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20 - Short Term Rental ProgramItem No. 20 TO: Mayor, Mayor Pro Tem & City Council Grayson Path, City Manager FROM: Robert G. Vine, Deputy City Manager SUBJECT: Short Term Rental Program and Ordinance Discussion DATE: February 26, 2024 BACKGROUND: On June 15, 2022, a committee consisting of City Council Members and staff began meeting to discuss Short Term Rentals and the appropriateness of creating an ordinance for city-wide registration and regulations. The driving force behind this project consists of public safety and quality of life for surrounding neighbors. STATUS OF ISSUE: After numerous meetings and research into what other municipalities are doing to address the topic of Short Term Rental properties, staff has modeled a draft ordinance and registration program patterned after that of the City of Frisco, Texas. This particular ordinance focuses on life safety rather than restrictions and enforcement. Tonight's agenda is strictly presentation, introduction of the topic, and obtaining initial feedback from the City Council. Unless the City Council directs otherwise, in an effort to involve our local Short Term Rental owner/operators, staff would like to host a community workshop where this proposed ordinance and registration program is shared with the local Short Term Rental owner/operators, listen to their input and possibly incorporate that input into the final ordinance draft presented to the governing body for consideration. BUDGET: Approval of this ordinance would require Short Term Rental entities to pay appropriate Hotel Occupation Tax if they are not already doing so. OPTIONS: Guidance only 1. Instruct staff to meet with local Short Term Rental owner/operators before bringing back a proposal for an ordinance and registration program for approval. 2. Instruct staff to bring proposal for an ordinance and registration program for approval back without meeting with local Short Term Rental owner/operators 3. Instruct staff to abandon this project. RECOMMENDATION: 1. Instruct staff to meet with local Short Term Rental owner/operators before bringing back a proposal for an ordinance and registration program for approval. I City of Paris City Council Regular Meeting January 26, 2024 What is a Short Term Rental? ide single-family homes, garage apartments, duplexes, quadplexes, and multifamily units. cabins, tiny homes and other similar structures could also I for this purpose. tration Program and supporting ordinance would require it rent their home or other dwellings for less than 30 days, to >TR permit and adhere to the requirements of the program. Short Term Rentals in Paris to a presentation by Avenu Insights on October 12, 2023, F Paris had 43 Short Term Rentals available on that date. sights is the compliance and registration software utilized by t cities, including Frisco, to manage their Short Term Rental tion Program. XMITS. Short Term Rental Analytics 'IMP, vi,4,'��,w f) f, February 2024 Rate (1) ...... .... Catendor ........... WeeOyr v Percent'lles v Export"CsV Nov Dec „,Ion 2024 Purpose? ase is not to limit where Short Term Rentals may operate 'd to zoning, to limit the number operating within a food or limiting them to homes with a homestead i — (all unconstitutional). III 'viii s i im iiia ilii iiiw ct theili,nf but rather to ensure they are n sa�fe u a nilii e r and provide a means to a safe i°t o iiia,- thos e thern foriiia iiia iiia iii ng — much itels/motels. Purpose? tIii U h ic � s ilii i g&aieilfarewithin the )viding neighborhood sustainability and preserving property wing current and reliable information about the owners of n Rentals will allow the City to provide those owners with )rmation on the condition of their properties and y contact information, to ensure � tloiil (taxes,. j)it'otect the a l t Il'i &iid safetyguests of �° 111oiii1111111111111 and to, aid of :I �° rdinances &i,Id ?quiring the registration of Short -Term Rental properties, )unci) seeks to protect property values and to prevent Damage within the City limits. Guest Safety Information Checklist Term Rental shall provide to guests a brochure and post in a conspicuous location of the Short- ing minimum information: or designated agent's name and twet,'rt,I'ou t 4I) Iiuot,t c oal'ftaca d including, but not limited to, parking restrictions, trash collection schedules and squired off-street parking, other available parking and prohibition of parking on landscaped s and wI a!6se restrictions as specified under the Code of Ordinances. guests lrm ]-ie case of an enizu ei, :: posing threats to personal safety or damage to property, ergency and non -emergency telephone numbers for police, fire and emergency medical instructions for obtaining severe weather, natural or manmade disaster alerts and updates. uua r,0J ykig ea t,jafl n I.OLAes, including the dwelling's exits, primary evacuation routes and racuation routes near the front door of the dwelling. tal owner shall provide in the Short -Term Rental ' ° i� ,,I(Jrig srinoke detectors in accordance with es, and at least ()u ie w(()urk i, ­i tyl:)e �,�`� � �� �°�� � a:,�l���l�a .sur°. The premises shall otherwise ��a��.