Loading...
HomeMy WebLinkAbout20072227 Ver 2_More Info Received_20130822_tear ater C1earWater Environmental Consultants, Inc. August 21, 2013 www.cwenvcom Ms. Karen Higgins DWR, Webscape Unit 1650 Mail Service Center Raleigh, North Carolina 27699 RE: Request for More Information IL Queens Gap — Phase 1 Rutherford County, North Carolina G 2 2013 DWQ Project # 2007 - 2227 -V2 _ Dear Ms. Higgins, Please reference the letter dated July 5, 2013 (Attachment A) sent by the NC Division of Water Quality (DWQ) in response to the permit application submitted by ClearWater Environmental Consultants, Inc. (CEC), on behalf of Rutherford County represented by Mr. Carl Classen. The permit application requested written authorization for the impacts associated with development of the Queens Gap residential subdivision and associated infrastructure. The comments provided by the DWQ are listed and discussed below. DWQ Comment #1: "Re- evaluate Stone Creek and the unnamed tributary to Stone Creek for sediment impacts... and provide a sediment removal plan to address the current sediment impacts, including the McCurry property as proposed in the application." Mr. Clement Riddle of CEC and Mr. Tim Fox of DWQ walked Stone Creek within the Queens Gap property boundary on January 8, 2013. Sediment deposition in that reach is approximately 4 years old. Sediment that was in the stream has flushed and sediment on the stream banks is stable in place with 4 years of vegetative growth. Conditions within Stone Creek remain the same to this date and no action is recommended in this area. CEC conducted an evaluation of the unnamed tributary to Stone Creek, downstream of Queens Gap on the McCurry property, on August 7 and 19, 2013 and recommends the following activities to remove the sediment from the affected areas. The plan as outlined below does not represent a guarantee by Rutherford County to remove sediment from the McCurry property. Commencement of the sediment removal plan is subject to approval by Mr. McCurry, an agreement between Mr. McCurry and Rutherford County which releases the County from liability associated with sediment removal activities, and granting of a temporary access easement by Mr. McCurry so that Rutherford County may legally enter the McCurry property and conduct the proposed activities. • A map of the project site has been attached for review (Figure 1). The locations of the clean-up areas have been identified on the map. 224 South Grove Street, Suite F Hendersonville, NC 28792 828 - 698 -9800 Tel 828 - 698 -9003 Fax Ms. Higgins August 21, 2013 Page 2 of 3 • CEC observed sediment deposition up to approximately 3 feet in two unnamed tributaries to Stone Creek. Prior to sediment removal, three check dams will be placed in the stream channel. The first check dam will be placed immediately downstream of the logging road culvert upstream of the McCurry property. The second check dam will be placed at the McCurry property line where the stream enters the McCurry property. And, the third check dam will be placed at the downstream end of the sediment removal reach upstream of the McCurry pond. Mr. McCurry has erected silt fencing in various locations on his property to try and contain sediment in upland locations. Generally, these silt fences are at capacity. Upland sediment that has been contained by silt fencing will be removed by machine and hauled off the McCurry property and old silt fencing will be removed. Sediment behind silt fences immediately upstream of the McCurry pond will be included in upland sediment removal. After sediment removal, disturbed areas will be matted and seeded. Mr. McCurry has built make -shift dams in the stream channels to contain sediment within the stream channels. Sediment has buried the existing stream channels up to 3 feet making it difficult to determine the original location of the stream channels. The debris dams will be removed. Sediment behind the dams will be removed in phases by machine and water flow will be allowed to define a channel. Additional sediment will be removed from the newly defined channel and hauled off the McCurry property. Areas around the stream channel will be reshaped; and matted and seeded. In locations where a discernible stream channel is present, sediment accumulations will be removed by shovel and bucket. Sediment removed from the channel will be hauled off the McCurry property. After sediment removal activities have occurred, sediment from behind the check dams will be removed. The check dams will remain in place until road work on Queens Gap is complete and stable. Check dams will be monitored regularly and cleaned