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Item Q13 BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: July 19. 2006 Bulk Item: Yes No .....L. Division: County Attorney Department: County Attorney Staff Contact Person: Jeny D. Sanders AGENDA ITEM WORDING: Discussion of and direction to staff regarding a Florida Department of Community Affairs Final Order, rejecting Monroe County Ordinance Number 015-2006, which amended Monroe County's Land Development Regulations to allow for density bonuses for affordable and employee housing units of 750 square feet or less. ITEM BACKGROUND: On June 29, 2006, pursuant to Section 380.05(6) if the Florida Statutes, the Florida Department of Community Affairs (DCA) issued Final Order Number DCA06-0R157 rejecting Monroe County Ordinance No. 015-2006 after finding it to be inconsistent with the Principles for Guiding Development of the Florida Keys Area of Critical State Concern. The DCA's Final Order was submitted for publication in the Florida Administrative Weekly on June 29, 2006 for publication on July 14,2006. Pursuant to Section 120.569, any person whose substantial interests are affected by the Final Order has the opportunity to request an administrative proceeding regarding the DCA's action. Such a request must be filed with the Agency Clerk of the Florida Department of Community Affairs within 21 calendar days of publication of the Final Notice. For this Final Order the filing deadline is August 4, 2006. PREVIOUS RELEVANT BOCC ACTION: April 19, 2006 Monroe County Ordinance 015-2006 was passed unanimously by the BOCC at its regular meeting. February 15, 2006 Workforce Housing Task Force recommendations were conceptually approved and directions given to staff by the BOCC pursuant to Resolution Nos. 093-2006 and 096-2006. CONTRACT/AGREEMENT CHANGES: N/A STAFF RECOMMENDATIONS: Staff recommends that Monroe County file a written Petition for Administrative Proceedings with the DCA challenging DCA Final Order Number DCA06-0R-157. TOTAL COST: N/A BUDGETED: Yes No COST TO COUNTY: N/A SOURCE OF FUNDS: N/A REVENUE PRODUCING: Yes No AMOUNT PER MONTH Year APPROVED BY: County Attorney ...,/' OMBlPurchasing _ Risk Management _ DOCUMENTATION: Included DMSION DIRECTOR APPROVAL: DISPosmON: AGENDA ITEM # .- DCA Final Order No.: DCA06-0R-157 In re: STATE OF FLORIDA __ DEPARTMENT OF COMMUNITY AF"' I ~ @ rn 0 w rn MONROE COUNTY LAND I ADOPTED BY MONROE COUNTY ORDINANCE NO. 015-2006 / GROWTH ~MMGtMENT DIVISION ~ __.,~.L - ~ - .' ~ '/ FINAL ORDER The Department of Community Affairs (the "Department") hereby issues its Final Order, pursuant to ~ 380.05(6), Fla. Stat., and ~ 380.0552(9), Fla. Stat. (2005), rejecting a land development regulation adopted by a local government within the Florida Keys Area of Critical State Concern as set forth below. FINDINGS OF FACT 1. The Florida Keys Area is a statutorily designated area of critical state concern, and Monroe County is a local government within the Florida Keys Area. 2. On May 22, 2006, the Department received for review Monroe County Ordinance No. 015-2006 ("Ord. 015-2006"). 3. The final order for this Ordinance must be signed by July 20, 2006. 4. The purpose of the Ordinance is to amend the definitions section of the Monroe County Land Development Regulations to add "dwelling, density bonus unit" and "dwelling, half unit," to the definitions, thereby allowing an award to a site if the units are 750 square feet in SIze. 5. Ordinance 015-2006 is inconsistent with the 2010 Monroe County Comprehensi ve Plan. Sections 9 .5-4(D- 31)( a) ("dwelling, density bonus unit"), 9.5 -4(D- 31 )(b) ("dwelling, half unit"), and 9.5-262 are inconsistent with Comprehensive Plan Policy 101.4.21, Future Land Use Densities and Intensities. That policy describes development in terms of dwelling units per acre. The plan does not address half allocations or density bonuses for half DCA Final Order No.: DCA06-0R-157 allocations. No basis has been established within the Comprehensive Plan for half of a dwelling uni 1. CONCLUSIONS OF LAW 6. The Department is required to approve or reject land development regulations that are enacted, amended, or rescinded by any local government in the Florida Keys Area of Critical State Concern. ~ 380.05(6), Fla. Stat., and ~ 380.0552(9), Fla. Stat. (2005). 