Loading...
HomeMy WebLinkAbout20090287 Ver 1_CAMA Application_2009031914 l~ NCDENR4? North Carolina Department of Environment and Naturar des Division Beverly Eaves Perdue James H Coastal gement Gelgso Dee Freeman Governor Director kNC? Secretary March 18, 2009 MEMORANDUM: 9 0 2 8 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 Major Permit Application Review Applicant: Cape Fear Boatworks, Inc. / Samuel Long Project Location: off Royster Rd NE, adjacent to the Cape Fear River, in Brunswick Co. Proposed Project: Modification of State Permit 176-06 to construct a 63-slip marina Please indicate below your agency's position or viewpoint on the proposed project and return this form by April 11, 2009. If you have any questions regarding the proposed project, contact Heather Coats at (910) 796-7423, 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 127 Cardinal Drive Ext., Wilmington, NC 28405 Phone: 910-796-72151 FAX: 910-395-3964 Internet: www.nccoastalmanagement.net An Equal Opportunity 1 Affirmative Action Employer NorthCarolina Naturally Form DCM MP-1 (Page 2 of 5) APPLICATION for Major Development Permit 3. Project Location County (can be multiple) Street Address Brunswick 11690 Royster Rd State Rd. # 1431 Subdivision Name City State Zip NA Leland NC 28451 - Phone No. Lot No.(s) (if many, attach additicnal page with list) 910 - 371 - 3460 ext. a. In which NC river basin is the project located? b. Name of body of water nearest to proposed project j Cape Fear Cape Fear River c. Is the water body identified in (b) above, natural or manmade? d. Name the closest major water body to the proposed project site. ®Natural ?Manmade ?Unknown Cape Fear River e. Is proposed work within city limits or planning jurisdiction? f. If applicable, list the planning jurisdiction or city limit the proposed ®Yes ?No work falls within. Town of Navassa, Brunswick County(CAMA Land Use Plan only) 4. Site Description a. Total length of shoreline on the tract (ft.) b. Size of entire tract (sq.ft.) 1227 53.5 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) 14' ?NHW or ®NWL e. Vegetation on tract Fescue/Bermuda on upland. Cladium jamaicense, Typha in coastal marsh area . ? f. Man-made features and uses now on tract - A u Boat lift facility, boat slip, boat maintenance facility, Concrete ramp for forklift g. Identify and describe the existing land uses adjacent to the proposed project site. u >l' s ,4,3 ,z, 3 s`t ) .,. American Distillation, Inc.-Distilss industrial alcohol for reuse. High Rise Service Co., Inc. h. How does local government zone the tract? i. Is the proposed project consistent with the applicable zoning? Industrial (Attach zoning compliance certificate, if applicable) ®Yes ?No ?NA j. Is the proposed activity part of an urban waterfront redevelopment proposal? ?Yes ®No k. es ?No ?NA Has a professional archaeological assessment been done for the tract? If yes, attach a copy. ? hard W. LawreRC'*11aer",' h : om If yes, by w Branch Archaeology I. Is the proposed project located in a National Registered Historic District or does it involve a es 0No ?NA National Register listed or eligible property? m. (i) Are there wetlands on the site? (ii) Are there coastal wetlands on the site? <Form continues on next page> Yes LINO ®Yes ?No (iii) If yes to either (i) or (ii) above, has a delineation been conducted? ®Yes ?No (Attach documentation, if available) Form DCM MP-1 (Page 3 of 5) APPLICATION for Major Development Permit n. Describe existing wastewater treatment facilities. Municipal sewer system o. Describe existing drinking water supply source. Town of Navassa, NC system E = j N p. Describe existing storm water management or treatment systems. Low density development with sheet flow runoff . ?' 11 °' ? 5. Activities and Impacts a. Will the project be for commercial, public, or private use? ®Commercial ?Public/Government ?Private/Community b. Give a brief description of purpose, use, and daily operations of the project when complete. The project is a planned 12'x 144' access pier and docking facilities for as many as 62 boats 26' or more in length, plus upland drystack storage for boats up to 33' in length. Daily operations will be maintenance, fueling and providing water access to customers. 