out as needed. A representative from CEC will be on site periodically to provide oversight during the sediment removal process. There may be a short term minor increase in turbidity during remediation activities; however, turbidity levels should return to normal quickly after the clean-up is complete. Sediment removal, as outlined above, will begin after the road is stable to a point where it is no longer contributing sediment to the McCurry property. The estimated timeframe for starting sediment removal is November 2013; however, this starting timeframe is subject to change. Road work at the sediment removal location is proposed in Phase 2 of the project. Sediment removal will be completed during Phase 2 and before additional land disturbance is started in Phase 3. Ms. Higgins August 21, 2013 Page 3 of 3 • Representative photographs of the site prior to the clean -up are attached for review (Attachment B). Photographs after clean-up will be included in the final report. • A final report will be submitted to Tim Fox and a final inspection site visit will be scheduled within 45 days of completion of the sediment removal activities. The applicant believes the information submitted in this package addresses all issues set forth by the DWQ in their letter dated July 5, 2013. The US Army Corps of Engineers (Corps) will receive a copy of this plan and additional permits from the Corps will be obtained if required. Should you have any questions or comments concerning this project please do not hesitate to contact me at 828 - 698 -9800. Sincerely, -, &A Oi-. Rebekah L. Newton Project Biologist Cc: DWI;, Asheville — Tim Fox US Army Corps of Engineers — Amanda Fuemmeler Queen's Gap -Phase 1 ( +/- 610 Acres) Attachment A DWQ Request for More Information (dated July 5, 2013) x- w� NrS R North Carolina Department of Environment and Natural Resources Division of Water Quality Pat McCrory Thomas A. Reeder Governor Acting Director July 5, 2013 Rutherford County Attn: Carl Classen 289 North Main Street Rutherfordton, NC 28139 Subject: Request for More Information 401 Water Quality Certification Project Name: Queens Gap Phase 1 DWQ Project # 2007 - 2227 -V2 Rutherford County Response deadline: August 5, 2013 Dear Mr. Classen: John E. Skvada, III Secretary The Division of Water Quality (DWQ) has performed a preliminary review of a 401 Water Quality Certification application submitted for the above referenced property. Additional information will be required in order to complete the review process. Please provide the following information so that we may continue to review your project. Additional Information Requested: 1. Re- evaluate Stone Creek and the unnamed tributary to Stone Creek for sediment impacts as identified in NOV- 2009 -PC -0615 and NOV- 2009 -PC -0817 (attached) and provide a sediment removal plan to address the current sediment impacts, including the McCurry property as proposed in the application. Please provide your response in writing to the addresses below prior to August 3, 2013. Four copies of the required information should be provided to the Wetlands, Buffers, Stormwater Compliance and Permitting Unit at: Ms. Karen Higgins WBSCP Unit 1650 Mail Service Center Raleigh, NC 27699 -1650 And a single copy to the Asheville Regional Office at: Location* 2090 U S Highway 70, Swannanoa, North Carolina 28778 Phone: 828 - 2986001 FAX: 828 - 299 -7043 Internet www.naaaterquallty org An rniml ()nnnrhindu 1 Afiirmahva Arhnn Gmninum t Carolina ura!!r� Rutherford County July 5, 2013 Page 2 of 2 Tim Fox Surface Water Protection Section 2090 US HWY 70 Swannanoa, NC 28778 If we do not hear from you by the deadline, we will assume that you no longer want to pursue this project and we will consider the project withdrawn. This letter only addresses the preliminary application review and does not authorize any impacts to wetlands, waters or protected buffers. Please be aware that any impacts requested within your application are not authorized (at this time) by the DWQ. Please call Tim Fog (828) 2964664, if you have any questions. Sincerely, 6Q Chuck Cranford, Regional Supervisor Surface Water Protection Asheville Regional Office Enc: NOV- 2009 -PC -0615 and NOV- 2009 -PC -0817 cc: Clement Riddle — C1earWater Environmental Consultants, Inc. Laura Herbert P.E. — NC DEMLR Steve Kichefski - US Army Corps of Engineers Asheville Field Office David McHenry - North Carolina Wildlife Resources Commission Karen Higgins - WBSCP Unit ARO File copy S:\. SWP\Rutherford WOlsWon- DOI%Queens Gap 2007 - 2227- V2\Addlafo .401QueemGapV2.07 -05 -13 doc NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor September 29, 2009 CERTIFIED MAIL RETURN RECEIPT REQUESTED Queens Gap Burt Baine Division of Water Quality Coleen H. Sullins Director PO Box 30 Rutherfordton, NC 28139 Retum Receipt #: 70071490 0004 0713 7697 Long Mountain 442 Acres, LLC Ryan P. McCarthy PO Box 30 Rutherfordton, NC 28139 Return Receipt #: 70071490 0004 0713 7710 Queen's Gap Investments, LLC Keith Vinson Two Town Square, Suite 320 Asheville, NC 28803 Retum Receipt #: 70071490 0004 0713 7734 Devinshire Land Development, LLC Burt Baine PO Box 30 Rutherfordton, NC 28139 Retum Receipt #: 70071490 0004 0713 7703 Queens Gap Mountain, LLC Louis W. Nanney PO Box 30 Rutherfordton, 28139 Return Receipt #: 70071490 0004 0713 7727 SUBJECT: NOTICE OF VIOLATION and RECOMMENDATION FOR ENFORCEMENT Queens Gap 401 Water Quality Certification - WQC003754 DWQ Tracking Number: NCR000591 NOV- 2009 -PC -0817 and continuing violation NOV- 2009 -PC -0615 Construction Stormwater Permit NCGO 10000 Stream Standard Violation - Other Waste (In- stream sediment) 401 Water Quality Certification (WQC) Conditions Rutherford County Response deadline: October 9, 2009 t ATER PROTECTION SECTION — ASHEVILLE REGIONAL OFFICE : U.S. Highway 70, Swannanoa, North Carolina 28778 1 FAX: 828- 299 -70431 Custo ner Service:1- 877623 -6748 www.ncwaterquaGty.org Opportunity %AffimwM Action Employer t Cull Dee Freeman Secretary Noe Carolina Naturally September 29, 2009 Page 2 of 5 Dear Sirs: On September 15, 2009, Chuck Cranford from the Asheville Regional Office of the Division of Water Quality (DWQ) conducted a site inspection at the Queens Gap development in Rutherford County. Ms. Darlene Kucken (N.C. Division of Land Resources) was present. Prior to leaving the site, a brief conversation was held with Mr. Jim Kiefner. Construction Stormwater Permit NCGO10000, 401 WQC condition, and stream standard violations were noted during the inspection. Sediment impacts to Stone Creek (Classified C/ Tr) were documented. Please note: The DWQ has not received a satisfactory response to NOV- 2009 -PC -0615 dated July 14, 2009. The site conditions requiring the issuance of NOV- 2009 -PC -0615 remained as described in said document and require immediate attention along with the violations noted below. VIOLATIONS I. Construction Stormwater Permit NCGO10000 - A Construction Stormwater Permit (NCGO10000) is issued upon the approval of an Erosion and Sedimentation Control Plan for sites greater than one acre. The NCGO10000 Permit authorizes discharge of stormwater under the National Pollutant Discharge Elimination System (NPDES) in accordance with Title 15 A North Carolina Administrative Code 2H.0100. a. Rain Gauge (Part I. Section B. No. 1.) A rain gauge was not observed on the site at the time of inspection. b. Rain Gauge Data (Part 1. Section B. No. 1.) Rain gauge data, measured daily, has not been made available for review. c. Schedule of Compliance (Part I. Section C. No. 2) Failure to operate and maintain stormwater controls to optimum efficiency as cited by Division of Land Resources Notice of Violation dated September 24, 2009, represents a violation of NCGO10000 Permit. d. Minimum Monitoring and Record Keeping (Part I. Section B. No. 3) Inspection records of erosion & sedimentation control measures and stormwater discharges, collected weekly and after every half-inch or greater rain event, have not been made available for review. e. Final Limitations and Controls for Stormwater Discharges (Part I. Section A. No.2) Failure to follow Erosion Control Plan, as cited in Division of Land Resources Notice of Violation dated September 24, 2009, represents a violation of NCG010000 Permit. f. Twenty -four Hour Reporting (Part II. Section E. No.3) The lack of notification to DWQ regarding sediment loss represents violations of NCGO10000 Permit. II. Stream Standard Violation - Other Waste (In- stream sediment) 15A NCAC 02B .0211 (3)f — Approximately 1,500 feet of Stone Creek (Classified C/Tr) was impacted by the deposition of sediment and gravel measuring from three (3) to twelve (12) inches deep September 29, 2,009 Page's of 5 throughout the stream reach, representing Water Quality Stream Standard violation of 15A NCAC 02B .0211(3) (f) III. 401 WQC Condition Violations — WQC003754, approved on August 26, 2008, specified that the activities must adhere to, among others, the following conditions: Sediment and Erosion Control 2. Erosion and sediment control practices must be in full compliance with all specifications governing the proper design, installation and operation and maintenance of such Best Management Practices in order to protect surface waters standards: a. The