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HomeMy WebLinkAbout20090649 Ver 1_401 Application_20090609ENVIRONMENTAL PROFESSIONALS INC. PLANNING FORJune 1, 2009 A BETTER ENVIRONMENT NC Division of Water Quality 401 Wetlands Unit p A I 1650 Mail Service Center Raleigh, NC 27699-1650 Re: Nationwide # 18 application submission, Foreman's Inc To Whom It May Concern: 09-0649 E F4 1Q731 111 ? D W L9 1 901 JUN ? 2009 DENR - WATER QUALITY WETLANDS AND STORIAATER BRANCH Please find attached the PCN application and a check for the application fee for a Nationwide #18 permit for our client Foreman's Inc. for the M.G. Brown Lumber Company site at 409 West Queen Street in Edenton, NC. The applicant is applying for fill of 0.1 acres of 404 wetlands for the construction of a new building. The site is an existing lumber yard and hardware store. The application has been also to the US Army Corps of Engineers Washington, NC Regulatory Field Office for review and processing. Mitigation credits have been requested from the Great Dismal Swamp Mitigation Bank. Sincerely, Environmental Pr fession , Inc. Kendall Turnage P.O. BOX 3368 • KILL DEVIL HILLS, NORTH CAROLINA 27948-3368 • 252-441 -0239 FAX: 252-441 -072 1 • EMAIL: environmentalpro@earthlink.net -09-0649 O?OFWATF9?G Office Use Only: Corps action ID no. DWQ project no. Form Version 1.3 Dec 10 2008 Pre-Construction Notification PCN Form A. Applicant Information 1. Processing 1 a. Type(s) of approval sought from the Corps: AL rX it ® Section 404 Permit ? Section 10 Permit 1 b. Specify Nationwide Permit (NWP) number: 18 or General Permit (GP) number: 1c. Has the NWP or GP number been verified by the Corps? ® Yes ? No 1 d. Type(s) of approval sought from the DWQ (check all that apply): ® 401 Water Quality Certification - Regular ? Non-404 Jurisdictional General Permit ? 401 Water Quality Certification - Express ? Riparian Buffer Authorization 1 e. Is this notification solely for the record because written approval is not required? For the record only for DWQ 401 Certification: ? Yes ® No For the record only for Corps Permit: ? Yes ® No 1f. Is payment into a mitigation bank or in-lieu fee program proposed for mitigation of impacts? If so, attach the acceptance letter from mitigation bank or in-lieu fee program. ® Yes ? No 1 g. Is the project located in any of NC's twenty coastal counties. If yes, answer 1 h below. ® Yes ? No 1 h. Is the project located within a NC DCM Area of Environmental Concern (AEC)? ? Yes ® No 2. Project Information 2a. Name of project: M.G. Brown 2b. County: Chowan 2c. Nearest municipality / town: Edenton 2d. Subdivision name: N/A 2e. NCDOT only, T.I.P. or state project no: N/A !? Q Lei D 3. Owner Information u 3a. Name(s) on Recorded Deed: Foreman's Inc. 9 3b. Deed Book and Page No. WATER QuALITy DB 128 page 138 WETtAAUS AND 3c. Responsible Party (for LLC if applicable): Gary Foreman and Clay Foreman 3d. Street address: 1808 Rivershore Road 3e. City, state, zip: Elizabeth City, NC 27909 3f. Telephone no.: 252-335-5454 3g. Fax no.: 252-335-1667 3h. Email address: foremansinc@yahoo.com Page 1 of 11 PCN Form - Version 1.3 December 10, 2008 Version 4. Applicant Information (if different from owner) 4a. Applicant is: ® Agent ? Other, specify: 4b. Name: 4c. Business name (if applicable): 4d. Street address: 4e. City, state, zip: 4f. Telephone no.: 4g. Fax no.: 4h. Email address: 5. AgentlConsultant Information (if applicable) 5a. Name: Kendall Turnage 5b. Business name (if applicable): Environmental Professionals, Inc. 5c. Street address: PO Box 3368 5d. City, state, zip: Kill Devil Hills, NC 27948 5e. Telephone no.: 252-441-0239 5f. Fax no.: 252-441-0721 5g. Email address: environmentalpro@earthiink.net Page 2 of 11 PCN Form - Version 1.3 December 10, 2008 Version B. Project Information and Prior Project History 1. Property Identification 1a. Property identification no. (tax PIN or parcel ID): 780406491408 1 b. Site coordinates (in decimal degrees): Latitude: 36.061111 Longitude: - 76.61778 (DD.DDDDDD) (-DD.DDDDDD) 1 c. Property size: 3.51 acres 2. Surface Waters 2a. Name of nearest body of water (stream, river, etc.) to Fil 's Creek U e,. UT'a14 E e proposed project: , . G - 2b. Water Quality Classification of nearest receiving water: Class B; NSW 2c. River basin: Pa -tank C,1{ O 3. Project Description 3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this application: The site is an operating lumber yard and hardware store. Adjacent land uses are mixed residential and business properties. 