7. Monroe County is a local government within the Florida Keys Area of Critical State Concern. ~ 380.0552, Fla. Stat. (2005) and Rule 28-29.002 (superseding Chapter 27F-8), Fla. Admin. Code. 8. "Land development regulations" include local zoning, subdivision, building, and other regulations controlling the development of land. ~ 380.031(8), Fla. Stat. (2005). The regulations adopted by Ord. 015-2006 are land development regulations. 9. AU land development regulations enacted, amended, or rescinded within an area of critical state concern must be consistent with the Principles for Guiding Development (the "Principles") as set forth in ~ 380.0552(7), Fla. Stat. See Rathkamp v. Department of Community Affairs, 21 F.A.L.R. 1902 (Dec. 4, 1998), aff'd, 740 So. 2d 1209 (Fla. 3d DCA 1999). The Principles are construed as a whole and no specific provision is construed or applied in isolation from the other provisions. 10. Ord. 015-2006 is inconsistent with the following Principles: (a) To strengthen local government capabilities for managing land use and development so that local government is able to achieve these objectives without the continuation of the area of critical state concern designation. (k) To provide adequate alternatives for the protection of public safety and welfare in the event of a natural or manmade disaster and for a post disaster reconstruction plan. (1) To protect the public health, safety, and welfare of the citizens of the Florida Keys and maintain the Florida Keys as a unique Florida resource. 11. Ord. 015-2006 is inconsistent with the Principles for Guiding Development as a 2 DCA Final Order No.: DCA06-0R-157 whole. 12. Ordinance 015-2006 is inconsistent with the 2010 Monroe County Comprehensive Plan. WHEREFORE, IT IS ORDERED thatOrd. 015-2006 is found to be inconsistent with the Principles for Guiding Development of the Florida Keys Area of Critical State Concern, and is hereby REJECTED. This Order becomes effective 21 days after publication in the Florida Administrative Weekly unless a petition is filed as described below. DONE AND ORDERED in Tallahassee, Florida. CY D ER State PI . g Administrator Division of Community Planning Department of Community Affairs 2555 Shumard Oak Boulevard Tallahassee, Florida 32399-2100 NOTICE OF ADMINISTRATIVE RIGHTS ANY PERSON WHOSE SUBSTANTIAL INTERESTS ARE AFFECTED BY THIS ORDER HAS THE OPPORTUNITY FOR AN ADMINISTRATNE PROCEEDING PURSUANT TO SECTION 120.569, FLORIDA STATUTES, REGARDING THE AGENCY'S ACTION. DEPENDING UPON WHETHER YOU ALLEGE ANY DISPUTED ISSUE OF MATERIAL FACT IN YOUR PETITION REQUESTING AN ADMINISTRA TNE PROCEEDING, YOU ARE ENTITLED TO EITHER AN INFORMAL PROCEEDING OR A FORMAL HEARING. IF YOUR PETITION FOR HEARING DOES NOT ALLEGE ANY DISPUTED ISSUE OF MATERIAL FACT CONTAINED IN THE DEPARTMENT'S ACTION, THEN THE ADMINISTRATIVE PROCEEDING WILL BE AN INFORMAL ONE, CONDUCTED PURSUANT TO SECTIONS 120.569 AND 120.57(2) FLORIDA STATUTES, AND CHAPTER 28-106, PARTS I AND III, FLORIDA ADMINISTRATIVE CODE. IN AN INFORMAL ADMINISTRA TNE PROCEEDING, YOU MAYBE REPRESENTED BY COUNSEL OR BY A QUALIFIED REPRESENTATIVE, AND YOU MAY PRESENT 3 DCA Final Order No.: DCA06-0R-157 WRITTEN OR ORAL EVIDENCE IN OPPOSITION TO THE DEPARTMENT'S ACTION OR REFUSAL TO ACT; OR YOU MAY EXERCISE THE OPTION TO PRESENT A WRITTEN STATEMENT CHALLENGING THE GROUNDS UPON WHICH THE DEPARTMENT HAS CHOSEN TO JUSTIFY ITS ACTION OR INACTION. IF YOU DISPUTE ANY ISSUE OF MATERIAL FACT STATED IN THE AGENCY ACTION, THEN YOU MAY FILE A PETITION REQUESTING A FORMAL ADMINISTRATIVE HEARING BEFORE AN ADMINISTRATIVE LA W JUDGE OF THE DIVISION OF ADMINISTRATIVE HEARINGS, PURSUANT TO SECTIONS 120.569 AND 120.57(1), FLORIDA STATUTES, AND CHAPTER 28-106, PARTS I AND II, FLORIDA ADMINISTRATIVE CODE. AT A FORMAL ADMINISTRATIVE HEARING, YOU MAY BE REPRESENTED BY COUNSEL OR OTHER QUALIFIED REPRESENT A TIVE, AND YOU WILL HAVE THE OPPORTUNITY TO