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HomeMy WebLinkAbout20081240 Ver 1_CAMA Application_2008081508 A NCDENR North Carolina Department of Environment and Natural Resources Division of Coastal Management Michael F. Easley, Governor James H. Gregson, Director August 13, 2008 MEMORANDUM: TO: Ms. Cyndi Karoly Environmental Biological Supervisor Division of Water Quality FROM: SUBJECT Applicant: Project Location: Doug Huggett Major Permits Processing Coordinator 240 William G. Ross Jr., Secretary "t r ' 0119 ?tM CAMA/DREDGE & FILL Permit Application Review Marina Business Ventures, LLC The project site is located at 100 Middle Street, adjacent to the Neuse River, New Bern, Craven County Proposed Project: The applicant is proposing to expand an existing 218 slip marina by 35 slips creating a 253 slip marina, which is a 16% increase in the number of slips. Expansion will not involve any driving of pilings or an increase in pier or platform size. Please indicate below your agency's position or viewpoint on the proposed project and return this form by 9/3/2008. If you have any questions regarding the proposed project, please contact Jonathan Howell at (252) 808-2808. When appropriate, in-depth comments with supporting data are requested. REPLY: This agency has no objection to the project as proposed. This agency has no comment on the proposed project. This agency approves of the project only if the recommended changes are incorporated. See attached. This agency objects to the project for reasons described in the attached comments. SIGNED 400 Commerce Avenue, Mority, North Carolina 28557 Phone. 252-808-2808 \ FAX. - 330-\ ante An Equal Opportunity \ Affirmative Action Employer - 50% Recycled \ 10% Post Consumer Paper Major Permit Fee Schedule Circle One DCM % DWQ % Development Type Fee (14300160143510009316256253) (2430016024351000952341) 1. Private, non-commercial development that does not involve the filling or excavation of any wetlands or open water areas: $250 100%($250) 0%($0) II. Public or commercial development that does not involve the filling or excavation of any wetlands or open water areas: $400 100%($400) 0%($0) III. For development that involves the filling and/or excavation of up to 1 acre of wetlands and/or open water areas, determine if A,B, C. or D below applies: III(A). Private, non-commercial development, if General Water Quality Certification No. 3490 (See attached) can be applied: $250 100%($250) 0%($0) III(B). Public or commercial development, if Ge Quality Certifi on .3490 (See atta ed) c be applied: $400 100%($40 ) 0%($0) 111(C). If General ater Quality Certification No. 3 ee attached) could be applied, bu DCM staff determined that additional review and written DWQ concurrence is needed because of concerns related to water quality or aquatic life: $400 60%($240) 40%($160) III(D). If General Water Quality Certification No. 3490 (see attached) cannot be applied: $400 60%($240) 40%($160) IV. Development that involves the filling and/or excavation of more than one acre of wetlands and/or open water areas: $475 60%($285) 40%($190) Check 4 4, qsi k4f,1' "tj 1N U, C Amount Project " Name C?CZi ?g r1 £' S DIVISION OF COASTAL MANAGEMENT FIELD INVESTIGATION REPORT 1. APPLICANT'S NANVIE: Marina Business Ventures. LLC 2. LOCATION OF PROJECT SITE: 100 Middle Street, adiacent to the Trent River, in the City of New Bern, Craven County Photo Index - 2006: 212-6242 grid (6/K-0)(7/L-O)(8/N) 2000: 72-841 grid (S,T-5:R,S,T- 7) 1995: 72-804 grid (S-11;R,S-13) State Plane Coordinates - X: 2586679.679 Y: 4967/81.534 Rover # L072815A LA'T 35°05'56.65980 LON 77°02'1.8.26704 3. INVESTIGATION TYPE: CAMA 4. INVESTIGATIVE PROCEDURE: Dates of Site Visit - 7/28/08 Was Applicant Present -No 5. PROCESSING PROCEDURE: Application Received - 8/11/08 Office - Morehead City 6. SITE DESCRIPTION: (A) Local Land Use Plan - City of New Bern Land Classification From LUP - Conservation (B) AEC(s) Involved: Public Trust Area, Estuarine Water (C) Water Dependent: Yes (D) Intended Use: Commercial (E) Wastewater Treatment: Existing - City Sewer (F) Type of Structures: Existing - 218 Slip Marina Planned - Additional/Reclassified 35 Slips (G) Estimated Annual Rate of Erosion: N/A Source - N/A 7. HABITAT DESCRIPTION: (A) Public Trust Area N/A. N/A I 19,380 sq. ft. (B) Shallow Bottom N/A N/A I N/A (D) Total Area Disturbed: N/A (E) Primary Nursery Area: No (F) Water Classification: SB-NSW Open: No 8. PROJECT SUMMARY: The applicant is proposing to expand an existing 218-slip marina by 35 slips creating a 253-slip marina, which is a 16% increase in the number of slips. Expansion will not involve any driving of pilings or an increase in pier or platform size. Marina Business Ventures, LLC Page 02 9. Narrative Description: The Marina Business Ventures, LLC property is located at 100 Middle Street in downtown New Bern, Craven County and is the marina structure associated with the Sheraton Grande Hotel. The project site is found by traveling west on Hwy. 70 towards New Bern and taking the Downtown New Bern exit. Cross the Trent River Bridge and take a left on Front Street. The Sheraton Grande Marina is on the left hand side of the road. The subject property is a full service hotel and marina that was permitted in 1985 under CAMA Major Permit #74-85. CAMA Permit #106-97 permitted an additional 71 boat slips that were not constructed prior to permit expiration. CAMA Major Permit #114-03 was issued for the construction of these additional 71 boat slips and the additional slips were constructed making a total of 218 permitted slips at the marina. The 218 slips are configured as 5 slips associated with dock "Z", 14 transient boat slips associated with dock "G", 71 boat slips authorized under CAMA Major Permit #114-03 associated with dock "E" and "A", and 128 boat slips associated with dock "B, C, D & F". The entire shoreline is bulkheaded and there are presently 6 piers originating from the property. After a site visit and the review of aerial photography, it appears that no SAV exists in the area. The Division of Water Quality classifies this area as SB-NSW waters. This area is not a Primary Nursery Area. This Trent River is closed to the taking of shellfish and no visible shellfish were observed. The Craven County Land Use Plan dated 1996 classifies this area as Developed on the highground and Conservation within the AEC's. The substrate composition at the project site within the Trent River is silty sand. 10. Proiect Description: The applicant is proposing authorization of 35 additional boat slips, which will increase the total number of slips from 218 to 253. The 253 slips include the reclassification of existing transient slips to permanent slips. The 253 slips will include 22 boat slips associated with Dock "G", 16 boat slips associated with Dock "F", 19 boat slips associated with Dock "E", 30 boat slips associated with Dock "D", 48 boat slips associated with Dock "C", 56 boat slips associated with Dock "B", 57 boat slips associated with Dock "A", and 5 boat slips associated with Dock "Z". There are no structural additions to the existing marina. The impacts associated with the reclassification of the existing slips were considered in the previous CAMA Major Permit # 114-03 as usurpation and shading, which included the existing 2 finger piers on Dock "A" and 1 mooring piling on Dock "D". 11. Anticipated Impacts: No additional construction impacts would result from the reclassification of the existing slips. However, there would be an additional 19,380 square feet of Public Trust Area usurped. Also, given the change in location of the transient slips, it is expected to have some impact on the boating public. The marina expansion represents a 16% increase in the number of slips. Jonathan Howell Morehead City August 8, 2008 RCN N!-1 4,1 APPLICATION for cY ,Fhi , ATIT B V4 WETI- a i A I l_ Oder Development Permit (last revised 12127106) North Carolina DIVISION OF COASTAL MANAGEMENT 0 8 1 2 4 0 1. Primary Applicant/ Landowner Information Business Name Marina Business Ventures, Llc Project Name (if applicable) New Bern Grand Marina Improvements Applicant 1: First Name MI Last Name Applicant 2: First Name MI Last Name If additional applicants, please attach an additional page(s) with names listed. Mailing Address 4901 Glenwood Avenue, Suite 210 PO Box City Raleigh State NC ZIP 27612 Country USA Phone No. 919 - 719 - 3090 ext. FAX No. 919 - 719 - 3095 Street Address (if different from above) City State ZIP Email rodonoghue@soleil-group.com 2. Agent/Contractor Information Business Name Frank H. Sheffield, Jr., Esq., Ward And Smith, P. A. Agent/ Contractor 1: First Name MI Last Name Agent/ Contractor 2: First Name MI Last Name Mailing Address PO Box City State 867 New Bern NC ZIP Phone No. 1 Phone