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HomeMy WebLinkAbout20011083 Ver 2_CAMA Application_20120307March 5 2012 MEMORANDUM TO Cyndi Karoly Supervisor 401 Oversight & Express Permits Unit Division of Water Quality- Surface Water Protection FROM Doug Huggett NC DENR DCM Major Permits Coordinator 400 Commerce Ave Morehead City NC 28557 (Courier 11- 12 -09) SUBJECT CAMA/Dredge & Fill Major Permit Application Review Applicant Masonboro Landing HOA (c /o M Conard Agent) Project Location Adjacent to Masonboro Sound at the end of Captains Lane off of Masonboro Loop Rd Wilmington NC New Hanover Co Proposed Project Applicant proposes to modify their current permit to allow for maintenance excavation within an existing basin and access channel Please indicate below your agency s position or viewpoint on the proposed project and return this form by March 29, 2012 If you have any questions regarding the proposed project contact Robb Mairs (910)796 -7423 when appropriate to -depth comments with supporting data is requested REDLY SIGNED 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 attached comments to the project for reasons described in the _DATE MAR 7 400 Commerce Ave Morehead City NC 28557 3421 Phone 252 -808 28081 FAX 252 247 3330 Internet www nccoastal management net An Gqual Opportunity 1 AfFirm3tiw Action employer NftQM0 OAR SMWft7&VACff NorthCaxohna Natarmllb, DIVISION OF COASTAL MANAGEMENT FIELD INVESTIGATION REPORT APPLICANTS NAME Masonboro Landing HOA 2 LOCATION OF PROJECT SITE Adjacent to Masonboro Sound at the end of Captains Lane off of Masonboro Loop Rd in New Hanover County Photo Index 2006 21 7384 R S 8 2000 21 264 R S 8 1995 22 249 R S T U 11 12 State Plane Coordinates X 22344502 Y 145299 GPS -O 050511 B Lat 34 08 37 63094 N Long 77 51 41 53017'W 3 INVESTIGATION TYPE CAMA/D &F 4 INVESTIGATIVE PROCEDURE Dates of Site Visit 2/7/2012 Was Applicant Present No 5 PROCESSING PROCEDURE Apolication Received 1/31/2012 6 SITE DESCRIPTION Office Wilmington (A) Local Land Use Plan New Hanover County Land Classification From LUP Conservation (B) AEC(s) Involved EW PTA ES ORW (C) Water Dependent Yes (D) Intended Use Community (E) Wastewater Treatment Existing N/A Planned N/A - (F) Type of Structures Existing Boat basin community marina (18 slips) freestanding bulkhead access pier and fixed platform (crabbing /fishing dock) Planned Maintenance dredging within basin and access channel (G) Estimated Annual Rate of Erosion N/A Source N/A 7 HABITAT DESCRIPTION [AREA] DREDGED FILLED OTHER (A) Vegetated Wetlands Total Area Disturbed (E) Primary Nursery Area (B) Non Vegetated Wetlands Open Water 21 330 sq ft (C) Other (highground) 70 000 sq ft (D) Total Area Disturbed (E) Primary Nursery Area (F) Water Classification 91 330 sq ft ( -2 0 acres) Yes SA ORW Open No 8 PROJECT SUMMARY The applicant proposes to modify their current permit to allow for maintenance excavation within an existing basin and access channel Masonboro Landing HOA Page 2 9 PROJECT DESCRIPTION The project site is the existing community marina for Masonboro Landing Subdivision adjacent to Masonboro Sound at the end of Captains Lane in New Hanover County To locate the property traveling south on College Road take a left onto Mohican Trail and travel east approximately 1 3 miles Turn right onto Masonboro Loop Road and travel south for approximately 0 4 miles until you reach Captains Lane at the entrance of the Masonboro Landing Subdivision that will be located on the left Travel east on Captains Lane for approximately 0 6 miles until it terminates at the project site The original marina basin and channel excavation was authorized in 1985 The existing marina facility consists of a boat basin approximately 235 in length by 78 in width and an access channel to the AIWW approximately 75 in width by 40 in width The originally permitted depth for the basin was 6 at normal low water (NLW) The