On or about April 30, 2001, the City and the Original Developer executed an amendment to the Original DA (the "Amended DA "). The Amended DA extends the term of the Original DA to July 18, 2010, and revises the schedule of Development Agreement Mitigation Fees. Similar to the Original DA, the Amended DA sets forth the exactions, dedications, and other requirements for the Project in their entirety. Specifically, section 2.1 of the Amended DA provides that "[o]ther than Development Mitigation Fees, Developer shall be obligated to pay only those fees listed in Exhibit D" to the Original DA "and/or expressly permitted under Section 4.8.1" of the Original DA, "and to comply with only those conditions and make only those dedications and improvements specified in this Agreement or included as conditions of approval to the Tentative Map, which conditions and dedications shall be limited to those permitted under the Applicable Law of the Project." Section 3.1 of the Amended DA clarifies that, "[e]xcept as expressly provided to the contrary in this First Amendment [to the Original DA], all provisions of the Original Development Agreement shall remain in full force and effect." F. Developer subsequently became the successor in interest to the Original Developer. Section 8.1 of the Original DA provides that "[p]ursuant to Government Code section 65868.5, the burdens and benefits of this Agreement shall bind and inure to the benefit of all successors in interest to the parties to the Agreement." G. In 2003, after the approval of the Amended DA, the City Council adopted Ordinance No. 1096 (codified at Mun. Code §§ 16.83.010 — 16.83.080), which establishes that the Western Riverside County Transportation Uniform Mitigation Fee ( "TUMF ") would be assessed on new development to mitigate the development's impact on the regional system of highways and arterials. Ordinance No. 1096 specifies, however, that "[t]he following new development shall be exempt from the TUMF:... [p]rojects which are the subject of a Development Agreement entered into pursuant to Government Code Section 65864, et seq., prior to the effective date of the ordinance codified in this chapter, wherein the imposition of new fees are expressly prohibited; provided, that if the term of such a Development Agreement is extended by amendment or by any other manner after the effective date of the ordinance codified in this -2- Page 4 of 13 chapter, the TUMF shall be imposed." (Mon. Code § 16.83.40.F.4.) The City Attorney, the City Staff, the City Council and the Developer have each concluded that, pursuant to section 16.83.49.F.4 of the City's Municipal Code, the entire Project is exempt from the TUMF because: (1) the Project was the subject of a Development Agreement entered into pursuant to Government Code Section 65864, et seq. prior to the effective date of Ordinance No. 1096, (2) sections 3.5, 4.8, 4.8.1, and 4.8.2 of the Original DA and section 2.1 of the Amended DA expressly prohibit the imposition of new fees, and (3) the Original DA and the Amended DA were not extended by amendment or by any other manner after the effective date of Ordinance No. 1096. H. On February 4, 2004, the Planning Commission adopted Resolution No. 2003 -02 recommending that the City Council approve Amendment No. 1 to the Specific Plan with amended Conditions of Approval. Among other changes, Amendment No. 1 to the Specific Plan specifically deleted a Condition of Approval from the Specific Plan that would have required the Developer to pay regional fees, such as the TUMF. In accordance with the Planning Commission's recommendation, the City Council adopted Ordinance No. 1090 on February 25, 2004, approving Amendment No. 1 to the Specific Plan, without any requirement to pay regional fees, such as the TUMF. I. On July 27, 2004, the City Council adopted Ordinance No. 1124 (codified at Mun. Code §§ 16.85.010- 16.85.110), which established a local development mitigation fee for funding the preservation of natural ecosystems in accordance with the Western Riverside County Multiple Species Habitat Conservation Plan (the " MSHCP Fee "). The Implementing Resolution for the MSHCP Fee (Resolution No. 2004 -11) specifies that "[t]his resolution shall not apply to. .. [a]ny project for which and to the extent that ... a development agreement pursuant to Government Code section 65964, et seq., approved or executed prior to the adoption of this Resolution, confers vested rights under the City's ordinances or state law to proceed with the project notwithstanding the enactment of this Resolution." The