3b. List the total estimated acreage of all existing wetlands on the property: 0.43 acres 3c. List the total estimated linear feet of all existing streams (intermittent and perennial) on the property: 471 linear feet of stream frontage on western edge of Filbert's Creek 3d. Explain the purpose of the proposed project: To provide adequate area for 55 ft X 70 ft lumber sales building and minimal additional parking. The fill area is at the upper portion of the wetland area and is not located in a CAMA AEC or coastal wetlands. 3e. Describe the overall project in detail, including the type of equipment to be used: The area will be isolated from the undisturbed wetlands by the constructing the proposed wood retaining wall, the proposed fill area will be supplemented with earthen fill material landward of the retaining wall. The fill area will be allowed to stabilize and the proposed building and additional parking area will be constructed. Stormwater will be allowed to infiltrate in the area landward of the retaining wall and portions of this stormwater will be directed towards the to the lumber yard. This retaining wall will also help to infiltrate the stormwater flow that currentkly flows directly into the wetland area. 4. Jurisdictional Determinations 4a. Have jurisdictional wetland or stream determinations by the Corps or State been requested or obtained for this property / ®Yes ? No ? Unknown project (including all prior phases) in the past? Comments: 4b. If the Corps made the jurisdictional determination, what type ? Preliminary ®Final of determination was made? 4c. If yes, who delineated the jurisdictional areas? Agency/Consultant Company: Environmental Name (if known): Kendall Turnage Professionals, Inc. Other: 4d. If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation. US Army Corps Jurisdictional Determination 200310004 and subsequent site visit by Josh Peletier (the current corps representative for Chowan County to reconfirm the wetland alignment. Page 3 of 11 PCN Form - Version 1.3 December 10, 2008 Version 5. Project History 5a. Have permits or certifications been requested or obtained for this project (including all prior phases) in the past? ®Yes ? No ? Unknown 5b. If yes, explain in detail according to "help file" instructions. CAMA General permit #25785A (bulkhead construction) and CAMA Major permit # 12-03 (bulkhead construction) 6. Future Project Plans 6a. Is this a phased project? ?Yes ® No 6b. If yes, explain. Page 4 of 11 PCN Form - Version 1.3 December 10, 2008 Version C. Proposed Impacts Inventory 1. Impacts Summary 1 a. Which sections were completed below for your project (check all that apply): ® Wetlands ? Streams - tributaries ? Buffers ? Open Waters ? Pond Construction 2. Wetland Impacts If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted. 2a. 2b. 2c. 2d. 2e. 2f. Wetland impact Type of jurisdiction number - Type of impact Type of wetland Forested (Corps - 404, 10 Area of impact Permanent (P) or (if known) DWQ - non-404, other) (acres) Temporary T W1 ®P ? T earthen fill (}etf?,n'??? H?,ra F` '( - ® Yes ? No ® Corps ® DWQ 0.1 r ? Yes ? Corps W2 ? P ? T ? No ? DWQ W3 ? P ? T ? Yes ? No ? Corps ? DWQ W4 ? P ? T ? Yes ? No ? Corps ? DWQ W5 ? P ? T ? Yes ? No ? Corps ? DWQ W6 ? P ? T ? Yes ? No ? Corps ? DWQ 2g. Total wetland impacts 0.1 acre 2h. Comments: 3. Stream Impacts If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this question for all stream sites impacted. 3a. 3b. 3c. 3d. 3e. 3f. 3g. Stream impact Type of impact Stream name Perennial Type of jurisdiction Average Impact number - (PER) or (Corps - 404, 10 stream length Permanent (P) or intermittent DWQ - non-404, width (linear Temporary (T) (INT)? other) (feet) feet) S1 ? P ? T ? PER ? Corps ? INT ? DWQ S2 ? P ? T ? PER ? Corps ? INT ? DWQ S3 ? P ? T ? PER ? Corps ? INT ? DWQ S4 ? P ? T ? PER ? Corps ? INT ? DWQ S5 ? P ? T ? PER ? Corps ? INT ? DWQ S6 ? P ? T ? PER ? Corps ? INT ? DWQ 3h. Total stream and tributary impacts 3i. Comments: Page 5 of 11 PCN Form - Version 1.3 December 10, 2008 Version 4. Open Water Impacts If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of the U.S. then individually list all open water impacts below. 4a. 4b. 4c. 4d. 4e. Open water Name of waterbody impact number - (if applicable) Type of impact Waterbody type Area of impact (acres) Permanent (P) or Temporary T 01 ?P?T 02 ?P?T 03 ?P?T 04 ?P?T 4f. Total open water impacts 4g. Comments: 5. Pond or Lake Construction If and or lake construction proposed, then complete the chart below. 5a. 5b. 5c. 5d. 5e. Wetland Impacts (acres) Stream Impacts (feet) Upland Pond ID I Proposed use or purpose (acres) number of pond Flooded Filled Excavated Flooded Filled Excavated Flooded P1 P2 5f. Total 5g. Comments: 5h. Is a dam high hazard permit required? ? Yes ? No if yes, permit ID no: 5i. Expected pond surface area (acres): 5j. Size of pond watershed (acres): 5k. Method of construction: 6. Buffer Impacts (for DWQ) If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts below. If an impacts require mitigation, then you MUST fill out Section D of this form. 6a. ? Neuse ?Tar-Pamlico ? Other: Project is in which protected basin? ? Catawba ? Randleman 6b. 6c. 6d. 6e. 6f. 6g. Buffer impact number - Reason Buffer Zone 1 impact Zone 2 impact Permanent (P) or for Stream name mitigation (square feet) (square feet) Temporary T im act required? ?Yes 131 ?P?T ? No 62 ? P ? T ? Yes ? No 133 ?P?T ?Yes ? No 6h. Total buffer impacts 6i. Comments: Page 6of11 PCN Form -Version 1.3 December 10, 2008 Version D. Impact Justification and Mitigation 1. Avoidance and Minimization 1 a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project. No other areas exist on the property that are vacant. Adequate area in the lumber yard is required for tractor trailer access, offloading and turn around for exit of the property. No additional buildings have been added to the business since approximately 1987. The fill area is designed at the most upper portion of the wetland area in order to avoid the occasionally innundated areas. 1 b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques. A retaining wall (with geotextile backing) will be constructed in order to provide for a definitive fill limit and containment for any fill. This will prevent filling over the approved fill limits. The stormwater that currently flows directly into the wetland will be forced to infiltrate behind this retaining wall. 2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State 2a. Does the project require Compensatory Mitigation for impacts to Waters of the U.S. or Waters of the State? ® Yes ? No 2b. If yes, mitigation is required by (check all that apply): ® DWQ ® Corps 2c. If yes, which mitigation option will be used for this project? ® Mitigation bank El Payment to in-lieu fee program ? Permittee Responsible Mitigation 3. Complete if Using a Mitigation Bank 3a. Name of Mitigation Bank: Great Dismal Swamp Mitigation Bank 3b. Credits Purchased (attach receipt and letter) Type Riparian Quantity 0.25 acres 3c. Comments: Copy of credit availability inquiry letter to Greart Dismal Swamp Mitigation Bank is attached to this application 4. Complete if Making a Payment to In-lieu Fee Program 4a. Approval letter from in-lieu fee program is attached. ? Yes 4b. Stream mitigation requested: linear feet 4c. If using stream mitigation, stream temperature: ? warm ? cool ?cold 4d. Buffer mitigation requested (DWQ only): square feet 4e. Riparian wetland mitigation requested: acres 4f. Non-riparian wetland mitigation requested: acres 4g. Coastal (tidal) wetland mitigation requested: acres 4h. Comments: 5. Complete if Using a Permittee Responsible Mitigation Plan 5a. If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan. Page 7 of 11 PCN Form -Version 1.3 December 10, 2008 Version 6. Buffer Mitigation (State Regulated Riparian Buffer Rules) - required by DWQ 6a. Will the project result in an impact within a protected riparian buffer that requires buffer mitigation? ? Yes ® No 6b. If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the amount of mitigation required. Zone 6c. Reason for impact 6d. Total impact (square feet) Multiplier 6e. Required mitigation (square feet) Zone 1 3 (2 for Catawba) Zone 2 1.5 6f. Total buffer mitigation required: 6g. If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank, permittee responsible riparian buffer restoration, payment into an approved in-lieu fee fund). 6h. Comments: Page 8 of 11 PCN Form - Version 1.3 December 10, 2008 Version E. Stormwater Management and Diffuse Flow Plan (required by DWQ) 1. Diffuse Flow Plan 1a. Does the project include or is it adjacent to protected riparian buffers identified ? Yes ® No within one of the NC Riparian Buffer Protection Rules? 1 b. If yes, then is a diffuse flow plan included? If no, explain why. ? Yes ? No Comments: 2. Stormwater Management Plan 2a. What is the overall percent imperviousness of this project? Existing 64.6% Proposed 68.3 % 2b. Does this project require a Stormwater Management Plan? ? Yes ® No 2c. If this project DOES NOT require a Stormwater Management Plan, explain why: This is a non residential parcel that is adding less then 10,000 Square feet of new impervious area and does not require a CAMA Major permit. 2d. If this project DOES require a Stormwater Management Plan, then provide a brief, narrative description of the plan: ? Certified Local Government 2e. Who will be responsible for the review of the Stormwater Management Plan? ? DWQ Stormwater Program ? DWQ 401 Unit 3. Certified Local Government Stormwater Review 3a. In which local government's jurisdiction is this project? N/A ? Phase II ? NSW 3b. Which of the following locally-implemented stormwater management programs ? USMP apply (check all that apply): ? Water Supply Watershed ? Other: 3c. Has the approved Stormwater Management Plan with proof of approval been ? Yes ? No attached? 4. DWQ Stormwater Program Review ® Coastal counties ? HQW 4a. Which of the following state-implemented stormwater management programs apply ? ORW (check all that apply): ? Session Law 2006-246 ? Other: 4b. Has the approved Stormwater Management Plan with proof of approval been ? Yes ® No attached? 5. DWQ 401 Unit Stormwater Review 5a. Does the Stormwater Management Plan meet the appropriate requirements? ? Yes ? No 5b. Have all of the 401 Unit submittal requirements been met? ? Yes ? No Page 9 of 11 PCN Form - Version 1.3 December 10, 2008 Version F. Supplementary Information 1. Environmental Documentation (DWQ Requirement) 1a. Does the project involve an expenditure of public (federal/state/local) funds or the ? Yes ® No use of public (federal/state) land? 1 b. If you answered "yes" to the above, does the project require preparation of an environmental document pursuant to the requirements of the National or State ? Yes ? No (North Carolina) Environmental Policy Act (NEPA/SEPA)? 1 c. If you answered "yes" to the above, has the document review been finalized by the State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval ? Yes ? No letter.) Comments: 2. Violations (DWQ Requirement) 2a. Is the site in violation of DWQ Wetland Rules (15A NCAC 2H .0500), Isolated Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards, ? Yes ® No or Riparian Buffer Rules (15A NCAC 2B .0200)? 2b. Is this an after-the-fact permit application? ? Yes ® No 2c. If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s): 3. Cumulative Impacts (DWQ Requirement) 3a. Will this project (based on past and reasonably anticipated future impacts) result in ? Yes ® No additional development, which could impact nearby downstream water quality? 3b. If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the most recent DWQ policy. If you answered "no," provide a short narrative description. 4. Sewage Disposal (DWQ Requirement) 4a. Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of wastewater generated from the proposed project, or available capacity of the subject facility. Wastewater is handled by the Town of Edenton wastewater system Page 10 of 11 PCN Form -Version 1.3 December 10, 2008 Version 5. Endangered Species and Designated Critical Habitat (Corps Requirement) 5a. Will this project occur in or near an area with federally protected species or ? Yes ® No habitat? 5b. Have you checked with the USFWS concerning Endangered Species Act ? Yes ® No impacts? ? Raleigh 5c. If yes, indicate the USFWS Field Office you have contacted. ? Asheville 5d. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical Habitat? US Fish and Wildlife website review of Chowan County listed species 6. Essential Fish Habitat (Corps Requirement) 6a. Will this project occur in or near an area designated as essential fish habitat? ? Yes ® No 6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat? The fill area is not located within section 10 waters 7. Historic or Prehistoric Cultural Resources (Corps Requirement) 7a. Will this project occur in or near an area that the state, federal or tribal governments have designated as having historic or cultural preservation ® Yes ? No status (e.g., National Historic Trust designation or properties significant in North Carolina history and archaeology)? 7b. What data sources did you use to determine whether your site would impact historic or archeological resources? It is near the historical district of Edenton, NC and underwater resources in Edenton Bay but this property is not listed in the National Historical Trust or properties significant in North Carolina history and archeaology. The fill area is not located in the water or Filbert's Creek so underwater archeaological resources will not be impacted. 8. Flood Zone Designation (Corps Requirement) 8a. Will this project occur in a FEMA-designated 100-year floodplain? -Eyes ? No 8b. If yes, explain how project meets FEMA requirements: activity is not located in a V zone and the retaining wall and fill configuration will not substantially alter flow patterns or cause flooding of adjacent properties. 8c. What source(s) did you use to make the floodplain determination? ncfloodmaps.com website s/ 7162y, Applicant/Agent's Printed Name Applicant/Agent' Signatur ' Date (Agent's signature is valid only if an authorization letter from the applicant is provided.) Page 11 of 11 PCN Form - Version 1.3 December 10, 2008 Version Avoidance and Minimization Document Foreman's Inc. Project: M.G. Brown, Edenton, NC The applicant is applying for a Nationwide#18 permit from the US Army Corps and a 401 Certification from the NC Division of Water Quality for impacts to 404 wetlands that will total 4343 Square Feet. The 3.51 acre project site is located at 409 West Queen Street in Edenton, NC. The site is an existing lumber yard and hardware store. The site does not contain an area of available highground that is large enough to site the proposed new building and additional parking. M.G. Brown is the only lumber company that exists near the downtown area of Edenton and has a long history at this site. The site is also in a unique location because of the ability to load lumber directly onto small construction barges for marine construction activities such as building piers, docks, bulkheads and installing mooring pilings. Avoidance The lumber yard was reviewed to see if adequate area existed there for the new building, but the lumber yard is subject to lumber deliveries from tractor trailers and also deliveries of lumber by the companies delivery trucks, so lumber yard must remain accessible and have adequate maneuverable area for these large trucks to enter, unload, turn around and exit the property. No area in the lumber yard was found suitable for the building location. For public safety, the applicant wishes to keep the sales building near the road front to keep the majority of the customers from having to enter the lumber yard, unless specifically picking up lumber materials. The remaining portions of the property are either covered by existing buildings or parking areas. There exists no other area on the site to place the new building. The portion of the wetland fill required for the parking expansion is minimal. The building will occupy the majority of the required fill area to accomplish the project. No expansion to the lumber yard is proposed or is expected in the future. The lumber yard is of adequate size to handle the current demand. The proposed fill area was designed to avoid cypress tree area to the east of the proposed fill location and provides a separation between the proposed development and the surface waters of Filbert's Creek. Minimization The fill area was minimized from the original request by the client. The original proposed building size by the client was 100' X 60'. This building size was reduced to down to 70'X 55' to minimize impacts to the wetland area. A wood retaining wall design was selected in order to avoid any request for wetland fill for the side slopes and to contain the earthen fill material landward of the fill limits. This will also provide an easily recognizable border between the wetlands and highground. This retaining wall will also allow for infiltration of the stormwater that currently flows directly into the 404 wetland area from the parking lot and drive aisle. No room exists on the site for any other type of stormwater infiltration. Mitigation The Great Dismal Swamp Mitigation Bank has been contacted in order to secure a minimum of 0.2 acres of available riparian mitigation credits. A response is forthcoming from this mitigation bank. If no credits are available from this private mitigation bank, the NCEEP will be contacted to supply in lieu fee credits. Payment will be made for the credits prior to any activities in wetlands. Proof of payment will be forwarded to the corps representative prior to impacts. UTHORMATION TO ACT AS REPRESENTATIVE FO Landowner ofrecor authorizes Environmental Professionals, Inc_ to: 1. a er the property to gather environmental and site information, in uding delineation of a ironmental regulatory jurisdictions; 2. r the site with the regulatory agencies (i.e. U.S. Army Corps o: 7 Engineers, N A h Carolina Division of Coastal Management, North Carolina Division of Water ality, etc.) as needed to review regulatory alignment(s) and to i ntify additional re atory jurisdictions; and 3, s mit plats and other information to acquire regulatory agency co fsrmations and/or a royals (U.S. Army Corps of Engineers, North Carolina Divisi of Coastal Management, North Carolina Division of Water Quality, etc.); and 4. p vide authorization for Environmental Professionals, Inc. to act your agent for the p ores of obtaining environmental permits and/or authorizations Iy 11? ?`? L andowner Da Client I Eod ZSS'ON 1 ZLo T "EsZ S F A-iddf1S SN I o i m 31biS-11U 6S : i 0 600E/VT/SO Copyright (C) 1998, Maptech, Inc EMIM)S .111\, - I kL PR1iH'E?:11. PLANNIM FOR A BETTER ENVIRO):NAIENT May 20, 2009 Great Dismal Swamp Mitigation Bank Attn. Gloria Nelson PO Box 6186 ChesapeakeNA 23323 Re: Foreman"s Inc. mitigation requirements/request Dear Ms. Nelson. Our client "Foreman's Inc." has applied for an Army Corps Nationwide #18 permit and a NCDWQ 401 Wetland Certification for the M.G. Brown site in Edenton. NC in the Pasquotank Basin. HUC # 03010205. Please provide us with a letter stating if the Great Dismal Swamp Mitigation Bank has the following available credits for purchase by our client: !Minimum miti-ation credits required by US Army- Corps and NCDWQ: Riparian- 0.2 acres (restoration) Please provide copies of the response to Environmental Professionals. Inc. and our client: Foreman's, Inc. 1808 Rivershore Road Elizabeth City. NC 27909 Environmental Professionals. Inc. vNill forward the credit availability letter to the US Army Corps of Engineers and NCDWQ. Please call if you have any questions regarding this request. Sincerely. Kendall -I'urna-c P.O. BOX 3368 • KILL DEVIL HILLS, NORTH CAROLINA 27948-3368 • 25' -1 I FAX: 252-441-0'21 9 EMAIL: environmentaluro@earthlink.iiet '5ee+ 9 CkQW?tN CC;;iN'Fy? i 00 r r? m x r m a Gf C b -i O Z 0 Z T h 2 r T I ? ? ? m I I D m ? a z H cry z ? 'm a ` ° z F'9 d d td r9 d Z z ? o z z ?- pROPpSep ? ReTAtHI Nc I?q?? A m r D Z ti O m 3 D Z ) I ?? C N ? ICI O n~ m /-7U z 00 n i CD Q m w W n g w L) QOw a Q } ~ 2 U o LLJ Q LL) F < Z O 0? ~ z Ndja ?N? LL o 0? J J? w of z +IZ wwzzQ L U oyo wC W ? zWOof?? z 0 W z mom = of L)0 - ?Y ? awzz o fn n Q ? ZG s E W Q wp Q Ww ? - } ?m ( a z V x W W(rOv m $ j w Q 2 OW r S W c??J U U J CD w (->i a? w w 0 ' U U a 02 = ? w O Z LLJ 0 LLJ O z S C7? w ?? r 5 o C, Z J w MB ?? .cL SO N (J )k? C-A ? ? 4 j t x n J j? p F[? ?' . r ?( ?• 0 N !)NIMVd a3SOMW 6 C, 0 ZNO? 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