erosion and sediment control measures for the project must be designed, installed, operated, and maintained in accordance with the most recent version of the North Carolina Sediment and Erosion Control Planning and Design Manual. b. The design, installation, operation, and maintenance of the sediment and erosion control measures must be such that they equal, or exceed, the requirements specified in the most recent version of the North Carolina Sediment and Erosion Control Manual. The devices shall be maintained on all construction sites, borrow sites, and waste pile (spoil) projects, including contractor -owned or leased borrow pits associated with the project. c. Sufficient materials required for stabilization and/or repair of erosion control measures and stormwater routing and treatment shall be on site at all times. 3. No waste, spoil, solids, or fill of any kind shall occur in wetlands, waters, or riparian areas beyond the footprint of the impacts depicted in the 404/401 Permit Application. All construction activities, including the design, installation, operation, and maintenance of sediment and erosion control Best Management Practices, shall be performed so that no violations of state water quality standards, statutes, or rules occur. REQUIRED RESPONSE This Office requests that you respond in writing by October 9, 2009. Your response should be sent to both the attention of Chuck Cranford, Division of Water Quality, 2090 US HWY 70, Swannanoa, NC 28778 and Mr. John Hennessy at the Wetlands and Stormwater Branch, NPS Assistance and Compliance Oversight Unit, 1617 Mail Service Center, Raleigh, NC 27699 -1617. Your response should address the following items: I. Construction Stormwater Permit NCGO10000 a. Please explain when you anticipate being in full compliance with the NCGO 10000 Permit and your Erosion and Sediment Control Plan. b. Please provide information detailing your compliance with the minimum monitoring and reporting requirements as requested above for each phase of the project. This information must include monitoring records from July 1, 2009 through to the date of your written response to this letter. Specifically, it is September 29, 2009 Page 4 of 5 requested that DWQ be provided a copy of all rain gauge data and weekly inspection/monitoring reports related to your inspections of the approved sedimentation and erosion control facilities and stormwater outfalls. Copies of all corresponding inspections subsequent to rain events greater than 0.5 inches are requested as well. Failure to provide this information will constitute violations of the subject NCG010000 Permit. c. The Permittee (Financially Responsible Party as indicated on Erosion and Sedimentation Control Plan application) is required to sign the inspection form each week, certifying that the report is accurate and complete. The Permittee may authorize a representative to sign these documents (please see Part H Section B (10 b) of the NCGO10000 Permit for proper procedure). d. You should include in your response an explanation of how you propose to prevent the problems noted in this NOV from reoccurring on this project and on future projects. H. Stream Standard - Other Waste (In- Stream Sediment) a. Please provide a map that details the jurisdictional waters on the tract and identifies and quantifies all unpermitted impacts. This map should also indicate any off -site waters that have been impacted. b. Please submit a Sediment Removal/Stream Restoration Plan (Restoration Plan) to this office for review and approval. The Restoration Plan must address removal of the accumulated sediment or other fill from Stone Creek. The Restoration Plan must be submitted to the Division of Water Quality for review and approval prior to implementation. You are encouraged to secure an environmental consultant experienced in stream restoration to assist you with development of the Restoration Plan and authorization necessary to achieve compliance. It is recommended that your consultant contact Chuck Cranford of the Asheville Regional Office for additional guidance during restoration plan development. The Restoration Plan should include the following: • A narrative explaining how sediment will be removed and how impacted jurisdictional waters will be restored. • A proposed schedule with dates that indicate when you expect to begin and complete the removal of sediment. • A diagram of the stream channel, referenced with photo documentation of sediment impacts. • A narrative explaining how sediment will be retained on the site and kept out of waterways, and how restoration activities will be conducted such that turbidity