��u�iu�anll��:, Illy wit1I� bt :u �� ���9� aur �u,&! rA O a :°.ol l u iaa"iuc� i i° iclll uu,i d u rt g rI :t Il fia °dIe (I t a fl Illbu i l d h,'i g a a l fi pie codes. ctives of a Registration Program and Supporting Ordinance —build and maintain a database of all Short Term Rental operating inside of the City Limits. 1�— promote life safety issues for these properties and those ere. t ilii°°is and the negative impact on the ng residences viol�l��Jns and negative impact on the surrounding ouiiiit set up — establishing accountability for these > that are providing lodging alternatives to hotels/motels. Enforcement Capabilities I of regulatory environment do we want to impose on our :y? ible rpmt ilii a l. aiid iu s' st � nt is not to infrtige, lb u� t o of regulations do we have the ability to enforce with our sources? ii��' Viii i Biu iiia 1117�i reqt,flre s,taff'to rnaintairi Registration records III:)roperty,, per''for anlWal life saf6tylhiis Ilf ec ns an�Ilm l atedits., These can be dorieMUh the ca ni e staffing. ccu pa ncy Tax Days Rented Average Rate # of Units Hotel Occupancy Tax 7% Annual Total 1 $ 125.00 43 $ 376.25 $ 4,515.00 2 $ 125.00 43 $ 752.50 $ 9,030.00 3 $ 125.00 43 $ 1,128.75 $ 13,545.00 4 $ 125.00 43 $ 1,505.00 $ 18,060.00 5 $ 125.00 43 $ 1,881.25 $ 22,575.00 5 $ 125.00 43 $ 2,257.50 $ 27,090.00 7 $ 125.00 43 $ 2,633.75 $ 31,605.00 3 $ 125.00 43 $ 3,010.00 $ 36,120.00 3 $ 125.00 43 $ 3,386.25 $ 40,635.00 .0 $ 125.00 43 $ 3,762.50 $ 45,150.00 Vo of this would go to the Chamber of Commerce with the remaining 5% being added to the City's portion of the Hotel Occupancy Tax Fund Where We Are in the Process iittee has agreed our Ordinance and Registration Program sely mirror that of Frisco, Texas. the ordinance has been completed along with the )n packet. d like to meet with those property owners currently Short Term Rental properties to share this information and iput before reporting back to the City Council with a final ARTICLE VIII REQUIREMENTS FOR OWNERS OF RESIDENTIAL PROPERTIES USED AS SHORT-TERM RENTALS § 18-461 Definitions. 18-462 Short-term rental permit required. 18-463 Short-term rental permit application. 18-464 Right to inspect short-term rental premises. 18-465 General standards. Guest safety notification and minimum requirements. 18-467 Other restrictions on use of premises. 18-468 Authority of the director. 18-469 Revocation of permit; appeal; administrative process. 18-470 through § 18-471. (Reserved) § 18-460 Purpose. This article is adopted to promote the public health, safety and general welfare within the city by providing neighborhood sustainability and preserving property values. Having current and reliable information about the owners of short-term rentals will allow the city to provide those owners with timely information on the condition of their properties and emergency contact information, to ensure collection of hotel occupancy taxes, to protect the health and safety of guests of short-term rentals and to aid in enforcement of applicable ordinances and laws. By requiring the registration of short-term rental properties, the city council seeks to protect property values and to prevent property damage within the city limits. § 18-461 Definitions. As used in this article, the following terms, phrases, words and their derivation shall have the following meaning: City - The City of Paris, Texas, and all areas within its corporate limits. City council - The city council of the City of Paris, Texas. Director or designee - The department(s) or division(s) of the city designated by the city manager to administer and/or enforce the provisions of this article and any person or persons designated by such a department or division to represent the department or division for said purpose. Guest -A person contracting with a short-term rental for use of a residential dwelling or premises as a short-term rental and the person's invitees at the short-term rental. Hotel - A building or group of buildings used as a temporary dwelling place for individuals in exchange for financial consideration where customary hotel services such as linen, housekeeping service and telephone are provided. Hotel room units are accessed through doorways into an internal hallway, courtyard or lobby. Financial consideration for hotel room units is generally calculated on a nightly basis. Hotel occupancy tax - Hotel occupancy tax as provided for in Article 2.08, Division 3 of the city code of ordinances and chapter 351 of the Texas Tax Code, as they exist or may be amended and any successor ordinances or laws. Owner -Any person having a legal or equitable interest in real property or identified in the official records of the county as holding title to real property or otherwise having control of real property, including the guardian of the estate of such person and the executor of the estate of such person. The term "owner" does not include the holder of a nonpossessory security interest in real property. Person -One or more individuals, corporations, partnerships, associations, labor organizations, legal representatives, mutual companies, joint stock companies, trusts, unincorporated organizations, trustees, fiduciaries and any other organization or entity of whatever character. Premises - The property, a lot, plot or parcel of land, including any structures or portions of