No. 2 28563 0867 252 - 672 - 540 0 ext. 5507 - - ext. FAX No. Contractor # 252 672 5477 Street Address (if different from above) City State ZIP 1001 College Court New Bern NC 28563-0867 Email fhs@wardandsmith.com <Form continues on back> >28 S , 1 • 83-4 AS a ? ? ..;? r a.s ,at a ayernes? ,n f Form DCM NIP-1 (Page 2 of 4) 3. Project Location County (can be multiple) Street Address State Rd #,, q Craven 1 Bicentennial Park Subdivision Name City State A ft, jieaa New Bern NC 28560- Phone No. Lot No. (s) (if many, attach additional page with list) 252 - 638 - 3585 ext. , , a. In which NC river basin is the project located? b. Name of body of water nearest to proposed project Neuse Trent River c. Is the water body identified in (b) above, natural or manmade? d. Name the closest major water body to the proposed project site. ®Natural ?Manmade ?Unknown Neuse River e. Is proposed work within city limits or planning jurisdiction? f. If applicable, list the planning jurisdiction or city limit the proposed ®Yes ?No work falls within. Marina connected to land in central business district. (/' rv i; 4. Site Description a. Total length of shoreline on the tract (ft.) b. Size of entire tract (sq.ft.) 1157.62 5.71 acres c. Size of individual lot(s) d. Approximate elevation of tract above NHW (normal high water) or N/A, NWL (normal water level) (If many lot sizes, please attach additional page with a list) ?NHW or ®NWL e. Vegetation on tract N/A f. Man-made features and uses now on tract Docks A, B, C, D, E, F, and floating wave attenuator (Dock G) and pump out station (Dock Z) g. Identify and describe the existing land uses adiacent to the proposed project site. Hotel with restaurant. Condominium. 1ocal nt zone the tract? i. Is the proposed project consistent withthe applicable zoning? = ining property. (Attach zoning compliance certificate, if applicable) . ®Yes ?No ?NA j. Is the proposed activity part of an urban waterfront redevelopment proposal? ?Yes ®No k. Hasa professional archaeological assessment been done for the tract? If yes, attach a copy. ?Yes ?No ®NA If yes, by whom? 1. Is the proposed project located in a National Registered Historic District or does it involve a ®Yes ?No ?NA National Register listed or eligible property? <Form continues on next page> APPLICATION for Major Development Permit 52-1308-2808 a: 1-888-4RCO AST www.nccoastaimanagement.net Form DCM MP-1 (Page 3 of 4) m. (i) Are there wetlands on the site? (ii) Are there coastal wetlands on the site? (iii) If yes to either (i) or (ii) above, has a delineation been conducted? (Attach documentation, if available) n. Describe existing wastewater treatment facilities. Pump out system; closed head facility. APPLICATION for Ma ibcvelopM&t Pbrmit, 9 ?Yes ON'S QYes ®No ?Yes Qoa y 41 a; '.a J je' o. Describe existing drinking water supply source. Supplied by hotel to docks; city water p. Describe existing storm water management or treatment systems. .Per terms of existing permit 5. Activities and Impacts a. Will the project be for commercial, public, or private use? ®Commercial ?Public/Government ®Private/Community b. Give a brief description of purpose, use, and daily operations of the project when complete. Project involves expansion of existing 218-slip marina by adding 35 slips, some of which are located in existing vacant spaces and others are re-configurations of slips permitted in 2003. No structural expansion or modifications are requested. c. Describe the proposed construction methodology, types of construction equipment to be used during construction, the number of each type of equipment and where it is to be stored. No structural modifications proposed. d. List all development activities you propose. See 5.b. above and attached plat. e. Are the proposed activities maintenance of an existing project, new work, or both? maintenance of existing project f. What is the approximate total disturbed land area resulting from the proposed project? 0 ?Sq.Ft or []Acres g. Will the proposed project encroach on any public easement, public accessway or other area ?Yes ®No ?NA that the public has established use of? h. Describe location and type of existing and proposed discharges to waters of the state. None. i. Will wastewater or stormwater be discharged into a wetland? ?Yes ®No ?NA If yes, will this discharged water be of the same salinity as the receiving water? ?Yes ?No ?NA j. Is there any mitigation proposed? ?Yes ?No [DNA If yes, attach a mitigation proposal. <Form continues on back> 252-806.2808 r,. 