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. Construction will be managed so that there is no impact to the shoreline. A private contractor, experienced in this type of construction will be selected to do the construction of the piers and dock. The proposed piers and docks will be constructed primarily of pilings and lumber pressure treated and rated for marine construction. A professional engineer or a professional marine contractor will design the piers and docks. A drop hammer or steam hammer will drive pilings from a barge in the river or from uplands. No equipment will be placed in the shoreline area during construction. First, the access pier will be constructed. Once the pilings are installed, the access pier structure will be constructed starting from the shore and progress water ward, using the completed portion of the pier (or a small barge) for construction access. d. List all development activities you propose. Construction will be managed so that there is no impact to the shoreline. A private contractor, experienced in this type of construction will be selected to do the construction of the piers and dock. The proposed piers and docks will be constructed primarily of pilings and lumber pressure treated and rated for marine construction. A professional engineer or a professional marine contractor will design the piers and docks. A drop hammer or steam hammer will drive pilings from a barge in the river or from uplands. No equipment will be placed in the shoreline area during construction. First, the access pier will be constructed. Once the pilings are installed, the access pier structure will be constructed starting from the shore and progress water ward, using the completed portion of the pier (or a small barge) for construction access. A three level dry storage structure with a concrete pad will be constructed that will not be located within the AEC area but will be on the property. A stormwater pond, and two sand filter devices will be constructed to treat stormwater. e. Are the proposed activities maintenance of an existing project, new work, or both? new work f. What is the approximate total disturbed land area resulting from the proposed project? 7 ?Sq.Ft or ®Acres g. Will the proposed project encroach on any public easement, public accessway or other area ?Yes ®No ?NA that the public has established use of? h. Describe location and type of existing and proposed discharges to waters of the state. Stormwater runoff will be conveyed by a vegetated swale for Drainage Area 1 to a stormwater detention pond designed according to NC DWQ standards. Stormwater runoff from Drainage Area 2 and 3 will be conveyed by gravity flow to sand filtering devices designed according to NC DWQ standards. DA 1 and 2 will be conveyed to the 404 wetlands. All stormwater runoff will eventually flow into the Cape Fear River. 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 Form DCM MP-1 (Page 4 of 5) APPLICATION for Major Development Permit j. Is there any mitigation proposed? ?Yes ®No ?NA If yes, attach a mitigation proposal. <Form continues on back> 6. Additional Information In addition to this completed application form, (MP-1) the following items below, if applicable, must be submitted in order for the application package to be complete. Items (a) - (t) are always applicable to any major development application. Please consult the application instruction booklet on how to properly prepare the required items below. a. A project narrative. 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 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 Lincoln Development Co., Inc. Wilmington River Club, LLC., Ste 302, 1508 Military Cutoff Rd., Wilmington, NC 28403 Phone No. Address PO Box 2021 PO Box 2021 Wilmington, NC 28402 Name J. Harold Mathews Phone No. Address 10292 Croft Point Lane Leland, NC 28451 Name Town of Navassa Phone No. Address 334 Main St. Navassa, NC 28451 g. A list of previous state or federal permits issued for work on the project tract. Include permit numbers, permittee, and issuing dates. State Stormwater Permit SW8 060324, August 4, 2006 CAMA Permit 176-06, November 6, 2006 CAMA Permit 138-84, July 13, 1984 g IF BI 3 a 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) Form DCM MP-1 (Page 5 of 5) APPLICATION for Major Development Permit 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 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 perrnit. 