City Attorney, the City Staff, the City Council and the Developer have each concluded that, pursuant to Resolution No. 2004 -11, the entire Project is exempt from the MSHCP Fee because: (1) the Project's Original DA and Amended DA were approved and executed prior to the adoption of the Resolution No. 2004 -11, and (2) sections 3.5, 4.8, 4.8.1, and 4.8.2 of the Original DA and section 2.1 of the Amended DA confer vested rights under the City's ordinances and state law to proceed with the Project notwithstanding the enactment of fees, taxes, assessments, conditions, dedications, exactions, or other requirements not expressly provided in the Original DA or included as a condition of approval to the Tentative Map. J. Subject to certain limitations not applicable here, section 65961 of the Government Code precludes a local agency from imposing any condition on a building permit that it could have lawfully imposed on a previously approved tentative map. In the relevant part, section 65961 provides: " ... upon approval or conditional approval of a tentative map for a subdivision of single- or multiple - family residential units, . . . during the five -year period following recordation of the final map or parcel map for the subdivision, a city ... shall not require as a condition to the issuance of any building permit .... conformance with or the performance of any conditions that the city ... could have lawfully imposed as a condition to the previously approved tentative ... map." -3- Page 5 of 13 K. Between July 2003 and August 2010, the City approved Tentative Tract Maps for the six tracts that comprise the Project (Final Tract Map Nos. 30788, 30789, 31917, 32337 -1, 32337- 2 and 32337 -F). When the City approved these Tentative Tract Maps, it did not impose as a Condition of Approval the future payment of local and/or regional fees, such as the City's Transportation Impact Fees ( "TIF "), Development Impact Fees ( "DIF "), and Fire Fees, and Western Riverside County's TUMF and MSHCP Fees. The City Attorney, the City Staff, the City Council, and the Developer have determined that section 65961 of the Government Code bars the City from imposing these fees as a condition of the issuance of building permits. L. To complete the first four subdivisions of the Project (Final Tract Map Nos. 30788, 30789, 31917, and 32337 -1), the Developer applied for and the City issued approximately 515 building permits. In connection with the issuance of these building permits, the City charged and the Developer paid City Impact Fees (consisting of the DIF, and Fire Fees) in the amount of $566,284 and MSHCP Fees in the amount of $536,721. All Parties agree that these prior fees were charged and paid in error. Of the $536,721 of MSHCP Fees erroneously collected, $521,217 had been transmitted by the City to the Regional Conservation Authority ( "RCA "). After discovering that these fees were collected in error, the City did not transmit the remaining $15,504, and is currently holding those fees for return to Developer. M. To complete the final two subdivisions of the Project (Tentative Tract Map Nos. 32337 -2 and 32337 - "F "), the Developer will need to apply for and the City will need to issue approximately 117 building permits. The Parties agree that the $566,284 in City fees erroneously collected in connection with previously issued building permits as described in Recital L shall be retained by the City and that future City fees that would be due for the 117 building permits shall be pursuant to the fee schedule agreed upon in the Amended DA. N. Pursuant to section 4.8.1 of the Original DA and section 2.1 of the Amended DA, the Developer has paid the City Development Agreement Mitigation Fees. O. Pursuant to the Original DA and the Environmental Impact Report ( "EIR" ), the Developer has taken the following measures to mitigate the Project's impact on traffic: (1) the Developer cooperated with the City to form a Mello -Roos District for the purpose of funding the planning, design, and construction of the street improvements required by the Original DA; (2) the Developer voted in favor of a special tax levy to the electors of the Mello -Roos District to fund the street improvements required by the Original DA; and (3) the Developer provided two new roads — an arterial highway and a secondary highway. The City has conclusively determined that the Project has fully mitigated its traffic impacts. P. Pursuant to the Original DA, the Specific Plan, and the Habitat Mitigation Plan, the Developer has taken the following measures to