majority of the basin is stabilized by a vertical wooden seawall The north side of the boat basin has been stabilized with a freestanding bulkhead approximately 230 in length There are eighteen (18) boat slips separated by mooring pilings arranged along a single floating dock located along the southern wall of the community boat basin There is a narrow border of Smooth Cordgrass (Spartrna alterniflora) located on the northern side of the freestanding wooden bulkhead of the basin The vegetation transitions into high marsh species including Black Needlerush (Juncus roemananus) Spike Grass (Distichlis splcata) Sea Oxeye (Bornchia frutescens) Sea Lavender (Limonium spp) Saltwort (Salicomla spp) and Salt Meadow Grass (Spartina patens) Several shrubs Marsh elder (Iva frutescens) Grounsel bush (Baccharus halimifolia) and small Red Cedar are present on a hummock within the adjacent high marsh area The applicants obtained State Permit #34 93 in 1993 authorizing maintenance dredging for the existing facility and maintained the permit until its expiration on December 31 2006 Several CAMA General Permits have been issued to the applicant for maintenance excavation within the boat basin and entrance channel since the expiration of this permit In 1996 State Permit #126 96 was issued to expand the twelve lot (12) subdivision to twenty (20) single family lots and expand the docking facilities within the basin to accommodate eighteen (18) boat slips In 2001 State Permit #94 01 was issued to construct the free standing bulkhead to stabilize the north side of the existing boat basin The applicant received State Permit #109 09 on August 4 2009 to construct the existing fixed pier with platform along the east side of the existing boat basin to provide the subdivision homeowners access to fishing and crabbing The existing pier and platform were authorized to extend from the existing wall located on the east side of the basin a distance 40 towards the AIWW as depicted on the application drawings Based on a recent as built survey provided to our office dated March 2 2012 the actual distance of this structure into the waterbody is 38 3 The survey also depicts the existing structure encroaches slightly into the USACE AIWW 80 setback requirement a distance of approximately 6 It appears that due to an oversight this permit application did not include regaining the maintenance dredging clause for the marina facility State Permit #109 09 is due to expire on December 31 2012 however it was subject to extension by the Session Law 2009 406 as amended by Session Law 2010 177 the Permit Extension Act and is set to expire on May 29 2015 The New Hanover County Land Use Plan classifies the project area as Conservation The waters of Masonboro Sound are classified SA ORW by the NC Division of Water Quality These waters are designated as a Primary Nursery Area (PNA) by the NC Division of Marine Fisheries and they are CLOSED to the harvest of shellfish for consumption with the closure limits extending approximately 300 400 south of the mouth of the marina basin Masonboro Landing HOA Page 3 10 PROPOSED PROJECT The applicant proposes to modify their current permit to allow for maintenance excavation within an existing basin and access channel Maintenance of the boat basin limits would be approximately 235 in length by 78 in width and the access channel to the AIWW approximately 75 in length by and 40 in width The proposed depths for the basin and access channel would be 6 feet at normal low water (NLW) The application states that approximately 2 709 cubic yards (cy) of material in the basin and access channel would be removed within the original authorized dimensions and depth aforementioned The access channel depth would connect into the same water depths within Masonboro Sound The application also states that the maintenance excavation would be executed through mechanical means by the bucket to barge