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HomeMy WebLinkAbout20201276 Ver 1_401 Application_20201029SAGE ECOLOGICAL SERVICES EST. 2016 6 October 29, 2020 NC Division of Water Resources 401 & Buffer Permitting Unit Attn: Mr. Paul Wojoski 512 N. Salisbury Street Raleigh, NC 27604 Re: Robbins Road Subdivision Request for NWP 29 SAW-2020-01334 Sage Project #2019.23 On behalf of Sumner Construction (applicant and owner), please find attached a complete application and supplemental information requesting written concurrence from the NC Division of Water Resources (NCDWR) that the activities associated with the proposed development of the Robbins Road Subdivision (Project) may proceed under General Certification 4139 (GC 4139). Please not that a 404-permit application was submitted to the USACE on October 8, 2020 under separate cover. This application is not intended to replace that application. Protect Purpose and Location The Project includes the construction of a single-family residential subdivision proposed to meet demand for housing in the area. The +/-48.8-acre project is located +/- 0.5 mile east of the intersection of Bethlehem Church Road and Robbins Road eight miles southeast of Youngsville, in Franklin County, NC. The coordinates of 35.9609°N, 78.346°W generally correspond to the center of the Project. Project Detail The overall Project consists of the construction of a single-family residential development with associated driveways and utilities which will connect to existing adjacent infrastructure in the area. A large farm pond is located on the southern parcel boundary. The northern property boundary is Norris Creek, which includes a substantial wetland floodplain system. Access to the Project site will be provided by a connection to Robbins Road. Water services will be provided by a proposed community well system. Wastewater will be treated by proposed individual septic systems. Heavy equipment typically used for utility installation projects (e.g. back hoes, bull -dozers, etc.) will be utilized. No federally threatened or endangered species are listed to occur within 1 mile of the Project according to the NC Natural Heritage Program (NHP) Database (see attached report dated April 1, 2020). The Site itself is not listed as a historic property or within a historic district. Seven properties are listed within 1.0 mile of the Site based on a query of the GIS files from NCSHPO. All seven properties are designated "Surveyed Only (SO)." Robbins Road Subdivision Page 1 of 2 Project History The majority of the Site has been cleared and used for agriculture for at least the past several decades. Land use in the vicinity consists of undeveloped, forested land, agricultural land, and residential development. Mr. David Gainey of Sage Ecological performed a wetland and stream delineation. A PJD was issued on October 7, 2020. The USACE Action ID is SAW-2020-01334. A site meeting was held with NCDWR staff on June 29, 2020 and a letter issued on July 8, 2020. RRO #20-169 corresponds to the NCDWR issued determination. Avoidance and Minimization The proposed buildings and roads were aligned so as to avoid and minimize impacts to wetlands, streams, and riparian buffers to the maximum extent practicable. The crossing location of Stream B was positioned in a location where large wetland impacts could be avoided. Construction fencing will be used to define the construction corridor and prevent any accidental additional impacts, while silt fencing will be installed to provide additional protection from runoff. Protect Impacts Proposed permanent wetland impacts total 0.0.087 acre as a result of roadway fill and culvert placement. Temporary wetland impacts total 0.021 acre as a result of clearing for road construction. Permanent stream impacts total 64 LF for a road crossing. Temporary stream impacts of 44 LF are proposed for dewatering to construct the road crossings. Permanent riparian buffer impacts total 8,033 sf in Zone 1 and 3,243 sf in Zone 2 for road crossings. Temporary riparian buffer impacts total 1,722 sf in Zone 1 and 1,344 sf in Zone 2 for road crossings. No other impacts are proposed. Mitigation Permanent wetland impacts are less than 0.1 acre and permanent stream impacts are less than 150 LF. Temporary wetland impacts will be returned to original grade and seeded using a native wetland seed mix. Therefore, mitigation for proposed wetland and stream impacts is not proposed. Buffer impacts are considered "Allowable Upon Authorization" per the Table of Uses. If you have any questions, please call me at (919) 244-0623. Sincerely, Sean Clark Sage Ecological Services, Inc. Robbins Road Subdivision Page 2 of 2 DWR mrlslon of Water Resources Pre -Construction Notification (PCN) Form October 26, 2020 Ver 3.3 Initial Review Has this project met the requirements for acceptance in to the review process?