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HomeMy WebLinkAbout20010839 Ver 1_Complete File_20010605G ? 4 Michael F. Easley Governor William G. Ross, Jr., Secretary Department of Environment and Natural Resources Kerr T. Stevens Division of Water Quality June 12, 2001 DWQ# 01-0839 Johnston County James H. Trogdon, NCDOT P.E. Division Engineer Post Office Box 3165 Wilson, NC 27895-3165 APPROVAL of 401 Water Quality Certification Dear Mr. Trogdon: You have our approval, in accordance with the attached conditions, to construct a stream crossing on UT Little Creek in Johnston County, as you described in your application materials received by the Division of Water Quality on June 5, 2001. After reviewing your application, we have decided that this fill is covered by General Water Quality Certification Number 3114. This Certification allows you to use Regional Permit Number 33 when the Corps of Engineers issues it. In addition, you should get any other federal, state or local permits before you go ahead with your project including (but not limited to) Sediment and Erosion Control, Coastal Stormwater, Non-Discharge and Water Supply Watershed regulations. Also this approval will expire when the accompanying 404 permit expires unless otherwise specified in the General Certification. This approval is only valid for the purpose and design that you described in your application. If you change your project, you must notify us and you may be required to send us a new application for a new certification. If the property is sold, the new owner must be given a copy of the Certification and approval letter and is thereby responsible for complying with all conditions. If total wetland fills for this project (now or in the future) exceed one acre, compensatory mitigation may be required as described in 15A NCAC 2H .0506 (h). For this approval to be valid, you must follow the conditions listed in the attached certification. If you do not accept any of the conditions of this certification, you may ask for an adjudicatory hearing. You must act within 60 days of the date that you receive this letter. To ask for a hearing, send a written petition which conforms to Chapter 150B of the North Carolina General Statutes to the Office of Administrative Hearings, P.O. Box 27447, Raleigh, N.C. 27611-7447. This certification and its conditions are final and binding unless you ask for a hearing. This letter completes the review of the Division of Water Quality under Section 401 of the Clean Water Act. If you have any questions, please telephone John Dorney at 919-733-9646. Sincerely, cr-A Kerr T. Stevens Attachment cc: Corps of Engineers Raleigh Regulatory Field Office Raleigh DWQ Regional Office Central Files File Copy North Carolina Division of Water Quality, 401 Wetlands Certification Unit, 1650 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address) 2321 Crabtree Blvd., Raleigh, NC 27604-2260 (Location) r ,14, /i M?STATC 40.1 ISSUED 0 i Q0 «( STATE OF NORTH CAROLINA DEPARTMENT OF TRANSPORTATION MICHAEL F. EASLEY LYNDO TIPPETT GOVERNOR SECRETARY May 24, 2001 U.S. Army Corps of Engineers Raleigh Regulatory Field Office 6508 Falls of the Neuse Road, Suite 120 Raleigh, NC 27609 Attention: Mr. Eric Alsmeyer NCDOT Coordinator Subject: Secondary road improvements to SR 2368 (Oliver Pond Road)from SR 2320 (Rains Crossroads Road) to SR 2367 (Hinnant Road) in Johnston County. State Project No. 6.312096T. The North Carolina Department of Transportation (NCDOT) proposes to upgrade SR 2368 (Oliver Pond Road) from SR 2320 (Rains Crossroads Road) to SR 2367 (Hinnant Road) in Johnston County. SR 2368 is an unpaved roadway that will be upgraded to a paved roadway. Total project length is 0.455 miles. Transportation and highway laws of North Carolina (G.S. 136-44.6, 136-44.7, 136-44.7A, 136-44.8, and 136-44.9) require the NCDOT to develop annual work programs for construction and maintenance of secondary roads. 'These general statutes specifically set forth requirements for annual construction and paving of existing unpaved roads. Paving of these roads is performed in priority order as established by the NCDOT for each unpaved road within a given county. This number is based on characteristics of each road, including number of homes, schools, churches, businesses, industries, recreational facilities, traffic counts, presence of school bus routes, and value as a thoroughfare. Oliver Pond Road is scheduled for paving in the 2000-2001 Secondary Roads Construction Program. PAYMENT RECEIVED Post Office Box 3165, Nilson, North Carolina. 