methodology The excavated material would be deposited onto the highground area of a private property located approximately 0 6 mi south of the site commonly known as Aqua Vista Farm owned by Mr Maurice Emmart located at 100 Aqua Vista Drive off Masonboro Road The property owner at this location currently maintains a basin and access channel with a boatramp and diked spoil area measuring approximately 5 acres in size This spoil location has been used as a spoil site for previous maintenance events for this community marina and other facilities in this vicinity of Masonboro Sound The application states the material would be stabilized with proper sedimentation and erosion control measures (See project narrative and Sheets 1 through 4) ANTICIPATED IMPACTS The proposed maintenance dredging would disturb approximately 21 330 sq ft of previously excavated shallow bottom area The project would include the removal of approximately 2 709 cy of material from the existing basin and access channel system Spoil disposal would disturb approximately 70 000 sq ft (1 6 acres) of highground area previously utilized for maintenance events Minor increases in turbidity should be expected during the dredging event however no long term adverse impacts are anticipated Submitted by Robb L Mairs Date 03/02/2012 Office Wilmington CAROLINA MARINE CONSTRUCTION, Inc 3600 E South College Rd PMB 326 Wilmington NC 28412 910 793 4143 fax 794 9909 January 26 2011 To DENR Attn Rob Mairs Rob As per our earlier discussions concerning Masonboro Landing we are applying for a new dredging permit for the Masonboro Landing Homeowners Association They previously had a dredging mayor permit but it was not renewed when the last contractor rebuilt their bulkhead There is approximately 2709 cubic yards of material that needs to be removed to achieve a 7 in the access channel and a 6 in the basin at mean low water We are proposing to remove this material by using a bucket to barge method then place the material at the Aqua Vista site Just to the south Spoil will be placed behind the existing dike walls If you have any questions or need anything further you can reach me on my cell anytime 910 470 6610 Thanks Mike N C DIVISION OF COASTAL MANAGEMENT AGENT AUTHORIZATION FORM Date Z 2 Name of Property Owner Applying for Permit Mailing Address 5L57/ 2 G A rl-A) / i,S t— ;q --' vc/ /t 11lIV67 o— oy6 ? 195 a9, /yJi�'ikcc.e f I certify that I have authorized (agent) �lv�H b U�' 6,V4 to act on my behalf, for the purpose of applying for and obtaining all LAMA Permits necessary to install or construct (activity) at (my property located at) This certification is valid thru (date) J - 112s l 2 Property Owner Slgnature ' Date CAROLINA MARINE CONSTRUCT=ON,Inc. 3600 E South College Rd PMB 326 Wilmington NC 28412 Phone 910 793 4143 Fax 794 9909 December 14 2011 To DENR Attn Rob Mairs I Maurice Emmart do hereby grant permission to Carolina Marine Construction to deposit 2200 cubic yards of material from Tangle Oaks and 700 cubic yards of material from Masonboro Landing on my property at Aqua Vista N/ Elnitl-�16&� Maurice Emmart MOM WFUCATION for Major Development Permit (last revised 12127106) 7LUw,- North Carolina DIVISION OF COASTAL MANAGEMENT 1 Primary Applicant/ Landowner Information Business Name Business Name Project Name (if applicable) Carolina Marine Construction Inc Captains Lane Agent/ Contractor 1 First Name MI Applicant 1 First Name MI Last Name Conard Agent/ Contractor 2 First Name Masonboro Landing HOA Last Name Mailing Address PO Box Applicant 2 First Name MI Last Name PMB 326 If additional applicants please attach an additional page(s) with names listed NC ZIP Mailing Address PO Box City Phone No 2 State 4032 Masonboro Loop Rd Suite 101 910 793 4143 ext Wilmington FAX No NC ZIP Country Phone No Street Address (if different from above) FAX No 28409 USA 910 799 9225 ext Street Address (d different from above) City