* r Yes r No Is this project a public transportation project?* C Yes r No Change only if needed. BIMS # Assigned 20201276 Is a payment required for this project?* r No payment required r Fee received r Fee needed - send electronic notification Reviewing Office * Raleigh Regional Office - (919) 791-4200 Information for Initial Review 1a. Name of project: Robbins Road Subdivision 1a. Who is the Primary Contact?* Sean Clark 1b. Primary Contact Email:* sclark@sageecological.com Date Submitted 10/29/2020 Nearest Body of Water Norris Creek Basin Tar -Pamlico Water Classification C;NSW Site Coordinates Latitude: 35.9609°N Pre -Filing Meeting Information ID# Pre -fling Meeting or Request Date* 9/23/2020 Longitude: 78.346°W Attach documentation of Pre -Filing Meeting Request here:* DWR Pre -Filing Meeting Request Form.pdf Version#* 1 What amout is owed?* IT $240.00 r $570.00 Select Project Reviewer* Stephanie Goss:eads\sagoss 1c. Primary Contact Phone:* (919)559-1537 Version 50.86KB A. Processing Information C^U County (or Counties) where the project is located: Franklin Is this a NCDMS Project r Yes r No Is this project a public transportation project?* r Yes r No la. Type(s) of approval sought from the Corps: W Section 404 Permit (wetlands, streams and waters, Clean Water Act) r Section 10 Permit (navigable waters, tidal waters, Rivers and Harbors Act) 1b. What type(s) of permit(s) do you wish to seek authorization? W Nationwide Permit (NWP) r Regional General Permit (RGP) r Standard (IP) 1c. Has the NWP or GP number been verified by the Corps? r Yes r No Nationwide Permit (NWP) Number: 29 - Residential Developments NWP Numbers (for multiple NWPS): 1d. Type(s) of approval sought from the DWR: rJ 401 Water Quality Certification - Regular r Non-404 Jurisdictional General Permit r Individual Permit to. Is this notification solely for the record because written approval is not required? For the record only for DWR 401 Certification: For the record only for Corps Permit: r 401 Water Quality Certification - E)press r Riparian Buffer Authorization 1f. Is this an after -the -fact permit application?* r Yes r No 1g. Is payment into a mitigation bank or in -lieu fee program proposed for mitigation of impacts? r Yes r No 1g. Is payment into a mitigation bank or in -lieu fee program proposed for mitigation of impacts? r Yes r No Acceptance Letter Attachment 1h. Is the project located in any of NC's twenty coastal counties? r Yes r No 1j. Is the project located in a designated trout watershed? r Yes r No B. Applicant Information 1d. Who is applying for the permit? W Owner r Applicant (other than owner) le. Is there an Agent/Consultant for this project?* r Yes r No 2. Owner Information 2a. Name(s) on recorded deed: Sumner Construction, Inc. 2b. Deed book and page no.: DB: 2196, DP: 1731 2c. Responsible party: Bobby Sumner 2d.Address * r Yes r No r Yes r No Street Address PO Box 1011 Address tine 2 aty Youngsville Postal / Zip Code 27596 2e. Telephone Number: (919)422-5713 2g. Email Address:* sclark@sageecological.com 4. Agent/Consultant (if applicable) 4a. Name: Sean Clark 4b. Business Name: Sage Ecological Services, Inc. 4c.Address Street Address 3707 Swift Drive Address Line 2 city Raleigh Postal / Zip Code 27606 4d. Telephone Number: (919)559-1537 4f. Email Address:* sclark@sageecological.com Agent Authorization Letter* Signed Agent Authorization for Robbins Road Property.pdf State / Rovince / Rion NC Country USA 2f. Fax Number: Slate / Province / Region NC Country USA 4e. Fax Number: 416.48KB C. Project Information and Prior Project History C^U 1. Project Information 1b. Subdivision name: (W appropriate) Robbins Road Subdivision 1c. Nearest municipality town: Youngsville 2. Project Identification 2a. Property Identification Number: 2b. Property size: 1890-24-8608 +/-48.8 acres 2c. Project Address Street Address Robbins Road Address tine 2 City State / Province / Pagion Harris NC Postal / Zip Code Country 27596 USA 3. Surface Waters 3a. Name of the nearest body of water to proposed project:* Norris Creek 3b. Water Resources Classification of nearest receiving water:* QNSW 3c. What river basin(s) is your project located in?