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Home My WebLink About20061851 Ver 1_Individual_20061129 ~~ Lowe's Motor Speedway Site Improvements ~n~F~ ~5, Concord, Cabarrus 1~~n rf'?a!T North Carolina ~'~~~ ~ ~ ~ ~ ~ ~~.~EIVED Individual Permit Report And Supporting Documentation Prepared For: Mr. Bob Rourke Speedway Motorsports P.O. Box 600 Concord, NC 28026 Prepared By: Leonard S. Rindner, PWS Environmental Planning Consultant 3714 Spokeshave Lane Matthews, NC 28105 (704) 904-2277 >``;;:. ~~; ;~: ; ~3 Date: November 18, 2006 ~°' ,s .~~`~ `~ ,a-~. ~~,~ 1 :;^~~ev: ,~~:~,: APPLICATION FOR DEPARTMENT OF THE ARMY PERMIT ~ OMB APPROVAL NO. 0710-0003 (33 CFR 3251 Expires December 31, 2004 The Public burden for this collection of information is sastimated to average 10 hours per response, akhough the majorky of applications shows requ-re 5 hours or bsa. This includes the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including wggestiorw for reducing this burden, to Department of Defense, Washington Headqusrten Service Directorate of Information Operations and Reports, 1215 Jefferson Davis Highway, Suke 1204, Arlington, VA 22202-4302; and to the Office of Management and Budget, paperwork Reduction Project (0710-0003), Wsshington, DC 20603. Respondents should be aware that notwithstanding any other provision of law, no person shsN be wbjsct to any penaky for failing to comply with a collection of information if k does not display a currently valid OMB control number. Please DO NOT RETURN your form to either of those addresses. Completed applications must be submitted to the District Engineer having jurisdiction over the bcation of the proposed activity. PRIVACY ACT STATEMENT Authorities: Rivers and Harbors Act, Seetion 10, 33 USC 403; Clean Water Act, Section 404, 33 USC 1344; Msrine Protection ,Research and Sanctwries Act, 33 USC 1413, Section 103. Principal Purpose: Irrformaition provided on this form will be used ~ svalusting the application for a permit. Routine Uses: This information may be shaved with the Department of Justice and other federal, stets, and local government agencies. Submission of requested information is voluntsry, however, it information is not provided the permit application cannot be evaluated nor can a permk be issued. sad activity must be attached to this Ona set of original drawings or good reproducible copies which show the location and character of tfie propo application (see sample drawings and instruetiorrs) and be submitted to the District Engineer having jurisdiction over the location of the proposed activity. An application that is not completed in full wiN be returned. urcuc ~ ruau Q Tn aF FulED BY THE CORPS( 1. APPLICATION N0. ~ 2. FIELD OFFICE CODE 13. DATE RECEIVED 4. D~4T~AF~I.IvATI~N EON~LE~ED 5. APPLICANT'S NAM/E// j~ 8. AUyT~~HORIZED AGENT'S NAME AND TITLE (en agent rs not requi,edl 6. APPLICANT'S ADDRESS 9. AGENT'S ADDRES~ ~~~ ~ `i ~ ~` R ~ "'. iT w Mn.~~j~a~ Lcorla: ~ 5, nd,..crl , , ,. t 'w Rb. F3o~ ~b b 1 UGC-~j~ ~i~C fil":CEIUED a. Residence r b. Business ~U ~{' "~ ~ ~ ~ Z U U a. Residence b. Business "7U ~{' cj~0 `-~ 'LZ-~ -i 11 STATEMENT OF AUTHORIZATION __ _ I hereby authorize, to act in my behalf as my agent in the processing of this application and to tarnish, upon request, supplements) information in support of this permit application. ~~_ ,~~ ~ APPLICANT'S DA NAME, LOCATION AND DESCRIPTION OF PROJECT OR ACTIVITY 12. PROJECT NAME OR TITLE fsee in~suucrionsr I_- (~~~eit.~S ~o~ur S~,e.e~~e/~ ~ ~-ft, (h^(~ruYZv/~G^r~ 13. NAME OF WATERBODY, IF KNOWN ri/eppJiceblel 15. LOCATION OF PROJECT ~~ ha~~~ s COUNTY N~ STATE 14. PROJECT STREET ADDRESS IN eppicntuel F~ ~v~.~t;~ mod. ~~d S~x.cr~w`~ gUv lex~ee~~l - S~ ~(-~-a~'~..~-- ~aS~- 16. OTHER LOCATION DESCRIPTIONS, IF KNOWN, rseeinsauaiw~sl r f / 17. DIRECTIONS 70 THE SITE f h~~S ~~--io ~ o~ U S Z~~ S ~,~ ~ ~-e~~ raC, 4~~d I~'(~~h~oC sf-re~=~" . txl~- ~5 e~ ln~r~~~-- ~~ f~ SI~-~~ ~~~c~I~TO~. R 4 u EDITION OF FEB 94 IS OBSOLETE. (Proponent: CECW-OR3 18. Nature of Activity (~%~n at pro~ecr, induce e/r teerrres~ j~ ~J o s c.~ ~ ~ ~ n~ : ~ Yh~ ~uy~ 2, vY~~'~ _' V ~-~.g~' C,~.~~,~.L 4L ~ p C,~; mPm~~"}' ~` h is ~ r r` ~Jp ! S~ ~~o iJ ~ r r ~ ~~ ~ S ~ ~-~~- (mow ~ ~ ~ ~ ~ ,.~„--Fz~ ~-- ~ ~Q~tci~~ ;,,.,~~~we. m~~' ~ /~.,Ic ~~n-~ v-~ i-'lvr-~-~`~~~~ S -~~-~ ~ 1 w~~ (~v~ 19. Project Purpose me reason or gepnse o> the prom, see insvuc6orrs) -~ CCM'~Pit-~n,~lT^ ~-~ Gm Ce ~~ l an Qom- , ~-j v rc~ v (G~r; S G ~,~ r w 4~-- l ~ ~l ~i~ ~~; ,hm ~Li (-eS . ~~ ~.--(-~r..~~~- ~~-h~ C~'r~o~ s~ ~ ~~-f' do ~~~n~-~~2~ USE BLOCKS 20-22 IF DREDGED ANDlOR F{LL MATERIAL IS TO BE DISCHARGED 20. Reasonls) for Discharge ~ v (/~ ~ M~ (.{~ '~ ./U ~LS-~-p'~. i:, ftJ ~~ `"`~~ ~ fie- -~~'G r ~'' ~ %Ve~~,..~ I~c~~ ,h~~~ ~-~ (~L~u~ (r'~'c~ev~^x I" (~ f /~-~1~./~ ~y~Dt SE"fylc-~ ~i f l i~ ~-~ ~ phi ~Q.~ GLGY VN I h IS'S`" ~ -~- C-ar ~' iS 1 ~ ~Cl,~S ~ (e~yrto~~ (~,r5-~YI (~1 ~Y i G~~ e~ I~'s;s ~C~I ~ ~ ~~ /~ 4~ .; C~~^a~ S~ L ~vr`w~-Fy~ yYl dN~~"z~' 21. Type(s) of Material Being Discharged and the Amount of Each Type in Cubic Yards -jai Uo(~, TZ `fG ~ ti; O o ~ ~~L ~°G:~-d~ S 22. Surface Area in Acres of Wetlands or Other Waters Filled rsee insyudionsJ r ~ YV~Iti}t/r"~ t~ r 7j~ ~ N °~ ~ ~ ~`1 ATP-c.~i l/`-r C~T~ 1~~ I rvwl 23. Is Any Portion of the Work Already Complete? Yes No L IF YES, DESCRIBE THE COMPLETED WORK 24. Addresses of Adjoining Property Owners, Lessees, Etc., Whose Property Adjoins the Waterbody (If more than can be entered here, please attach a supplemental fist), ~.~~ ~ I 25. List of Other Cert~cations or Approvals/Denials Received from other Federal, State or Local Agencies for Work Described in This Application. er,Fnrcv TVPF APPRDVAL• IDENTIFICATION NUMBER DATE APPLIED DATE APPROVED DATE DENIED 'Would include but is not restricted to zoning, building and flood plain permits n ~ 26. Application is hereby made for a permit or permits to authorize the work de ri a rn thi applic n. ertify that the information in this application is complete and accurate. I further certify that f possess the a i to a rk described herein or am acting as the duly authorized agent of the applicant. / ~ l 1 ~~ ~ ~° SIGNATURE OF APPLICANT DATE SIGNATURE OF AGENT DATE The application must be signed by the person who desires to underta the proposed activity (applicant) or it may be signed by a duly authorized agent if the statement in block 11 has been filled out and signed. 18 U.S.C. Section 1001 provides that: Whoever, in any manner within the jurisdiction of any department or agency of the United States knowingly and willfully falsifies, conceals, or covers up any trick, scheme, or disguises a material fact or makes any false, fictitious or fraudulent statements or representations or makes or uses any false writing or document knowing same to contain any false, fictitious or fraudulent statements or entry, shall be fined not more than $10,000 or imprisoned not more than five years or both. LEONARD S. RINDNER, PWS _ Environmental Planning Consultant 3714 Spokeshave Lane Professional Wetland Scientist Matthews, NC 28105 Land Planning (704) 904-2277 November 18, 2006 Mr. Steve Lund US Army Corps of Engineers -Reg. Field Office 151 Patton Avenue -Room 208 Asheville, NC 28801 - 5006 Ms. Cyndi Karoly Division of Water Quality -NCDENR 2321 Crabtree Boulevard, Suite 250 Raleigh, NC 27604 Mr. Alan Johnson NCDENR -Division of Water Quality 610 East Center Street, Suite 301 Mooresville, NC 28115 Re• Lowe's Motor Speedway -Site Improvements - + 1 329 Acres Site Concord Cabarrus Count North Carolina Dear Madame and Sir On behalf of my client, Mr. Bob Rourke of Speedway Motorsports, I am providing you with the following information concerning the proposed site improvements for Lowe's Motor Speedway in Concord, North Carolina. Lowe's Motor Speedway is one of the largest sports facilities in the United States. Approximately 250,000 to 300,000 people from all over the United States attend each of the major NASCAR racing events. Speedway Motorsports and Lowe's Motor Speedway have a tremendous economic impact in the region and North Carolina. The proposed improvements are necessary to facilitate tourism and related functions, expansion of large contiguous areas of parking areas, provide services, and to implement comprehensive stormwater management improvements which include approximately 11 acres of extended stormwater detention wetlands. BACKGROUND Speedway Motorsports is applying for a Department of the Army Permit to discharge fill material into an unnamed tributaries and wetlands of Rocky River (Water Classification C) in the Yadkin River basin to relocate the large concession area from the north side of US Highway 29 to adjacent to the Speedway; to improve safe access and egress into and out of the stadium by eliminating a major constriction; expand parking areas for approximately 3,300 cars; provide tourism and related administrative services; and construct stormwater management facilities. The project includes stormwater treatment for approximately 406 acres of essentially untreated existing development, including the Speedway itself. As a scale reference, the infield of the Speedway itself is larger than a shopping mall. The developer has initiated review with the United States Army Corps of Engineers (Ms. Amanda Jones) and the North Carolina Department of Environment and Natural Resources (Mr. John Dorney) prior to this submittal and has responded to initial comments regarding avoidance, minimization, mitigation requirements and stormwater treatment requirements. The project site is for the most part previously graded and developed consisting of the Lowe's Motor Speedway, parking areas, and other supportive facilities. Based on a field survey the proposed activity will not affect species, or their critical habitat, designated as endangered or threatened pursuant to the Endangered Species Act of 1973. The project is for the most part previously developed and graded. According to the latest published version of the National Register of Historic Places for the presence or absence of registered properties, or properties listed as being eligible for inclusion therein, this site is not registered property or property listed as being eligible for inclusion in the Register. The compensatory mitigation proposal involves an "in lieu payment to the North Carolina Ecosystem Enhancement Program for approximately 2,345 linear feet of perennial stream impacts and approximately 1.25 acres or riparian wetland impacts. The proposed comprehensive stormwater water management plan includes treatment of stormwater runoff within the drainage basins affected by the proposed stream and wetland impacts, which includes approximately 426 acres. Currently there are virtually no significant stormwater treatment devices