State ZIP 5625 Captains Lane Wilmington NC 28409 Email Chris Lumpkm [ clumpkin @constructivebwldingsolutions com] 2 Agent/Contractor Information Business Name Carolina Marine Construction Inc Agent/ Contractor 1 First Name MI Last Name Michael B Conard Agent/ Contractor 2 First Name MI Last Name Mailing Address PO Box City State 3600 E South College Rd PMB 326 Wilmington NC ZIP Phone No 1 Phone No 2 28412 910 793 4143 ext ext FAX No Contractor # 910 794 9909 58629 Street Address (if different from above) City State J ZIP Email portcityexecutive @charter net <Form continues on back> 252 808 2808 1 088 4RCOAS3 uvww rnccoasfslma nagernernt re' Form DCM MP 1 (Page 2 of 4) APPLICATION for Major Development Permit 3 Project Location County (can be multiple) Street Address State Rd # New Hanover 5625 Captains Lane d Approximate elevation of tract above NHW (normal high water) or Subdivision Name City State Zip Masonboro Landing Wilmington NC 28409 Phone No Lot No (s) (if many attach additional page with list) ext i Is the proposed project consistent with the applicable zoning? a In which NC river basin is the project located? b Name of body of water nearest to proposed project Cape Fear ICWW 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 Atlantic Ocean 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 residential 4 Site Description a Total length of shoreline on the tract (ft) b Size of entire tract (sq ft ) 126 33 516 sq ft c Size of individual lot(s) d Approximate elevation of tract above NHW (normal high water) or NWL (normal water level) (If many lot sizes please attach additional page with a list) +4 ®NHW or ❑NWL e Vegetation on tract grass & shrubs f Man made features and uses now on tract 6 x 234 floating dock 6 x 20 stationary pier 16 x 16 sundeck 4 x 16 drop down g Identify and describe the existing land uses adjacent to the proposed project site residential homes marsh h How does local government zone the tract? i Is the proposed project consistent with the applicable zoning? residential (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? I 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> 252 806 -2805 P ahav�a+t��a - �r Form DCM MP 1 (Page 3 of 4) APPLICATION for Major Development Permit m (i) Are there wetlands on the site? ®Yes []No (ii) Are there coastal wetlands on the site? ®Yes ❑No (iii) If yes to either (i) or (ii) above has a delineation been conducted? ®Yes []No (Attach documentation if available) n Describe existing wastewater treatment facilities N/A o Describe existing drinking water supply source N/A p Describe existing storm water management or treatment systems N/A 5 Activities and Impacts a Will the protect 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 protect when complete recreational boating fishing 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 Material to be removed in a bucket to barge method with excavator mounted on barge with bin walls Spoil to be hauled to Aqua Vista site unloaded with (2) S 250 Bobcat skid steer loaders d List all development activities you propose remove 2709 cubic yards of material from access channel and basin e Are the proposed activities maintenance of an existing protect new work or both? maintenance for existing protect f What is the approximate total disturbed land area resulting from the proposed protect? 21 330 ®Sq Ft or []Acres g Will the proposed protect 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 surface runoff 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 t Is there any mitigation proposed? ❑Yes ®No ❑NA If yes attach a mitigation proposal s z cM <Form continues on back> 252 808 280,. 