* Tar -Pamlico 3d. Please provide the 12-digit HUC in which the project is located. 0302010104 4. Project Description and History 4a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this application:* The majority of the Site has been cleared for agriculture. A large farm pond is located on the southern parcel boundary. The northern property boundary is Norris Creek, which includes a substantial wetland floodplain system. Other drainages on the Site are forested. Land use in the vicinity consists of undeveloped, forested land, agricultural land, and rural residential homes. A 404-permit application was submitted to the USACE on October 8, 2020 under separate cover. This application is not intended to replace that application. 4b. Have Corps permits or DWR certifications been obtained for this project (including all prior phases) in the past?* r Yes r No r Unknown 4d. Attach an 8 1/2 X 11 excerpt from the most recent version of the USGS topographic map indicating the location of the project site. (for DWR) Figure1 - USGS.pdf Figure1 - USGS with Callouts.pdf 1.01 MB 781.3KB 4e. Attach an 8 1/2 X 11 excerpt from the most recent version of the published County NRCS Soil Survey map depicting the project site. (for DWR) Figure 2- Soils with Callouts.pdf 817.95KB 4f. List the total estimated acreage of all existing wetlands on the property: +/- 12.008 ac. 4g. List the total estimated linear feet of all existing streams on the property: +/- 4,080 LF and a +/- 2 ac. pond 4h. Explain the purpose of the proposed project:* The purpose of the proposed project is to construct a single-family residential development with associated roadways, amenities, and utilities to meet the demand for housing in this area. 41. Describe the overall project in detail, including indirect impacts and the type of equipment to be used:* The overall project consists of the construction of a single-family residential development. Access to the Site will be provided by a connection to Robbins Road. Water services will be provided by a proposed community well system. Wastewater will be treated by proposed individual septic systems. The project will construct three roadways two of wfiich will require crossing drainages that contain waters of the US. Heavy equipment typically used for utility installation projects (e.g. back hoes, bull -dozers, etc.) will be utilized. 4j. Please upload project drawings for the proposed project. 06-Robbins_Const. Plans_24x36_2020-08-25.pdf 1.16MB Robbins —impact E)hibits_24X36_2020-09-22.pdf 1.08MB 5. Jurisdictional Determinations 5a. Have the wetlands or streams been delineated on the property or proposed impact areas?* r Yes r No O Unknown Comments: 5b. If the Corps made a jurisdictional determination, what type of determination was made?* r Preliminary r Approved r Not Verified r Unknown r N/A Corps AID Number: SAW-2020-01334 5c. If 5a is yes, who delineated the jurisdictional areas? Name (if known): David Gainey Agency/Consultant Company: Sage Ecological Services, Inc. Other: 5d. List the dates of the Corp jurisdiction determination or State determination if a determination was made by the Corps or DWR The PJD is dated 2020-10-07. The NCDWR buffer determination (RRO #20-169) is dated July 8, 2020. 5d1. Jurisdictional determination upload SAW-2020-01334-PJDletter1.pdf 786.51 KB 6. Future Project Plans 6a. Is this a phased project?* r Yes r No Are any other NWP(s), regional general permit(s), or individual permits(s) used, or intended to be used, to authorize any part of the proposed project or related activity? D. Proposed Impacts Inventory 1. Impacts Summary 1a. Where are the impacts associated with your project? (check all that apply): W Wetlands W Streams -tributaries W Buffers r Open Waters r Pond Construction 2. Wetland Impacts 2af Reason (?) 2b. Impact type * (?) 2c. Type of W.* 2d. W. name* 2e. Forested * 2f. Type of Jurisdicition*(?) 