structures thereon. Short-term rental (STR) - A dwelling that is: Used or designed to be used as the home of a person, family or household, including a single-family dwelling, garage apartment, guest house or a unit in a multi -unit building, including an apartment, condominium, cooperative or timeshare; and Rented wholly or partly for a fee and for a period of less than thirty (30) consecutive days. The term "short-term rental" does not include a premises that is used for a nonresidential purpose, including an educational, health care, retail, restaurant, banquet space or event center purpose or another similar use; a bed -and -breakfast as defined in the city's zoning ordinance; or a hotel. Short-term rental listing service -A person that participates in the short-term rental business by facilitating booking services through which an owner may offer short-term rentals to potential guests. Short-term rental listing services usually, though not necessarily, provide booking services through an online platform that allows an owner to advertise the premises through a website provided by the short- term rental listing service and the short-term rental listing service conducts a transaction by which potential guests arrange their use and their payment, whether the potential guest pays rent directly to the owner or to the short-term rental listing service. Short-term rental permit -A permit issued by the city that identifies the subject property as a lawful short- term rental. § 1-462 Short-term rental permit required. No short-term rental shall operate within the city without a current, valid short-term rental permit. All individual units having cooking, sleeping and bathing facilities within common buildings, regardless of ownership, shall require a separate, individual permit for each unit intended to be used as a short-term rental. A person commits an offense under this article if that person owns or operates a short-term rental in the city without a valid permit. § 18-463 Short-term rental permit application. laLApplication for a short-term rental permit shall be made through the city's online permit portal. Each application for a short-term rental permit shall be accompanied by a nonrefundable application fee in the amount of three hundred dollars ($300.00) and shall include the following information: ULA list of all owners, operators and agents (if applicable) of the short-term rental, including names, addresses and current email addresses and telephone numbers of each such person; llThe name, address and 24-hour telephone number of a contact person who is the owner, operator or designated agent and who shall be responsible and authorized to respond to complaints concerning the short-term rental within one hour or less; j3LAn acknowledgement that any permit granted under this article does not supersede any property -specific restrictions against short-term rentals that may exist under law, agreement, lease, covenant or deed restriction; ULA depiction of the floor plan that identifies sleeping areas, proposed maximum number of guests, evacuation routes and location of all fire extinguishers and smoke detectors; MThe guest safety information required by section 18-466; ULA sworn statement that the owner has met and will continue to comply with all requirements of this article including, but not limited to, obtaining annual independent inspections of required fire extinguishers in compliance with the city's current fire code; and ULAII other information required by the director or designee ULApplications shall be considered complete when all documentation required under this article has been submitted and all permit fees have been paid. Incomplete applications will not be accepted. Unless revoked by the director earlier pursuant to this article, a short-term rental permit expires one (1) year after the date of issuance. A permit holder shall apply for renewal prior to the expiration of the permit on a form provided by the director or designee. The permit holder shall update the information contained in the original permit application required under this section or any subsequent renewals under this section, if any of the information has changed. The permit holder shall sign a statement affirming that there is either no change in the information contained on the original permit application and any subsequent renewal applications, or that any information that has been updated is accurate and complete. Complete applications for renewal received after the expiration of a current permit shall be treated as applications for a new permit. The amount of the nonrefundable fee for renewal of a short- term rental permit is three hundred dollars ($300.00). ULUpon receipt of a complete application for renewal of a short-term rental permit, the director or designee may deny the renewal of a short-term rental permit if it is determined that the permit was issued in error or on the basis of incorrect information supplied by the applicant or if: ULThe permit holder has pleaded no contest to or been convicted of a violation of any ordinance of the city, or any state or federal law, related to operation of a short-term rental on the premises or has permitted such a violation on the premises by any other person. Such