11-888-4RCOAST , www.nccoastaimanagement.net Form DCM MP-1 (Page 4 of 4) APPLICATION for Major Development Permit 6. Additional Information In addition to this completed application form, (MP-1) the following items below, if applicable, must be submitted in order for the application package to be complete. Items (a) - (fj are always applicable to any major development application. Please consult the application instruction booklet on how to properly prepare the required items below. a. A project narrative. See attached. b. An accurate, dated work plat (including plan view and cross-sectional drawings) drawn to scale. Please give the present status of the proposed project. Is any portion already complete? If previously authorized work, clearly indicate on maps, plats, drawings to distinguish between work completed and proposed. See attached Plat and Exhibit A List of Slips. c. A site or location map that is sufficiently detailed to guide agency personnel unfamiliar with the area to the site. See attached. d. A copy of the deed (with state application only) or other instrument under which the applicant claims title to the affected properties. See attached. e. The appropriate application fee. Check or money order made payable to DENR. N/A f. A list of the names and complete addresses of the adjacent waterfront (riparian) landowners and signed return receipts as proof that such owners have received a copy of the application and plats by certified mail. Such landowners must be advised that they have 30 days in which to submit comments on the proposed project to the Division of Coastal Management. Name See attached Phone No. Address Name Phone No. Address Name Phone No, Address g. A list of previous state or federal permits issued for work on the project tract. Include permit numbers, permittee, and issuing dates. CAMA Major Development Permit No. 114-03; issued by Donna D. Moffitt on August 14, 2003 h. Signed consultant or agent authorization form, if applicable. See attached. i. Wetland delineation, if necessary. N/A j. A signed AEC hazard notice for projects in oceanfront and inlet areas. (Must be signed by property owner) N/A k. A statement of compliance with the N.C. Environmental Policy Act (N.C.G.S. 113A 1-10), if necessary. If the project involves expenditure of public funds or use of public lands, attach a statement documenting compliance with the North Carolina Environmental Policy Act. N/A 7. Certification and Permission to Enter on Land I understand that any permit issued in response to this application will allow only the development described in the application. The project will be subject to the conditions and restrictions contained in the permit. I certify that I am authorized to grant, and do in fact grant permission to representatives of state and federal review agencies to enter on the aforementioned lands in connection with evaluating information related to this permit application and follow-up monitoring of the project. I further certify that he i ormation provided in this application is truthful to the best of my knowledge. Date ! l G? Print Name, Signature' Please indicate application attachments pertaining to your proposed project. ?DCM MP-2 Excavation and Fill Information ?DCM MP-5 Bridges and Culverts ?DCM MP-3 Upland Development ?DCM MP-4 Structures Information 252-808-2808 _ 'l-888.4RCOAST ;: www.nccoastalmanagernent.not i 1 Form DCM MP-4` 4 ., STRUCTURES{ (Construction within Public Trust Areas)j VJ 1, Attach this form to Joint Application for CAMA Major Permit, Form DCM MP-1. Be sure to complete all other sectio sitthe°-dbic? +> 1;t Application that relate to this proposed project. Please include all supplemental information. 1. DOCKING FACILITY/MARINA CHARACTERISTICS a. (i) Is the docking facility/marina: ®Commercial []Public/Government ®Private/Community d. (i) Are Finger If yes: (ii) Number (iii) Length (iv) Width (v) Floating b. (i) Will the facility be open to the general public? ®Yes ?No c. (i) Dock(s) and/or pier(s) (ii) Number 8 (iii) Length n/a (iv) Width n/a (v) Floating ?Yes ®No e. (i) Are Platforms included? ?Yes RNo If yes: (ii) Number (iii) Length (iv) Width (v) Floating ?Yes ?No Note: Roofed areas are calculated from dripline dimensions. g. (i) Number of slips proposed 35 (ii) Number of slips existing 218 i. Check the proposed type of siting: ? Land cut and access channel []Open water; dredging for basin and/or channel ®Open water; no dredging required []Other; please describe: k. Typical boat length: 20-60' m. (i) Will the facility have tie pilings? ©Yes ?No (ii) If yes number of tie pilings? 1 []This section not applicable Piers included? ®Yes ?No 1 40 feet 4.0 feet ?Yes ®No f. (i) Are Boatlifts included? ?Yes ®No If yes: (ii) Number (iii) Length (iv) Width h. Check all the types of services to be provided. ? Full service, including travel lift and/or rail, repair or maintenance service ? Dockage, fuel, and marine supplies ® Dockage ("wet slips") only, number of slips: 35 ? Dry storage; number of boats: ? Boat ramp(s); number of boat ramps: ? Other, please describe: j. Describe the typical boats to be served (e.g., open runabout, charter boats, sail boats, mixed types). mixed types I. (i) Will the facility be open to the general public? ®Yes ?No 252-808-2808 11 1-$88-4RC DAST :: v+eWW,n esa a a ra rt.rae revised: 12,'27106 Page 2 0i 4) L 2, DOCKING FACILITYIMARINA OPERATIONS 0Thrssoetion riot apO?able a. Check each of the following sanitary facilities that will be included in the proposed project. -?? ® Office Toilets ® Toilets for patrons; Number: 3 ; Location: in the hotel annex ® Showers ® Boatholding tank pumpout; Give type and location: two shower facilities -same location - pumpout on Z dock b. Describe treatment type and disposal location for all sanitary wastewater. N/A c. Describe the disposal of solid waste, fish offal and trash. trash containers at each dock taken to trash dumpster as required d. How will overboard discharge of sewage from boats be controlled? N/A locked head facility e. (i) Give the location and number of "No Sewage Discharge" signs proposed. located at the head of each dock (ii) Give the location and number of "Pumpout Available" signs proposed. same f. Describe the special design, if applicable, for containing industrial type pollutants, such as paint, sandblasting waste and petroleum products. no storage available as this type of work is not allowed g. Where will residue from vessel maintenance be disposed of? N/A h. Give the number of channel markers and "No Wake" signs proposed. N/A i. Give the location of fuel-handling facilities, and describe the safety measures planned to protect area water quality. N/A - no fuel facility j. What will be the marina policy on overnight and live-aboard dockage? allowable k. Describe design measures that promote boat basin flushing? N/A 1. If this project is an expansion of an existing marina, what types of services are currently provided? all of the above 262-008-2808 9. 1-888-4 COA T ¢, wwvv.nc,coastal anal rn!L net revised: 92/27106 1 3 *f 4) i ,A m. Is the marina/docking facility proposed within a primary or secondary nursery area? ?Yes NNo n. Is the marina/docking facility proposed within or adjacent to any shellfish harvesting area? ?Yes NNo y ; o. Is the marina/docking facility proposed within or adjacent to coastal wetlands/marsh (CW), submerged aquatic vegetation SAVT'Sftetf bottom; " (SB), or other wetlands (WL)? If any boxes are checked, provide the number of square feet affected. ?CW ?SAV ?SB ?WL ®None p. Is the proposed marina/docking facility located within or within close proximity to any shellfish leases? ?Yes ®No If yes, give the name and address of the leaseholder(s), and give the proximity to the lease. 3. BOATHOUSE (including covered Lifts) ®This section not applicable a. (i) Is the boathouse structure(s): ?Commercial ?PubliciGovernment ?Private/Community (ii) Number (iii) Length _ (iv) Width Note: Roofed areas are calculated from dripline dimensions. 4. GROIN (e.g., wood, sheetpile, etc. If a rock groin; use MP-2, Excavation and Fill.) NThis section not applicable a. (i) Number (ii) Length (iii) Width 5. BREAKWATER (e.g., wood, sheetpile, etc.) E] This section not applicable a. Length b. Average distance from NHW, NWL, or wetlands c. Maximum distance beyond NHW, NWL or wetlands 16. MOORING PILINGS and BUOYS [g This section not applicable a. Is the structure(s): ?Commercial []Public/Government ?Private/Community b. Number c. Distance to be placed beyond shoreline Note: This should be measured from marsh edge, if present e. Arc of the swing d. Description of buoy (color, inscription, size, anchor, etc.) 252-808-2808 :: 1 x888-4RCOA T :: v_+ ww-nccoastal anagement,net revised- 12/27106 7. GENERAL a. Proximity of structure(s) to adjacent riparian property lines greater than 15' Note: For buoy or mooring piling, use arc of swing including length of vessel. c. Width of water body 1/4 mile o e. (i) Will navigational aids be required as a result of the project? ?Yes MNo ?NA (ii) If yes, explain what type and how they will be implemented. i b. Proximity of structure(s) to adjacent docking facilities. none adjacent d. Water depth at waterward end of structure at NLW or NWL estimated 9-12' 8. OTHER ?This section not applicable a. Give complete description: August 11, 2008 Date New Bern Grand Marina Improvements Project Name Frank H. Sheffield, Jr, Esq., Ward and Smith, P.A. Applicant Name Applicant Signature J 1? 252-808-2808 a: 1-8 38-4RCOAST :: uvva.nccoastalrnan yemP-nt.net revised. 12127fti6 t Project Narrative z Purpose a? y This application, which is submitted on behalf of Marina Business Ventures, LLC, requests authorization for 35 new slips (located in open spaces adjoining the various docks) and 19 modified slips at the New Bern Grand Marina ("Marina") located on the Trent River waterfront adjacent to New Bern's Sheraton Grand Hotel. Existing Conditions The Marina has 218 permanent boat slips and space for approximately 14 transient vessels located at eight docks (Docks A, B, C, D, E, F, G and Z, as authorized by CAMA Permit No. 114-03 dated August 14, 2003. The Marina includes a protective breakwater (Dock G), head pump-out facility (Dock Z), power hookups, showers and bathrooms, laundry facilities, and dock-side potable water service. Adjoining the Marina is the 171-room Sheraton Grand Hotel and the new 121-unit Sky Sail Yacht Club luxury residential condominium (due to open in summer or fall 2008). The Marina is owned by Marina Business Ventures, LLC and managed by The Soleil Group of Raleigh, North Carolina, which also manages the hotel and condominium. Marina Business Ventures, LLC, which has some degree of common ownership with the hotel and condominium at the member level, was formed for the purpose of operating the marina as a marine condominium (i.e., "dockominium"). Marina Business Ventures, LLC is the holder of the riparian rights to the public trust waters adjoining the hotel and condominium properties pursuant to a Development Agreement and Grant of Easement recorded in 1984 by the City of New Bern. Proiect Description This project will authorize a total of 35 new slips, which will increase the total number of boat slips from 218 to 253. It also will approve modifications of 19 existing slips to conform to as-build conditions. The project involves no physical additions to the existing dock structure. The project also requires no dredging. It merely involves converting certain existing spaces adjoining the docks to permanent slips suitable for mooring of vessels. The applicant proposes to reserve a total of 27 slips (as tentatively indicated in Exhibit A) as transient slips for use of the general public. The remainder will be sold to private owners, some of whom will rent their slips to the general public for investment purposes. Three slips on Dock Z and Dock A will be reserved as pump-out stations. NBMAIN\750824\1 EXHIBIT A New Bern Grand Marina Condominium Requested New Slips 1 .Y A Dock OA, OB, 1, 63 B Dock OA, OB, 50, 57 C Dock OA, OC, 45, 46 D Dock OB, 29 E Dock 15,16 F Dock OA, OB, OC, OD, OE, OF, OG, 7, 8, 9 G Dock 7, 9, 11, 13, 15, 17, 19, 21 Z Dock OB Modified Slips A Dock OA, 34, 36, 38, 40, 42, 44, 46, 48 D Dock OA, OC E Dock OA, OB, OC, 1 F Dock 1, 3, 5 Z Dock OA j Transient Slips (tentative designation; subject to change) A Dock 1,63 B Dock OA, OB, 50, 57 C Dock OA, OB, 45, 46 D Dock OA, OB, OC E Dock OA, OB, OC, 1 F Dock OA, OB, OC, OD, OE, OF, OG, 7, 9 G Dock 2 Pump Out Slips A Dock OB Z Dock OA, OB ti NBMAIN\762790\1 3/10/2008 b O a N N _'c c W, Goo s ^ o Jill at it. j 10 4J n OG 1x11111 ' f 6 :? I U .v a?rn I $ • ? ? • ? ?At a S ? ? ? s m ? L if1 •1.1 6??Q? 1 • ?tf ? w Yf ? ? ? N 1 ^ w 21 1 A ?, ? a dc 0 1 g a v o ay X '? ?0 ea ??'?, ,u I ? 4 ??snts 1-4 a n n r A ?? n P AR OA $5 ., a x oN & F t w w"8x8' " c? its a to, 2 'A 8 Y jog ?a 8g R8 ?R 8g :s $i cis I D «+ a !! a a i} R 8 a ?, "• g R? R 8 ? w^ e w ?^ R 3 8 R 8 it x R g ??? s ? $? CIA ??? ??nts ?? 8 = P? ?? $ ?«•v«a? xa as "- / p1 "Of N ,,,?„/111111111\\\\\\\ C