2g. Impact area* W1 Roadway Fill/Culvert P Headwater Forest Wetland WB-2 Yes Both 0.042 (acres) W2 Clearing T Headwater Forest Wetland WB-2 Yes Both 0.008 (acres) W3 Roadway Fill/Culvert P Headwater Forest Wetland WC Yes Both 0.045 (acres) ��T Headwater Forest Wetland WC �Ye=]Both 0.013 ff___]Fe.ring (acres) 2g. Total Temporary Wetland Impact 0.021 2g. Total Wetland Impact 0.108 2h. Comments: Cleared areas will be reseeded using a native seed mix 3. Stream Impacts 2g. Total Permanent Wetland Impact 0.087 3a. Reason for impact (?) 3b.lmpact type * 3c. Type of impact* 3d. S. name* 3e. Stream Type* Type of 3gSwidth * 3h. Impact(?) ❑ �[3f. urisdiction* length* S1 road crossingPermanent Culvert Stream B Intermittent Both 4 64 Average (feet) (lir�rfeet) 82 road crossing Temporary Dewatering Stream C Intermittent Both 4 2 Average (feet) (lir�rfeet) S3 road crossing Temporary Dewatering Stream B Intermittent Both 4 42 Aver�e(feet) (linearfeet) 3i. Total jurisdictional ditch impact in square feet: 0 3i. Total permanent stream impacts: 64 3i. Total stream and ditch impacts: 108 3i. Total temporary stream impacts: 44 3j. Comments: The impact labeled as "SY above is actual the dewatering associated with Impact S1 however because the EPCN form prelabels the stream impacts it tends to make it difficult to match up with impact maps. 6. Buffer Impacts (for DWR) 6a. Project is in which protect basin(s)? Check all that apply. r Meuse V Tar -Pamlico r Catawba r Randleman C Goose Creek r Jordan Lake [ Other 6b. Impact Type 6c. Per or Temp 6d. Stream name 6e. Buffer mitigation required? 6f. Zone 1 impact 6g. Zone 2 impact Al - Allowable P Stream B No 4,864 0 A2 - Allowable P Stream B No 0 3,243 A3 - Allowable T Stream B No 1,360 0 A4 - Allowable T Stream B No 0 805 B1 - Exempt T Stream B No 0 225 62 - Exempt T Stream B No 116 0 C1 - Allowable P Stream C No 1,001 0 C2 - Allowable P Stream C No 2,052 0 C3 - Allowable T Stream C No 362 0 C4 - Allowable T Stream C No 0 1 314 6h. Total buffer impacts: Zone 1 zone 2 Total Temporary impacts: 1,838.00 1,344.00 Zone 1 Zone 2 Total Permanent impacts: 7,917.00 3,243.00 Zone 1 Zone 2 Total combined buffer impacts: 9,755.00 4,587.00 6i. Comments: Proposed impacts A-1 through A-4 are associated with a perpendicular stream crossing of stream B and total an area less than 1/3 acre (i.e. Allowable). Proposed impacts B-1 and B-2 are associated with grading (i.e. Exempt). Proposed impacts C-1 through C-4 are associated with a perpendicular stream crossing of stream C and total an area less than 1/3 acre (i.e. Allowable). Supporting Documentation E. Impact Justification and Mitigation U 1. Avoidance and Minimization la. Specifically describe measures taken to avoid or minimize the proposed impacts in designing the project: The proposed roads were aligned so as to avoid and minimize impacts to wetlands, streams, and riparian buffers to the maAmum extent practicable. The crossing location of Stream B was positioned in a location where large wetland impacts could be avoided. Construction fencing will be used to define the construction corridor and prevent any accidental additional impacts, while silt fencing will be installed to provide additional protection from runoff. 1b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques: General techniques include the use of construction fencing to define the construction corridor and prevent any accidental additional impacts. Silt fencing will also be used to prevent sediment runoff into the streams. Ground cover will be established immediately after ground disturbance during construction. 2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State 2a. Does the project require Compensatory Mitigation for impacts to Waters of the U.S. or Waters of the State? r Yes r No 2b. If this project DOES NOT require Compensatory Mitigation, explain why: All proposed buffer impacts are either "Allowable" or "Exempt' therefore no buffer mitigation is required. Stream and Wetland impacts have been minimized and avoided to the maAmum extent practicable and are below the thresholds that typically require mitigation. F. Stormwater Management and Diffuse Flow Plan (required by DWR) 1. Diffuse Flow Plan la. Does the project include or is it adjacent to protected riparian buffers identified within one of the NC Riparian Buffer Protection Rules? r Yes r No What type of SCM are you providing? r Level Spreader W Vegetated Conveyance (lowar SMNT) r Wetland Swale (higher SMNT) r Other SCM that removes minimum 30 % nitrogen r Proposed project will not create concentrated stormwater flow through the buffer Diffuse Flow Documentation 2. Stormwater Management Plan 2a. Is this a NCDOT project subject to compliance with NCDOT's Individual NPDES permit NCS000250?