violation may include, but is not limited to, parking, noise, littering, destruction of property, disorderly conduct or failure to pay hotel occupancy taxes; or uThere are grounds for suspension, revocation or other registration sanctions as provided for in this article. llA permit to operate a short-term rental is not transferable to another owner, operator or location. § 18-464 Right to inspect short-term rental premises. To ensure compliance with the requirements of this article, a short-term rental may be inspected in the following methods: part of the issuance of a new short-term rental permit and any renewals thereof, the city may conduct an inspection to verify compliance with this article. (2 Fire extinguishers. The owner is responsible for obtaining annual independent inspections of the fire extinguishers in compliance with the city's current fire code. (3_).minsx ectionswu; on report or 5gsj cion of a violation. The city may perform inspections when a violation . of this article or other law is reported or suspected. § 18-465 General standards. All short-term rentals permitted pursuant to this article are subject to the following standard requirements: (1) Parking. Parking shall comply with the zoning ordinance. No required parking shall be permitted within public right-of-way or access easements as defined by city code or state regulations regarding parking. Yards shall not be used to provide the necessary parking. j Updated information. The owner shall provide timely updates to the city of any changes to the name, address and 24-hour telephone number of the contact person who is the owner, operator or designated agent responsible and authorized to respond to complaints concerning the short-term rental within one hour or less. Should a law enforcement officer respond to the short-term rental and issue a citation for any violation of city ordinances or other law, such responsible person may be contacted by the officer or designee. The responsible person shall attempt to contact the occupants within one (1) hour of any contact from the city to address the occupants about the complaints. Should a second complaint be filed and citation issued to the occupants or guests, the owner and responsible party must take appropriate steps to assure future complaints do not occur. Failure to provide updated information to the city regarding the 24-hour contact person shall be a violation of this section. 3 ,Other standards. It is unlawful: jLTo advertise on a short-term rental listing service or offer a short-term rental without first obtaining a short-term rental permit in accordance with this article; jLTo operate a short-term rental in a manner that does not comply with all applicable city and state laws and codes; (1 To operate a short-term rental without paying the required hotel occupancy taxes; Ll?)_To operate a short-term rental with an active alarm system that has not been registered with the city police department; uTo operate a short-term rental with an active alarm system that is registered with the city police department but is not listed on the permit as a short-term rental; (F) To rent to a guest who is under the age of twenty-one (21); L(jLTo post or allow external signage on or off the premises of the short-term rental that indicates the property is a short-term rental; ft!LTo fail to include the city permit number for the short-term rental in all advertisements, including online, for the short-term rental within the description or body for public reference; aTo permit the use of a short-term rental to promote activities that are illegal or for the purpose of temporary or transition housing for registered sex offenders; operating a structured sober, recovery or other purpose living home or similar enterprise; selling illegal drugs; selling alcohol or another activity that requires a permit or license under the Texas Alcoholic Beverage Code; operating as a sexually oriented business, or for rental periods of less than 24 hours; and (J) To permit the use of tents, hammocks, recreational/camper vehicles or other vehicles and outdoor areas that are not residential dwellings as short-term rentals. § 18-466 Guest safety notification and minimum requirements. llEach owner of a short-term rental shall provide to guests a brochure and post in a conspicuous location of the short-term rental the following minimum information: The owner, operator or designated agent's name and twenty-four (24) hour contact telephone number; Pertinent neighborhood information including, but not limited to, parking restrictions, trash collection schedules and location of required off-street parking, other available parking and prohibition of parking on landscaped areas; Quiet hours and noise restrictions as specified under Chapter 8, Article 8.04, under this code; Information to assist guests in the case of an emergency posing threats to personal safety or damage to property, including emergency and nonemergency telephone numbers for police, fire and emergency medical services and instructions for obtaining severe weather, natural or manmade disaster alerts and updates; and Depiction of floor plan identifying evacuation routes, including the dwelling's exits, primary evacuation routes and secondary evacuation routes