1 883 4'Pr A57 01w V nccom�' I -n ann9� m =T%z rel Form DCM MP 1 (Page 4 of 4) APPLICATION for Mayor Development Permit 6 Additonal lnformaton 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) — (t) are always applicable to any mayor development application Please consult the application instruction booklet on how to properly prepare the required items below a A project narrative 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 c A site or location map that is sufficiently detailed to guide agency personnel unfamiliar with the area to the site d A copy of the deed (with state application only) or other instrument under which the applicant claims title to the affected properties e The appropriate application fee Check or money order made payable to DENR 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 mad 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 Mary Holmes Phone No 910 200 9757 Address 5630 Shremaker Lane Name Sarah Merriman Phone No 910 799 3324 Address 5624 Captains Lane Name Phone No Address g A list of previous state or federal perms iss ed for work on thz3Y-93 ct tract Include permit numbers permittee and issuing dates J - TV era4�� � Qqb 5 � r �231tcb6 h Signed consultant or agent authorization form if applicable i Wetland delineation if necessary j A signed AEC hazard notice for projects in oceanfront and inlet areas (Must be signed by property owner) 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 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 the information provided in this application is truthful to the best of y knowledge a Date Print Name Ar, 'r cl �� Signature 7 Ple se indicate application attachments pertaining to your proposed project I CM MP 2 Excavation and Fill Information ❑DCM MP 5 Bridges and Culverts ❑DCM MP 3 Upland Development ❑DCM MP 4 Structures Information 252 808 2R OS 5 � 81 4RCOAST 'UfW cca ^s }a -°1 ,1r4aq me-7 net Z=]A lIglTiVfJJA EXCAVATION and FILL (Except for bridges and culverts) Attach this form to Joint Application for CAMA Major Permit Form DCM MP 1 Be sure to complete all other sections of the Joint Application that relate to this proposed project Please include all supplemental information Describe below the purpose of proposed excavation and /or fill activities All values should be given in feet 1 EXCAVATION El This section not applicable a Amount of material to be excavated from below NHW or NWL in b Type of material to be excavated cubic yards sand loam 2709 Y c (i) Does the area to be excavated include coastal wetlands /marsh d' High ground excavation in cubic yards (CW) submerged aquatic vegetation (SAV) shell bottom (SB) 0 or other wetlands (WL)? If any boxes are checked provide the number of square feet affected ❑CW ❑SAV ❑SB OWL ®None (it) Describe the purpose of the excavation in these areas N/A 12 DISPOSAL OF EXCAVATED MATERIAL ❑This section not applicable a Location of disposal area b Dimensions of disposal area Aqua Vista site c (i) Do you claim title to disposal area? ❑Yes ®No ❑NA (ii) If no attach a letter granting permission from the owner e (i) Does the disposal area include any coastal wetlands /marsh (CW) submerged aquatic vegetation (SAV) shell bottom (SB) or other wetlands (WL)? If any boxes are checked provide the number of square feet affected ❑CW ❑SAV ❑SB OWL ❑None (ii) Describe the purpose of disposal in these areas N/A 200 x 350 d (i) Will a disposal area be available for future maintenance? ®Yes ❑No ❑NA (ii) If yes where? Aqua Vista f (i) Does the disposal include any area in the water? ❑Yes ®No ❑NA (ii) If yes how much water area is affected? 