Loading...
Item J13 J.13 �` CountCounty ��Monroe. ,y, ? "tr, BOARD OF COUNTY COMMISSIONERS y M T� \�1a� Mayor Michelle Coldiron,District 2 �1 1 nff `_ll Mayor Pro Tem David Rice,District 4 -Ile Florida.Keys Craig Cates,District 1 Eddie Martinez,District 3 w Mike Forster,District 5 County Commission Meeting January 20, 2021 Agenda Item Number: J.13 Agenda Item Summary #7695 BULK ITEM: No DEPARTMENT: Building TIME APPROXIMATE: STAFF CONTACT: Karl Bursa(305) 453-8759 10:00 AM AGENDA ITEM WORDING: Update on the Federal Emergency Management Agency (FEMA) Preliminary Flood Insurance Rate Maps (FIRMS)published notice to open comments and appeals of the proposed updates to Monroe County's FIRMS in the Federal Register, the appeal process, Woods Hole Group Findings and the required Comprehensive Plan and Land Development Code amendments necessary because of new FIRM maps. ITEM BACKGROUND: As part of the Federal Emergency Management Agency's (FEMA) Risk MAP study for South Florida, PRELIMINARY Flood Insurance Rate Maps (FIRMS) for Monroe County were released on December 27, 2019. These maps show FEMA's preliminary data on Flood Zones and required Base Flood Elevations for Monroe County which will replace the effective 2005 maps once they are finalized and adopted by the County. Generally the following changes are occurring: • The existing maps are outdated (County's surge analysis is 40 years old). • There are 4 Current County Flood Zones: o Zone AE: An area inundated by 1% annual chance flooding, for which BFEs have been determined. o Zone VE: An area inundated by 1% annual chance flooding with velocity hazard (wave action) for which BFEs have been determined. o Shaded X Zone: An area of moderate flood hazard between the limits of the base flood and the 0.2% annual chance flood. o Unshaded X Zone: An area of minimal flood hazard outside the SFHA and higher than the elevation of 0.2% annual chance flood. • The New FIRMS will include a new boundary (Limit of Moderate Wave Action [LiMWA]), which will be shown on the maps and if a property is within this boundary, it will be required to be built to VE Zone construction standards • There is a datum change from NGVD29 to NAVD88, which means there is now approximately a 1.4' difference in existing elevation • Required structure elevations throughout all areas of the County, including cities have changed Packet Pg. 2068 J.13 During the week of January 27, 2020, FEMA held Preliminary Map Open House Meetings where the public was invited to meet with FEMA representatives and staff members from the various municipalities to discuss the Preliminary Maps and how the changes would impact property owners. Last year, in anticipation of the new maps, the Monroe County BOCC approved a contract for Woods Hole Group (WHG), Inc. to provide assistance to Monroe County to review and comment on the updated FIRMS. Representatives of WHG have been working side by side with Staff to analyze the maps and the data used to create them for any discrepancies, inconsistencies, or errors in methodology. On May 4, 2020, some of this analysis was submitted to FEMA requesting that FEMA reconsider the Preliminary Maps in advance of the start of the required notice in the Code of Federal Register (CFR) and the appeal period. It was hoped that early coordination with FEMA regarding Woods Hole Group's findings could help to limit the need for an appeal of the Preliminary FIRMS, while still maintaining the County's ability to appeal, if issues remain with the methods utilized by FEMA to develop the maps. On June 11, 2020 FEMA responded, addressing each of the 21 comments submitted on the Preliminary Maps. In each case, FEMA respectfully declined to make any adjustments or changes to the Preliminary Maps and analysis as it is currently presented. On June 17, 2020, WHG presented their findings to the Board, which indicated potential inconsistencies with standard practices on key components of the Risk MAP study and with available data used to support FEMA's study. While further review of these issues is