near the front door of the dwelling. Each short-term rental owner shall provide in the short-term rental working smoke detectors in accordance with adopted codes, and at least one working type A fire extinguisher. The premises shall otherwise comply with applicable code of ordinance requirements, including but not limited to all building and fire codes. § 18-467 Other restrictions on use of premises. This article does not create any right to operate a short-term rental in violation of any lease, license, deed restriction, covenant, easement or other legal encumbrance. Unless expressly authorized by the city, any premises which has received a city housing incentive is ineligible to receive a permit to operate a short- term rental during the period of time that the owner (or third party beneficiary, as the case may be) is eligible to receive a city housing incentive. § 18-468 Authority of the director. The director shall implement and enforce this article and may by written order establish such procedures, not inconsistent with this article or other city ordinances, rules, or regulations, or any county, state, or federal laws or regulations, as the director determines are necessary to discharge any duty under this article. § 18-469 Revocation of permit; appeal; administrative process. (a„) Revocation of;ermt., After providing an opportunity for a hearing, the director is entitled to revoke a permit required by this article for serious or repeated violations of any of the requirements of this article, for violations of other applicable law relating to public health, safety or welfare and/or for interference with law enforcement officers in the performance of their duties. Prior to revocation, the director or designee shall notify the permit holder, in writing, of the reason for which the permit is subject to revocation and that the permit shall be revoked at the end of the tenth (10th) calendar day following service of such notice unless a written request for a hearing is submitted to the director by the permit holder within such ten (10) calendar day period referred to in the notice. If a written request for a hearing is received by the director within the required time period, (1) the revocation shall not take effect unless and until the director determines to do so in his ruling at the conclusion of the hearing; and (2) the director shall hold a hearing and either enact or reject the revocation. At least two (2) business days before the hearing occurs, the director or designee shall provide the permit holder with notice of the time and place of the hearing. The permit holder shall be permitted to attend and be heard at the hearing. If no request for a hearing is filed within the ten (10) calendar day period referred to in the notice, the revocation of the permit becomes final. (b)Appeals.-An administrative decision issued in connection with the requirements of this article, including denial of issuance or renewal or revocation or suspension of a permit required by this article, is final unless the permit holder submits a written request for an appeal to the city manager. The appeal shall be filed in writing within ten (10) calendar days of the date of notice of the administrative decision. At least two (2) business days before the appeal hearing occurs, the city shall provide the permit holder with notice of the time and place of the hearing. The permit holder shall be permitted to attend and be heard at the hearing. The city manager or designee shall hear and rule on the appeal within thirty (30) calendar days after notice of the appeal. The city manager or designee shall have the power to reverse a decision of the director or designee where he finds that the basis for such decision was not meritorious and that such a reversal will not adversely affect the public health, safety or welfare. The decision of the city manager or designee is final. The city manager's or designee's failure to take action on any such appeal shall constitute approval of the decision by the director or designee. (c) Administrative process. A notice required by this section is properly served when it is delivered to the permit holder via hand -delivery, or when it is sent by registered or certified mail, return receipt requested, or when it is sent via federal express or any courier service that provides a return receipt showing the date of actual delivery to the last known address of the permit holder. The hearings provided for in this section shall be conducted by the applicable regulatory authority at a time and place designated by it. The applicable regulatory authority shall make final findings, and shall sustain, modify or rescind any notice or order considered in the hearing. A written report of the hearing decision shall be furnished to the permit holder by the applicable regulatory authority. Guest Safety Information Checklist Each owner of a Short -Term Rental shall provide to guests a brochure and post in a conspicuous location of the Short -Term Rental the following minimum information: • The owner, operator, or designated agent's name and twenty-four (24) hour contact telephone number. • Pertinent neighborhood information including, but not limited to, parking restrictions, trash collection schedules and