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 Print Name _Sammuel E. Long, Jr. Signature Please indicate application attachments pertaining to your proposed project. ®DCM MP-2 Excavation and Fill Information ?DCM MP-5 Bridges and Culverts ®DCM MP-3 Upland Development ?DCM MP-4 Structures Information FE-8 3 239 Form DCM MP-2 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. Access Other Channel (NLW or Canal Boat Basin Boat Ramp Rock Groin Rock Breakwater (excluding shoreline NWL stabilization Length Width Avg. Existing NA NA Depth Final Project NA NA Depth 1. EXCAVATION a. Amount of material to be excavated from below NHW or NWL in cubic yards. 0 c. (i) Does the area to be excavated include coastal wetlandsimarsh (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: ®This section not applicable b. Type of material to be excavated. earth(sandy) d. High-ground excavation in cubic yards. 6420 - All for stormwater management 2. DISPOSAL OF EXCAVATED MATERIAL ?This section not applicable a. Location of disposal area. b. Dimensions of disposal area. Onsite Approx. 300'x 500' 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 ?WL ®None (ii) Describe the purpose of disposal in these areas: d. (i) Will a disposal area be available for future maintenance? ®Yes ?No ?NA (ii) If yes, where? on site f. (i) Does the disposal include any area in the water? ?Yes ®No ?NA (P) If yPs, how much water area is affected? 21?f' 3. SHORELINE STABILIZATION [D This section not applicable (If development is a wood groin, use MP-4 - Structures) ?? a tl Y G 'y9 8 bb A?'a?. Farm DCM P>2 (Excavation and Fill, Page 2 of 2) a. Type of shoreline stabilization: b. Length: []Bulkhead ?Riprap []Breakwater/Sill []Other: Width: c. Average distance waterward of NHW or NWL: d. Maximum distance waterward of NHW or NWL: e. Type of stabilization material: f. (i) Has there been shoreline erosion during preceding 12 months? []Yes ?No ?NA (ii) If yes, state amount of erosion and source of erosion amount information. g. Number of square feet of fill to be placed below water level Bulkhead backfill Riprap Breakwater/Sill Other i. Source of fill material. h. Type of fill material. 4. OTHER FILL ACTIVITIES []This section not applicable (Excluding Shoreline Stabilization) a. (i) Will fill material be brought to the site? []Yes ENo ?NA b. (i) Will fill material be placed in coastal wetlands/marsh (CW), If yes, (ii) Amount of material to be placed in the water (iii) 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 ?WL ENone (ii) 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)? Silt fencing until vegetated cover is established. Backhoe or excavator, Dump truck, barges, cranes, pile driver c. (i) Will navigational aids be required as a result of the project? []Yes ®No ?NA (ii) If yes, explain what type and how they will be implemented. d. (i) Will wetlands be crossed in transporting equipment to project site? []Yes ®No ?NA (ii) If yes, explain steps that will be taken to avoid or minimize environmental impacts. ` -/ / -F Date plicant Signature Cape Fear Boatworks, Inc. Project Name Cape Fear Boatworks, Inc. plicant Name y Form DCM MP-3 UPLAND DEVELOPMENT (Construction and/or land disturbing activities) 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. GENERAL UPLAND DEVELOPMENT a. Type and number of buildings, facilities, units or structures b. Number of lots or parcels. proposed. I NA c. Density (give the number of residential units and the units per acre). NA e. If the proposed project will disturb more than one acre of land, the Division of Land Resources must receive an erosion and sedimentation control plan at least 30 days before land-disturbing activity begins. (i) If applicable, has a sedimentation and erosion control plan been submitted to the Division of Land Resources? ®Yes ?No ?NA (ii) If yes, list the date submitted: Required & completed, to be submitted. d. Size of area to be graded, filled, or disturbed including roads, ditches, etc. 7 acres f. List the materials (such as marl, paver stone, asphalt, or concrete) to be used for impervious surfaces. Concrete, Gravel g. Give the percentage of the tract within the coastal shoreline AEC to be covered by impervious and/or built-upon surfaces, such as pavement, building, rooftops, or to be used for vehicular driveways or parking. 0 i. Give the percentage of the entire tract to be covered by impervious and/or built-upon surfaces, such as pavement, building, rooftops, or to be used for vehicular driveways or parking. 14.2% j. Describe proposed method of sewage disposal. Municipal Sewer System 1. Describe location and type of proposed discharges to waters of the state (e.g., surface runoff, sanitary wastewater, industrial/ commercial effluent, "wash down" and residential discharges). Surface runoff from one drainage area will be conveyed by vegetated swale to a stormwater detention pond. Stormwater from the remainder of the drainage basins will be conveyed by gravity flow to sand filters. All stormwater will be conveyed eventually to the Cape Fear River h. Projects that require a CAMA Major Development Permit may also require a Stormwater Certification. (i) Has a site development plan been submitted to the Division of Water Quality for review? ?Yes ®No ?NA (ii) If yes, list the date submitted: k. Have the facilities described in Item (i) received state or local approval? ®Yes ?No ?NA If yes, attach appropriate documentation. m. Does the proposed project include an innovative stormwater design? ®Yes ?No ?NA If yes, attach appropriate documentation. _. f", eiz I If For DC MP- (Upland Development, Page o 2) m. Describe proposed drinking water supply source (e.g., well, community, public system, etc.) Public Water Supply n. (i) Will water be impounded? ®Yes ?No ?NA (ii) If yes, how many acres? Approx. 1 o. When was the lot(s) platted and recorded? p. If proposed development is a subdivision, will additional utilities be In the process of being recorded-will submit when complete installed for this upland development? ?Yes ?No ®NA Date Cape Fear Boatworks, Inc. Project Name Cape Fear Boatworks, Inc. plicant Name P plicant Signature 2009 Form DCM MP-4 STRUCTURES (Construction within Public Trust Areas) 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. 1. DOCKING FACILITY/MARINA CHARACTERISTICS ?This section not applicable a. (i) Is the docking facility/marina: b. (i) Will the facility be open to the general public? ECommercial ?Public/Government ?Private/Community ®Yes ?No c. (i) Dock(s) and/or pier(s) (ii) Number 24 Docks, 1main pier (iii) Length See attached (iv) Width See attached (v) Floating ®Yes ?No e. (i) Are Platforms included? ®Yes ?No If yes: (ii) Number 5 (iii) Length 103', 100', 315' 161' 150' (iv) Width 16, 8, 8, 8, 8 (v) Floating ®Yes ?No Note: Roofed areas are calculated from dripline dimensions. g. (i) Number of slips proposed 62 (ii) Number of slips existing 4 d. (i) Are Finger Piers included? ®Yes ?No if yes: (ii) Number 6 (iii) Length 60',72.5',80.8' ,81.5,815,82' (iv) Width 16' ,8',8',8',8',8' (v) Floating ®Yes ?No f. (i) Are Boatlifts included? ?Yes ®No If yes: (ii) Number (iii) Length (iv) Width h. Check all the types of services to be provided. E Full service, including travel lift and/or rail, repair or maintenance service ® Dockage, fuel, and marine supplies E Dockage ("wet slips") only, number of slips: 62 ® Dry storage; number of boats: 425 ? Boat ramp(s); number of boat ramps: ? Other, please describe: i. Check the proposed type of siting: ? Land cut and access channel ?Open water; dredging for basin and/or channel ®Open water; no dredging required ?Other; please describe: k. Typical boat length: 26' or more m. (i) Will the facility have tie pilings? ?Yes ONo (ii) If yes number of tie pilings? j. Describe the typical boats to be served (e.g., open runabout, charter boats, sail boats, mixed types). Mixed types 26' or more in length 1. (i) Will the facility be open to the general public? ®Yes ?No R`?ail Y ? i 12. DOCKING FACILITY/MARINA OPERATIONS ?This section not applicable ?'° :al 4°r'z 4V a. Check each of the following sanitary facilities that will be included in the proposed project. ® Office Toilets ® Toilets for patrons; Number: 1; Location: Office Building ? Showers ® Boatholding tank pumpout; Give type and location: Edson Model, Fixed station on existing dock, pumps into existing sewage pump station and then to Brunswick county sewer to County POTW b. Describe treatment type and disposal location for all sanitary wastewater. Brunswick County Municipal Treatment C. Describe the disposal of solid waste, fish offal and trash. County Landfill d. How will overboard discharge of sewage from boats be controlled? Not allowed. Signage will be posted conspicuously. Pumpout service will be available e. (i) Give the location and number of "No Sewage Discharge" signs proposed. 80 double facing signs. 1 large sign at beginning of main access pier, 1 sign at beginning of each finger pier, 1 sign at office entrance. (ii) Give the location and number of "Pumpout Available" signs proposed. Same as e. above. f. Describe the special design, if applicable, for containing industrial type pollutants, such as paint, sandblasting waste and petroleum products. All maintenance work will be done within a closed facility and any waste that is nonhazardous shall be disposed of through the landfill and hazrdous waste will be transported for disposal at a permitted treatment land diposal facility. g. Where will residue from vessel maintenance be disposed of? Same as f. above. h. Give the number of channel markers and "No Wake" signs proposed. NA i. Give the location of fuel-handling facilities, and describe the safety measures planned to protect area water quality. Fuel will be supplied from a portable tank trunk(similar to home fuel delivery trucks) and will not be stored adjacent or over the river. A secondary containment area will be provided for parking the truck. Containment will be sized to hold entire contents of truck. Fueling will only be available at the existing dock. Hard piping will be installed from the truck parking location to a dispenser on the dock. j. What will be the marina policy on overnight and live-aboard dockage? Overnight dockage will be permitted but no live-aboard dockage is planned k. Describe design measures that promote boat basin flushing? N/A ., -L 20009 1. If this project is an expansion of an existing marina, what types of services are currently provided? R There is an existing Maintenance faciltiy but not marina. M. Is the marina/docking facility proposed within a primary or secondary nursery area? ?Yes ®No n. Is the marina/docking facility proposed within or adjacent to any shellfish harvesting area? ?Yes ®No o. Is the marina/docking facility proposed within or adjacent to 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. ?m ?SAV ?SB ?WL ENone p. Is the proposed marina/docking facility located within or within close proximity to any shellfish leases? ?Yes ®No If yes, give the name and address of the leasehoider(s), and give the proximity to the lease. 3. BOATHOUSE (including covered lifts) ®This section, not applicable a. (i) Is the boathouse structure(s): ?Commercial ?Public/Government ?Private/Community (ii) Number (iii) Length (iv) Width Note: Roofed areas are calculated from dripline dimensions. 4. GROIN (e.g., wood, sheetpile, etc. If a rock groin, use MP-2, Excavation and Fill.) ®This section not applicable a. (i) Number (ii) Length (iii) Width 5. BREAKWATER (e.g., wood, sheetpile, etc.) ®This section not applicable a. Length b. Average distance from NHW, NWL, or wetlands c. Maximum distance beyond NHW, NWL or wetlands 6. MOORING PILINGS and BUOYS ®This section not applicable a. is the structure(s): b. Number ?Commercial ?Public/Government ?Private/Community c. Distance to be placed beyond shoreline d. Description of buoy (color, inscription, size, anchor, etc.) Note: This should be measured from marsh edge, if present. e. Arc of the swing 7. GENERAL a. Proximity of structure(s) to adjacent riparian property lines 15' Note: For buoy or mooring piling, use arc of swing including length of vessel. c. Width of water body 487 e. (i) Will navigational aids be required as a result of the project? ?Yes ®No ?NA (ii) If yes, explain what type and how they will be implemented. b. Proximity of structure(s) to adjacent docking facilities. N/A d. Wa depth at waterward end of structure at NLW or NWL 'A 112 2005 Q •0 T O v (D r G u Q ? 3 - N CD 7 4?6 W 4h, W (b A CX1 OJ co OD Q) •1 3 (n N N G X X X X X X X X CnCnCn0) n0) nrn ? X X X X -,W -,X X ? 0 0 0 0 0 0 0 0 cn Cn 0) 1 0 -? 1 II 11 II II II II II II O"Ui OO W I I 11 11 If w It O 11 CA N O N 4?-- N .? N A N N Ch co O Cn -IN. O O O W O M O M Cn O co N O S O 0 0 0 0 0 0 0 0 0 O O co O O co O O O cu Q ? O 7h O If cn m .P 41. co .A A O? P TI :? X X X k k k X X _ ? ii Cn.AA4?, UnCnmCn O O O O Cn 0 0 0 0 II 11 If It 11 11 II 11 w c D - -, O N CD 00 (b 07 W Cb ? ? X X X X X - x :j co co co co N Cn 0 O N _ to (11 N 11 A 0 0 0 0 0 0 0 0 0 It I 11 1 11 1 it O 0 0 0 0 0 0 0 0 0 N 4 0 0 0 0 (n W V' vl Cn In P. Cm 0) O) m N N CA O O -P .ty co -P 4?- CD A X X X X X X X X wcaw?.r,U,.4. a 0 0 0 Cl 0 0 0 0 11 11 11 11 11 11 11 11 Cn 1 N - - .p s N N N A C)) 0 O m m OOC)OOOOOCD ,? s U Z Q: m o w p o > N 0 WZ J tz /Wye LL C, "'I" to )(11 i ??. ?l9'titiS M SSLO.tip?'? ? ? % ??Z 0 obu? O' r? I Oo .O ?O a r 3 v ? 0 v°o. 1 _. I ?v v 61 ?O \ O ti N 12.2p p?--? 77 ? v o +I 9 II o y Z 'O d w O W W ii d 'O 7 r+ C 3 R m 0 0 M II Y a- O N O m R V O O LL d Q N U O 1 N O ? IL M d ? A M o rn O ti ?o D a N a 4) m