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Enforcement of Development Regulations

Categories
Administration & Enforcement, Land Subdivision, Land Use & Code Enforcement, Zoning

Published: 02/11/22

Author:

They can’t park all of those cars in the front yard! That subdivision street is not being built to standard! That newly permitted storage facility has not installed the required fencing to ensure community safety!  What’s the town to do?

This blog outlines the authority for local governments to enforce development regulations such as land use zoning, land subdivision, and related development regulations.

As discussed more fully below, a local government’s enforcement options include notices of violation and stop work orders, civil penalties, revoking and withholding permits, and legal action in court. In general, development regulations adopted under Chapter 160D may not be enforced criminally, but criminal enforcement is still available for development regulations related to unsafe buildings and certain regulations that are separately authorized in other sections of the General Statutes.

Overview

Chapter 160D of the North Carolina General Statutes authorizes counties and municipalities to adopt and enforce local development regulations. Article 4 of Chapter 160D provides the details on “Administration, Enforcement, and Appeals.” North Carolina local governments are authorized to “appoint administrators, inspectors, enforcement officers, planners, technicians, and other staff to develop, administer, and enforce development regulations authorized by this Chapter.” Among many other duties, those staff are tasked with “conducting inspections; issuing or denying certificates of compliance or occupancy; enforcing development regulations, including issuing notices of violation, orders to correct violations, and recommending bringing judicial actions against actual or threatened violations” (G.S 160D-402).

G.S. 160D-403 and -404 specify some of the tools for enforcement: inspections, revocation of development approvals, withholding of certificates of occupancy, notices of violation, stop work orders, and “appropriate action or proceedings” to prevent work or activity in violation of development regulations. G.S. 160D-404 provides a cross-reference to the enforcement tools for general police power ordinances outlined at G.S. 160A-175 and 153A-123. That includes civil penalties, legal proceedings in court, and treating the violation as a misdemeanor (limitations on criminal enforcement discussed more below).

This blog discusses the general enforcement authority for development regulations authorized under Chapter 160D. For some topics—such as the state building code, minimum housing codes, and certain environmental requirements—the statutes set forth separate administrative and enforcement options and requirements. Additionally, local legislation may grant separate enforcement authority to specific local governments.

Inspections

Before there can be enforcement there must be inspection. Inspections may occur at multiple steps of the development process: during development and construction (to confirm permitting and sign-off on work in progress); at the conclusion of construction (to certify compliance and completion); and after and/or unrelated to construction (to investigate potentially unlawful activity or situations). For permitted work, G.S. 160D-403(e) authorizes local administrative staff to inspect work done pursuant to a development approval to ensure it is done in accordance with state law, local law, and the terms of the approval. Staff may enter the premises during reasonable hours and upon presenting credentials, but the inspector must have consent or an administrative search warrant to inspect areas that are not open to the public. For potential violations that relate to unpermitted work or unauthorized activities, the general authority for inspection outlined at G.S. 160D-402(b) apply.

For any and all inspections the Fourth Amendment protections of privacy apply. While the breadth and depth of Fourth Amendment protections are beyond the scope of this blog, it is worth noting the highlights. A zoning inspector—as a government official—may not infringe upon an individual’s reasonable expectation of privacy. The inspector may make a reasonable approach to the front door of the residence or the public space of the business. The inspector may seek permission for the inspection from an authorized individual. And, if the inspector does not have permission, the inspector may seek an administrative search warrant from the judiciary. Without permission or a warrant, the inspector may not go snooping around a backyard, force her way into a house, nor barge into the backrooms of a business.

Documentation and Communication

If the officer determines that a violation exists, documentation and communication are essential. Photographs, field notes, internal documents, and communications to the violator should be carefully collected and maintained. The evidence of the violation and the correspondence with the violator will be critical to a successful enforcement action.

Depending on the nature of the violation and the policies of the local government, the initial communication may be a courtesy letter or phone call to seek compliance or the communication may go straight to enforcement penalties. The options for enforcement are outlined below.