ongoing, the scale of impacts to the Preliminary FIRMS ranges from the entire County to individual neighborhoods. WHG noted inconsistencies both in method of risk modeling and in areas identified below that need additional adjustment, including: ■ Storm selection ■ Statistical analysis of storm sets ■ Wave model validation ■ ADCIRC+SWAN model mesh resolution ■ ADCIRC+SWAN modeling of reefs ■ Overland modeling of mangroves ■ Transect spacing & location for overland modeling ■ Topography The County Commission concurred and requested WHG work to develop appeal materials. On December 22, 2020, FEMA published notice to open comments and appeals of the proposed updates to Monroe County's FIRMS in the Federal Register. FEMA is required to publish two (2) notices regarding the appeal period in the local newspapers of record (not published yet). At the time of the second local public notice, Monroe County's Comment and Appeal Period for the Preliminary Map update will begin and will run for ninety (90) days. During this time, all interested parties are encouraged to submit comments or appeals to the proposed changes to the FIRMS. All comments and appeals must be submitted by the conclusion of the appeal period (date TBD) or the appeals will be not be considered by FEMA. Packet Pg. 2069 J.13 Based on BOCC direction received on June 17, 2020, representatives from WHG are concluding the necessary preparations for appeal submission. In the event Monroe County's appeals are not successful, the final procedural step available for an applicant who has found inconsistencies or potential errors with the updated Preliminary FIRMS is to request review of the Scientific Resolution Panel (SRP). The County can request a Scientific Resolution Panel if: • A Letter of Final Determination (LFD) has not yet been issued by FEMA, and • Scientific and technical data submitted during the 90-day appeal period shows changes to the Preliminary maps and the County has been consulting with FEMA on the appeal for at least 60 days (but not more than 120 days) The Scientific Resolution Panel (SRP) can also be requested by the County if FEMA issues a resolution letter to the appeal. In this situation, the County has 30 days to request the SRP if the County finds issues with the resolution letter. Attached are detailed projected timelines for the mapping appeal. Further, a shorter version follows: APPEAL PROCESS MAP TIMELINE ADOPTION (a ., ,"o nl ed) May April December APPEAL 2021 2022 2022 (Starts) (Ends) SRP PROCESS MAP ul, TIMELINE ( ° ; e ) ADOPTION June May ` SRP 2022 2023 January m' 2024 > (Starts): (Ends) Finally, once the maps are ready for adoption, Comprehensive Plan and Land Development Code amendments will be necessary to conform with the anticipated new FEMA maps adoption dates and the State of Florida Model Floodplain Ordinance, currently being developed by Planning staff and summarized as follows: • Update LDC Chapter 122 to be consistent with the State of Florida model ordinance, to be consistent with updated FEMA policies, and to eliminate Florida Building Code regulations, including: o Revisions for consistency with the flood load and flood resistant construction requirements of the Florida Building Code o adoption of updated FIRM maps <maps TBD> o defines specific duties and authorities of the Floodplain Administrator Packet Pg. 2070 J.13 o addressing structures exempt from the Florida Building Code (for example: manufactured homes, RVs, concrete slabs, fill) o defines permit application and inspection requirements • Update Code of Ordinances Chapter 6 to be consistent with the Florida Building Code and adopt amendments for local higher floodplain standards, including: o Revisions for consistency with the flood load and flood resistant construction requirements of the Florida Building Code o Updating the specific duties and authorities of the Building Official to be consistent with Floodplain Administrator updates in Chapter 122 o Shifting local higher floodplain standards from Chapter 122 to Chapter 6 (for example: 299SF downstairs