standards are not exceeded. sgpter 29, 3009 d ' s Page 5 of 5 c. Once the Restoration Plan has been implemented and is complete, a final report documenting restoration of the stream should be submitted to Chuck Cranford. III. 401 WQ Certification a. Refer to the items above in I. a. -c. for response requirements. Thank you for your attention to this matter. This Office is considering sending a recommendation for enforcement to the Director of the Division of Water Quality regarding these issues and any future /continued violations that may be encountered. Your above - mentioned response to this correspondence will be considered in this process. This office requires that the violations, as detailed above, be abated immediately. These violations and any future violations are subject to a civil penalty assessment of up to $25,000.00 per day for each violation. Should you have any questions regarding these matters, please contact Chuck Cranford at (828) 296 -4664. Sincerely, U Roger C. Edwards Regional Supervisor Surface Water Protection Section cc: John Hennessy — NPS Assistance and Compliance Oversight Unit ARO File Copy DWQ Central Files Darlene Kucken - Division of Land Resources Jennifer Robertson — WNR (e -copy) 0: \WPDATA\DEMWQ\Ruthaford1401s \Qu =CmpWOV 2009- PC- 0817.doc f. I +r I ,. r a w9-ii' y NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor July 14. 2009 CERTIFIED MAIL RETURN RECEIPT REQUESTED 7007 1490 0004 0798 9234 Burt Baine Queens Gap Mountain, LLC PO Box 30 Rutherfordton, NC 28139 Division of Water Quality Coleen H. Sullins Director SUBJ1?Cl': NOTICE OF VIOLATION and Dee Freeman Secretary CERTIFIED MAIL RETURN RECEIPT REQUESTED 70071490 0004 0798 9241 Keith Vinson Queen's Gap Investments, I,LC 32 Orange Street Asheville, NC 28801 RECOMMENDATION FOR ENFORCEMENT NOV- 2009 -PC -0615 Queens Gap 401 Water Quality Certification - WQC003754 Stream Standard Violation - Other Waste (In- stream sediment) 401 Water Quality Certification (WQC) Conditions Rutherford County Response deadline: July 30, 2009 or 15 days from receipt Uear Messrs. Baine and Vinson: On July 2, 2009. Chuck Cranford from the Asheville Regional Office of the Division of Water Quality (DWQ) conducted a site inspection at the Queens Gap Development in Rutherford County. Mr. Baine, Mr. Jim Kietner. Mr. Bill Beck (Division of Land Resources) and Ms. Darlene Kucken (DI.R) were present. Stream standard and 401 WQC condition violations were noted. Sediment impacts to an unnamed tributary to Stone Creek (Classified C/Tr) were documented. VIOLATIONS I. Stream Standard Violation - Other Waste (In- stream sediment) 15A NCAC 0213.0211 (3)f — An indeterminate length of an unnamed tributary to Stone Creek (classified Crl'r) was impacted by sediment deposition upwards of 24 inches throughout the stream reach, representing Water Quality Stream Standard violation of 15A NCAC 0213 .0211 (3) (t) SURFACE WATER PROTECTION SECTION - ASHEVILLE REGIONAL OFFICE One Location 2090 U.S Highway 70 Swannanoa, North Carolina 28778 NorthCarolina Phone 828- 296 45001 FAX 828.299 -70431 Customer Service 1.877 - 623 -6748 Naw,44711Y Internet www rimaterquality org nn co -A t*oonumry Af(rmatve k w n Employer July 14. 2008 Pave 2 of 4 II. 401 WQC Condition Violations — WQ0003754, approved on August 26, 2008, specified that the activities must adhere to, among others, the following conditions: Sediment and Erosion Control 2. Erosion and sediment control practices must be in full compliance with all specifications governing the proper design, installation and operation and maintenance of such Best Management Practices in order to protect surface waters standards: a. The erosion and sediment control measures for the project must be designed, installed, operated, and maintained in accordance with the most recent version of the North Carolina Sediment and Erosion Control Planning and Design Manual. b. The design, installation, operation, and maintenance of the sediment and erosion control measures must be such that they equal, or exceed, the requirements specified in the most recent version of the North Carolina Sediment and Erosion Control Manual. The devices shall be maintained on all construction sites, borrow sites, and waste pile (spoil) projects, including contractor -owned or leased borrow pits associated with the project. c. Sufficient materials required for stabilization and/or repair of erosion control measures and stormwater routing and treatment shall be on site at all times. 