Stop Work Order

A stop work order may be issued for illegal or dangerous work or activity. While stop work orders are commonly used for state building code violations, stop work orders are not limited to such violations. Stop work orders are a general enforcement tool to stop illegal or dangerous development and activities on land. Under G.S. 160D-404(b), if any work or activity subject to a local development regulation or state regulation delegated for local enforcement is undertaken in substantial violation of state or local law or in a manner that endangers life or property, then staff may issue a stop work order for the part of the work or activity creating the violation or hazard. So, for example, if construction is begun at a site before building permits are obtained, the local inspector may issue a stop work order. Similarly, if a business owner undertakes an activity that is not allowed in that zoning district, the local inspector may issue a stop work order. Upon issuance of a stop work order, no further work or activity can take place in violation of the order.

A stop work order must be in writing and directed to the person doing the work or activity. The order must state the work or activity to be stopped, the reasons for the order, and the conditions under which the work or activity may be resumed. The stop work order must be delivered by hand delivery, electronic mail, or first-class mail to the holder of the development approval and the property owner, if different. The administrator providing the stop work order must certify for the file the timing and content of the stop work order. This certification is deemed conclusive in the absence of fraud.

As outlined at G.S. 160D-404(b), a violation of a stop work order constitutes a Class 1 misdemeanor, but that has limited applicability. Because of the broader limitations on criminal enforcement (discussed below), a violation of a stop work order would only be enforced criminally for ordinances related to unsafe buildings.

Generally, appeals of stop work orders go to the board of adjustment, but appeals of stop work orders under the building code or housing code follow the appeal provisions for those articles.

Notice of Violation

Under G.S. 160D-404(a), a notice of violation (NOV) may be issued when it is determined that work or activity is in violation of a local development regulation or development approval, or in violation of a state law delegated to the local government for enforcement (such as building code enforcement or certain environmental permits).

The NOV must be delivered to the holder of the development approval and the landowner, if different. The NOV may also be delivered to the occupant or person undertaking the work or activity. Notice must be delivered by personal delivery, electronic delivery, or first-class mail. The NOV may also be posted on the property. The administrator providing the NOV must certify for the file the timing and content of the NOV, and such certification must be deemed conclusive in the absence of fraud. Aside from building permits and housing code violations, which have their own appeal processes, NOVs are appealed to the board of adjustment under G.S. 160D-405.

Civil Penalties

A civil penalty is a monetary penalty for a violation of a local ordinance. The underlying purpose of civil penalties is to secure compliance, cover administrative costs for enforcement, and seek equity with those who are complying with applicable rules. Civil penalties are not intended for revenue generation. Civil penalties commonly are used in conjunction with a notice of violation when a violator has not complied. The local ordinance may establish that each day’s continuing violation is a separate and distinct offense (G.S. 160A-175(g); 153A-123(g)), so civil penalties may accrue over time, with another charge each day of noncompliance.

While the statutes do not set a maximum or minimum amount for civil penalties, a civil penalty likely should not exceed the maximum for criminal penalties. With regard to misdemeanor violations of local ordinances, G.S. 14-4 sets a presumption that fines are $50 or less, but allows fines up to $500 if expressly stated in the ordinance. Using the limits on criminal fines as a gauge, civil penalties should not exceed $500 per day.

Given the accruing nature, amounts owed for civil penalties may be substantial. Importantly, the maximum amount of the penalty may not exceed the amount reasonably related to the harm of the violation and the cost to the local government to secure compliance. Courts may cap the amount to be recovered accordingly.

While civil penalties may be assessed from the time the violation began, the local government should give notice to the violator that civil penalties are accruing. Generally civil penalties begin with the notice of violation or after allowing a specified time for compliance. The assessment of a civil penalty may be appealed to the board of adjustment. If a violator fails to appeal the determination of a violation or imposition of a civil penalty within 30 days of notice, then the violator waives those claims (except in appeals challenging the constitutionality of the ordinance).

A civil penalty is treated as a debt owed to the local government. While the civil penalty is not an automatic lien against the property, the local government may bring a civil action in court to recover the penalty as a debt (160A-175(c); 153A-123(c)).

Withhold Permits

At the conclusion of work under a development approval, a local government may make final inspections to ensure the work complies with applicable laws and the terms of the approval before issuing a certificate of compliance or occupancy (G.S. 160D-403(g)). For projects requiring a building permit, a certificate of compliance is required prior to occupying the structure. For other development approvals, local governments have the option to require a certificate of compliance at the conclusion of the work. If the work fails to comply with applicable state laws, local ordinances, and permit requirements, the final certificate of compliance or occupancy may be withheld.