enclosure limitation and foundation requirements [anchoring to rock]) o Including technical amendments to the Florida Building Code for additional local higher floodplain standards (for example: elevation certificate requirements and additional elevation requirements [freeboard]) • Amend Comprehensive Plan and LDC to increase maximum height of structures to address increased base flood elevation requirements with the new FIRM maps and freeboard including a height limit exception of up to a maximum of five (5) feet above the 35-foot height limit to meet Florida Building Code required design flood elevation requirements. Exception shall not result in a new building or a substantially improved building or a lawfully existing building to exceed a maximum height of 40 feet. • Amend LDC ROGO/NROGO sections to require updates to plans for permits requiring an ROGO/NROGO allocation prior to permit issuance; including a requirement for the applicant to submit plan revisions to the building permit application demonstrating full compliance with the current Florida Building Code and the updated FIRM maps <maps TBD>. PREVIOUS RELEVANT BOCC ACTION: On August 21, 2019, the Monroe County BOCC approved a contract for Woods Hole Group, Inc. to provide assistance to Monroe County Staff to review and comment on the FEMA Draft Flood Maps for Monroe County. On September 18, 2019, Monroe County Floodplain Management Staff delivered a review of the Draft Maps, proposed changes, and initial reactions/findings of Staff at the monthly meeting of the Board of County Commissioners. On January 22, 2020, Monroe County Floodplain Management Staff delivered an update on the Preliminary Flood Insurance Rate Maps and the Consultation Coordination Officer (CCO) and Public Open House Meetings. On April 20, 2020, the Monroe County BOCC, through Chief of Floodplain Regulatory Operations Karl Bursa, sent a letter to FEMA requesting an 18-month delay to the start of the Appeal Period for the Preliminary Flood Insurance Rate Maps. Packet Pg. 2071 J.13 On May 4, 2020, Monroe County, through Assistant County Administrator Christine Hurley, sent a letter to FEMA documenting the preliminary findings of Woods Hole Group, illustrating areas where portions of the Preliminary Flood Insurance Rate Maps and the accompanying analysis contained potential errors or inconsistencies. On June 1, 2020, FEMA sent a letter declining the Monroe County BOCC's request for delay of start of the Appeal Period. In this communication, FEMA also provided the County with an updated timetable showing the approximate beginning of the Appeal Period in September of 2020 following the conclusion of Pre-Appeal activities. On June 11, 2020, FEMA sent a letter addressing Monroe County's letter regarding potential errors or inconsistencies with the Preliminary Flood Insurance Rate Maps. FEMA's response acknowledged the County's concerns; however, FEMA declined to make any changes to the maps or the underlying analysis, stating that they stand by their data as presented. On June 17, 2020, the Monroe County BOCC directed Staff and representatives of Woods Hole Group to begin preparation in anticipation of an Appeal of the FEMA Preliminary Flood Insurance Rate Maps. CONTRACT/AGREEMENT CHANGES: N/A STAFF RECOMMENDATION: Staff recommends the Monroe County Board of County Commissioners request Woods Hole Group continue the process of developing materials for Monroe County to undertake a formal appeal of the Preliminary Flood Insurance Rate Maps. DOCUMENTATION: FEMA—Federal Register notice of Monroe County FIRM maps_12.22.2020 Anticipated timeline - FEMA maps and associated County ordinances 2021_Appeal_Timeline FINANCIAL IMPACT: Effective Date: N/A Expiration Date: N/A Total Dollar Value of Contract: N/A Total Cost to County: N/A Current Year Portion: N/A Budgeted: N/A Source of Funds: N/A CPI: N/A Indirect Costs: N/A Estimated Ongoing Costs Not Included in above dollar amounts: N/A Packet Pg. 2072 J.13 Revenue Producing: N/A If yes, amount: Grant: N/A County Match: N/A Insurance Required: N/A Additional Details: N/A REVIEWED BY: Assistant County Administrator Christine Hurley Completed 01/04/2021 3:13 PM Mayte Santamaria Completed 01/04/2021 4:04 PM Rick Griffin Completed 01/05/2021 8:15 AM Bob Shillinger Completed 01/05/2021 10:05 AM Purchasing Completed 01/05/2021 10:47 AM Budget and Finance Completed 01/05/2021 11:10 AM Maria Slavik Completed 01/05/2021 11:22 AM Liz Yongue Completed 01/05/2021 12:30 PM Board of County Commissioners Pending 01/20/2021 9:00 AM Packet Pg. 2073 Federal Register/Vol. 85, No. 246/Tuesday, December 22, 2020/Notices 83591 State and county Location and Chief executive officer of community Community map repository Date of modification Community case No. No. Denton(FEMA City of Aubrey(20- The Honorable Janet Meyers, Mayor,City Denton County GIS Depart- Nov. 18,2020 ................. 480776 Docket No.: 06-0957P). of Aubrey, 107 South Main Street, Au- ment, 701 Kimberly Drive, B-2052). brey,TX 76227. Suite A285, Denton, TX 0. 76208. Gillespie(FEMA City of Fredericks- The Honorable Gary Neffendorf, Mayor, City Hall, 126 West Main Nov. 19,2020 ................. 480252 Docket No.: burg(19-06- City of Fredericksburg, 126 West Main Street, Fredericksburg, TX B-2054). 2756P). Street,Fredericksburg,TX 78624. 78624. Johnson(FEMA City of Burleson(19- The Honorable Ken Shetter, Mayor, City City Hall, 141 West Renfro Nov.23,2020 ................. 485459 Docket No.: 06-3252P). of Burleson, 141 West Renfro Street, Street,Burleson,TX 76028. B-2052). Burleson,TX 76028. Montgomery City of Conroe(19- The Honorable Toby Powell, Mayor, City City Hall, 300 West Davis Nov. 12,2020 ................. 480484 (FEMA Dock- 06-2853P). of Conroe, P.O. Box 3066, Conroe, TX Street,Conroe,TX 77301. et No.:B- 77305. Uj 2052). Tarrant(FEMA City of Colleyville The Honorable Richard Newton, Mayor, City Hall, 100 Main Street, Nov. 12,2020 ................. 480590 Docket No.: (20-06-1166P). City of Colleyville, 100 Main Street, Colleyville,TX 76034. 0 B-2049). Colleyville,TX 76034. 0) Tarrant(FEMA City of Mansfield Mr. Clayton Chandler, Manager, City of Geographic Information Sys- Nov.9,2020 ................... 480606 Docket No.: (20-06-0705P). Mansfield, 1200 East Broad Street, tems (GIS) Department, B-2052). Mansfield,TX 76063. 1200 East Broad Street, Mansfield,TX 76063. Utah:Grand(FEMA Unincorporated The Honorable Mary McGann, Chair, Grand County Courthouse, 125 Nov. 13,2020 ................. 490232 Docket No.:B- areas of Grand Grand County Council, 125 East Center East Center Street, Moab, r 2052). County(20-08- Street,Moab,UT 84532. UT 84532. 0298P). Virginia: Independent City of Fairfax(20- Mr. Robert A. Stalzer, Manager, City of Public Works Department, Nov. 16,2020 ................. 515524 M City(FEMA Dock- 03-0228P). Fairfax, 10455 Armstrong Street, Room 10455 Armstrong Street, > et No.:B-2052). 316,Fairfax,VA 22030. Fairfax,VA 22030. CV [FR Doc.2 02 0-2 8 2 21 Filed 12-21-20;8:45 am] in order to qualify or remain qualified eXchange(FMIX) online at https:// CV BILLING CODE 9110-12-P for participation in the National Flood www.floodmaps.fema.gov/fhm/fmx_ CV Insurance Program(NFIP). In addition, main.html. the FIRM and FIS report, once effective, r DEPARTMENT OF HOMELAND will be used by insurance agents and SUPPLEMENTARY INFORMATION: FEMA SECURITY others to calculate appropriate flood proposes to make flood hazard insurance premium rates for new determinations for each community Federal Emergency Management buildings and the contents of those listed below,in accordance with section Agency buildings. 110 of the Flood Disaster Protection Act [Docket ID FEMA-2020-0002;Internal of 1973,42 U.S.C.4104,and 44 CFR Agency Docket No. FEMA-B-2077] DATES:Comments are to be submitted 67.4(a). on or before March 22,2021. These proposed flood hazard Proposed Flood Hazard ADDRESSES:The Preliminary FIRM, and determinations,together with the 0 Determinations where applicable,the FIS report for floodplain management criteria required AGENCY: Federal Emergency each community are available for by 44 CFR 60.3, are the minimum that Management Agency,DHS. inspection at both the online location are required. They should not be https://www.fema.gov/ construed to mean that the community ACTION: Notice. preliminaryfloodhazarddato and the must change any existing ordinances SUMMARY: Comments are requested on respective Community Map Repository that are more stringent in their 0 proposed flood hazard determinations, address listed in the tables below. floodplain management requirements. U which may include additions or Additionally,the current effective FIRM The community may at any time enact modifications of any Base Flood and FIS report for each community are stricter requirements of its own or Elevation(BFE),base flood depth, accessible online through the FEMA pursuant to policies established by other Special Flood Hazard Area(SFHA) Map Service Center at https:// Federal, State, or regional entities. v_r boundary or zone designation, or msc.fema.gov for comparison. These flood hazard determinations are regulatory floodway on the Flood You may submit comments,identified used to meet the floodplain Insurance Rate Maps (FIRMS),and by Docket No. FEMA-B-2077,to Rick management requirements of the NFIP 76 where applicable,in the supporting Sacbibit,Chief,Engineering Services and are used to calculate the Flood Insurance Study (FIS)reports for Branch,Federal Insurance and appropriate flood insurance premium the communities listed in the table Mitigation Administration,FEMA,400 rates for new buildings built after the report become effective.C Street SW,Washington,DC 20472, FIRM and FIS re below. The purpose of this notice is to g P seek general information and comment (202) 646-7659,or(email) The communities affected by the regarding the preliminary FIRM, and patrick.sacbibit@fema.dhs.gov. flood hazard determinations are where applicable,the FIS report that the FOR FURTHER INFORMATION CONTACT:Rick provided in the tables below. Any Federal Emergency Management Agency Sacbibit,Chief,Engineering Services request for reconsideration of the (FEMA)has provided to the affected Branch,Federal Insurance and revised flood hazard information shown communities. The FIRM and FIS report Mitigation Administration,FEMA,400 on the Preliminary FIRM and FIS report are the basis of the floodplain C Street SW,Washington,DC 20472, that satisfies the data requirements management measures that the (202) 646-7659,or(email) outlined in 44 CFR 67.6(b)is considered community is required either to adopt patrick.sacbibit@fema.dhs.gov; or visit an appeal. Comments unrelated to the or to show evidence of having in effect the FEMA Mapping and Insurance flood hazard determinations also will be Packet Pg. 2074 J.13.a 83592 Federal Register/Vol. 85, No. 246/Tuesday, December 22, 2020/Notices considered before the FIRM and FIS appeal.Additional information identified by the unique project number report become effective. regarding the SRP process can be found and Preliminary FIRM date listed in the Use of a Scientific Resolution Panel online at https://www.floodsrp.org/pdfs/ tables. Additionally,the current (SRP)is available to communities in srp_overview.pdf. effective FIRM and FIS report for each support of the appeal resolution The watersheds and/or communities community are accessible online process. SRPs are independent panels of affected are listed in the tables below. through the FEMA Map Service Center experts in hydrology,hydraulics, and The Preliminary FIRM, and where at https://msc.fema.gov for comparison. other pertinent sciences established to applicable,FIS report for each review conflicting scientific and community are available for inspection (Catalog of Federal Domestic Assistance No. technical data and provide at both the online location https:// 97.022,"Flood Insurance.") recommendations for resolution.Use of www.fema.gov/ Michael M.Grimm, the SRP only may be exercised after preliminaryfloodhazarddato and the Assistant Administrator for Risk FEMA and local communities have been respective Community Map Repository Management,Department of Homeland engaged in a collaborative consultation address listed in the tables.For Security,Federal Emergency Management process for at least 60 days without a communities with multiple ongoing Agency. mutually acceptable resolution of an Preliminary studies,the studies can be Community Community map repository address Monroe County, Florida and Incorporated Areas Project: 15-04-4157S Preliminary Date: December 27,2019 r City of Key Colony Beach ........................................................................ Building and Planning Department, 600 West Ocean Drive, Key Colony Beach, FL 33051. y City of Key West ....................................................................................... Building Department, 1300 White Street, Key West, FL 33040. > City of Layton Layton Building Department, 68260 Overseas Highway, Long Key, FL 33001. City of Marathon ....................................................................................... Planning Department, 9805 Overseas Highway, Marathon, FL 33050. Unincorporated Areas of Monroe County ................................................ Monroe County Building and Permitting Department, 2798 Overseas CD Highway, Suite 300, Marathon, FL 33050. Village of Islamorada ................................................................................ Building and Planning Department, 86800 Overseas Highway, Islamorada, FL 33036. cv r Jones County, North Carolina and Incorporated Areas Project: 11-04-7660S Preliminary Date: November 30, 2018 0. 0. Unincorporated Areas of Jones County ................................................... Jones County Government Office, 418 Highway 58 North, Trenton, NC 28585. Tyrrell County, North Carolina and Incorporated Areas Project: 11-04-8218S Preliminary Date: November 30, 2018 Unincorporated Areas of Tyrrell County ................................................... Tyrrell County Planning Department, 108 South Water Street, Colum- bia, NC 27925. O [FR Doc.2020-28223 Filed 12-21-20;8:45 am] indicated Letter of Map Revision C Street SW,Washington,DC 20472, O BILLING CODE 9110-12-P (LOMR) for each of the communities (202) 646-7659,or(email) listed in the table below are finalized. patrick.sacbibit@fema.dhs.gov, or visit 0 Each LOMR revises the Flood Insurance the FEMA Mapping and Insurance DEPARTMENT OF HOMELAND Rate Maps (FIRMS),and in some cases eXchange(FMIX) online at https:// SECURITY the Flood Insurance Study(FIS)reports, www.floodmaps.fema.gov/fhm/fmx_ currently in effect for the listed main.html. Federal Emergency Management communities. The flood hazard SUPPLEMENTARY INFORMATION: The y Agency determinations modified b each LOMREmergency gAgency Y Federal Management � [Docket ID FEMA-2020-0002] will be used to calculate flood insurance (FEMA)makes the final flood hazard premium rates for new buildings and determinations as shown in the LOMRs Changes in Flood Hazard their contents. for each community listed in the table Determinations DATES:Each LOMR was finalized as in below. Notice of these modified flood AGENCY: Federal Emergency the table below. hazard determinations has been Management Agency,DHS. ADDRESSES:Each LOMR is available for Published in newspapers of local ACTION: Notice. inspection at both the respective circulation and 90 days have elapsed Community Map Repository address since that publication.The Deputy SUMMARY: New or modified Base(1 listed in the table below and online Associate Administrator for Insurance percent annual chance)Flood through the FEMA Map Service Center and Mitigation has resolved any appeals Elevations (BFEs),base flood depths, t o s the F ema. ay. resulting from this notification. Special Flood Hazard Area(SFHA) p f g The modified flood hazard boundaries or zone designations,and/or FOR FURTHER INFORMATION CONTACT:Rick determinations are made pursuant to regulatory floodways (hereinafter Sacbibit,Chief,Engineering Services section 206 of the Flood Disaster referred to as flood hazard Branch,Federal Insurance and Protection Act of 1973,42 U.S.C.4105, determinations) as shown on the Mitigation Administration,FEMA,400 and are in accordance with the National Packet Pg. 2075 (leaddy pue sdeW VWD_A uo a&epdn) seoueulpao A&unoo pa&eloosse pue sdew VWD_A-oullaual&poledlol&uy:&uawLjoe&&y n d V' a- Y _ s e w a a 2 2 = - o� o� Ewa aan aan x - z z - -- M! (lea ue s ) aulla Il Iea til M N04 r a IL ,r = 8 o Cc a M Lu � d FA N 0 _ m w CA LU of � V C N N ? i mN fa H rz CL °r a a 44 r rr� 'I tl�r a I t S 'h r, r , `. �� ;��,rri�wr����ir ,'' ��II iyl; ��� 0 • `j � � `'6T� �' �sr�� ����z ��s�� ��� r „ ' {�>4 �s ��,1= t,?41��� '�� , 1 • 1 • • 1 1 • ° 1 1 1 1 , • 1 • 1 • .e • 1 ° 1 • • 1 1 ° .• 0 • • . • • • • 1 • • e e • , o 1 • ® • 1 ' 1 • o ° • e 1 1 ® • • 1 .• ° 1 1 1 • 1 • _ ct l, },< -17 4 ) tL co 4 (D 0)�t -0 aJ J L co a CD 73 !— ® (D *^ Uy > ,t 1''" 0) 0 +s r rl a At CF7 cif 13 ) 0 W CD 0 L L '4 ca 0 CCU ca � cll CD fl3 �r 0 W - cri c 0 is ;y Cu `s �4 t 4' - s V IM r � �h4 i i • ® i e s • �y� �7���)Sltpptlss • 1s��W �ti��);� ti i(yt�ss{Y���i , • i{ i s • co LL- 0 z • • U-i LY: < CL • - k - o• �� `'nb t }� � nil`. _ _ rila a� i y g co �o co 0 e i � o' • LLI s e s- • � 0 a , Y Y4U t� IY ,;Yy. Q f6 '- w fu ro CL c a-J t J}�t i�}i 7 a tit ,s �, �■ �. � � � � '. �, �tli�Ifl�,Ii to O i)�1,������{t �c+tip Isl�t1 � �',� � �� � •��. III filff����Ui���rlt�r ���1� ti�i� •�,� � �� �� � `� ��bait tt l��}i ii�l�tlr�iVt4ii���t 1� "•� i (d�r4f i it�l.�i ��S�tt �.... � r£ S� 5 �til A�Cl�i O O M C m t �#--i t r m O + ,�,� Q (�' (. �..� E N s_ .W > O � � Q G > "0 Q N mom I Q N Q N 7 3 O O p v', pSL E o E a.,m 0.`m cn,� _ O 3 `m ° a T G o m.E E w E U'C r• V ..Fn {� � � .v. ifl E ca.. ..,o....o..o .., n b w L n Lt 2. 't ✓1'C m O 0 , h ch H E3,2 P4 ._..._��o__ao° ��v_-,.a.v.�c.�.�z_ _�mo�a.LL�mao�t�' Z � ❑c y `n.� �,, caa m' c 0 z E v y y P w E LL u O U E F., Ez, w m o a o O �v�._E E[.E a�E� E m `d Iv N �A O y n 4]n "d Y YJ 7w g O C YJ p.' a.O w d � • elk 1 1 ® 1 • 1 ® 1 • 1 • ® 4 1 • , ® • ® ® • • • • • • ® � ° • sd t*1 �� Un [ V) • L7 W s ® rA ® v x . CA ° • Ul N -w ® U „w.. • • ° o 1 s • • . e • • e • • o E • • < .. w � � Q 40 40 • • • ® • ® • • cl CL CL • • ® ' • ® ® • ® • • • ® • • . . . ° ® • e �: � ` � «: e � @ . \ � �� \� , e �� � :� � � . . � @ . . � e �� <# �� ■ ■ � 4 . ® ■ #< ^ � � e . � � > :. e � ® � � e /� ^ � e . � � ■ � e ./ y� �. ® `� ■ ® ® � � e « ■ � � � . � % �# e • ® - �, e « ` � � �& � e � \ . , � - ■ \ � | � � � . e - ,, e \� � � � ■ � � : � , � • � � / � � • � � �� :: � � � ■ y e e .. 2 \ ■ - ■ � e � �© � � � - � �� � � � ^ � \ e • � e , \� e ® � � � � � - � ■ ® �# d � :� e 4 « :. 2 � � � « e d� ��# - � � e , , �& «I � � � � a d . �� - , m �� 4 .� e � ® �: -4 « e �. . d � � �. e ' � \� . / � � � @ ■ , ° �� - ` � �d4 � a � e � ® . 2\ � � � ■ � • � � � � e ® �� � @ � - . � � � � e e � . e � . e , ■ 4 #l \\ � � \ ■ . \� ® e � ■ � a ` � «: . \� �« ~ �� � � � � e , � , ■ � : � � � � � - «« ■ ° ■ . . � � � e . . � e � � - � � @ - � ■ - «< � � m • © e e � - � �: a � � e �� ■ � . � ■ `l , , �} � � � ■ ■ �. � . ■ � . � .� . ■ : \ e � �� ® ^ �° a i 1 ® ® • ® ® • ® • � • ® ® , ® • t • ® i • • ® � • ® i i ® ® • i ® • ® • • ® ® i ® • • e ® ® ® ' ® ® i • ® • ®® ® • ' i ® , e ® ® • i ® • •• ® ' • ® ® • ® � ® • • • ® • i • • • • ® • • ® , ® i • � e • � • ® ® • i � 1 ® e � i ® i ® , , • r • • ® • ' • • � •• • ® • • � • • • • ' , ' ® � e • ® ® ® • i ® • • • � ® • ® • ® ® • ® i • • i • ® ® ® ® ' • ® ® ' • ® ® ® ® � • e • • i ® ® ® ' ® ® i i • • ® i 1 ' ® � • ' r • 1 ® • • ® � • • ® , . e • r ® • • e • • ® . � r • • • ® ® ® � • � ® , • , . e ' • • ® • e e ' � ® ® � ® e • • • • ® ® ® ® • • • • � • ® ® � • • ® • ® � • '• e ' • ® • • ® • ® � � • e • e . ® • • • e r ® e . e � • • . e • • ® • • • ® , ® • . e • • • � ® • , � • • � . e • ® ® ® .• ® � • • • � � • • • 1 • • � • • ® ® ' e � • , r • r ® � • 1 e • • e • r ® ® � ® • • i • i • • � • i e • � • i • ® ® ® ® i i ® ® i i ® i , ' ® • • ® ' . e , ® • ® ® , ® ® • ® � � • ® i • • ® • ® � 1 • � ® ® • , • ® i ® • i ® • i i • ® i • ® ® ' • ® � • ® ® , • ® • ® i ® � • ® ' i • • � • i ® . ® . e ' ® � • • • • • ® • '® • � ® • ® . e � ® , • ® ® • � • • • e • � ` ® • 1 ® ® •