mitigate the Project's impact on sensitive biological resources on the Project site: (1) the Developer hired consulting firms to perform multiple environmental assessments of sensitive plant and animal species; (2) the Developer complied with the Habitat Mitigation Plan endorsed by the CDFG and the Revised Habitat Mitigation Plan endorsed by the USFWS; (3) the Developer paid $176,000 in Parkland Dedication In -Lieu Fees; (4) using Mello -Roos funds, Owner Park Fees, and Development Agreement Mitigation Fees, the Developer acquired a Park Site; and (5) the Developer reserved approximately 140 gross acres (29% of the Project site) as natural open space and approximately -4- Page 6 of 13 142 acres as open space. The City has conclusively determined that the Project has fully mitigated its biological impacts. Q. With the exception of the final 121 building permits and the specific on -site improvements relating thereto, the Original Developer and the Developer completed the development of the Project in accordance with the Original DA and the Amended DA prior to the expiration of the DA. Much of the development of the Project occurred prior to the City's 2003 adoption of Ordinance No. 1096 and its 2004 adoption of Ordnance No. 1124. R. In a letter dated September 14, 2011, the Developer notified the City that the Developer had erroneously paid MSHCP Fees in connection with the issuance of prior building permits. The Developer further notified the City that its future permits were not subject to MSHCP Fees and TUMF Payments. In the letter, the Developer explained that: (1) the resolutions and ordinances enacting the TUMF and the MSHCP Fee exempt pre- approved new development, like the Project, from their mitigation fee requirements; (2) section 65961 of the Government Code bars the City from demanding TUMF and MSHCP Fees in connection with the building permits needed to complete the final subdivisions of the Project because the City did not impose these fees as a Condition of Approval when it approved the Tentative Tract Maps for these subdivisions; (3) pursuant to the Original DA, the Amended DA, the Specific Plan, and the Habitat Mitigation Plan, the Developer has already taken measures to fully mitigate the future impact of the entire Project, and accordingly, requiring duplicative mitigation measures would violate the Mitigation Fee Act (Government Code §§ 66000 — 66025) and the takings clauses of the State and Federal Constitutions; and (4) by fulfilling its mitigation obligations under the Original DA, the Amended DA, the Specific Plan, and the Habitat Mitigation Plan, the Developer acquired a vested right to complete the Project without paying newly- imposed TUMF and the MSHCP Fees. The City has determined based upon its independent evaluation of the Developer's position that the Developer's position is meritorious. S. This Agreement is entered into in good faith for the purpose of settling all disputes between the Parties relating to the payment of past and future fees relating to the Project. NOW, THEREFORE, in consideration of the mutual covenants set forth in this Agreement, and for other good and valuable consideration, the receipt and adequacy of which are hereby acknowledged, the Parties to this Agreement covenant and agree as follows: 1. Prior MSHCP Fees Erroneously Assessed For the building permits previously issued in the Project, Developer was erroneously assessed and erroneously paid, $536,721 for the Western Riverside County MSHCP Fees. The City has turned all but $15,504 of funds over to the RCA. Within 30 days of the execution of this Agreement, the City shall refund to the Developer the $15,504 in funds that were retained by the City. The City and the Developer agree that these funds were assessed and paid in error for the reasons stated in the Recitals. The City agrees to coordinate in good faith with Developer to assist Developer in seeking a reimbursement or credit from RCA for the amounts erroneously paid. City Staff will provide documentation, declarations, and/or testimony as needed to assist Developer in establishing that the MSHCP fees were erroneously assessed and collected. -5- Page 7 of 13 2. Future MSHCP Fees Based upon facts and legal authorities set forth in the Recitals and in Developer's prior correspondence to the City, the Parties agree that the remaining building permits for the Project are not subject to the MSHCP Fees. If it is subsequently determined by a court of competent jurisdiction in a final judgment that future Project building permits are subject to the MSHCP fees, Developer will be entitled to a credit of up to $521,217 subject to and to the extent such credit is approved by RCA in lieu of the refund to be requested from RCA pursuant to Section 1 herein. 3. Regional Transportation Uniform Mitigation Fee (TUMF) Based upon the facts and legal authorities set forth in the Recitals and in the Developer's prior correspondence to the City, the Parties agree that future building permits for the Project are not subject to TUMF payments. 4. City Impact Fees Based upon the facts and legal authorities set forth in the Recitals and in the Developer's prior correspondence to the City, and in settlement of such other matters involving fees, the City shall retain the City Impact Fees referenced in Recital L. 5. Future Development Impact Fees under Amended DA Based upon the facts and legal authorities set forth in the Recitals and in the Developer's prior correspondence to the City, City agrees that future building permits for the Project shall be subject only to the development fees under the fee schedule agreed upon in the Amended DA. 6. Representations. Warranties and Covenants Each Party to this Agreement (each, the "Representing Party ") hereby represents and warrants to the other Parties as follows: a. The Representing Party has the right, power, legal capacity and authority to enter into and perform its obligations under this Agreement, and no approvals or consents of any person or entity other than the Representing Party are necessary in connection with it. The execution and delivery of this Agreement and the documents related hereto by the Representing Party have been duly authorized by it, and this Agreement and the documents related hereto, when executed and delivered, shall constitute a legal, valid and binding obligation of the Representing Party enforceable against it in accordance with their terms. b. Each person executing this Agreement on behalf of an entity, other than an individual executing this Agreement on his or her own behalf, represents that he or she is authorized to execute this Agreement on behalf of said entity. c. The Representing Party has not assigned or transferred to any third party any of the rights, claims, causes of action or items to be released or transferred, which it is obligated to transfer or to release as part of this Agreement. If a Representing Party breaches the foregoing representation and warranty, such Representing Party shall defend, indemnify and hold harmless the non- breaching Parties, of, from and against all liabilities, claims, demands, damages, costs, expenses, and attorneys' fees incurred by such non - breaching Parties as a result of any person or entity asserting any such assignment or -6- Page 8 of 13 transfer in violation of this paragraph's representation and warranty. It is the intention of the Parties, and each of them, that this indemnity does not require payment as a condition precedent to recovery. 7. Indemnification Developer shall defend, indemnify, and hold the City harmless from any of the following: a. Any lawsuit filed against the City, the City Council, or any City official or employee (collectively, "the Indemnified Parties ") challenging this Agreement; b. Any lawsuit filed against the Indemnified Parties arising from the City's determination that the remaining building permits in the Project are exempt from the MSHCP fees and TUMF payments. c. Any administrative proceeding or claim against the Indemnified Parties arising from the City's determination that the remaining building permits in the Project are exempt from the MSHCP fees and TUMF payments, provided, however, that at the Developer's option, the Developer may choose to voluntarily pay the disputed fees and upon such payment, its obligation to defend, indemnify, and hold the Indemnified Parties harmless shall be satisfied in full. The City shall promptly notify the Developer of the assertion of any claim, lawsuit, or proceeding against the Indemnified Parties, and shall fully cooperate in the defense against the claim, action or proceeding. Any such action shall only be settled with consent of Developer. To the extent that any of the litigation or administrative proceedings referenced above also involve projects or fee disputes other than the Project and specific fee dispute outlined in the recitals herein, Developer's obligations under this section shall be limited to providing the defense and indemnification only with respect to the matters specific to the Project and fee disputes described in the recitals. 