Notably, a local government may not withhold permits on one property or parcel to compel compliance on another property or parcel (G.S. 160D-1110).

Revoke Development Approvals

In addition to other general enforcement actions, a local government may revoke a development approval. As required at G.S. 160D-403, a local government shall revoke a development approval for

  • any substantial departure from the approved application, plans, or specifications;
  • refusal or failure to comply with the requirements of any applicable local development regulation or any state law delegated to the local government for enforcement purposes in lieu of the state; or
  • false statements or misrepresentations made in securing the approval.

A local government may revoke a mistakenly issued development approval. In using this discretion, the administrator must balance multiple factors:

  • Was it a clear error? A clear error is more defensible than revoking a permit issued based on a judgment call or close interpretation.
  • How long has the owner relied on the development approval? The longer the mistake, the less defensible to revoke the permit.
  • How much has the owner relied on the development approval? The more money and effort the owner has expended on the mistakenly issued permit, the less defensible a revocation will be.

For any revocation, it must follow the same notice, review, and decision process as for the granting of the development approval. For example, a staff person could not unilaterally revoke a special use permit. That would need to go back before the board that approved the special use permit.

The local government must provide written notice to the permit holder stating the reason for revocation. A revocation by a staff person may be appealed as an administrative decision under G.S. 160D-405, including applicable provisions on stays of enforcement.

Note that revocation is an option in addition to stop work orders and notices of violation. An enforcement official might issue a stop work order or NOV as an immediate administrative action and then go through a full revocation process if the owner fails to take corrective action.

Separate sections in the state statutes have specific provisions for the revocation of development agreements (G.S. 160D-1008) and building permits (G.S. 160D-1115).

Court Action

A local government may take a violator to court to secure compliance. Under G.S. 160D-404(c)(1), a local government “may institute any appropriate action or proceedings to prevent the unlawful erection, construction, reconstruction, alteration, repair, conversion, maintenance, use, or development; to restrain, correct or abate the violation; to prevent occupancy of the building, structure, or land; or to prevent any illegal act, conduct, business, or use in or about the premises.”

G.S. 160A-175 and G.S. 153A-123 also authorize a local government to bring a civil action against a violator to address violations of land development regulations. In such actions the court may issue remedial orders, such as “mandatory or prohibitory injunction and order of abatement commanding the defendant to correct the unlawful condition upon or cease the unlawful use of the property.” With regard to judicial orders of abatement, if the violator fails to comply, she may be cited for contempt of court, the local government may execute the court’s order of abatement, and the local government may have a lien on the property for the costs of abatement.

Note that civil action in court is subject to the applicable statutes of limitation.

Stays on Appeal

As outlined at G.S. 160D-405(f), if an enforcement decision is appealed to the board of adjustment or court, the enforcement action and any civil penalties or fines are stayed for the duration of the appeal. However, a stay does not apply if the public official certifies in an affidavit to the board that “a stay would cause imminent peril to life or property or, because the violation is transitory in nature, a stay would seriously interfere with enforcement of the development regulation.” If enforcement is not stayed, then the appellant may file for an expedited hearing.

Limited Criminal Enforcement

In 2021, the North Carolina General Assembly adopted broad criminal justice reform. Among other things the legislation dramatically curtailed criminal enforcement of local ordinances. Under the new statutory language adopted as part of S.L. 2021-138, a local government must amend local ordinances to specifically identify violations that may be enforced criminally. The law specifically calls out local development regulations: Among the ordinances that may not be enforced criminally are “[a]ny ordinance adopted under . . . Chapter 160D of the General Statutes, except for those ordinances related to unsafe buildings.” In other words, most zoning, subdivision, and general land use regulations may not be enforced with a criminal penalty.

There is allowance that ordinances related to unsafe buildings may still be enforced with criminal penalty. Additionally, some ordinances related to development are authorized outside of Chapter 160D. Arguably those regulations may still be enforced with criminal penalty. These issues are discussed in more detail in this blog on Limits on Criminal Enforcement of Development Regulations.

Conclusion

When it comes to enforcing development regulations, many enforcement tools are available: notices of violation, stop work orders, civil penalties, withholding development approvals, revoking development approvals, and legal action in court. Criminal enforcement is limited, but still available for ordinances relating to unsafe buildings.

Coates’ Canons NC Local Government Law

Enforcement of Development Regulations

Published: 02/11/22

Author:

They can’t park all of those cars in the front yard! That subdivision street is not being built to standard! That newly permitted storage facility has not installed the required fencing to ensure community safety!  What’s the town to do?

This blog outlines the authority for local governments to enforce development regulations such as land use zoning, land subdivision, and related development regulations.

As discussed more fully below, a local government’s enforcement options include notices of violation and stop work orders, civil penalties, revoking and withholding permits, and legal action in court. In general, development regulations adopted under Chapter 160D may not be enforced criminally, but criminal enforcement is still available for development regulations related to unsafe buildings and certain regulations that are separately authorized in other sections of the General Statutes.

Overview

Chapter 160D of the North Carolina General Statutes authorizes counties and municipalities to adopt and enforce local development regulations. Article 4 of Chapter 160D provides the details on “Administration, Enforcement, and Appeals.” North Carolina local governments are authorized to “appoint administrators, inspectors, enforcement officers, planners, technicians, and other staff to develop, administer, and enforce development regulations authorized by this Chapter.” Among many other duties, those staff are tasked with “conducting inspections; issuing or denying certificates of compliance or occupancy; enforcing development regulations, including issuing notices of violation, orders to correct violations, and recommending bringing judicial actions against actual or threatened violations” (G.S 160D-402).

G.S. 160D-403 and -404 specify some of the tools for enforcement: inspections, revocation of development approvals, withholding of certificates of occupancy, notices of violation, stop work orders, and “appropriate action or proceedings” to prevent work or activity in violation of development regulations. G.S. 160D-404 provides a cross-reference to the enforcement tools for general police power ordinances outlined at G.S. 160A-175 and 153A-123. That includes civil penalties, legal proceedings in court, and treating the violation as a misdemeanor (limitations on criminal enforcement discussed more below).

This blog discusses the general enforcement authority for development regulations authorized under Chapter 160D. For some topics—such as the state building code, minimum housing codes, and certain environmental requirements—the statutes set forth separate administrative and enforcement options and requirements. Additionally, local legislation may grant separate enforcement authority to specific local governments.

Inspections

Before there can be enforcement there must be inspection. Inspections may occur at multiple steps of the development process: during development and construction (to confirm permitting and sign-off on work in progress); at the conclusion of construction (to certify compliance and completion); and after and/or unrelated to construction (to investigate potentially unlawful activity or situations). For permitted work, G.S. 160D-403(e) authorizes local administrative staff to inspect work done pursuant to a development approval to ensure it is done in accordance with state law, local law, and the terms of the approval. Staff may enter the premises during reasonable hours and upon presenting credentials, but the inspector must have consent or an administrative search warrant to inspect areas that are not open to the public. For potential violations that relate to unpermitted work or unauthorized activities, the general authority for inspection outlined at G.S. 160D-402(b) apply.

For any and all inspections the Fourth Amendment protections of privacy apply. While the breadth and depth of Fourth Amendment protections are beyond the scope of this blog, it is worth noting the highlights. A zoning inspector—as a government official—may not infringe upon an individual’s reasonable expectation of privacy. The inspector may make a reasonable approach to the front door of the residence or the public space of the business. The inspector may seek permission for the inspection from an authorized individual. And, if the inspector does not have permission, the inspector may seek an administrative search warrant from the judiciary. Without permission or a warrant, the inspector may not go snooping around a backyard, force her way into a house, nor barge into the backrooms of a business.

Documentation and Communication

If the officer determines that a violation exists, documentation and communication are essential. Photographs, field notes, internal documents, and communications to the violator should be carefully collected and maintained. The evidence of the violation and the correspondence with the violator will be critical to a successful enforcement action.

Depending on the nature of the violation and the policies of the local government, the initial communication may be a courtesy letter or phone call to seek compliance or the communication may go straight to enforcement penalties. The options for enforcement are outlined below.

Stop Work Order

A stop work order may be issued for illegal or dangerous work or activity. While stop work orders are commonly used for state building code violations, stop work orders are not limited to such violations. Stop work orders are a general enforcement tool to stop illegal or dangerous development and activities on land. Under G.S. 160D-404(b), if any work or activity subject to a local development regulation or state regulation delegated for local enforcement is undertaken in substantial violation of state or local law or in a manner that endangers life or property, then staff may issue a stop work order for the part of the work or activity creating the violation or hazard. So, for example, if construction is begun at a site before building permits are obtained, the local inspector may issue a stop work order. Similarly, if a business owner undertakes an activity that is not allowed in that zoning district, the local inspector may issue a stop work order. Upon issuance of a stop work order, no further work or activity can take place in violation of the order.

A stop work order must be in writing and directed to the person doing the work or activity. The order must state the work or activity to be stopped, the reasons for the order, and the conditions under which the work or activity may be resumed. The stop work order must be delivered by hand delivery, electronic mail, or first-class mail to the holder of the development approval and the property owner, if different. The administrator providing the stop work order must certify for the file the timing and content of the stop work order. This certification is deemed conclusive in the absence of fraud.

As outlined at G.S. 160D-404(b), a violation of a stop work order constitutes a Class 1 misdemeanor, but that has limited applicability. Because of the broader limitations on criminal enforcement (discussed below), a violation of a stop work order would only be enforced criminally for ordinances related to unsafe buildings.

Generally, appeals of stop work orders go to the board of adjustment, but appeals of stop work orders under the building code or housing code follow the appeal provisions for those articles.

Notice of Violation

Under G.S. 160D-404(a), a notice of violation (NOV) may be issued when it is determined that work or activity is in violation of a local development regulation or development approval, or in violation of a state law delegated to the local government for enforcement (such as building code enforcement or certain environmental permits).

The NOV must be delivered to the holder of the development approval and the landowner, if different. The NOV may also be delivered to the occupant or person undertaking the work or activity. Notice must be delivered by personal delivery, electronic delivery, or first-class mail. The NOV may also be posted on the property. The administrator providing the NOV must certify for the file the timing and content of the NOV, and such certification must be deemed conclusive in the absence of fraud. Aside from building permits and housing code violations, which have their own appeal processes, NOVs are appealed to the board of adjustment under G.S. 160D-405.

Civil Penalties

A civil penalty is a monetary penalty for a violation of a local ordinance. The underlying purpose of civil penalties is to secure compliance, cover administrative costs for enforcement, and seek equity with those who are complying with applicable rules. Civil penalties are not intended for revenue generation. Civil penalties commonly are used in conjunction with a notice of violation when a violator has not complied. The local ordinance may establish that each day’s continuing violation is a separate and distinct offense (G.S. 160A-175(g); 153A-123(g)), so civil penalties may accrue over time, with another charge each day of noncompliance.

While the statutes do not set a maximum or minimum amount for civil penalties, a civil penalty likely should not exceed the maximum for criminal penalties. With regard to misdemeanor violations of local ordinances, G.S. 14-4 sets a presumption that fines are $50 or less, but allows fines up to $500 if expressly stated in the ordinance. Using the limits on criminal fines as a gauge, civil penalties should not exceed $500 per day.

Given the accruing nature, amounts owed for civil penalties may be substantial. Importantly, the maximum amount of the penalty may not exceed the amount reasonably related to the harm of the violation and the cost to the local government to secure compliance. Courts may cap the amount to be recovered accordingly.

While civil penalties may be assessed from the time the violation began, the local government should give notice to the violator that civil penalties are accruing. Generally civil penalties begin with the notice of violation or after allowing a specified time for compliance. The assessment of a civil penalty may be appealed to the board of adjustment. If a violator fails to appeal the determination of a violation or imposition of a civil penalty within 30 days of notice, then the violator waives those claims (except in appeals challenging the constitutionality of the ordinance).

A civil penalty is treated as a debt owed to the local government. While the civil penalty is not an automatic lien against the property, the local government may bring a civil action in court to recover the penalty as a debt (160A-175(c); 153A-123(c)).

Withhold Permits

At the conclusion of work under a development approval, a local government may make final inspections to ensure the work complies with applicable laws and the terms of the approval before issuing a certificate of compliance or occupancy (G.S. 160D-403(g)). For projects requiring a building permit, a certificate of compliance is required prior to occupying the structure. For other development approvals, local governments have the option to require a certificate of compliance at the conclusion of the work. If the work fails to comply with applicable state laws, local ordinances, and permit requirements, the final certificate of compliance or occupancy may be withheld.

Notably, a local government may not withhold permits on one property or parcel to compel compliance on another property or parcel (G.S. 160D-1110).

Revoke Development Approvals

In addition to other general enforcement actions, a local government may revoke a development approval. As required at G.S. 160D-403, a local government shall revoke a development approval for

  • any substantial departure from the approved application, plans, or specifications;
  • refusal or failure to comply with the requirements of any applicable local development regulation or any state law delegated to the local government for enforcement purposes in lieu of the state; or
  • false statements or misrepresentations made in securing the approval.

A local government may revoke a mistakenly issued development approval. In using this discretion, the administrator must balance multiple factors:

  • Was it a clear error? A clear error is more defensible than revoking a permit issued based on a judgment call or close interpretation.
  • How long has the owner relied on the development approval? The longer the mistake, the less defensible to revoke the permit.
  • How much has the owner relied on the development approval? The more money and effort the owner has expended on the mistakenly issued permit, the less defensible a revocation will be.

For any revocation, it must follow the same notice, review, and decision process as for the granting of the development approval. For example, a staff person could not unilaterally revoke a special use permit. That would need to go back before the board that approved the special use permit.

The local government must provide written notice to the permit holder stating the reason for revocation. A revocation by a staff person may be appealed as an administrative decision under G.S. 160D-405, including applicable provisions on stays of enforcement.

Note that revocation is an option in addition to stop work orders and notices of violation. An enforcement official might issue a stop work order or NOV as an immediate administrative action and then go through a full revocation process if the owner fails to take corrective action.

Separate sections in the state statutes have specific provisions for the revocation of development agreements (G.S. 160D-1008) and building permits (G.S. 160D-1115).

Court Action

A local government may take a violator to court to secure compliance. Under G.S. 160D-404(c)(1), a local government “may institute any appropriate action or proceedings to prevent the unlawful erection, construction, reconstruction, alteration, repair, conversion, maintenance, use, or development; to restrain, correct or abate the violation; to prevent occupancy of the building, structure, or land; or to prevent any illegal act, conduct, business, or use in or about the premises.”

G.S. 160A-175 and G.S. 153A-123 also authorize a local government to bring a civil action against a violator to address violations of land development regulations. In such actions the court may issue remedial orders, such as “mandatory or prohibitory injunction and order of abatement commanding the defendant to correct the unlawful condition upon or cease the unlawful use of the property.” With regard to judicial orders of abatement, if the violator fails to comply, she may be cited for contempt of court, the local government may execute the court’s order of abatement, and the local government may have a lien on the property for the costs of abatement.

Note that civil action in court is subject to the applicable statutes of limitation.

Stays on Appeal

As outlined at G.S. 160D-405(f), if an enforcement decision is appealed to the board of adjustment or court, the enforcement action and any civil penalties or fines are stayed for the duration of the appeal. However, a stay does not apply if the public official certifies in an affidavit to the board that “a stay would cause imminent peril to life or property or, because the violation is transitory in nature, a stay would seriously interfere with enforcement of the development regulation.” If enforcement is not stayed, then the appellant may file for an expedited hearing.

Limited Criminal Enforcement

In 2021, the North Carolina General Assembly adopted broad criminal justice reform. Among other things the legislation dramatically curtailed criminal enforcement of local ordinances. Under the new statutory language adopted as part of S.L. 2021-138, a local government must amend local ordinances to specifically identify violations that may be enforced criminally. The law specifically calls out local development regulations: Among the ordinances that may not be enforced criminally are “[a]ny ordinance adopted under . . . Chapter 160D of the General Statutes, except for those ordinances related to unsafe buildings.” In other words, most zoning, subdivision, and general land use regulations may not be enforced with a criminal penalty.

There is allowance that ordinances related to unsafe buildings may still be enforced with criminal penalty. Additionally, some ordinances related to development are authorized outside of Chapter 160D. Arguably those regulations may still be enforced with criminal penalty. These issues are discussed in more detail in this blog on Limits on Criminal Enforcement of Development Regulations.

Conclusion

When it comes to enforcing development regulations, many enforcement tools are available: notices of violation, stop work orders, civil penalties, withholding development approvals, revoking development approvals, and legal action in court. Criminal enforcement is limited, but still available for ordinances relating to unsafe buildings.

This blog post is published and posted online by the School of Government for educational purposes. For more information, visit the School’s website at www.sog.unc.edu.

Coates Canons
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