252 808 2808 1 886-ORCOAS`5 r-vvw.r aiacc�astat nanaaw -gent net revised 12 26/06 Access Other Channel Canal Boat Basin Boat Ramp Rock Groin Rock (excluding (NLW or Breakwater shoreline NWL ) stabilization Length 75 235 Width 40 78 Avg Existing 3 4 2 3 NA NA Depth Final Project 7 6 NA NA Depth 1 EXCAVATION El This section not applicable a Amount of material to be excavated from below NHW or NWL in b Type of material to be excavated cubic yards sand loam 2709 Y c (i) Does the area to be excavated include coastal wetlands /marsh d' High ground excavation in cubic yards (CW) submerged aquatic vegetation (SAV) shell bottom (SB) 0 or other wetlands (WL)? If any boxes are checked provide the number of square feet affected ❑CW ❑SAV ❑SB OWL ®None (it) Describe the purpose of the excavation in these areas N/A 12 DISPOSAL OF EXCAVATED MATERIAL ❑This section not applicable a Location of disposal area b Dimensions of disposal area Aqua Vista site c (i) Do you claim title to disposal area? ❑Yes ®No ❑NA (ii) If no attach a letter granting permission from the owner e (i) Does the disposal area include any coastal wetlands /marsh (CW) submerged aquatic vegetation (SAV) shell bottom (SB) or other wetlands (WL)? If any boxes are checked provide the number of square feet affected ❑CW ❑SAV ❑SB OWL ❑None (ii) Describe the purpose of disposal in these areas N/A 200 x 350 d (i) Will a disposal area be available for future maintenance? ®Yes ❑No ❑NA (ii) If yes where? Aqua Vista f (i) Does the disposal include any area in the water? ❑Yes ®No ❑NA (ii) If yes how much water area is affected? 252 808 2808 1 886-ORCOAS`5 r-vvw.r aiacc�astat nanaaw -gent net revised 12 26/06 FOrM MIA 04,1 2 iExccavateor 2nL `fn " -age z. of 2) 3 SHORELINE STABILIZATION ®This section not applicable (If development is a wood groin use MP 4 — Structures) a i ype or snoreune stabilization ❑Bulkhead ❑Riprap ❑Breakwater /Sill ❑Other c Average distance waterward of NHW or NWL e Type of stabilization material g Number of square feet of fill to be placed below water level Bulkhead backfill Riprap Breakwater /Sill Other I Source of fill material b Length Width d Maximum distance waterward of NHW or NWL f (Q Has there been shoreline erosion during preceding 12 months? ❑Yes ❑No ❑NA (u) If yes state amount of erosion and source of erosion amount information h Type of fill material 4 OTHER FILL ACTIVITIES ❑This section not applicable (Excluding Shoreline Stabilization) a (Q Will fill material be brought to the site? ❑Yes ❑No ❑NA b (i) Will fill material be placed in coastal wetlands /marsh (CW) If yes (u) Amount of material to be placed in the water (m) Dimensions of fill area (iv) Purpose of fill submerged aquatic vegetation (SAV) shell bottom (SB) or other wetlands (WL)? If any boxes are checked provide the number of square feet affected ❑CW ❑SAV ❑SB OWL ❑None (u) Describe the purpose of the fill in these areas 5 GENERAL a How will excavated or fill material be kept on site and erosion b What type of construction equipment will be used (e g dragline controlled? backhoe or hydraulic dredge)? behind established dike walls long reach excavator barge with bin walls push boat c (Q Will navigational aids be required as a result of the project? ❑Yes ®No ❑NA (u) If yes explain what type and how they will be implemented d (Q Will wetlands be crossed in transporting equipment to project site? ❑Yes ®No ❑NA (u) If yes explain steps that will be taken to avoid or minimize environmental impacts Date Applicant CA a Applicant Signature Project Name �� r 252 808 2808 1 888 4R OASi vvrtrvu ncc.Jas alcr_anaf, a---rz let r + Z o db 1?0 " �b w O 8d S WU T UO ?Ito Y J h 2 Q. s� timW m n pof �6Y a 2 � Q- `V s n • � h yp \ h \�\ 2°mU \ \ V v I_ _- �Y mWU • � aS I \ LU 1 g 6 1 3 53 z.� \oyl� I m R OWE I I to / I na 3 t Itz i m x 10 � \ /¢(7V101) 66 Ob tS C� gg r W E\a 900£ 2 22 00 90 d 1 3 9D /y 9B Q a r 1� zm $ Qo' o�¢¢ aQ d 5 a omce, 2¢00 all z; { i l V _ � i < -- -J) c —r —I M J K � K �• � 11 ti O -ll � � n -r I 1 � C � 4 tl t 1� 4 V + I � (U t1)e �i !I • }� t jY v fi LM Ll � a J o r c �J a + 1 + � 1 P ! 1� 3 5 � N 1 G '-- �` J t —14" �� E +- 6, rf-mo vcj -Y 23 s ' -7'6 f x rY , r j Lo P x Gf/ <-- i g a ----> L +i 1 1 P% j� mgLd 4--- ft ld i t �tNrS�fe} �(owc— -g k int4ce-161 It �G (h d. f. qcl 0, iL d /S -}3 1 r ^ft�f a Teri <l I „I `�I il4r aC TO NWy ''It, — I - I Lt ` �I) L 4r I`dal !Vf I b 1 �i a, I rAA p ' e'i} r►` lit (i slip 3 I l 'll •� , p E 11A i 6 ! 9 u 'I)� j' # w 1 'IVA I' C VN 11 lip: