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HomeMy WebLinkAbout20160055 Ver 2_CAMA Permit Application_20160617Coastal Management ENVIRONMENTAL QUALITY June 17, 2016 MEMORANDUM: TO: Chad Coburn 401 Wetlands DWR - WiRO PAT MCCRORY Governor DONALD R. VAN DER VAART secretary RECEIVED/NCDENROR JUN 17 2016 Water Quality Regional Operations Section Wilmington Regional Office BRAXTON DAVIS Director FROM: Heather Coats, Assistant Major Permits Coordinator NCDEQ — Division of Coastal Management 127 Cardinal Drive Ext., Wilm., NC 28405 heather. coats(u)ncdenrgov Fax: 395-3964 [Courier 0446-3 SUBJECT: CAMA /Dredge & Fill Application Review Applicant: Quinn Ventures, LLC Project Location: 916 S. Anderson Blvd., adjacent to Topsail Sound, in Topsail Beach, Pender Co. Proposed Project: to fill approx. 1,742 sq. ft. of §404 wetlands and to install a bulkhead along the property shoreline, just above the NHW line Please indicate below your agency's position or viewpoint on the proposed project and return this form to Heather Coats at the address above by July 10, 2016. If you have any questions regarding the proposed project, contact Jason Dail at (910) 796-7221 when appropriate, in-depth comments with supporting data is 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 DATE Nothing Corrparesr State of North Carolina I Environmental Quality I Coastal Management 127 Cardinal Drive Ext., Wilmington, NC 28405 910-796-7215 June 14, 2016 Quinn Ventures, LLC C/o Gary Ange (Agent) 107 Candlewood Drive Wallace, NC 28466 Dear Mr. Ange: PAT MCCRORY r"'Mor DONALD R. VAN DER VAART 1'p(IYI(IY4 BRAXTON DAVIS D "do The Division of Coastal Management hereby acknowledges receipt of your CAIi [A major development permit modification request, submitted on behalf of Quinn Ventures, LLC, requesting authorization under the Rules of the N.C. Coastal Resources Commission for development activities at 916 S. Anderson Boulevard, adjacent to Topsail Sound, in Topsail Beach, Pander County. It was received as complete on June 6, 2016, and appears to be adequate for processing at this time. The projected deadline for making a decision on your permit application is August 20, 2016. An additional 75 -day review period is provided by law when such time is necessary to complete the review. If you have not been notified of a final action by the initial deadline stated above, you should consider the review period extended. Under those circumstances, this letter will serve as your notice of an extended review. However, an additional letter will be provided on or about the 75th day. If this agency does not render a permit decision within 70 days from June 6, 2016, you may request a meeting with the Director of the Division of Coastal Management and permit staff to discuss the status of your project. Such a meeting will be held within five working days from the receipt of your written request and shall include the property owner, developer, and project designer/consultant. NCGS 113A -119(b) requires that Notice of an application be posted at the location of the proposed development. Enclosed you will find a "Notice of Permit Filing" postcard which must be posted at the property of your proposed development. You should post this notice at a conspicuous point along your property where it can be observed from a public road. Some examples would be: Nailing the notice card to a telephone pole or tree along the road right-of-way fronting your property; or ata point along the road right-of-way where a private road would lead one into your property. Failure to post this notice could result in an incomplete application. An onsite inspection will be made, and if additional information is required, you will be contacted by the appropriate State or Federal agency. Please contact me if you have any questions and notify me in writing if you wish to receive a copy of my field report and/or comments from reviewing agencies. erely, s s n Daii, Field Representative cc: WiRO — file Heather Coats, MHC Liz Hair, USACE Joanne Steenhuis, DWR State of North Carolina I Environmental Quality I Coastal Management 127 C9rdinal Drive Ext, Wilmington, NC 28405 919 796 7215 Date R a ILf Name of Property Owner Applying for Permit. MaMgAddress: 'Pv��� ff certat°y that a have authorized (agent) &ary e�j el to rig on my behalf, for the purpose of applying for and obtaining all CAMA Permits necessary to lustall.or construct (activity) at (my property located at) I %r ° Y/s$s,�81 5101 This certification three (date) Bate RECEIVED DCPA WILMINGTON, 4kk 3 MAJOR PERMIT FEE SCHEDULE Quinn Ventures MM39-16 /$400 #1151 /Pender Co. DCM % DWQ % Development Ta Fee 14300160143510009316256253 2430016024351000952341 I. Private, non-commercial development that does not involve the filling or excavation of any wetlands oro en water areas: $250 100%($250) 0%($0) II. Public or commercial development that does not involve the filling or excavation of any wetlands oro en water areas: $400 100%($400) 0%($0) Ill. 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 General Water Quality Certification No. 3490 See attached can be applied: $400 100%($400) 0%($0) III(C). If General Water Quality Certification No. 3490 (see attached) could be applied, but DCM staff determined that additional review and written DWQ concurrence is needed because of concerns related to water quality oraquatic 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/oro en water areas: $475 60%($285) 40%($190) DIVISION OF COASTAL MANAGEMENT FIELD INVESTIGATION REPORT 1. APPLICANT'S NAME: Quinn Ventures, LLC — Major Permit Mod. Request (No. 39-16) 2. LOCATION OF PROJECT SITE: 916 S. Anderson Blvd., adjacent to Topsail Sound, in Topsail Beach, Pender County. Photo Index — 2006:25-6588, N-0 13-15 2000: 25-324, 0-13-15 1995: 25-307, P-14-16 State Plane Coordinates - X: 2979103 Y:1508024 Lat:34°21'53.64"N Long: 77°37'53.69"W 3. INVESTIGATION TYPE: CAMA/Dredge and Fill 4. INVESTIGATIVE PROCEDURE: Dates of Site Visit— 12/15/15 and 5/5/16 Was Applicant Present — No and Yes 5. PROCESSING PROCEDURE: Application Received Complete — 6/06/16 Office - Wilmington 6. SITE DESCRIPTION: (A) Local Land Use Plan - Town of Topsail Beach Land Classification from LUP — Developed / Conservation (B) AEC(s) Involved: EW, PT (C) Water Dependent: Yes (D) Intended Use: Commercial (E) Wastewater Treatment: Existing—None Planned - None (F) Type of Structures: Existing — Existing dilapidated pier and 20' of subsurface wood wall. Planned — "404" type wetland fill and bulkhead (G) Estimated Annual Rate of Erosion: N/A Source - N/A HABITAT DESCRIPTION: [AREA] DREDGED FILLED OTHER (A) Vegetated Wetlands 1,742 sq. ft. ("404" type wetlands) (B) Non -Vegetated Wetlands (Open water) (C) Other — High ground 1,500 sq. ft. (bulkhead installation and back fi11) (D) Total Area Disturbed: 3,242 sq. ft. (0.07 acres) (E) Primary Nursery Area: NO (F) Water Classification: SA Open: NO 8. PROJECT SUMMARY: The applicant proposes to fill approximately 1,742 sq. ft. of "404" type wetlands and install a bulkhead along the property's shoreline, just above the normal high water (NHW) line. Quinn Ventures, LLC — Major Permit Mod. To LAMA Major Permit 39-16 Page Two 9. PROJECT DESCRIPTION: The permittee is requesting approval; through this CAMA major permit modification to State Permit No. 39-16, to allow for the construction of a bulkhead and the tilling of approximately 1,742 sq. ft. of "404" type wetlands. The relative information of the new project is described below. The subject property is located at 916 S. Anderson Blvd., adjacent to Topsail Sound, in Topsail Beach, Pender County. To find the property from the Wilmington Regional Office, take Highway 17 North from Wilmington approximately 20 miles and turn right on N.C. State Highway 210. Travel approximately 2.8 miles to the intersection of NC 210 and NC 50. Turn right onto NC 50/NC 210 and travel approximately 1.9 miles onto Topsail Island. Turn right onto S. Topsail Dr. /NC 50 and travel approximately 6.8 miles to a point approximately 500 feet south of Crews Avenue. The property is not marked; however, it is immediately south of Bush Marina and just north of South Beach Yacht Club. Existing man-made features include what looks to be an old subsurface bulkhead which runs approximately 20' north from the southwestern corner of the property and an old dilapidated pier that spans from the property's shoreline. The high ground portion is elevated approximately 3'-5' above the normal high water (NHW) level. Vegetation on the tract is natural and includes mostly scrub vegetation. A 0.04 acre section of "404" type wetlands exist near the center of the property. This area has been delineated and purportedly confirmed by the US Army Corp of Engineers. In addition, there is a narrow section (6-15' in width) of Coastal Wetlands along the western property boundary that traverses 2/3`d of the shoreline. The property has approximately 75 linear feet of shoreline that is naturally vegetated and stabilized. Water depths in the vicinity of the proposed water dependent structure(s) range from -1. P to -4.5', relative to normal low water (NLW). Residential and commercial properties border the site to the north, south and east and Topsail Sound to the west. The waters of Topsail Sound (adjacent to the project site) are classified as SA by the North Carolina Division of Water Resources. They ARE NOT designated as a Primary Nursery Area (PNA) by the North Carolina Division of Marine Fisheries, and they are CLOSED to the harvest of shellfish. PROPOSED PROJECT: The applicant proposes to fill approximately 1,742 sq. ft. of "404" type wetlands and install a bulkhead along the property's shoreline, just above the normal high water (NIIW) line. As designed, and according to sheet 1 of 1 of the application package, dated received by DCM on June 6, 2016, the applicant intends to extend a bulkhead along the property's western shoreline, bordering Banks Channel. The bulkhead would be located approximately 10' above the location of the normal high water line, and approximately 2'-3' above the upper limits of Coastal Wetlands. Due to a sharp change in elevation (sand berm located just above the normal high water line), the area of Coastal Wetlands on this site is only 6'-15' wide. The proposed wall would tie in, or abut the existing walls located on either side of the applicant's property. The total length of the proposed bulkhead would be approximately 75 linear feet. Following completion of the bulkhead, the applicant proposes to place fill material behind the wall. In addition, the applicant proposed to fill a 1,742 sq. ft. section (or 23' x 76' area) of "404" type wetlands that are centrally located within the "belly" of the property. A delineation of the wetlands boundary has been conducted (by Land Management Group) and has been verified by the US Army Corp of Engineers. Following the proposed fill activities, the applicant proposes to grade the site and prepare for residential development. Quinn Ventures, LLC —Major Permit Mod. To CAMA Major Permit 39-16 Page Three 10. ANTICIPATED IMPACTS: The proposed development would result in the filling of approximately 1,742 sq. ft. of "404" type wetlands and would disturb approximately 1,500 sq. ft. of high ground (bulkhead installation with tie -backs). In total, approximately 3,242 sq. ft. of land area would be disturbed as a result of the project. Submitted by: Jason Dail Date: June 14, 2016 Office: Wilmington Quinn Ventures, LLC 5/26/2016 Our property located at 916 5 Anderson has been granted a CAMA Major Permit, #39-16, to construct a docking/floating pier structure. This is a CAMA Major Modification request to build a new bulkhead and complete a wetland fill of approximately .04 acres. It has verbally been reviewed by NCDEQ and the Corp of Engineers. Regards, /�j�g _ Gary Ange, Agent a! j'i Business Name Project Name (if applicable) WE -H demo , * inr. Ven+v ✓es, L- -C q (> S - F I I — Applicant 1: First Name MI Last Name . KI �\ Qt/jr�JA Applicant 2: First Name MI Last Name If additional applicants, please attach an additional page(s) with names listed. Mailing Address PO Box City State 52L Wow. rorin 9A V11�SG� NC ZIP Country P t o No. FAX No. n! O 39 F C/ /B -Z-�0 - I O O 7 ext. Street Address (if different from above) �l City State ZIP Email Kim P, Wq, 1 r�c . (C/U Business Name Agent/ Contractor 1: First Name MI Last Name &-ary AAe- Agent/ Contractor 2: First Name MI Last Nang Mailing Address PO Box City State l o Card 4' VO 04 D��� v�ll� PPtJG ZIP p' Phone No. 1 Phone No. 2 t) 4� � - - ext. - - ext. FAX No. Contractor # Street Address (if different from above) City State ZIP Email �✓ li I r.'I%{V 1, :,EU ;r.-, <Form continues on back> 252-808-2809 ., 1888-4RCOAS»"d' ,. r�r +rr,nuc+a :asCa§uraasasa�es�sent.eaei Form DCM MP -1 (Page 2 of 4) County (can be multiple) Pr*V Subdivision Name Street Address q16 i APPLICATION for Major Development Permit State Rd'. # Arc@Q�'sa� City State Zip Phone No. &Tl'J ext. a. In which NC river basin is the project located? ��iQ.rn✓ ��/2irr T�'a.� c. Is the water body identified in (b) above, natural or manmade? Natural []Manmade ❑Unknown e. Is proposed work within city limits or planning jurisdiction? 1AYes ❑No 113JZ�R I Nc is -q Lot No.(s) (if many, attach additional page with list) N fit- ' I' b. Name of body of water nearest to proposed project [kms Gbwt ( --Tv SIi I Solid@ d. Name the closest major water bod to the proposed project site. f. If applicable, list the planning jurisdiction or city limit the proposed -{—work falls within... p 4, Site 0e"dottpn a. Total length of shoreline on the tract (ft.) b. Size of entire tract sq.ft.) Zo 6 SF c. Size of individual lot(s) d. Approximate elevation of tract above NHW (normal high water) or aye\. lot izes, with list) NWL (normal water level) 31� � NHW or❑NWL (If many jt/ease attach additional page a "`lll e. Vegetation on tract 1 NbYAU( Grid tY ��G�gro p�y I c� ✓EIC f L Man-made features and uses now on tract KA g. Identify jand .describe �the eexxisytingAtlaaPnd uses add aacceengt to the proposed project site. t Lot - q -;,-cd el A h. How does local government zone the tract? I. Is the proposed project consistent with the applicable zoning? {� I g� (Attach zoning compliance certificate, if applicable) KYes []No []NA j. Is the proposed activity part of an urban waterfront redevelopment proposal? ❑Yes XNo k. Has a professional archaeological assessment been done for the tract? If yes, attach a copy. ❑Yes 4INo ❑NA If yes, by whom? I. Is the proposed project located in a National Registered Historic District or does it involve a ❑Yes XNo [1]NA National Register listed or eligible property? <Form continues on next page> 252-808-2808 „ 1-888-41RCOAST ;. wwvu.�accvastatrnanagerxreretaravf: 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? aa j�1Yes ❑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. N6� Describe the proposed construction methodology, types of construction equipment to be used during construction, the number of each type o. Describeexistingdrinking water supply source. of equipment and where it is to be stored. 1V4 p. Describe existing storm water management or treatment systems. - Nk List all development activities you propose. 5 ActivAtie$and rmpac�s :, a. Will the project be for commercial, public, or private use?❑Commercial ❑Public/Government q� o�,I❑Private/Community)'''r� b. Give a brief description of purpose, use, and daily operations of the project when complete. 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. d. List all development activities you propose. t 2 r '- e. Are the proposed activities maintenance of an existing project, new work, or both? \4 A Ir—w 'Y f. What is the approximate total disturbed land area resulting from the proposed project? r 14- ❑Sq.Ft or,BAcres 11 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. NN i. Will wastewater or stormwater be discharged into a wetland? ❑Yes No [INA If yes, will this discharged water be of the same salinity as the receiving water? ❑Yes XNo ❑NA j. Is there any mitigation proposed? ❑Yes o ❑NA If yes, attach a mitigation proposal. REE- V <Form continues on back> r; s 2Ct116 v U_ 252-808-2808 ;< 1.888-468COAST .. wuu x.r€s:caa ,Ra€rx*arraSe: ngeexi,nefi ,Form DCM MP -1 (Page 4 of 4) a. A project narrative. APPLICATION for Major Development Permit 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. Q. A site or location map that is sufficiently detailed to guide agency personnel unfamiliar with the area to the site. I 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. I 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 ij�rP T S Phone No.�iio VII—hV-71 g. A list of previous state or federal permits issued for work on the project tract. Include permit numbers, permittee, and issuing dates. al --0' 3q— kv 1,'V5T Ito - I h. Signed consultant or agent authorization form, if applicable. r I 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. 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 my knowledge. Date Zy' l� Print Name �� A�Cgiwth �/c n�7c t�esr LAX p—� V SignatureWW_,_ Please indicate application attachments pertaining to your proposed project. ,DCM MP -2 Excavation and Fill Information DDCM MP -5 Bridges and Culverts DDCM MP -3 Upland Development - RIS"'� Ci1J _'tJ ❑DCM MP -4 Structures Information iiv, •.j, ��52-Sfld-�SEt fE 1-$$5d-�$c�£a .t`c.