* r Yes r No 2b. Does this project meet the requirements for low density projects as defined in 15ANCAC 02H .1003(2)? r Yes r No Comments: Percent Impervious will be less than 12 G. Supplementary Information 1. Environmental Documentation 1a. Does the project involve an expenditure of public (federal/state/local) funds or the use of public (federal/state) land?* r Yes r No 2. Violations (DWR Requirement) 2a. Is the site in violation of DWR Water Quality Certification Rules (15A NCAC 2H .0500), Isolated Wetland Rules (15A NCAC 2H .1300), or DWR Surface Water or Wetland Standards or Riparian Buffer Rules (15A NCAC 2B .0200)? * r Yes r No 3. Cumulative Impacts (DWR Requirement) 3a. Will this project result in additional development, which could impact nearby downstream water quality?* r Yes r No 3b. If you answered "no," provide a short narrative description. The project is not extending additional utilities to the area so the completion of this project will not increase or decrease the probability of future development in surrounding areas. 4. Sewage Disposal (DWR Requirement) 4a. Is sewage disposal required by DWR for this project?* r Yes r Nor NIA 5. Endangered Species and Designated Critical Habitat (Corps Requirement) 5a. Will this project occur in or near an area with federally protected species or habitat?* r Yes r No 5b. Have you checked with the USFWS concerning Endangered Species Act impacts?* r Yes r No 5d. Is another Federal agency involved?* r Yes r No r Unknown Se. Is this a DOT project located within Division's 1-8? r Yes r No St. Will you cut any trees in order to conduct the work in waters of the U.S.? r Yes r No 5g. Does this project involve bridge maintenance or removal? r Yes r No 5h. Does this project involve the construction/installation of a wind turbine(s)?` r Yes r No 51. Does this project involve (1) blasting, and/or (2) other percussive activities that will be conducted by machines, such as jackhammers, mechanized pile drivers, etc.? r Yes r No 5j. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical Habitat? The NC Natural Heritage Database was queried and a report (dated April 1, 2020) was received from NCNHP which identified no recorded federally listed species on the project site or within a 1-mile radius. Consultation Documentation Upload 05-NCNHP Report for Robbins Road Property.pdf 772.96KB 6. Essential Fish Habitat (Corps Requirement) 6a. Will this project occur in or near an area designated as an Essential Fish Habitat?* r Yes r No 6b. What data sources did you use to determine whether your site would impact an Essential Fish Habitat?* The proposed project takes place in Franklin County which is not near any coastal or tidal habitat that mould support EFH (i.e. salt marshes, oyster reefs, etc.). 7. Historic or Prehistoric Cultural Resources (Corps Requirement) 7a. Will this project occur in or near an area that the state, federal or tribal governments have designated as having historic or cultural preservation status?* r Yes r No 7b. What data sources did you use to determine whether your site would impact historic or archeological resources?* http://gis.ncdcr.gov/hpoweb/ - The Site itself is not listed as a historic property or Within a historic district. Seven properties are listed within 1.0 mile of the Site based on a query of the GIS files from NCSHPO. All seven properties are designated "Surveyed Only (SO)." 7c. Historic or Prehistoric Information Upload 8. Flood Zone Designation (Corps Requirement) 8a. Will this project occur in a FEMA-designated 100-year floodplain?* r Yes r No 8b. If yes, explain how project meets FEMA requirements: The 100-year floodplain is contained on portions of the project area however no construction activities (e.g. fill, etc.) Will occur within the floodplain. 8c. What source(s) did you use to make the floodplain determination?