location of required off-street parking, other available parking and prohibition of parking on landscaped areas. • Reference quiet hours and noise restrictions as specified under Chapter 8, Article 8.04 Code of Ordinances. • Information to assist guests in the case of an emergency posing threats to personal safety or damage to property, including emergency and non -emergency telephone numbers for police, fire and emergency medical services and instructions for obtaining severe weather, natural or manmade disaster alerts and updates. • Depiction of floor plan identifying evacuation routes, including the dwelling's exits, primary evacuation routes and secondary evacuation routes near the front door of the dwelling. • Each Short -Term Rental owner shall provide in the Short -Term Rental working smoke detectors in accordance with adopted codes, and at least one working type A fire extinguisher. The premises shall otherwise comply with applicable Code of Ordinance requirements, including but not limited to all building and fire codes EXAMPLE OF REQUIRED INFORMATION Host 24-hour Contact Information: Name and Phone Number • Parking: Parking is not permitted on grass or any landscaped areas. Street parking is allowed in residential neighborhoods except where prohibited for up to 72 consecutive hours (add where your parking is allowed, driveway, street parking). • Trash Collection: Curbside trash and recycling pick-up is each (add day of pickup) Roll out bins to the curb for collection by 7:00 a.m. o Bins should be spaced at least three feet apart and away from other obstacles o All trash must be inside the bin with the lid fully closed o Secure all trash items in plastic bags o Items outside cart will not be collected, an overloading bin will result in non -collection • Quiet Hours: Quiet hours are observed daily from 10:00 p.m. to 7:00 am o City of Paris Chapter 8, Article 8.04 of the Code of Ordinances prohibits noise disturbances (any unreasonably loud or disturbing noise in the city, which is offensive to a reasonable, prudent adult). o Following list includes, but is not limited to, activities that can create unreasonable loud or disturbing noises in violation of City Ordinances • Emergency Services: o Fire / Medical / Police Emergencies: Dial 9-1-1 o Hospital; Paris Regional Health: 903-737-11110 Paris Fire Station non -emergency line: 903-784-9225 o Police non -emergency line: 903-784-6688 o Paris Public Works: 903-784-9289 o Paris Animal Shelter: 903-737-4199 • Severe Weather: Turn on the TV or radio for updates on severe weather. Local TV and radio stations will broadcast information updates as they become available. You may also sign up for the RAVE Alert System to be notified of any emergencies at: https://www.smart9ll.com/smart9ll/ref/reg.action?pa=paristexas Street Address Unit Number City Number of Bedrooms: Maximum Number of Guests Advised: Is There an Active/Registered Alarm System? (circle one) YES NO Does this property receive a City of Paris housing incentive? (circle one) YES NO If the property is advertised on any platform or website, indicate all below: (circle all that apply) Airbnb VRBO TripAdvisor Occupancy of Dwelling: (circle one) Evolve FlipKey HomeAway Vacasa Other: Owner occupied unit Non -owner occupied—Business owned Non -owner occupied—Individual owned Zip Code Type of Dwelling: ❑ Single-family ❑ Multi -family []Garage Apartment ❑Guest House ❑Duplex ❑ TownHome Homeowner's Association (HOA): YES NO Please provide all required details of the owner of the property First/Business Name: Last Name: Phone Number: Email: Address: City State Zip Code Please provide details for the 24-hour contact for the owner, operator or designated agent capable of one hour response time. Business Name: Individual Name: Email: Primary Phone Number: Secondary Phone Number: REQUIRED TO BE SUBMITTED WITH APPLICATION: ❑ A depiction of the floor plan that identifies the sleeping area, the proposed maximum number of guests, evacuation routes, and location of all fire extinguishers and smoke detectors. ❑ Guest Safety Information Pamphlet Applicant Signature Date Entrance Fire Extinguisher Smoke Alarm Escape Routes Hotel/STR Name: Owner Name: Location Address: Mailing Address (if different): Federal ID Number: For the period ending: Due date for report: Gross Receipts: (A) Tax Rate: (B) 0.07 Tax Due: A*B (C) Specific instructions Line (A) Enter the total amount of room receipts for the month for location shown. Enter "0" if no taxable receipts were collected. Line (B) The Hotel Occupancy Tax rate is 7%. Line (C) Multiply Line A by 7%. I declare, under the penalties for filing false reports, that this return (including any accompanying schedules and statements) has been examined by me and to the best of my knowledge and belief is a true, correct, and complete report. If the return is prepared by other than the taxpayer, his/her declaration is based on all the information relating to the matters required to be reported in this report of which he/she has knowledge. Type or print name and title Telephone number Signature Date Make check payable to City of Paris Mail report and check to City of Paris, P.O. Box 9037, Paris, Texas 75461 =or office use only: -onvention: Penalty: rourism/Promotion: Interest: