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HomeMy WebLinkAbout20081387 Ver 1_401 Application_20080908N! T 0 North Carolina Wildlife Resources Commission 0 Division of Engineering Services • 1720 Mail Service Center • Raleigh, NC 27699-1720 Ms. Cindy Karoly NCDENR, Division of Water Quality, 401 Unit 2321 Crabtree Rd., Suite 250 Raleigh, NC 27604 September 8, 2008 Re: GP-30; Cheoah Point ADA Walkway, Santeelah Lake, Graham County, NC Dear Ms. Karoly: Please find enclosed seven copies of the completed Pre-Construction Notification application along with supporting drawings and documents for the proposed ADA compliant walkway and floating dock at our Cheoah Point Boating Access Area. . This application has also been submitted to US Army Corps of Engineers Asheville regulatory field office. A letter of concurrence from the North Carolina Wildlife Resources Commission mountain region permit coordinator has been attached following his review of this application. The Commission has made an electronic funds transfer in the amount of $240 to the N.C. Division of Water Quality to cover the water quality certification fee (see attached Electronic Payment Ref. No. 29928). This amount was determined based on proposed stream impacts being less than 150 linear feet. This project is a cooperative effort between NCWRC, the Forest Service, and APGI, in response to public requests for improved fishing and boating opportunities. The proposed site is on Santeelah Lake, and is currently in use as a public boating access point. The project will consist of the installation of an elevated wooden walkway from the parking lot down to a concrete abutment, which has attached a floating dock to aid in the launch and recovery of boats from the ramp area. The elevated walkway is to be supported by piles, with the side away from the ramp also stabilized by the addition of concrete footers. Walkway construction is to be with treated lumber, and the concrete abutment will be poured when the lake level is down enough to allow for construction to be in the dry, preventing live concrete from coming into contact with the water. Sediment fence will be installed and maintained between the excavation site and the water's edge during construction. Any disturbed earth will be stabilized by seeding and installation of coir erosion control matting. Impacts should be minimal in that very little excavation will need to be performed to place the piles and abutment. If you have any questions or comments regarding this project, please feel free to contact me at (919) 218-2064 or tom.covington@ncwildlife.org. Sincerely, 3 Tom Covington ! t Facilities Construction and Capital Projects Engineer u in ?>,_ ? j ?9 7!J(l? enclosure DEi"Ilt - • O'k E'; Q UAL' i', Sep 9, 2008 11:35:48 AM OCP AP DOCUMENT GENERAL INFORMATION DGI NEXT FUNCTION: ACTION: HISTORY: 09/09/2008 11:35:38 -------------------- -------------------- PAY ENTITY ------------------- ------------------- 17PT ------------------- ------------------- VENDOR/EMP NUMBER: --------------------- --------------------- 566000372 40 VEND/EMP SHORT NAME: DENR DOCUMENT NUMBER CHEOAH090808 DOCUMENT DATE : 09/08/2008 CONTROL NUMBER : 0296 CONTROL DATE : 09/08/2008 DOCUMENT TYPE : INVOICE APPLICATION AREA : JS DOCUMENT STATUS : PD-FULL DATE ENTERED : 09/08/2008 CURRENCY CODE DATE LAST UPDATED: 09/08/2008 GROSS DOC AMOUNT 240.00 PROV ACCTG DATE AMOUNT PAID 240.00 COUNTY CDE/TRIP NBR: PO REFERENCE SIGN APPROVAL CODE DATES APPROVED REMIT MESSAGE: DIV.WATER QLTY:WETLANDS & STORMWATER PERMIT:CHEOAH POINT BAA Sep 9, 2008 11:35:54 AM OCP AP DOCUMENT PAYMENT GENERAL INFORMATION DPG NEXT FUNCTION: ACTION: HISTORY: 09/09/2008 11:35:50 BROWSE: PAY ENTITY 17PT VEND/EMP NBR: 566000372 40 VEND/EMP SHORT NAME: DENR DOCUMENT NBR: CHEOAH090808 DOCUMENT DATE : 09/08/2008 PAYMENT NBR: 001 PRTL PYMT NBR: 000 IND AMOUNT SALES TAX/VAT SALES TAX 2 SALES TAX 3 FREIGHT ADDITIONAL COST VAT INCLUSIVE N EXPENSE IND GL EFFECTIVE DATE: 09/08/2008 EXTRACT DATE ACCRUAL CANC DATE: GROSS INVOICE 240.00 PAYMENT AMOUNT 240.00 AMOUNT PAID 240.00 PAYMENT TERMS : NET PAY IMMEDIATELY PAYMENT DATE : 09/08/2008 PAYMENT ROUTE CD : FACTOR NUMBER REASON CODE/DESC CURRENCY CODE DISCOUNT TYPE NOT TAKEN DISCOUNT TAKEN PAYMENT STATUS PAID PAYMENT REF NBR 0000033174 PAYMENT TYPE ELECTRONIC HANDLING CODE ONE INVC PER PYMT: YES BANK ACCT PYMT CD: IGO .00 Office Use Only: Form Version March 05 USACE Action ID No. DWQ No. (If any particular item is not applicable to this project, please enter "Not Applicable" or "N/A".) 1. Processing 1. Check all of the approval(s) requested for this project: ? Section 404 Permit ? Riparian or Watershed Buffer Rules ? Section 10 Permit ? Isolated Wetland Permit from DWQ ® 401 Water Quality Certification ? Express 401 Water Quality Certification 2. Nationwide, Regional or General Permit Number(s) Requested: General Permit 30 3. If this notification is solely a courtesy copy because written approval for the 401 Certification is not required, check here: ? 4. If payment into the North Carolina Ecosystem Enhancement Program (NCEEP) is proposed for mitigation of impacts, attach the acceptance letter from NCEEP, complete section VIII, and check here: ? 5. If your project is located in any of North Carolina's twenty coastal counties (listed on page 4), and the project is within a North Carolina Division of Coastal Management Area of Environmental Concern (see the top of page 2 for further details), check here: ? il, F_ II. Applicant Information; ?.... l.rf 1. Owner/Applicant Information Name: US Forestry Service :fig ?;1v Mailing Address: Attn: Scott Haas WE M! ° AND 4; , " ,, rE r3RAIN' I 1070 Massey Branch Road Robbinsville NC 28771 Telephone Number: 828-479-6431 Fax Number: 828-479-6784 E-mail Address: sehaasgfs.fed.us 2. Agent/Consultant Information (A signed and dated copy of the Agent Authorization letter must be attached if the Agent has signatory authority for the owner/applicant.) Name: Tom Covington Company Affiliation: North Carolina Wildlife Resources Commission Mailing Address: 136 Aztec Circle Mooresville NC 28117 Telephone Number: 919-218-2064 Fax Number: 919-707-0162 Updated 11/1/2005 Page 5 of 13 E-mail Address: tom.covingtonga ncwildlife.org III. Project Information Attach a vicinity map clearly showing the location of the property with respect to local landmarks such as towns, rivers, and roads. Also provide a detailed site plan showing property boundaries and development plans in relation to surrounding properties. Both the vicinity map and site plan must include a scale and north arrow. The specific footprints of all buildings, impervious surfaces, or other facilities must be included. If possible, the maps and plans should include the appropriate USGS Topographic Quad Map and NRCS Soil Survey with the property boundaries outlined. Plan drawings, or other maps may be included at the applicant's discretion, so long as the property is clearly defined. For administrative and distribution purposes, the USACE requires information to be submitted on sheets no larger than 11 by 17-inch format; however, DWQ may accept paperwork of any size. DWQ prefers full-size construction drawings rather than a sequential sheet version of the full-size plans. If full-size plans are reduced to a small scale such that the final version is illegible, the applicant will be informed that the project has been placed on hold until decipherable maps are provided. 1. Name of project: Cheoah Point ADA Access Walkway 2. T.I.P. Project Number or State Project Number (NCDOT Only): 3. Property Identification Number (Tax PIN): 4. Location County: Graham Nearest Town: Robbinsville Subdivision name (include phase/lot number): NA Directions to site (include road numbers/names, landmarks, etc.): From the intersection of Hwy 129 and hwy 143 in Robbinsville, Go North on Hwy 129 for approximately 7.5 miles, and go left onto SRI 146. Take the first left onto SR 1147, and site will be approximately 0.2miles on the left. 5. Site coordinates (For linear projects, such as a road or utility line, attach a sheet that separately lists the coordinates for each crossing of a distinct waterbody.) Decimal Degrees (6 digits minimum): 35.3740 ON 83.8694 °W 6. Property size (acres): 0.55 Acres 7. Name of nearest receiving body of water: Santeelah Lake 8. River Basin: Little Tennessee (Note - this must be one of North Carolina's seventeen designated major river basins. The River Basin map is available at http://h2o.enr.state.nc.us/admin/mgps/.) 9. Describe the existing conditions on the site and general land use in the vicinity of the project at the time of this application: Existing conditions are an asphalt parking lot, concrete boat Updated 11/1/2005 Page 6of13 launch ramp and an unimproved, very narrow, non ADA compliant trail down to an unusable floating dock. 10. Describe the overall project in detail, including the type of equipment to be used: Project will consist of installing an ADA compliant elevated wooden walkway down to a concrete abutment and floating dock. Equipment used will be a backhoe to dig footers, a trackhoe to lift the floating dock into the water, and a tractor with auger to dig the holes where no footers are to be installed. 11. Explain the purpose of the proposed work: To provide a floating dock to allow for easier launching and recovery of boats, and to provide ADA compliant access to the floating dock. IV. Prior Project History If jurisdictional determinations and/or permits have been requested and/or obtained for this project (including all prior phases of the same subdivision) in the past, please explain. Include the USACE Action ID Number, DWQ Project Number, application date, and date permits and certifications were issued or withdrawn. Provide photocopies of previously issued permits, certifications or other useful information. Describe previously approved wetland, stream and buffer impacts, along with associated mitigation (where applicable). If this is a NCDOT project, list and describe permits issued for prior segments of the same T.I.P. project, along with construction schedules. Unknown V. Future Project Plans Are any future permit requests anticipated for this project? If so, describe the anticipated work, and provide justification for the exclusion of this work from the current application. No VI. Proposed Impacts to Waters of the United States/Waters of the State It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to wetlands, open water, and stream channels associated with the project. Each impact must be listed separately in the tables below (e.g., culvert installation should be listed separately from riprap dissipater pads). Be sure to indicate if an impact is temporary. All proposed impacts, permanent and temporary, must be listed, and must be labeled and clearly identifiable on an accompanying site plan. All wetlands and waters, and all streams (intermittent and perennial) should be shown on a delineation map, whether or not impacts are proposed to these systems. Wetland and stream evaluation and delineation forms should be included as appropriate. Photographs may be included at the applicant's discretion. If this proposed impact is strictly for wetland or stream mitigation, list and describe the impact in Section VIII below. If additional space is needed for listing or description, please attach a separate sheet. Updated 11/1/2005 Page 7 of 13 1. Provide a written description of the proposed impacts: 9 piles and an 8'x8' concrete abutment are to be installed below normal full pool. 2. Individually list wetland impacts. Types of impacts include, but are not limited to mechanized clearing, grading, fill, excavation, flooding, ditching/drainage, etc. For dams, separately list impacts due to both structure and flooding. Wetland Impact Site Number (indicate on map) Type of Impact Type of Wetland (e.g., forested, marsh, herbaceous, bog, etc.) Located within 100-year Floodplain es/no) Distance to Nearest Stream (linear feet) Area of Impact (acres) Total Wetland Impact (acres) 3. List the total acreage (estimated) of all existing wetlands on the property: 4. Individually list all intermittent and perennial stream impacts. Be sure to identify temporary impacts. Stream impacts include, but are not limited to placement of fill or culverts, dam construction, flooding, relocation, stabilization activities (e.g., cement walls, rip-rap, crib walls, gabions, etc.), excavation, ditching/straightening, etc. If stream relocation is proposed, plans and profiles showing the linear footprint for both the original and relocated streams must be included. To calculate acreage, multiply length X width, then divide by 43,560. Stream Impact Number (indicate on ma) Stream Name Type of Impact Perennial or Intermittent? Average Stream Width Before Impact Impact Length (linear feet) Area of Impact (acres) Total Stream Impact (by length and acreage) 5. Individually list all open water impacts (including lakes, ponds, estuaries, sounds, Atlantic Ocean and any other water of the U.S.). Open water impacts include, but are not limited to fill, excavation, dredging, flooding, drainage, bulkheads, etc. Open Water Impact Name of Waterbody Type of Waterbody Area of Site Number (if applicable) Type of Impact (lake, pond, estuary, sound, bay, Impact (indicate on ma) ocean, etc.) (acres) 1 Lake Santeelah Abutment and piles lake 0.0017 Updated 11/1/2005 Page 8 of 13 Total Open Water Impact (acres) 0.0017 6. List the cumulative impact to all Waters of the U.S. resulting from the project Stream Impact (acres): Wetland Impact (acres): Open Water Impact (acres): 0.0017 Total Impact to Waters of the U.S. (acres) 0.0017 Total Stream Impact (linear feet): 7. Isolated Waters Do any isolated waters exist on the property? ? Yes ® No Describe all impacts to isolated waters, and include the type of water (wetland or stream) and the size of the proposed impact (acres or linear feet). Please note that this section only applies to waters that have specifically been determined to be isolated by the USACE. 8. Pond Creation If construction of a pond is proposed, associated wetland and stream impacts should be included above in the wetland and stream impact sections. Also, the proposed pond should be described here and illustrated on any maps included with this application. Pond to be created in (check all that apply): ? uplands ? stream ? wetlands Describe the method of construction (e.g., dam/embankment, excavation, installation of draw-down valve or spillway, etc.): Proposed use or purpose of pond (e.g., livestock watering, irrigation, aesthetic, trout pond, local stormwater requirement, etc.): Current land use in the vicinity of the pond:_ Size of watershed draining to pond: VII. Impact Justification (Avoidance and Minimization) Expected pond surface area: Specifically describe measures taken to avoid the proposed impacts. It may be useful to provide information related to site constraints such as topography, building ordinances, accessibility, and financial viability of the project. The applicant may attach drawings of alternative, lower-impact site layouts, and explain why these design options were not feasible. Also discuss how impacts were minimized once the desired site plan was developed. If applicable, discuss construction techniques to be followed during construction to reduce impacts. Rather than create the entire walkway with fill, an elevated wooden walkway will be installed. In addition, the size of the concrete abutment is minimized, to keep the disturbed footprint as small as possible. Construction will take place during a period of lake drawdown, so that live concrete will never come into contact with the water, and will allow for better cleanup and ground stabilization after the work is complete. VIII. Mitigation Updated 11/1/2005 Page 9 of 13 DWQ - In accordance with 15A NCAC 2H .0500, mitigation may be required by the NC Division of Water Quality for projects involving greater than or equal to one acre of impacts to freshwater wetlands or greater than or equal to 150 linear feet of total impacts to perennial streams. USACE - In accordance with the Final Notice of Issuance and Modification of Nationwide Permits, published in the Federal Register on January 15, 2002, mitigation will be required when necessary to ensure that adverse effects to the aquatic environment are minimal. Factors including size and type of proposed impact and function and relative value of the impacted aquatic resource will be considered in determining acceptability of appropriate and practicable mitigation as proposed. Examples of mitigation that may be appropriate and practicable include, but are not limited to: reducing the size of the project; establishing and maintaining wetland and/or upland vegetated buffers to protect open waters such as streams; and replacing losses of aquatic resource functions and values by creating, restoring, enhancing, or preserving similar functions and values, preferable in the same watershed. If mitigation is required for this project, a copy of the mitigation plan must be attached in order for USACE or DWQ to consider the application complete for processing. Any application lacking a required mitigation plan or NCEEP concurrence shall be placed on hold as incomplete. An applicant may also choose to review the current guidelines for stream restoration in DWQ's Draft Technical Guide for Stream Work in North Carolina (see DWQ website for most current version.). 1. Provide a brief description of the proposed mitigation plan. The description should provide as much information as possible, including, but not limited to: site location (attach directions and/or map, if offsite), affected stream and river basin, type and amount (acreage/linear feet) of mitigation proposed (restoration, enhancement, creation, or preservation), a plan view, preservation mechanism (e.g., deed restrictions, conservation easement, etc.), and a description of the current site conditions and proposed method of construction. Please attach a separate sheet if more space is needed. 2. Mitigation may also be made by payment into the North Carolina Ecosystem Enhancement Program (NCEEP). Please note it is the applicant's responsibility to contact the NCEEP at (919) 715-0476 to determine availability, and written approval from the NCEEP indicating that they are will to accept payment for the mitigation must be attached to this form. For additional information regarding the application process for the NCEEP, check the NCEEP website at http://www.nceep.net/pages/inlieureplace.htm. If use of the NCEEP is proposed, please check the appropriate box on page five and provide the following information: Amount of stream mitigation requested (linear feet): Amount of buffer mitigation requested (square feet): Amount of Riparian wetland mitigation requested (acres): Updated 11/1/2005 Page 10 of 13 Amount of Non-riparian wetland mitigation requested (acres): Amount of Coastal wetland mitigation requested (acres): IX. Environmental Documentation (required by DWQ) 1. Does the project involve an expenditure of public (federal/state/local) funds or the use of public (federal/state) land? Yes ® No ? 2. If yes, does the project require preparation of an environmental document pursuant to the requirements of the National or North Carolina Environmental Policy Act (NEPA/SEPA)? Note: If you are not sure whether a NEPA/SEPA document is required, call the SEPA coordinator at (919) 733-5083 to review current thresholds for environmental documentation. Yes ? No 3. If yes, has the document review been finalized by the State Clearinghouse? If so, please attach a copy of the NEPA or SEPA final approval letter. Yes ? No ? X. Proposed Impacts on Riparian and Watershed Buffers (required by DWQ) It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to required state and local buffers associated with the project. The applicant must also provide justification for these impacts in Section VII above. All proposed impacts must be listed herein, and must be clearly identifiable on the accompanying site plan. All buffers must be shown on a map, whether or not impacts are proposed to the buffers. Correspondence from the DWQ Regional Office may be included as appropriate. Photographs may also be included at the applicant's discretion. 1. Will the project impact protected riparian buffers identified within 15A NCAC 2B .0233 (Neuse), 15A NCAC 2B .0259 (Tar-Pamlico), 15A NCAC 02B .0243 (Catawba) 15A NCAC 2B .0250 (Randleman Rules and Water Supply Buffer Requirements), or other (please identify V Yes ? No 2. If "yes", identify the square feet and acreage of impact to each zone of the riparian buffers. If buffer mitigation is required calculate the required amount of mitigation by applying the buffer multipliers. * I Impact Required Zone f-.- Fo*N I Multiplier I I 1 I ( 3 (2 for Catawba) 2 1.5 Total * Zone 1 extends out 30 feet perpendicular from the top of the near bank of channel; Zone 2 extends an additional 20 feet from the edge of Zone 1. 3. If buffer mitigation is required, please discuss what type of mitigation is proposed (i.e., Donation of Property, Riparian Buffer Restoration / Enhancement, or Payment into the Updated 11/1/2005 Page 1 I of 13 Riparian Buffer Restoration Fund). Please attach all appropriate information as identified within 15A NCAC 2B .0242 or .0244, or .0260. XI. Stormwater (required by DWQ) Describe impervious acreage (existing and proposed) versus total acreage on the site. Discuss stormwater controls proposed in order to protect surface waters and wetlands downstream from the property. If percent impervious surface exceeds 20%, please provide calculations demonstrating total proposed impervious level. Property size is 0.55 acres above normal full pool. Current impervious surface is 0.41 acres. Impervious area above full pool will not increase, in that the walkway is elevated off ground level. No changes to the stormwater controls are posed, and the proposed walkway will not alter the current runoff situation at all. XII. Sewage Disposal (required by DWQ) Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of wastewater generated from the proposed project, or available capacity of the subject facility. XIII. Violations (required by DWQ) Is this site in violation of DWQ Wetland Rules (15A NCAC 2H.0500) or any Buffer Rules? Yes ? No ? Is this an after-the-fact permit application? Yes ? No ? XIV. Cumulative Impacts (required by DWQ) Will this project (based on past and reasonably anticipated future impacts) result in additional development, which could impact nearby downstream water quality? Yes ? No ? If yes, please submit a qualitative or quantitative cumulative impact analysis in accordance with the most recent North Carolina Division of Water Quality policy posted on our website at http://h2o.enr.state.nc.us/ncwetlands. If no, please provide a short narrative description: XV. Other Circumstances (Optional): It is the applicant's responsibility to submit the application sufficiently in advance of desired construction dates to allow processing time for these permits. However, an applicant may choose to list constraints associated with construction or sequencing that may impose limits on Updated I t/1/2005 Page 12 of 13 work schedules (e.g., draw-down schedules for lakes, dates associated with Endangered and Threatened Species, accessibility problems, or other issues outside of the applicant's control). 8 Sept 08 Applicant/Agent's Signature Date (Agent's signature is valid only if an authorization letter from the applicant is provided.) Updated 11/1/2005 Page 13 of 13 USDA United States Forest National Forests in North Carolina 1070 Massey Branch Rd Department of Service Nantahala National Forest Robbinsville, NC 28771-7899 Agriculture Cheoah Ranger District 828-479-6431 File Code: 2330 Date: September 8, 2008 Tom Covington Facilities Construction and Capital Projects Engineer North Carolina Wildlife Resources Commission 136 Aztec Circle Mooresville, NC 28117 Dear Mr. Covington, The Cheoah Ranger District has reviewed the engineering drawings for the Cheoah Point ADA Accessible Boat Dock and has completed all required National Environmental Policy Act (NEPA) documentation for this project. This letter provides permission for the NCWRC to apply for section 404 and/or section 10 permits from the USACE and any Water Quality permits required by the State of North Carolina for this project. If you have further questions, please contact Scott Haas at (828) 479-6431 x 4102 Sincerely, /s/ Scott E. Haas (for) FRANK FINDLEY Deputy District Ranger North Carolina Wildlife Resources Commission 9 September 4, 2008 Mrs. Debbie Miller U.S. Army Corps of Engineers, Regulatory Branch 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 Mr. Ian McMillan NCDENR, Division of Water Quality, 401 Unit 1628 Mail Service Center Raleigh, North Carolina 27699-1628 SUBJECT: 404 Permit Application for US Forest Service, Mr. Scott Haas Cheoah Point ADA Access Walkway - Santeetlah Lake Graham County Dear Mrs. Miller and Mr. McMillan: Mr. Scott Haas of the US Forest Service requested a 404 Permit from the U.S. Army Corps of Engineers and a 401 Water Quality Certification from the Division of Water Quality. The project involves filling about 0.00017 acre of Santeetlah Lake in order to construct an ADA compliant pier and dock at the Cheoah Point boat access area. The North Carolina Wildlife Resources Commission (Commission) has designed and will construct and maintain the facility. Comments from the Commission's biologists are provided under provisions of the Clean Water Act of 1977 (33 U.S.C. 466 et seq.) and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d). This project will not harm trout spawning and the Commission has no major concerns with the project provided effective sediment and erosion controls are used and shoreline vegetation removal minimized during construction. Thank you for the opportunity to review and comment on this project. Pending availability of field staff, the Commission may inspect the work site during or after construction. If there are any questions regarding these comments, please contact me at 828/452-0422 extension 24. Sincerely, Dave McHenry Mountain Region Coordinator, Habitat Conservation Program cc: Mr. Tom Covington, NC Wildlife Resources Commission Mailing Address: Division of Inland Fisheries - 1721 Mail Service Center - Raleigh, NC 27699-1721 Telephone: (919) 707-0220 - Fax: (919) 707-0028 0 J O C L Q (? v X W ' sset g`ei sae met t ? i 4l LL ?L 7 ?L 31 Yl L 07 C O N 0 N 0 N L 1 q) U u N N ca U O D m O CY) N d' 0) N E -0 a 4-- O 0- 0 O O a ED i4 i l 1 i a? 3 O Q) E E O O rn O c 0 a N W 6 O a E L- O Z -:? 00 0 ? 3 d. O W Q W Q N N L ' n u J C O V O U 0 a w O U z C7 W 0 w Z ? J Z c? O ? o cn o w aa_ w Q U T O nL D- y V O c6 O w Y c 3 c w N LU Q Q Q z 0 W- C U = U ~ a° 0 z z co Q d ° U = C7 Z 0 0 U) LU U 0 W w W LL J >J_ Q z J 0 Q 0 Z ?-Oo 73 Q? O S L L E O 73 O I?Y) L O O U ? .9 N U C N O O p a 0 U) 3 O a? a? O X nz;_- O V 0 0 O- i in a? 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