8. Entire Agreement This Agreement contains the entire agreement of the Parties, and supersedes any prior written or oral agreements between them concerning the subject matter of this Agreement. This Agreement may only be waived, modified or amended by the written agreement of all Parties to this Agreement. 9. Partial Invaliditv In the event that any term, covenant, condition or provision of this Agreement shall be held by a court of competent jurisdiction to be invalid or against public policy, the remaining provisions shall continue in full force and effect. 10. No Waiver The waiver by one Party of the performance of any covenant, condition or promise shall not invalidate this Agreement, nor shall it be considered as a waiver by such Parry of any other (or the enforcement for subsequent breaches or failures of the same) covenant, condition or promise. The delay in pursuing any remedy or in insisting upon full performance for any breach or failure of any covenant, condition or promise shall not prevent a Party from later pursuing remedies or insisting upon full performance for the same or similar breaches or failures. -7- Page 9 of 13 11. Headings The headings, subheadings and numbering of the different paragraphs of this Agreement are inserted for convenience and reference only and are not to be taken as part of this Agreement or to control or affect the meaning, construction or effect of the same. 12. Governing Law This Agreement shall be interpreted and enforced in accordance with the laws of the State of California. 13. Successors In Interest This Agreement shall inure to the benefit of, and shall be binding upon, the assigns, successors in interest, agents and related entities of each of the Parties hereto. 14. Necessary Acts Each Party to this Agreement agrees to perform any further acts and execute and deliver any further documents that may be reasonably necessary to carry out the provisions of this Agreement. 15. Advice of Counsel Each Party hereto, by its due execution of this Agreement, represents to every other Party that it has reviewed each term of this Agreement with its counsel in the above - referenced litigation, and that hereafter no Party shall deny the validity of this Agreement on the ground that the Party did not have advice of counsel generally or advice of its counsel in the aforementioned litigation. 16. Construction Each Party has cooperated in the drafting and preparation of this Agreement. In any construction to be made to this Agreement, or of any of its terms and provisions, the same shall not be construed against any Party. 17. Notices Any notice or demand which by any provision of this Agreement is required or permitted to be given or served shall be deemed so given or served if sent by United States mail, certified or registered mail, postage prepaid, with return receipt requested. Such notices or demands shall be effective upon the earlier of (a) three (3) business days after mailing, or (b) actual receipt as evidenced by the return receipt, and shall be addressed as follows: To: City of Lake Elsinore 130 South Main St. Lake Elsinore, CA 92530 With a Copy to: Barbara Leibold, Esq. Leibold McClendon & Mann, P.C. 23422 Mill Creek Dr Suite 105 Laguna Hills, CA 92653 To: K. Hovnanian Forecast Homes, dba K. Hovnanian at La Laguna 2525 Campus Drive Irvine, CA 92612 With a Copy To: M. Katherine Jenson, Esq. Rutan & Tucker, LLP -8- Page 10 of 13 611 Anton Boulevard, Suite 1400 Costa Mesa, CA 92626 18. Either Party may change its address for service of notices by giving written notice to the other Party of the new address. 19. No Third Parties Benefited This Agreement is made for the sole benefit and protection of the Developer (and its successors, if any) and Committee. No other person shall have any right of action or right to rely thereon, and the Parties hereto hereby agree that nothing contained in this Agreement shall be construed to vest in any other person or entity any interest in or claim upon the funds that may be advanced pursuant to this Agreement or any rights under this Agreement. 20. Execution This Agreement may be executed in counterparts. [Remainder of Page Intentionally Left Blank] -9- Page 11 of 13 IN WITNESS WHEREOF, the Parties have executed this Agreement as of the date first written above. Dated: March 2012 APPROVED AS TO FORM: BY: Name: Barbara Leibold Title: City Attorney Dated: March 2012 APPROVED AS TO FORM: By: Name: M. Katherine Jenson Title: Special Counsel CITY OF LAKE ELSINORE By: _ Name: Title: City Manager K. HOVNANIAN AT LA LAGUNA LLC By: _ Name: Title: -10- Page 12 of 13 Page 13 of 13