for Lowe's Motor Speedway and existing surrounding parking areas, including the race track and infield. The proposed plan includes a comprehensive stormwater management plan to treat stormwater runoff in accordance with requirements for projects within 1 mile of the Rocky River, which is a 303d listed stream. Because the project involves large areas of contiguous parking, with consideration of maintenance issues related to the way the parking facilities are utilized by race fans, regional extended stormwater wetlands facilities are the proposed stormwater treatment facilities. In general, the parking areas are used for "tailgating" as well as overnight camping and cooking, often for several weeks. The requested permit has considered an evaluation of the probable and cumulative impacts and its intended use on the public interest. Based on a comprehensive analysis we believe that this proposal complies with the Environmental Protection Agencies' 404(b)(1) guidelines. The economic benefits of this project have been balanced by a mitigation plan to minimize and balance the environmental consequences. The proposal reflects the national concern for both the protection and utilization of important resources. Relevant factors included in the proposal include general environmental concerns, wetlands, cultural values, fish and wildlife values, land use, water quality, considerations of property ownership, and in general, the needs and welfare of the people. SUMMARY OF WATERS OF THE U.S. MethodoloEy Preliminary identification and delineation of the Jurisdictional Waters on the site were determined according to the Corps of Engineers Wetland Delineation Manual, Technical Report Y-87-1, 1987, with Appendices. Preliminary data gathering included review and interpretation of topographic maps; USDA Soil Conservation Survey; aerial photographs, and preliminary site visits to selected areas. Then the Routine On-Site Determination Method was utilized to determine the upper boundary of the wetlands. General Wetland Classification and Description The wetlands on this site can be described as Palustrine Forested Broad and Scrub Shrub -Broad Leaved Temporarily Flooded. They have formed in perched water table conditions, in flat to nearly level areas adjacent to the streams. Other wetlands have formed in former disturbed detention facilities. According to Natural Resource Conservation Service, Technical Guide-Section II-A-2, June 1991, Chewacla soils are listed as Map Units with. inclusions of Hydric Soils in Cabarrus County. Vegetative Communities A vast majority of the unpaved areas of the site include grass parking. The existing grass is primarily Bermuda. The wetland areas and areas adjacent to existing streams areas are primarily are generally forested. All the wetlands and streams are disturbed in various degrees as a result of runoff from existing parking and other developed areas. 3 Bottomland Hardwood/Headwater Forest The headwater wetland areas on this site have developed in the flat to nearly level drainage ways and depressions. Species which occur in these areas Green Ash, Sweetgum, Red Maple, and other typical species that tolerate these wet and shallow root conditions. Common understory trees and shrubs include silky dogwood, willow and alder. Woody vines include poison ivy, and greenbriar. The herbaceous layer is variable based on exposure to light. Species include sedge and rush species, jewelweed, and others. Open Field(other than grass parkin This includes all non-wetland areas dominated by herbaceous plants, such as the cleared right of ways and other disturbed and cleared areas. These have been periodically mowed and are dominated by pasture grasses and perennial herbs including broomsedge, goldenrod, and bush clover. Other areas have been undisturbed for longer and are in transition to dominant species such as blackberry, greenbriar, redcedar, pines, and saplings. Mixed Forest The non-wetland forested areas of the site are dominated by mixed forest. The Mixed Forest is characterized by a mixture of canopy species of pines and hardwoods. Small areas within these forest areas may have a predominance of pine or hardwoods. Pines include shortleaf pine, Virginia pine, and loblolly pine, with eastern redcedar. Hardwoods include pine, sweetgum, red maple, red oak, white oak, tulip poplar, hickory, and other common species. The subcanopy contains saplings and seedlings of canopy species. Other subcanopy species include black cherry, holly, dogwood, elm, and privet. Woody vines common in the understory include poison ivy, muscadine grape, honeysuckle, and other herbaceous and woody species. Hydrophytic Vegetation has been identified according to the National List of Plant Species That Occur in Wetlands: Southeast (Re ig on 2~, US Department of the Interior, Fish and Wildlife Service. Hydric Soils None of the soils are listed as Hydric according to the National List of Hydric Soils, 1991, however inclusions of hydric soils occur within Chewacla (Ch) soils in depressions and level drainage ways. Hydric soils are defined as soils that are saturated, flooded, or ponded long enough during the growing season to develop anaerobic conditions in the upper part. Hydrology Water Classification - C The unnamed tributaries of Rocky River is part of the Yadkin River Basin and currently classified a Class C - aquatic life propagation and survival, fishing, wildlife, secondary recreation, and agriculture. Wetland hydrology is provided by a surface runoff, overbank flooding, seeps, and springs over a clayey subsoil. Jurisdictional Waters of the U.S. and Description 1) Wetland (PFOIA, PSS1A, PEM1C) + 1.38 acres 2) Rocky River and Mallard Creek (+/- 4,000 lf) + 2.75 acres 2) Perennial Stream (4,842 lf) ± 0.69 acres 3) Intermittent Stream (1,281 lf) + 0.02 acres Total Jurisdictional Waters* ± 4.84 acres 4 NO PRACTICABLE ALTERNATIVE/AVOIDANCE ANALYSIS As stated earlier, approximately 200,000 to 300,000 people attend the major NASCAR events at the Lowe's Motor Speedway. In order to provide safe access to the large concession areas by relocating Morehead Road; minimize vehicle/pedestrian conflicts; facilitate safe access and egress from the racetrack for race fans by eliminating a major constriction; provide parking for 3,300 cars (10,000 to 15,000 race fans); develop service and administrative buildings, and to implement the proposed comprehensive stormwater management plan, large contiguous areas must be graded. Reduction of scope was also not considered feasible for the development of the Subject Property. The streams and wetland that are proposed to be impacted are in central areas of the site, leaving potentially available upland areas difficult to access without substantial retaining walls. In order to avoid the streams and wetlands, the site would have to be divided into separate and disjointed parking areas on opposite sides of the stream. Additionally the stream beds and wetlands are much lower than the proposed fmished grades based on engineering requirements (30' to 40' or more). In order to function safely, the slope across parking areas should not exceed 5%. To accomplish this and leave the stream bed undisturbed is impracticable. If the stream were to be saved, it would be located within deep ravines. Retaining walls would have to be located on either side of the stream to make up the grade difference of 30 to 40 feet from the bottom of the stream bed to the proposed fmished elevation of the parking areas. In addition, this would create a very unsafe condition, considering the festival atmosphere that is taking place during the days leading up to the race and race day itself. In order to stay below the Individual Permit threshold of 300 linear feet +/- 5,000 linear feet of retaining walls would have to be constructed. If the average height of the walls was 35 feet, the retaining walls would cost approximately $5,000,000 at a unit price of $25/square foot not including footings. These conditions would cause the objectives of the project to be significantly reduced and not feasible. The Speedway would not be able to relocate the concession area adjacent to the Lowe's Motor Speedway to minimize vehicle and pedestrian conflicts crossing US Highway 29; or provide the required services and parking for its customers, and eliminate a very unsafe pedestrian egress and ingress constriction caused by the proximity of Morehead Road to the Lowe's Motor Speedway. The existing parking areas adjacent to the Speedway are over sealed landfill. In order to properly engineer the approximately 7 acre extended stormwater wetland to capture 258 acres of currently untreated stormwater runoff, including the Speedway itself, it must be in the location depicted on the plans. Locating the stormwater facility offline would conflict with the sealed landfill. In addition, the sealed landfill does not lend itself to structural foundations necessary to construct buildings. To minimize and mitigate for the proposed impacts a comprehensive stormwater management plan has been developed to treat the most utilized areas of the Lowe's Motor Speedway project area. Approximately 406 acres previously untreated stormwater, including the Lowe's Motor speedway itself, will be treated by approximately 11 acres of extended stormwater wetlands. )n addition, mitigation for stream and wetland impacts is proposed to be an "in lieu fee" payment to the NCEEP for 2,345 linear feet of stream and 1.25 acres of wetlands. PROPOSED IMPACTS, MINIMIZATION and MITIGATION Proposed Impacts -Jurisdictional Waters of the U.S. 1) Wetland (PFOIA, PSS1A, PEM1C) ± 1.38 acres 2) Rocky River and Mallard Creek (+/- 4,000 1f) + 0.00 acres 2) Perennial Stream (2,345 lf) ± 0.32 acres 3) Intermittent Stream (597 If) ± 0.05 acres Total Jurisdictional Waters* ± 1.75 acres A mitigation plan is proposed fora "no net loss" of stream habitat, value, and function to the extent feasible on this site. Due to the economic, engineering, and spatial requirements of a development of this magnitude, large contiguous areas must be graded for building pads and parking. However the following Best Management Practices will be employed to minimize impacts to Jurisdictional Waters. These will include: a) Siltation Barriers; Sediment Traps and Diversion Ditches b) Barricades to define construction limits c) Methods to prevent short term impacts will be inspected regularly and maintained during construction of the project. d) Project construction will strictly adhere to an approved Sedimentation and Erosion Control Plan. Best Management Practices will include utilizing siltation trapping ponds and other erosion control structures where appropriate. Impacts from hazardous materials and other toxins to fish and aquatic life such as fuels will be avoided by not permitting staging azeas to be located near surface waters. e) As required by the 401 Water Quality Certification conditions, measures will be taken to prevent "live" or fresh concrete from coming into contact with waters until the concrete has hardened. The developers aze committed to creating an environmentall~ponsible nroiect. Minimization and mitigation measures were developed based on discussions with the USACE, NCDENR. The plan and commitments made in this report reflect a positive response to the preliminary discussions, determinations, and concerns of the regulatory agencies. Except for temporary construction and development impacts, we believe that the proposed project with the proposed mitigation will not cause significant cumulative impacts to the ecological functions or values of Jurisdictional Waters of the United States. MITIGATION PLAN The mitigation plan is proposed to minimize the loss of stream habitat and wetland habitat. The project will also meet State and Local stormwater management requirements. Stream and Wetland Mitigation To meet restoration mitigation requirements for stream and wetland impacts by grading, the developer is proposing to contribute a substantial "in lieu fee" to the North Carolina Ecosytem Enhancement Program. Mitigation is proposed for 2,345 linear feet of stream impacts and l .25 acres of wetland impacts. STORMWATER MANAGEMENT A Stormwater Management Plan will be designed and implemented for the project to meet the 401 Water Quality Certification requirements. Stormwater runoff from impervious surfaces has the potential to degrade water quality in all types of waters. The Stormwater Management Plan will include facilities that will attenuate the first inch of runoff over a 24-hour period from approximately 406 acres of the site. Water will be released over a 2 to 5 day period. Discharge velocity of the outclass will be less than 5 cfs. The stormwater management facilities will meet or exceed the requirements in NCDENR Stormwater Best Management Practices, April 1999. The Storm water Management Plan will also include extended detention stormwater wetlands: Summary - Within the area required to serve as an Extended Detention Wetland the permanent pool of water will be sized as closely as possible using the Table 1.1 in the Stormwater Best Management Practices, NCDENR, April, 1999. - Requirement of the detention of the runoff from the 1 " storm for a period of 2 to 5 days. -Area will include a forebay - 70% of the area required will be designed as a marsh with a depth of 0 - 18", with an equal distribution of area between 0" to 9" and 9" to 18". A small pool area (15% of the required surface area) will be located near the outlet. - It is expected that herbaceous and scrub/shrub wetland species will rapidly volunteer in the area. Many of the recommended species currently exist in the area to be utilized for this function. Supplemental plantings will be selected from Table II.2 in the Stormwater Best Management Practices, NCDENR, April, 1999 based on actual field conditions. Emergent Zone/Aquatic Schedule Use of Existing Hydric Soil, if available Soil from the existing wetland areas that have permitted for impacts will be stripped and stored as feasible for utilization in lining the proposed wetland site. Other topsoil adjacent to the wetlands may also be suitable. Using these existing soils should hasten the development of vegetated cover and hydric soil conditions. This is also an excellent use of an important natural resource. Many of the recommended planted species currently exist in the vicinity of the area to be utilized for this function. The majority of the species in the wetlands include Obligate (OBL) and Facultative Wet (FACW) vegetation. Herbaceous plant species present include Softrush (Juncus effusus), sedge (Carex spp.), Duck potato (Sagitaria latifolia, Arrow arum (Peltandra virginia), Common Three-Square (Scirpus pungens), Touch-me-not (Impatiens capensis), Smartweed (Polygonum spp.), and others. Supplemental plantings will be selected from Table IL2 in the Storm water Best Management Practices, NCDENR, April, 1999 based on actual field conditions, if required. Being that the site is in the vicinity of other wetlands and floodplain areas it is expected that the area will benefit from the natural seed sources available. It is expected that herbaceous and scrub/shrub wetland species will rapidly volunteer in the area. Botanical Name Common Name Size Notes Rushes/Sed~es* Juncus effusus Smooth Needle Rush 2 yr. peat pot 3' O/C. Scirp. americanus Common Three Square 2 yr. peat pot 3' O/C. Acoris calamus Sweet Flag 2 yr. peat pot 3' O/C. * Planting shall be in naturalistic /random clumps to encourage diversity. Size at planting and variety may vary based on availability, cost, and aesthetic objectives. Equal proportions shall be utilized. Final layout of clusters to be field determined based on final surface and ponding conditions. Shallow Water Plants* Peltandra virginica Arrow Arum 2 yr. peat pot 3' O/C. Sagitaria latifolia Duck Potato 2 yr. peat pot 3' O/C. Saururus cernus Lizard's Tail 2 yr. peat pot 3' O/C. Nuphar luteum Spatterdock 2 yr. peat pot 3' O/C. * Planting shall be in naturalistic /random clumps to encourage diversity. Size at planting and variety may vary based on availability, cost, and aesthetic objectives. Equal proportions shall be utilized. Final layout of clusters to be field determined based on fmal surface and ponding conditions. Herbaceous species will be planted in 25 to 50 cm diameter clusters at a density of 1000 clusters per acre or will. be seeded with a wetland seed mix at a rate which will result in coverage of at least 100 stems per square meter upon germination. Survival rates of seeding, roots, and/or individual plants will be explored for each species selected based on availability, site specific data, and cost factors. 7 THREATENED AND ENDANGERED SPECIES Federally listed plant and animal. species with endangered or threatened status are protected under the Endangered Species Act of 1973. The US Fish and Wildlife Service has identified two endangered species - Schweinitz's sunflower (Helianthus schweinitzii), and the Carolina heelsplitter (Lasmigona decorata). Schweinitz's sunflower thrives in full sun characteristic of succession fields, margins, and forested openings. The habitat essentially does not exist on this site, as most of the area is maintained grassed parking. The Carolina heelsplitter is a freshwater mussel which prefers shaded areas either in a ponded portion of a small stream or in runs along steep banks with moderate current. Primary habitat are waters less than three feet deep with a soft mud, muddy sand, or shady gravelly substrate. It is normally restricted to protected silted areas or under banks especially associated with obstructions such as stumps or fallen trees. Its current distribution according to the US Fish and Wildlife Service is limited to portions of two streams -- Goose Creek, Waxhaw Creek, Six Mile Creek -- and the Lynches River originating from rural areas in Union County. Therefore it is not expected to occur on this site. State Protected Species The Carolina Darter (Etheostoma Collis) is a fish that inhabits small streams such as those found in the project area. This species has a federal status of Proposed Special Concern and a state status of Special Concern. The species prefers small clear streams of less than 15' width with moderate to swift current and a sand/gravel benthic composition. It apparently tolerates a wide range of water quality conditions and vegetation types adjacent to the streams and appears resistant to pollution. (E. Menhinick). Therefore, strict adherence to an approved erosion and sedimentation control plan will be maintained during the construction period in order to control degradation of water quality. Cultural Resources Except for existing streams and wetland areas, the site is developed and graded. Aquatic Habitat The aquatic systems in the project area consist of headwater wetlands and intermittent tributaries of Rocky River. A variety of wildlife is supported by these systems including mammals, birds, reptiles, amphibians, fish, insects, mollusks, and crustaceans. Therefore strict adherence to an approved erosion and sedimentation control plan will be maintained during the construction period in order to control. degradation of water quality downstream and protect the areas to be preserved. Short term construction impacts, primarily stream sedimentation will affect aquatic habitat, however this will be minimized to the extent practicable to promote rapid recovery. Project construction will. strictly adhere to an approved sedimentation and erosion control plan. Best Management Practices will include utilizing siltation trapping ponds and other erosion control structures where appropriate. Impacts from hazardous materials and other toxins to fish and aquatic life such as fuels will be avoided by not permitting staging areas to be located near surface waters. Also, as required by the 401 Water Quality Certification conditions, measures will be taken to prevent "live" or fresh concrete from coming into contact with waters until the concrete has hardened. Aquatic resources are expected to be enhanced through the restoration of wetland areas that flood and pond for longer durations. CONCLUSION The Lowe's Motor Speedway provides important economic benefits to the region as well as North Carolina. Over 200,000 to 300,000 people attend the major NASCAR events. Based on the value of the jurisdictional waters and wetlands on this site, the developer has chosen to balance the site's economic viability with its environmental value. The goal of the proposed stormwater treatment and mitigation plan will. to help balance the environmental consequences of this development by restoring and creating beneficial wetland or riparian habitat and enhancing and preserving the Jurisdictional Waters of the U.S. Please contact me if you have any questions or require additional explanation. Thank you for your consideration. Sincerely, Leonard S. Rindner, PWS Environmental Planning Consultant Professional Wetland Scientist cc: Mr. Bob Rourke Speedway Motorsports P.O. Box 600 Concord, NC 28026 9 ~~ ~~ ~4 ~~~ ~~ fi~ ~,~, n~~~ q Speecivray Blrvd ~ ~~~~ ~°'~ G'~ ~~~~~ SITE ~~ ~~~' 4 °"' ~ ~„ ~ aft. ~ ~~ ~ Y ~r ~ ~, ~~ ~'d~ ~f~~~ Unntets~ty ~I~ Ql_vd ~S / '` cr ,'~'`" 'C ..,;~~~$fif• ~~f~~ ~ 2[}[to hhaPGlues#, Inc. LOWES MOTOR SPEEDWAY L F' _~yy L i ~.7,i ~'T-. Phgrrx MIII a Rooky Rtver.. X2006 N'14VTEQ VICINITY MAP SCALE: NTS aims a~ ,_.~_ ~' 64 3', W4x1 ~,anccrd BYP - ~..-, Jackson Parks C'~~~ ~G Lh~ G~' Reb4rta Mlif :~ c r; T` ~.' uy Stallings Rd ta~pozone J; ~ ~ ~ , . ~opyix~t 131 a r nAs kc r! ~,_. ,; . l• ~ , 'f EEDWAY BOULEVARD ~ t''' XI TINE SP E S .~IF ,, - _ . ~-- _._ . ~ i i 1. _ ~ `fi ~,. .~~~ ~ ' ~rr F ~ ... A ~ ~ - ~, - r - - ~ ~ _ 1 f 1 _ / - 'kJ S, ~~ ! ~' ~t t~ 'G3 p Ile ~'1: Rh '~ .. v y y, I _ .5.' ,,. _.. ~. • yr ' 4 . - ^. ( , s ~ i - ~ ~ ~ ~~ -~- .. ~~,.. ~J ,f .~fallar~;:: ~+ ~ ~ ~ 1 , ' ,.~ ~ +~ -.~ it P~J. . - w - , ;~;; re y~ -~ ~ ~,~ .y " i. +.,~- Y` ~ { -erg, i + ~ ~ ~~~ ~ _ _.. .. ` JK ` ' `'~ S .Y ~_ w ul' ` M7K 0 d .6 1.2 1.8 2.4 3 km ~~ d 0.4 0.$ 1.2 1.6 2 mi 35.3531°N, 80.6827°W (NAD27) Charlotte Motor Speedway, USGS Harrisburg (NC) Quadrangle Projection is UTM Zane 17 NAD83 Datum USGS TOPO MAP BOUNDARIES ARE APPROXIMATE -----~• ~ 1 /~ ~', I ~.. ~' ~' t n,, ~- .:.,~.,,~ . ~ . ~ j '~ _` . _ .. ~ ~. ,.~- 1 ~4~ ~.. ~ ~ ~..,~ ~~ PROJECT 1 ,~~ ~ ~- ~~ \ 2 ~ x ~ .. , ~ ~,~~ , ~~ ' '~ .. -~ _ ' ~ ~~ ~~ ~~;,r ~ ~. ~'~ '1. ,, i '~, ~ -'6 ,~ r -~ ~~ ~ ~. „~ - ~ U b ~ , ._ ~ r~ .., ~ ~ ,. ~ , ~ ~ t r ~~'~ mE~a=~ ~ ~ ~ .~ \ \PR~J$CT 3~~ ~~ ~.~~ ~: -~ . ~ ~ ~• , ~ ~ ~ ~~ ~~ ~ - ,` ,`~ ~. ,- , 4 LOWES MOTOR SPEEDWAY SITE MAP SCALE: 1" = 2000' ~J i ., ~ W'ia 4,~ ~. z... jr .. v~~~"' ~f + xsu %1 .e wx~ ~(~ - E / /, , s,., _- '' '~~ ~.~ ;; -> - -' -~ ~~ _ -- ~ ~ -- _ ~~~~ ~1~ ~ ~"~ 1~ y t .~~~ ~~ ~~Y ~~ ~!~~ 3. EXISTING CONCESSION AREA TO BE RELOCATED MINIMIZE PEDESTRIAN/NC HWY CROSSING CONFLICT `~ .----. -_-. J . t_ ~ - `\ ~~~ ~ ~ \ . PROVIDE PARKING AND STORMWATER ` ~ ~ TREATMENT ~~ 3 ~ `Z ~ 1 / \ ~~\ ~ \ i q ~~ , A ~( -- ~. may. ~ ~~ ~,. ~ a -~ r_; ~ `~ ~ ~ _. ,~~~_ _ ~1+ `. ~4..~~ _. .~ d PROVIDE PARKING AND ="'` STORMWATER TREATMENT ::~~.. ~~ ~. >> ~ - - ~~ ;: r ~ :.~ f~ 1 ,. RELOCATE CONCESSION AREA HERE r"_~- ~ '-'~ ~ '' I ~ _ r j, ,_ ~,. t __ ~ RELOCATE MOREHEAD ROAD AWAY FROM SPEEDWAY \~ • IMPROVE SAFE PEDESTRIAN ACCESS EGRESS • CREATE SPACE FOR CONCESSION AREA - . -~ . ,;~ ~,_ _ _ - ,~ _, '~'~ - 1329 AC A - TOTAL SITE AR PROJECT 1-POND 1- DRAINAGE AREA = 26.6 AC PROJECT 2 -POND 2 -DRAINAGE AREA = 258.8 AC PROJECT 3 -POND 3 -DRAINAGE AREA = 100.0 AC PROJECT 3 -POND 4 -DRAINAGE AREA = 21.3 AC TOTAL TREATED A REA. -PROJECTS 1-3 = E 406.7 AC ,~ PROPOSED PARKING s OFFICES/SERVICES ?~ ;1 ~ •-- ..i '~~ `..1~° CONCEPTUAL SITE PLAN OBJECTIVES LOWES MOTOR SPEEDWAY SCALE: 1" = 2000' _.~_/ ~ 1 ..,__ / :! t~ - ,...~, j ' ~ . a~ `... ~. ~, 'to ''m" ~ '~ '; / ~ ,~~~! A ~ ~-' ~ `~ -~~ j ~ ~~ ' ~l '~ _ ~+RROJE i`2 ~~ ~: ' ~TM ~~ ~~ _ .. ,. ___ ,1rr~ ~ - ~ ~_ ~~ ~~ ~,~ 7NN~. ~~~ V ~ ~ _, . _ . _: ,~ PR1~EC'I' ~. ~ _) 3., 'n/ :_ ,~ ~ '~ ~ . /,. ~ -i. • ~_. STORMWATER TREATMENT PROPOSED FOR THIS AREA ~ '~` 'M ' ~ ~ `' TOTAL SITE AREA = 1329 AC PROJECT 1-POND 1- DRAINAGE AREA = 26.6 AC PROJECT 2 -POND 2 -DRAINAGE AREA = 258.8 AC PROJECT 3 -POND 3 -DRAINAGE AREA = 100.0 AC PROJECT 3 -POND 4 -DRAINAGE AREA = 21.3 AC TOTAL TREATED A REA -PROJECTS 1-3 = 406.7 AC LOWES MOTOR SPEEDWAY DRAINAGE AREA MAP SCALE: ~1" = 2000' -___... _ ~ ~, J , 4;, .~ ~ `' `. ~.~ ~ ''y - EXISTING CONCESSIONS AREA ~~( ,. ~, ~ ~ } \, \ ° ~' \ ~`," ~~ \~ ~~ '~ ~\~ ,F \ '' .i `~..--fir ' ` ,- /,, \ is ~j~~' ,~~ ~ ~~ ~~ cl~~~<~~i ~ ~r~`-~f t r ~ ~ j~ r ~~ ~ `~~ .~ ~ `"~ ~ y -f ~ ~. C. .q . - r ~~~ , A~ \~ r ~ ~, ~ ~ ~ ,~' ' 2 i ~ `~~ 'i .. ! ~~ ~' '' ~~'~ '~ r' EXISTING MOREHEAD ROAD ~~ _ _ ~.~ C `~" ~' I II ,~ -~-~-~y -~~ ~ ~ l1 `~, f,, f~ J5 f ~ ` ~ f PROPOSED RELOCATED ~~. ~'~ -`-`~~`'~. ~f~CONCESSION AREA ~~ PROPOSED PARKING AND ~\ ` STORMWATER TREATMENT ~-' ~, 'r`` ~ ~' } ~ `' ~ ~~ v; ~ ~ ~ ~ P ~~ G u,, ~~~ PROPOSED RELOCATED ~ ~ ~'~ ~. ~~ ~ MOREHEAD ROAD tl '~ ~~ 1 ~ ~ ~ ~"~~-" 3 M r; " .. 1 i j ~ ~ ,. 1%' ~~ ~h~~ ~~~'~.. ~, ~~"_ ~~~ ~ f ._ 1 ~ ,. ~. ~• ~;;~-~-- v _ ...A ~~:~.;: ~, ti ~~ .. ! _'.~ • j. ~.. t ~ _! PROPOSED PARKING AND STORMWATER TREATMENT i~ ~ ~ -. ~~~ ` i` i~ w r j ,~ ., 1 .• -"' j~ PROPOSED PARKING AND ' ~ f~ y``-'' "'~ ~'' STORMWATER TREATMENT ,.-:~ OFFICES/SERVICES BLDGS h ``\ ~~~~1 7 ~~ ,' e i .` ~, /. /- EX. INT. STREAM FROM EX. PIPE ~ ~ ROCKY RIVER STORMWATER TREATMENT FOR 26.6 ACRES EXTENDED STORMWATER DET. WETLAND J SURFACE AREA = 0.64 AC ~ 1 .~ NATURALIZED RETENTION POND 0.32 AC ~ L1J i V 1WLL / •` i A .- ~ '~ ±330 LF INT. STREAM IMPACT ~ ~ '~ ~ ~ ~• WETLAND IMPACT 1 ~~ _` ~ _ \ i `, ~ ~ w I `, `•.,~ .i. 1 ~~ ~ '" ~ \~ y ~. A ~ ~' DIRT ~~ , i ' TRACK ~ ~ - EXISTING WETLAND . •~ _. - y ~ . ~ _ _ ±0.06 AC IMPACT _ ' ~ , i ' j>- ~ . r' ±0.02 AC WETLAND .......~ _ ~~ i, i' Qpy ~ ~~ ~. ~~ ~. / ~.~ ~~~- ~. i Gpl~ . ,~ ~ ,.. ~~'° ~~-~,---~ ' ~. ~ • ~ ~. 800 TO 1000 CAR PARKING SPACES ~' i ~ i.. ~ i' i ~. _ ~ i i ~ i ~' ~ ~ PROPOSED SITE PLAN LOWES MOTOR PROJECT 1 SPEEDWAY SCALE: 1" = 300' .` /. wwww .~ /~ /~ wwww w I • / ~''~ ~' ~' /~ ~• ~~ / / , / • / ` / • /•/• ~.~ /. I~ '~ J/• ~' / !/ ~ /' ~4 EXISTING PARKING ON LANDFILL ~' ,/ /./.GO~ ~. /. ~. ~~ i h' G LOWES ~\ !' ~ MOTOR '~ SPEEDWAY ~~ - ~ STREAM IMPACT ±750 LF TO CONSTRUCT ~' `~-- ... EXTENDED STORMWATER WETLAND '~ -TREAT 258 ACRES ' '~ / 1 `~ ~ _ a^. ' _ `~ - __ ~ ~ _. WETZANDS & STR~Iv1 T4~ '~ `BE REZvYIOVED 1 __ - _{ ~ $ DA= 258.8 AC I '~ ~ '~, ~ ~~ r ~,~ _,,=~ ~ ~1/~'I,~. www ` ', ~~• . - 3` wwwwwwwwww ` ~ = w w w w w w w w w w w w ° C ~ ~ .wwwwwwwwww www w ~ i w w w w w w w w w w wwww w j ~ i ,~ www w w w w w wwwww w ,~ ~ www ww www wwwwww ~~ =. g~', ~ ~' w w wwww w w w w w w w w. ~ w w w w w w w w w w w w w ~~ ~ w w w' wwwwwwwwww `r . w w w w w w w w w w w w w w ra ,a w ww wwwww=wwww ' ~ y w w w n w ,. >. ^'-~ - -- °- ~ ~~ ~ B , ,~-~_ ~~~~ , ~, ~° ~~~~~~ ~ `` SURFACE AREA-6.2 AC 3 BUILDINGS & ~~~ ~~ PROPOSED PARKING +/=1300 PARKING SPACES '"` SERVICE/OFFICE BLDGS ~_ / ~ ~ / i , i /i ,~ .` r •• EXISTING PARKING ON LANDFILL ~ ~ ~ • ~ • •,., ~ / ~, / / / - PROPOSED SITE PLAN LOWES MOTOR PROJECT 2 SPEEDWAY SCALE: 1" = 400' ~• ~. i. _ ._. i r_ ~,, ~ z a. ' ~ LOWES MOTOR SPEEDWAY /' ~ .M~ - .E, ~.~ ~ ' ` MOREHEAD ROAD REALIGNMENT •~ ~• •~ ~~ mss' ~ ~ - ;-.,: ~ ~`~` ~~ 1 - ;-~ 267 LF INT. STREAM IMPACT .` .~ ~ ~ `'~. ~~ ~.~~ h'fp ~ ,,,, '" ~j O ~ ,~''".,,,,..,,p SF~ ~ • ~ .' `. ~ eo ~~ ±0.27 AC WETLAND IMPACT _ ~~'F `~ ss~ _.,,,t,,,~, ~ oti ~ ..~.~ ~ , , ' q~ , ' ±800 TO 1000 CAR: PARKING ~•~ ~~,,- --- -~,~' 4 AC PAAHI[JG 800 LF PERENNIAL STREAM IMPACT D~ +~ aso srA FOR CONCESSION AREA ~ ~~~~~~~~ _. _ AND ROAD CROSSING F ~~ _- i _ ~ ~ ~ y a ~ • w w~ww`I~w 1 • w w+ y y 1 1 ~ r ,.: ~ ~ '~$A ` ~~ C ~ _ .. • ~ '~~ S ~C ., . '~iM~i~ i ,> `~ C wwwww ~~~ •~ wwwwwww h wwwwwww ~ `~ w w w w w ww w wwwwwww- w w w w w w w w w w w w STREAM PRESERVED ~ wwwww ; w w+ '+'' . w w w ~ ~ ~ ~\ w AO' w i w www w a .•'~ ~ EXT. STORMWATER WETLANDS ~ 4-0 ACRES ~ ~'" EXTENDED ~• ~ ~~/ DETENTION TO TREAT ±100 ACRES ~ ~ wETInNDS ,` ~~ _ *500 LF STREAM IMPACT ~ ~ ~ PROPOSED SITE PLAN LOWES MOTOR PROJECT 3 SPEEDWAY SCALE: 1" = 400' AERIAL PHOTOGRAPH LOWES MOTOR PROJECT 3 SPEEDWAY SCALE: 1" = 300' ~ ~ O O r 644 640 636 632 ~ ~ f ~~ n O ~ ~ II ~ o~ ~~ 7~.0 ~~ IoI n O M r-ti -+~ O oz ~9 . ~ 628 \ i 824. ~ i ~ EXISTING -~ ~ s2o \ GROUND I 818 812 soa ,~ ~i- PROPOSED POND CATER SURFACE 1 soa ; ~ ~ soo 1 / 596 \ ~ / 592 568 10+00 11+00 12+00 13+00 14+00 15 +00 16+00 6aa Bao ` s3s r b 632 ~~~--~ ~ 626 O O 624 820 [:3[y 612 608 b C/1 O 604 ~~ 800 N ~~ N O ~ 596 ~.~ 592 ~. ~ ~ ~ 568 ~~ ~ C ~ ~~ 584 xo ~ z Sao j 576 10+00 ~ ~ i ~ n ~ ~ ,~ -, ~__ 17+00 72+00 73+00 14+00 15+00 16+00 17+00 18+00 l i r b ~ ~ d ~ o seo 0 866 l- PROPOSED s52 GROUND ExISTING OUNll 54e GR ~ r _ ~ ~ i -~ 5aa _ i b ~~ ~ 1 n eao ' ~ ~ / ~, ~- PROPOSED POND \ % i-~ ~s , _ / % WATER SURFACE ~ _ ~ ~ ~ _ / ~ / ~~~ W 832 ~ O ~ V n 828 i \ ~ Q ~ . ~ 624 ~ ~ ~ ~~ n ~ 620 10+00 11+00 12+00 13+00 14+00 15+00 16+00 17+00 18+00 O x~ oz ~n r ~~ ~o '~ o z '~ ~~ O s it ~'' p I ~~ r~ z .o ~~ II n ga xo oz ~d d 694 690 s82 678 674 670 666 662 656 10+00 „+oo f - -~ ~ PROPOSED GROUND ~~ ~ ~. e ~` J \ ~- ~{ISTING ~ ~ GROUND \ /i ~~ 12+00 13+00 14+00 15+00 18+00 17+00 18+00 11-21-' D6 13:34 FF30M-DENF3 EEP y1y"l15Lbb1 i-~r~c. rnc.~ ~~ ~ ~~1 ...t ll~~ PROGI[AM November 21, 2006 Bob Rourko Speedway Motorsports PO Bo~c 600 Concord, NC 28026 Project: Cowes Motor Speedway County; Cabarrus This 'letter replaces an earlier ono dated Septtmbor 29, ?006. The purpose of this letter is to notify you that the North Carolina Ecosystem Enhancement Program (NCBEP) is willing to acezpt payment for impacts associated with the above referenced project. Please note that this decision does not assure that the payment will be approved by the permit issuing agencies as mitigation for project impacts. It is the responsibility of the applicant to contact theso agencies to dcterrnine if payment to the NC>rEP will be approved. This acceptance is valid for six months >Yorn the date of this letter. If we have ttot receired a copy of the issued 404 Permit/401 Certification wMhin this time Iratne, this acceptance will expire. It is the applicant's responsibility to send copies of the 404/401/CAMA permits to NC SEP. Onec NC 8EP receives a copy of the 404 Pernrit and/or the 401 Certification an invoice will be issued and payment must be made. Based on the information supplied by you the impacts that may roquire compensatory mitigation are summarix~A in the following table, River Basin 'Wetlands Stream Bufftr Suffor Cataloging (Acres) ('Linter Feet) Zone 1 Zone 2 Unit (Sq. Ft.) (S . Ft.) Ri avian Non-% avian Coastal Marsh Cold Cool Warm Yadkin 1.3 0 0 0 0 2,711 0 0 03040105 Upon receipt of payment, EPP will take responsibility for providing the compensatory mitigation for the permitted impacts up to a 2:1 mitigation-to-impact ratio, (buffers. Zone 1 at a 3:1 ratio and Zone 2 at a 1.5:1 ratio). The type and amount of the compensatory mitigation will be as specified in the Section 404 Permit and/or 401 Water Quality Certification, and/or CAMA Permit. The mitigation will be performed in accordance with the Memorandum of Understanding betweon the N. C. Department of Environment and Natural Resources and tho U. S. Army Corps of Engineers dated November 4, 1998. If you have eny questions or need additional information, please contact Kelly Williams at (919) 716-1921. Si cerely, c liam , Crilmorc, PE birector cc: Cyndi Karoly, Wetlands/40] Unit Amanda )ones, USACIr-Asheville Alan ]ones,'DWQ•Mooresville l.,wnard Ridner, agent (fax) Rector ~ ale... ~ .. Pao Ou.,r State ~~ North Carolina Eoosystem Enhancement Program, 18ti2 Mall Service Center, Raleigh, NG 27699-1652! 919.715-0476 lwww.nceep.net Al jpl U-01 so, rl 4 Af air 1� At m JL vo 40 � +swl � �` • •{� �• :ate � . h _ fi' �� ti 14 E ' •y.�•�`' •r :f� � !/` Y' �Stw T°. is � , Nk 40� 91 ILL 41, 41 fp �.:{r:�5ha ��", �r ' •sem �•YI'.i.` y .��'!.� ^�•+. � •• �,�-�� • 1. "V � � , ' I � ✓ -�' � ��r . '+ . �/� p'�, ,,�,► ,, � "�l44 :Ifs•.. • • z �,t. •y.!'' .. / • f�/ / /� 1� �.. ,hit Eli It r A ' l • • � ` �y t f 4' Ir � r � y { ., r. �„� 4, �. r +„t (\, , t k' ��f 'y� ��! �A � � � . j�%�, fi� �' ; t , of �•�.�; IL. • � �� ,'� _ �, , � 1" fit,, � _ �' r '