�s'd" .. e�aw w,5x cocs:asfaEanaxaaey r, :rain¢.:r s:i Form ®CNB MP -2 (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. a. Amount of material to be excavated from below NHW or NWL in cubic yards. c. (i) Does the area to be excavated include 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 ❑WL ❑None (ii) Describe the purpose of the excavation in these areas: a. Location of disposal area. b. Type of material to be excavated. d. High -ground excavation in cubic yards. b. Dimensions of disposal area. c. (i) Do you claim title to disposal area? d. (1) Will a disposal area be available for future maintenance? ❑Yes ❑No [INA []Yes; ❑Nc ❑NA (ii) If no, attach a letter granting permission from the owner. (ii) If yes, where? 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 _ ❑WL ❑None (ii) Describe the purpose of disposal in these areas: f. (1) Does the disposal include any area in the water? ❑Yes ❑No ❑NA (ii) If yes, how much water area is affected? .?Cf1T:, Ei\;!l l:ql{ii(J'Ti= i'Jt JUIN r, r ?016 %-88$4RCOAx'r' e:s vmvsu'.nc. �ca:asf'el�n tetly �s5eeat.ae 2 rev'vscsi€ 92:?a? "£3 Access Other Channel Rock (excluding (NLW or Canal Boat Basin Boat Ramp Rock Groin Breakwater shoreline NWL) stabilization Length Width Avg. Existing NA NA Depth Final ProjectNA NA Depth a. Amount of material to be excavated from below NHW or NWL in cubic yards. c. (i) Does the area to be excavated include 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 ❑WL ❑None (ii) Describe the purpose of the excavation in these areas: a. Location of disposal area. b. Type of material to be excavated. d. High -ground excavation in cubic yards. b. Dimensions of disposal area. c. (i) Do you claim title to disposal area? d. (1) Will a disposal area be available for future maintenance? ❑Yes ❑No [INA []Yes; ❑Nc ❑NA (ii) If no, attach a letter granting permission from the owner. (ii) If yes, where? 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 _ ❑WL ❑None (ii) Describe the purpose of disposal in these areas: f. (1) Does the disposal include any area in the water? ❑Yes ❑No ❑NA (ii) If yes, how much water area is affected? .?Cf1T:, Ei\;!l l:ql{ii(J'Ti= i'Jt JUIN r, r ?016 %-88$4RCOAx'r' e:s vmvsu'.nc. �ca:asf'el�n tetly �s5eeat.ae 2 rev'vscsi€ 92:?a? "£3 Foy - (Excavation and Fill, Page 2 of 2) "a. 'Type of shoreline stabilization: Bulkhead ❑Riprap ❑Breakwater/Sill [-]Other:_ C. Average distance waterward of NHW or NWL: Length: 0 Width: d. Maximum distance waterward of NHW or NWL: e. r Type C material: f. (i) Has there been shoreline erosion during preceding 12 Q -p ry months? ❑Yes 10 ❑NA (ii) If yes, st+aie amount of erosion and source of erosion amount information. g. Number of square feet of fill to be placed below water level. Bulkhead backfill ---0.4- Riprap CL— Breakwater/Sill . Other i. Source of fill material. a. (i) Will fill material be brought to the site? If yes, (ii) Amount of material to be placed in the water ry (iii) Dimensions of fill area (iv) Purpose of fill a. How will excavated or fill material be kept on site and erosion controlled? f s-� c. (i) Will nav'gaj�one] aids be required as a result of the project? Oyes ®tAo [INA(ii) If yes, expl m what type and how they will be implemented. h. Type of fill material. s <n' l � �f A'. (1) Will fill material be placed in coastal wetlands/marsh (CW), submerged aquatic vegetation (SAV), shell bottom (SB), or other wetlands (WL)? If any boxes are checked, provide the number ofsquarefeet affected. ' �cvJ,�dl_ ❑SAV ❑SB _ L ' None (ii) Describe the purpose of the fill in these areas c a b. What type of construction equipment will be used (e.g., dmgline backhoe, or hydraulic dredge)? d. (i) Will wetlands ke grossed in transporting equipment to project site? ❑Yes Ido [INA (ii) If yes, explain steps that will be taken to avoid or minimize environmental impacts. 252»806-2808 :r 1-8884RCOAST., www,eacoa.�sfrelraaanrt�xc�s�aveas4.eaeY revised: 12126foo pZ 'sm X100 O N r aARM ' l\�I� Py zo X - z o O �� CJ �Onrbte�'f4P O ["trD p- . •0 q n m �8so K Oz ,o n FA O r p � n7 14 Qw >0 ��p aacra� m 00 1+�� `r� r wO m-„ C) ZU -9 41 n 'sm X100 O N r aARM ' l\�I� Py zo X - z o O �� CJ �Onrbte�'f4P O ["trD p- . •0 q n m �8so K Oz ,o n FA