* FEMA Flood Map Service Center NC Flood Risk Information System DFIRM Panel #8800; Dated April 16, 2013. Miscellaneous Comments A 404-permit application was submitted to the USAGE on October 8, 2020 under separate cover. This application is not intended to replace that application. Miscellaneous attachments not previously requested. NCDWR Buffer Determination Letter (RRO #20-169) for Robbins Road.pdf 2.34MB Robbins Road PCN Cover Letter to NCDWR.pdf 113.71 KB Signature * 17 By checking the box and signing below, I certify that • The project proponent hereby certifies that all information contained herein is true, accurate, and complete to the best of my knowledge and belief; and • The project proponent hereby requests that the certifying authority review and take action on this CWA 401 certification request within the applicable reasonable period of time. • I have given true, accurate, and complete information on this form; • I agree that submission of this PCN form is a "transaction" subject to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act"); • I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act"); • I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written signature; AND • I intend to electronically sign and submit the PCN form. 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Governor •s ; NC DEPARTMENT OF Susi Hamilton, Secretary ■■ ■■ NATURAL AND CULTURAL RESOURCES 013 0 Walter Clark, director, Land and Water Stewardship NCNHDE-11758 April 1, 2020 Sean Clark Sage Ecological Services 3707 Swift Drive Raleigh, NC 27606-2543 RE: Robbins Road Property; 2020.023 Dear Sean Clark: The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide information about natural heritage resources for the project referenced above. Based on the project area mapped with your request, a query of the NCNHP database indicates that there are no records for rare species, important natural communities, natural areas, and/or conservation/managed areas within the proposed project boundary. Please note that although there may be no documentation of natural heritage elements within the project boundary, it does not imply or confirm their absence; the area may not have been surveyed. The results of this query should not be substituted for field surveys where suitable habitat exists. In the event that rare species are found within the project area, please contact the NCNHP so that we may update our records. The attached `Potential Occurrences' table summarizes rare species and natural communities that have been documented within a one -mile radius of the property boundary. The proximity of these records suggests that these natural heritage elements may potentially be present in the project area if suitable habitat exists. Tables of natural areas and conservation/managed areas within a one -mile radius of the project area, if any, are also included in this report. If a Federally -listed species is found within the project area or is indicated within a one -mile radius of the project area, the NCNHP recommends contacting the US Fish and Wildlife Service (USFWS) for guidance. Contact information for USFWS offices in North Carolina is found here: httr)s://www.fws.gov/offices/Directory/ListOffices.cfm?statecode=37. Please note that natural heritage element data are maintained for the purposes of conservation planning, project review, and scientific research, and are not intended for use as the primary criteria for regulatory decisions. Information provided by the NCNHP database may not be published without prior written notification to the NCNHP, and the NCNHP must be credited as an information source in these publications. Maps of NCNHP data may not be redistributed without permission. The NC Natural Heritage Program may follow this letter with additional correspondence if a Dedicated Nature Preserve, Registered Heritage Area, Clean Water Management Trust Fund easement, or Federally -listed species are documented near the project area. If you have questions regarding the information provided in this letter or need additional assistance, please contact Rodney A. Butler at rod ney.butlerCo�ncdcr.aov or 919-707-8603. Sincerely, NC Natural Heritage Program DEPAR7HEN7 OF NATURAL AND CULTURAL RESOURCES 121 W. JONES STREET. RALEIGH. NC 27603 • 1691 MAIL SERVICE CENTER. RALEIGH. NC 27609 OFC 919.707.9120 • FAX 919.707.9121 0 CIA CO CO / \ \ nE 2 / § o e e ? ® 9 / CO e = \ � t ° 3 / CO e \ CO % / CO 66 �� 0 / ® \ \\ � /\ § \ƒ CO s CO _ ® /9 }/ E \/ y u x ±2 / CO % 4 (\ CO/ \\ 27 k \ © j± ? s \ ( \(® �\ \ E \ / ƒ » z x <\\ //� U% ^ \z9 m O a\ cocoa c y c a» ƒ 2 _ ` CO s \ \ 2 2 ± x/§ w s COw\ e& CO /\ \ 2 Z z ±/ 2%% CO 4 &Z a}oo \u�0±\�� Z ° -02 m ƒ /®ƒ /\% 4ETE g \ \Z0% / �} \ \� \ /\ 0 CO�� � zE n — E 3` \ \ / ( \ 0 \ z G = O -0 O CO E ` CO k � e k = ? 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