3. No waste, spoil, solids, or fill of any kind shall occur in wetlands, waters, or riparian areas beyond the footprint of the impacts depicted in the 404/401 Permit Application. All construction activities, including the design, installation, operation, and maintenance of sediment and erosion control Best Management Practices, shall be performed so that no violations of state water quality standards, statutes, or rules occur. 4. Sediment and erosion control measures shall not be placed in wetlands or waters without prior approval from the Division. If placement of sediment and erosion control devices in wetlands and waters is unavoidable, design and placement of temporary erosion control measures shall not be conducted in a manner that may result in dis- equilibrium of wetlands or stream beds or banks, adjacent to or upstream and downstream of the above structures. All sediment and erosion control devices they shall be removed and the natural grade restored within two (2) months of the date that the Division of band Resources or locally delegated program has released the project. REQUIRED RESPONSE This Office requests that you respond in writing within 15 days of receipt of this Notice. Your response should be sent to both the attention of Chuck Cranford, Division of Water Quality, 2090 US IiWY 70, Swannanoa, NC 28778 and Mr. John Hennessy at the Wetlands and Stormwater Branch, NPS Assistance and Compliance Oversight Unit, 1617 Mail Service Center. Raleigh, NC 27699 -1617. Your response should address the following items: I. Stream Standard - Other Waste (In- Stream Sediment) ,uuy 14, Juua .Page sof4" a. Please provide a map that details the jurisdictional waters on the tract and identifies and quantifies all unpermitted impacts. This map should also indicate any off -site waters that have been impacted. b. Please submit a Sediment Removal/Stream Restoration Plan (Restoration Plan) to this office for review and approval. The Restoration Plan must address removal of the accumulated sediment or other fill from all impacted waters. The Restoration Plan must be submitted to the Division of Water Quality for review and approval prior to implementation. You are encouraged to secure an environmental consultant experienced in stream restoration to assist you with development of the Restoration Plan and authorization necessary to achieve compliance. It is recommended that your consultant contact Chuck Cranford of the Asheville Regional Office for additional guidance during restoration plan development. The Restoration Plan should include the following: • A narrative explaining how sediment will be removed and how impacted jurisdictional waters will be restored. • A proposed schedule with dates that indicate when you expect to begin and complete the removal of sediment. • A diagram of the stream channel, referenced with photo documentation of sediment impacts. • A narrative explaining how sediment will be retained on the site and kept out of waterways, and how restoration activities will be conducted such that turbidity standards are not exceeded. c. Once the Restoration Plan has been implemented and is complete, a final report documenting restoration of the stream should be submitted to Chuck Cranford. H. 401 WQ Certification a. Refer to the items above in I. a. -c. for response requirements. July 14, 2008 Page 4 of Thank you for your attention to this matter. This Office is considering sending a recommendation for enforcement to the Director of the Division of Water Quality regarding these issues and any future/continued violations that may be encountered. Your above - mentioned response to this correspondence will be considered in this process. This office requires that the violations, as detailed above, be abated immediately. These violations and any future violations are subject to a civil penalty assessment of up to $25,000.00 per day for each violation. Should you have any questions regarding these matters, please contact Chuck Cranford at (828) 2964664. Sincerely, 7TV fr • " h Roger C. Edwards Regional Supervisor Surface Water Protection Section cc: John Hennessy — NPS Assistance and Compliance Oversight Unit ARO File Copy DWQ Central Files Division of Land Resources Jennifer Robertson — WNR (e -copy) 0. \WPDATA\DEMWQ\Ruthc*r&Stomwaw Construction NCO0101na000591queensgap\NOV- 2009 -PC -0615 7- 8- 09.doc Attachment B Representative Photographs #, .01 i w Ys ,+ 9 4,, f 4 { ° � • f w ° • • • • • 1 It"11-71 it w �M In aw r ...ter j ,•.tA �' �"` �j•. {������ . . E��sdwi� 08/19/2013 0 9: 2 /� � /�/ i` \: z \� � \ �� / / � rg- - 11 1 - - - I : a .S kv r i r 8'/19/2013 U9:35 `' Photo 5. Sediment and debris dam. ��.' �. ., �, y, ♦s, '+�''�` - +±may / �� ` .. �. ~ x� V y .Wr+ #'i �'1- "err ^��.. x� .Wr+ 3w •�. � v w.;