27895-3165 Impacts to Waters of the United States Construction of the project will necessitate impacts to waters of the United States in the Neuse River Basin. The project crosses one unnamed intermittent tributary to Little Creek, which is shown in the following table. Impacts to the stream from construction include an additional 80 square feet (0.002 acres) fill in surface water and a total of 60 linear feet existing channel impacted. LOCATION EXISTING EXISTING PROPOSED PROPOSED Station Width in. Length ft. Width in. Length ft. 23+00 24 35 36 60 No impacts to wetlands associated with roadside shoulder and ditch construction are anticipated due to the subject project. Waters of the U.S. Mitigation Avoidance: All wetlands or surface waters not affected by the project will be protected from unnecessary encroachment. No staging of construction equipment or storage of construction supplies will be allowed in or near wetlands or surface waters. Minimization: The side slopes have been steepened to the extent possible at jurisdictional sites. Strict Enforcement of sedimentation and erosion control Best Management Practices for the protection of wetlands and surface waters will be enforced during project construction. Continued coordination will occur with maintenance forces and the Environmental Officer during construction to minimize impacts to waters of the U.S. at these sites. Compensatory Niiti ation: Construction of the project will result in no impacts to waters of the U.S. Impacts have been minimized to the maximum extent possible during the design process. Riparian Buffer Impacts The construction of the project involves a road crossing of a stream that is subject to the Neuse Riparian Buffer Rule. Construction impacts at each jurisdictional crossing are less than 40 linear feet of riparian buffer. Based on the impacts to the riparian buffer at this site, the crossing is exempt from the Rule. Efforts will be made to minimize the impacts of additional storm water by the installation of extra check dams, level spreaders and vegetated swales wherever possible. Dewatering The NCDOT proposes to temporarily dewater the stream during the construction of the project. This will involve the temporary placement of sandbags, sheet metal cofferdams, or Class B or Class 2 rip rap covered with filter fabric in the stream channel approximately 10 feet upstream of the proposed pipe inlet. To maintain water flow during construction, water upstream of this impervious structure will be temporarily pumped out and conveyed downstream of the construction activity where it will be allowed to filter through vegetation before flowing into the stream. The stream will be dewatered for less than five consecutive working days. This will result in minor temporary impacts to these surface waters. - Temporary impacts to the stream from this activity will result in the dewatering of a total of 350 square feet (0.008 acres) of streambed and approximately 70 linear feet stream channel for the proposed pipe replacement. The sandbags or riprap covered with filter fabric will be entirely removed after construction. Regulatory Review The subject project has been reviewed and concurrence obtained from the State Historic Preservation Office that there is no effect to any National Register or Study-listed properties within the subject projects Area of Potential Effects. The subject project has been reviewed by the Environmental Officer and by the U.S. Fish and Wildlife Service (USFWS) representative for the presence of listed threatened and endangered species. The subject project has been determined to have no effect on any listed threatened or endangered plant or animal species. Permit Issues The purpose of this letter is to provide notification under Section 404 Nationwide Permit (NWP) 14, Linear Transportation Crossings. Notification for the use of this NWP to the USACE is provided for this project, as a courtesy to the USACE. Also, notification to the North Carolina Division of Water Quality (NCDWQ) for Section 401 Water Quality Certificate (WQC) No. 3289 is required for this project. NCDOT will comply with all conditions associated with this NWP and WQC. Additionally, the purpose of this letter is to request authorization under a Section 404 NWP 33 to dewater the stream during project construction. The 401 WQC No. 3114 (which corresponds to NWP 33) does not require written concurrence from the NCDWQ as NCDOT intends to comply with conditions for the WQC. Summary NCDOT proposes to upgrade and pave SR 2368 in Johnston County. Temporary impacts to the stream from dewatering activity will involve 350 square feet (0.008 acres) of streambed and 70 linear feet of stream channel. Impacts associated with the pipe replacement at this project include 80 square feet (0.002 acres) of additional fill in surface water and 25 linear feet existing channel impacted. No wetland impacts are anticipated as a result of the subject project. The project is located in the Neuse River Basin. Impacts at the stream crossing are less than 40 linear feet in the buffer and are therefore exempt from the Riparian Buffer Rule. The NCDOT asks that the dewatering of the stream be authorized under a Section 404 NWP 33. The NCDOT will adhere to all applicable Section 404 NWPs and Section 401 WQCs conditions. If you have any questions or need additional information, please contact Ms. Robin M.Little at (252) 237-6164. Y, Divi4ioAnaineer , III, P.E. cc: Mr. David Franklin, USACE,Wilmik4ton Mr. John Dorney, NCDWQ, Raleigh Mr. David Cox, NCWRC, Creedmoor Mr. Garland Pardue, USFWS, Raleigh Ms. Renee Gledhill-Earley, SHPO, Raleigh Mr. J.C. Rhodes, Assistant District Engineer Mr. Bryant Bunn, P.E., NCDOT Division Maintenance Engineer Mr. Don Goins, P.E., Chief Engineer, Operations Office Use Only: romi l lion April 2001 0.108 30 USACE Action ID No. DWQ No. If any particular item is not applicable to this project, please enter "Not Applicable" or "N/A" rather than leaving the space blank. 1. Processing Check all of the approval(s) requested for this project: ® Section 404 Permit ? Section 10 Permit ® 401 Water Quality Certification ® Riparian or Watershed Buffer Rules 2. Nationwide, Regional or General Permit Number(s) Requested: NWP 14, 33 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 Wetlands Restoration Program (NCWRP) is proposed for mitigation of impacts (see section VIII - Mitigation), check here: ? II. Applicant Information Owner/Applicant Information Name: Mr. James H. Trogdon III P.E. Division Engineer Mailing Address: North Carolina Department of Transportation /Division 4 P.O. Box 3165 Wilson, NC 27895-3165 Telephone Number: (252) 237-6164 Fax Number: (252) 234-6174 E-mail Address: jtrogdon a, dot.state.nc.us 2. Agent 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: Ms. Robin M. Little Company Affiliation: Division Environmental Officer Mailing Address: North Carolina Department of Transportation/Division 4 P.O. Box 3165 Wilson NC 27895-3165 Telephone Number: (252) 237-6164 Fax Number: (252) 234-6174 E-mail Address: rmIittlendot state nc us Page 3 of 12 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 detailedsite 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: SR 2368, State Proi ect No. 6.312096T 2. T.I.P. Project Number (NCDOT Only): NA Property Identification Number (Tax PIN): NA 4. Location County: Johnston Nearest Town: Pine Level Subdivision name (include phase/lot number): Directions to site (include road numbers, landmarks, etc.): 70 West to 70 Alt. Through Pine Level to north on SR 2309, approx 1.5 miles to east on SR 2367. SR 2368 is 1.0 miles on right. 5. Site coordinates, if available (UTM orLat/Long): UTM 17 752384E 3934120N (Note - If project is linear, such as a road or utility line, attach a sheet that separately lists the coordinates for each crossing of a distinctwaterbody.) 6. Describe the existing land use or condition of the site at the time of this application: Rural, residential. 7. Property size (acres): NA 8. Nearest body of water (stream/river/sound/ocean/lake): UT to Little Creek (DW ID 1127- 43-12 C NSW 9. River Basin: Neuse River (Note - this must be one of North Carolina's seventeen designated major river basins. The River Basin map is available athttp://h2o.enr.state.nc.us/admin/maps/.) Page 4 of 12 10. Describe the purpose of the proposed work: Grading,, drainage, base, paving; and erosion control to bring existing gravel road in compliance with standard safety design specifications, replace culvert. 11. List the type of equipment to be used to construct the project: Heavy constriction equipment ( back hoe, track hoe excavator, dump truck 12. Describe the land use in the vicinity of this project: Rural residential/agricultural mix. 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. V. Future Project Plans Are any additional permit requests anticipated for this project in the future? If so, describe the anticipated work, and provide justification for the exclusion of this work from the current application: NA 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. The applicant must also provide justification for these impacts in Section VII below. All proposed impacts, permanent and temporary, must be listed herein, and must be clearly identifiable on an accompanying site plan. All wetlands and waters, and all streams (intermittent and perennial) must 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. Pagc 5 of 12 1. Wetland Impacts Wetland Impact Site Number (indicate on map) Type of Impact* Area of Impact (acres) Located within 100-year Floodplain** ('es/110) Distance to Nearest Stream (linear feet) Type of Wetland*** 0 110 * List each impact separately aid identify temporary impacts. Impacts include, but are not limited to: mechanized clewing, grading, till, excavation, flooding, ditching/drainage, etc. For dams, separately list impacts due to both structure and flooding. ** 100-Year floodplains are identified through the Federal Emergency Management Agency's (FEMA) Flood Insurance Rate Maps (FIRM), or FEMA-approved local floodplain maps. Maps are available through the FEMA Map Service Center at 1-800-358-9616, or online at http://ww?y.fenm. oy *** List a wetland type that best describes wetland to be impacted (e.g., fresliNvater/saltwater marsh, forested wetland, beaver pond, Carolina Bay, bog, etc.) List the total acreage (estimated) of existing wetlands on the property: NA Total area of wetland impact proposed: 0 2. Stream Impacts, including all intermittent and perennial streams Stream Impact Site Number (indicate on ma) Type of Impact* Length of Impact (linear feet) Stream Name** Average Width of Stream Before Impact Perennial or Intermittent? ( leasespecify) 1 124" RCP 25 UT to Little Creek 3 Intermittent " List each impact separately and identify temporary impacts. Impacts include, but are not limited to: culverts and associatc6p-rap, dams (separately list impacts due to both structure and flooding), relocation (include linear feet before and after, and net loss/gain), stabilization activities (cement wall, rip-rap, crib wall, 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. Stream names can be found on USGS topographic neaps. If a stream has no name, list as UT (unnamed tributary) to die nearest doNNiistream named stream into whicli it flows. USGS maps are available through the USGS at 1-800-358-9616, or online at yyw}y_u_sgs_?ny. Several internet sites also allow direct download and printing of USGS maps (e.g., ?Y3y??_;tphnzone,cclrr? wNNrw.m,1j)cLest.coni, etc.). Cumulative impacts (linear distance in feet) to all streams on site: 25 3. Open Water Impacts, including Lakes, Ponds, Estuaries, Sounds, Atlantic Ocean and any other Water of the U.S. Open Water Impact Site Number (indicate on ma) Type of Impact* Area of Impact (acres) Name Wate) (if f applicable) Type of Walcrbody (lake, pond, estuary, sound, bay, ocean, etc.) * List each impact separately and identify temporary impacts. Impacts include, but are not limited to: till, excavation, dredging, flooding, drainage, bulkheads, etc. Page 6 of 12 4. 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.): Size of watershed draining to pond: Expected pond surface area: VII. Impact Justification (Avoidance and Minimization) 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 constriction to reduce impacts. All wetlands or surface waters notaffected by the project will be protected from unnecessary encroachment. No staging, of construction equipment will be allowed in or near wetlands or waters of the U.S. Strict enforcement of sedimentation and erosion control Best Management Practices for the protection of wetlands and surface waters will be enforced during project constriction. VIII. Mitigation 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 March 9, 2000, 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. Page 7of12 If mitigation is required for this project, a copy of the miti gation 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 NCWRP 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, available at http://h2o.enr.state. nc.us,%ncwetlands/strm,((ide.htmt 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 Wetlands Restoration Program (NCWRP) with the NCWRP's written agreement. Check the box indicating that you would like to pay into the NCWRP. Please note that payment into the NCWRP must be reviewed and approved before it can be used to satisfy mitigation requirements. Applicants will be notified early in the review process by the 401/Wetlands Unit if payment into the NCWRP is available as an option. For additional information regarding the application process for the NCWRP, check the NCWRP website at http:/;712o.cnr.statc.nc.uVR'rp/l1idcN.litIll. If use of the NCWRP is proposed, please check the appropriate box on page three 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)- Amount of Non-riparian wetland mitigation requested (acres Amount of Coastal wetland mitigation requested (acres): IX. Environmental Documentation (DWQ Only) Does the project involve an expenditure of public funds or the use of public (federal/state/local) land? Yes ® No ? 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. Page 8 of 12 Yes ? No 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 (DWQ Only) 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. Will the project impact protected riparian buffers identified within 15A NCAC 213 .0233 (Neuse), 15A NCAC 2B .0259 (Tar-Pamlico), 15A NCAC 2B .0250 (Randleman Rules and Water Supply Buffer Requirements), or other (please identify )? Yes ® No ? If you answered "yes", provide the following information: 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. Zone* Impact (square feet) Multiplier Required Mitigation 1 0 3 0 2 0 1.5 0 Total 0 0 'Lone 1 extends out 3U leet peipendicular Irom near bans: of cuannel; Gone L cmenus an additional 20 feet from the edge of Zone t. If buffer mitigation is required, please discuss what type of mitigation is proposed (i.e., Donation of Property, Conservation Easement, Riparian Buffer Restoration / Enhancement, Preservation or Payment into the Riparian Buffer Restoration Fund). Please attach all appropriate information as identified within 15A NCAC 213 .0242 or.0260. XI. Stormwater (DWQ Only) Describe impervious acreage (both 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. Pagc 9 of 12 Existingoravel road surface area will not be widened within riparian buffer Temporary dewatering and all appropriate best management practices for sediment and erosion control will be implemented during pipe replacement. XII. Sewage Disposal (DWQ Only) 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. NA XIII. Violations (DWQ Only) Is this site in violationof DWQ Wetland Rules (15A NCAC 2H.0500) or any Buffer Rules? Yes ? No Is this an after-the-fact permit application? Yes ? No XIV. 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 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). V6 ApplicDenYs\9ianature ' De (Agent' signature is valid only if an authorization letter from the applicant i provided.) US Army Corps Of Engineers Field Offices and County Coverage Asheville Regulatory Field Office Alexander Cherokee Ircdell Mitchell Union US Anny Corps of Engineers Avery Clay Jackson Polk Watauga 151 Patton Avenue Buncombe Cleveland Lincoln Rowan Yancey Rooin 208 Burke Gaston Macon Rutherford Page 10 of 12 -• v' ? ?, zalq \ riO'R • /'. .? ._/` cou T r /: o b •' \ 122/ ,.? -?..\ ;?%; ?.•? 21ta 'P ant - IQ ?-/?' b '1 .??. 3 ? \• 1 -10 ?21 A R " 2161 - o ` ?. • ° Z1S9 1 2 `. y ////////>/ 5 7 Ln 3f.• a •:}: ? nz ? l • 10 \L'?2? 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