PRESENT EVIDENCE AND ARGUMENT ON ALL THE ISSUES INVOLVED, TO CONDUCT CROSS-EXAMINATION AND SUBMIT REBUTTAL EVIDENCE, TO SUBMIT PROPOSED FINDINGS OF FACT AND ORDERS, AND TO FILE EXCEPTIONS TO ANY RECOMMENDED ORDER. IF YOU DESIRE EITHER AN INFORMAL PROCEEDING OR A FORMAL HEARING, YOU MUST FILE WITH THE AGENCY CLERK OF THE DEPARTMENT OF COMMUNITY AFFAIRS A WRITTEN PLEADING ENTITLED, "PETITION FOR ADMINISTRATIVE PROCEEDINGS" WITHIN 21 CALENDAR DAYS OF PUBLICATION OF THIS NOTICE. A PETITION IS FILED WHEN IT IS RECEIVED BY THE AGENCY CLERK, IN THE DEPARTMENT'S OFFICE OF GENERAL COUNSEL, 2555 SHUMARD OAK BOULEVARD, TALLAHASSEE, FLORIDA 32399-2100. THE PETITION MUST MEET rHE FILING REQUIREMENTS IN RULE 28- 106.104(2), FLORIDA ADMINISTRATIVE CODE. IF AN INFORMAL PROCEEDING IS REQUESTED, THEN THE PETITION SHALL BE SUBMITTED IN ACCORDANCE WITH RULE 28-106.301, FLORIDA ADMINISTRATIVE CODE. IF A FORMAL HEARING IS REQUESTED, THEN THE PETITION SHALL BE SUBMITTED IN ACCORDANCE WITH RULE 28-106.201(2), FLORIDA ADMINISTRATIVE CODE. A PERSON WHO HAS FILED A PETITION MAY REQUEST MEDIATION. A REQUEST FOR MEDIATION MUST INCLUDE THE INFORMATION REQUIRED BY RULE 28-106.402, FLORIDA ADMINISTRATIVE CODE. CHOOSING MEDIATION DOES NOT AFFECT THE RIGHT TO AN ADMINISTRATIVE HEARING. YOU WAIVE THE RIGHT TO AN INFORMAL ADMINISTRATIVE PROCEEDING OR A FORMAL HEARING IF YOU DO NOT FILE A PETITION WITH THE AGENCY CLERK WITHIN 21 DAYS OF PUBLICATION OF THIS FINAL ORDER. 4 DCA Final Order No.: DCA06-0R-157 CERTIFICATE OF FILING AND SERVICE I HEREBY CERTIFY that the original of the foregoing Final Order has been filed with the undersigned designated Agency Clerk, and that true a orrect 9~e been furnished to the persons listed below by the method indicated this y 0 2006. By U.S. Mail: Honorable Charles McCoy Mayor of Monroe County 500 Whitehead Street, Suite 102 Key West, Florida 33040 Danny L. Kolhage Clerk to the Board of County Commissioners 500 Whitehead Street Key West, Florida 33040 Aref Joulani Acting Director Planning and Environmental Resources 2798 Overseas Highway, Suite 400 Marathon, Florida 33050 Bv Hand Deliverv or Interagency Mail: Tracy D. Suber, Bureau of State Planning, DCA Tallahassee Rebecca Jetton, ACSC Administrator, DCA Tallahassee Richard E. Shine, Assistant General Counsel, DCA Tallahassee Christine M. Cosby, Assistant General Counsel, DCA Tallahassee 5 ORDINANCE NO. .Jll2. - 2006 AN ORDINANCE OF THE MONROE COUNTY BOARD OF COUNTY COMMISSIONERS ADDING TO EXISTING DEFINITIONS (Sec. 9.5-4); AMENDING MAXIMUM RESIDENTIAL DENSITY AND DISTRICT OPEN SPACE (Sec. 9.5- 262) TO ALLOW FOR DENSITY BONUSES FOR AFFORDABLE UNITS OF 750 SQ. FT. OR LESS; AMENDING REQUIRED PARKING (Sec. 9.5-352); AMENDING AND/OR ADDING FOR CONSISTENCY PURPOSES RELATED PROVISIONS; PROVIDING FOR SEVERABILITY AND REPEAL OF INCONSISTENT PROVISIONS; PROVIDING EFFECTIVE DATE; PROVIDING FOR INCORPORATION IN THE MONROE COUNTY CODE OF ORDINANCES WHEREAS, the Board of County Commissioners has considered the comments of the public, recommendations of the Planning Commission, recommendations of staff and the Workforce Housing Task Force and its counsel, and other matters, and; WHEREAS, the Board of County Commissioners makes the following Findings of Fact: I. The lack of sufficient affordable housing opportunities for the local workforce creates serious risks to the local economy. 2. There is limited land area suitable for residential development remaining in the County. 3. There is a current estimated unmet need of about 7,317 affordable units the County. 4. Allowing a density bonus will allow for the creation of more affordable housing under the Code, is a legitimate state interest and is proper to implement Goals 101 and 601 of the plan (e.g., Objective 101.4; Policy 101.4.5; Policy 601.1.12 and Objectives 601.2 and 601.6). 5. These amendments to the land development regulations are appropriate in that they recognize the need for additional detail and comprehensiveness in addressing housing needs in Monroe County, based upon, among other factors, new issues, including accelerated conversion of existing affordable housing stock, increased housing pressures due to housing loss caused by Hurricane Wilma, and the changed projections and assumptions regarding resulting demographic trends. 6. These amendments to the land development regulations specifically further Fla. Stat. ~ 163.3202(3) by implementing innovative land development regulation provisions such as transfer of development rights, incentive and inclusionary housing. 7. These amendments to the land development regulations are necess~ to ensure that, despite the limited availability of developable lands, the County's existing and future housing stock includes adequate affordable housing opportunities. 1 8. The proposed amendments to the Land Development Regulations are consistent with and further goals, objectives and policies of the Year 2010 Comprehensive Plan. NOW, THEREFORE, BE IT ORDAINED BY THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA, THE FOLLOWING: That the preceding findings support its decision to approve the amendments to the Land Development Regulations of the Monroe County Code as provided herein: Section 1. Add Sec. 9.5-4(D-31)(a) as follows: (D-31)(a) Dwelling, density bonus unit means the additional number of dwelling half units that can be added to a site pursuant to the means as defined in Section 9.5- 262** and shall be one (1) or more rooms physically arranged to create a housekeeping establishment for occupancy by one (1) family with separate toilet facilities. The abbreviation "DDBU" shall mean "dwelling density bonus unit". Section 2. Add Sec. 9.5-4(D-31) (b) as follows: (D- 31 )(b) Dwelling, half unit means deed restricted affordable housing units as defined in MCC ~ 9.5-4 (A-4-5) that range in size from 400 to 750 square feet which shall be considered one-half (.5) of a dwelling unit for the purpose of calculating density as laid out in ~9.5-262**. Section 3. Amend cbart rows of Sec. 9.5-262 and add *'Ie row as follows: Maximum residential density and district open space. *, Land use district Allocated density Maximum net density Open space DU/acre DU/buildable area ratio * Urban Residential 6.0 12.0 0.2 (Affordable and 6.0 25.0** 0.2 Employee housing) Suburban Commercial 3.0 6.0 0.2 (Affordable and 3.0 18.0** 0.2 Employee housing) Mixed Use 1.0 12.0 0.2 (Affordable and 1.0 18.0** 0.2 Employee housing) ** For the purposes of these density calculations only, notwithstanding the definition of a dwelling unit as defined in ~9.5-4 (0-31), deed restricted affordable or employee housing units (as defined in MCC~99.5-(A-4-5) and (E-I), respectively), in the SC, MU and UR 2 land use districts that range in size from 400 to 750 square feet shall be considered a dwelling half unit. An equal number of additional dwelling half unit(s) shall be available for each dwelling half unit provided. The additional dwelling half units shall be defined as dwelling density bonus unit(s). Section 4. Amend Section 9.5-352 by adding row as follows: (c) Required Number of Off-Street Parking Spaces: The following is the number of parking spaces to be provided for each use: TABLE INSET: Specific Use Category Dwelling half units Minimum Required Number of Spaces 1.0 spaces per dwelling half unit Section 5. Severabilitv. If any section, paragraph, subdivision, clause, sentence or provision of this Ordinance shall be adjudged by any court of competent jurisdiction to be invalid, such judgment shall not affect, impair, invalidate, or nullify the remainder of this Ordinance, but the effect thereof shall be confined to the section, paragraph, subdivision, clause, sentence or provision immediately involved in the controversy in which such judgment or decree shall be rendered. Section 6. Conflictin2 Provisions. In the case of direct conflict between any provision of this ordinance and a portion or provision of any appropriate federal, state or county law, rule, code or regulation. the more restrictive shall apply. Section 7. Transmittal This ordinance shall be transmitted by the Planning and Environmental Resources Department to the Florida Department of Community Affairs to determine the consistency of this ordinance with the Florida Statutes and as required by F.S. 380.05(6) and (l I). Section 8. Filine This ordinance shall be filed in the Office of the Secretary of State of Florida but shall not become effective until a notice is issued by the Department of Community Affairs or Administration Commission approving the ordinance. 3 Section 9. Effective Date. This ordinance shall become effective as provided by law and stated above. Where Comprehensive Plan amendments may be required in order for any part of this ordinance to be deemed consistent with the Comprehensive Plan, the effective date of such part shall be as of the effective date of the required Comprehensive Plan amendment and as otherwise required by law. PASSED AND ADOPTED by the Board of County Commissioners of Monroe County, Florida at a regular meeting held on the 19th day of April, 2006. Mayor Charles "Sonny" McCoy Mayor Pro Tern Murray Nelson Commissioner Dixie Spehar Commissioner George Neugent Commissioner David Rice Yes Vacant Yes Yes Yes BOARD OF COUNTY OF MONROE COUN APPROVED AS TO FORM: County Attorney y" McCoy ~ 0 ~ l> ~("):: fTI~-< O'r- on. C:-A :z:. ~ c' ~n~ . :-i...., ""TJ .J- r- ~ )> = CI c:r- :z >- -< ." r- FTl o o '"0 :z .." C) :0 ::u i-" n o :;0 c - - r Co.) 4 CLERK OF THE CIRCUIT COURT MONROE COUNTY BRANCH OFFICE MARATHON SUB COURTHOUSE 3117 OVERSEAS HIGHWAY MARATHON, FLORIDA 33050 TEL. (305) '1JJ9-(JJ].7 FAX (305) 289.1745 MONROE COUNlY COURTHOUSE 500 WHITEHEAD STREET, SUITE 101 KEY WES'I; FLORIDA 33040 TEL. (305) 292-3550 FAX (305) 295-3663 BRANCH OFFICE PLANTATION KEY GOVERNMENT CENTER 8Il82O OVERSEAS HIGHWAY PLANTATION KEY, FLORIDA 33070 TEL. (305) 852-7145 FAX (305) 852-7146 May 10, 2006 Ms. Liz Cloud, Program Administrator Administrative Code & Weekley R.A. Gray Building 500 S Bronough Street Tallahassee FL 32399-0250 Via Certified Mail 7002 2030 0001 2668 9617 Dear Ms. Cloud, Enclosed please find certified copies of the following: Ordinance No. 014-2006 approving the request by !tnor Corporation to amend the Land Use District for the following property from Urban Residential Mobile-Limited (URM-L) to Urban Residential (UR). The property is physically located on Laurel and 2nd Avenue and is legally described as Stock Island Maloney Sub PBl-55 Lots 1 thru 7 & Adj Bay Btm Lots 11 to 21 Inc Sqr 32 048-164-65, Stock Island, Monroe County, Florida. The real estate number is 00124540.000000, at approximate mile marker 5. Ordinance No. 015-2006 adding to existing definitions (Sec. 9.5-4); amending Maximum Residential Density and District Open Space (Sec. 9.5-262) to allow for density bonuses for affordable units of 75 sq.ft. or less; amending required parking (Sec. 9.5-352); amending and/or adding for consistency purposes related provisions; providing for severability and repeal of inconsistent provisions; providing effective date; providing for incorporation in the Monroe County Code of Ordinances. Ordinance No. 016-2006 amending the existing definition for maximum sales price of an affordable housing unit (Sec. 9.5-4); amending affordable and employee housing provisions (Sec. 9.5-266); providing for severability and repeal of inconsistent provisions; amending and/or adding for consistency purposes related provisions; providing effective date; providing for incorporation in the Monroe County Code of Ordinances. Monroe County Clerk's Office Ordinance Nos. 014-2006, 015-2006 & 016-2006 These Ordinances were adopted by the Monroe County Board of County Commissioners at a Regular Meeting in formal session on April 19, 2006. Please file for record. Should you have any questions please feel free to contact me at (305) 295-3130. Danny L. Kolhage Clerk of the Circuit Court and ex officio Clerk to the Board of County Commissioners by: Pamela G. Hancock, D.C. cc: Growth Management County Attorney BaCC File (.,;J 'W:;'1~ ~-.;~/ \c~ '~, , ,...../.... '1 "". iHl:.:.. " ~: - ~~~~t""",,\_ I:"~" ...-!l.1':-.:-.....~ ~.. ' -. .' - -. ,1' ""J . < FLORIDA DEPARTMENT OF STATE Sue M. Cobb Secretary of State DIVISION OF LIBRARY AND INFORMATION SERVICES May 19, 2006 Honorable Danny L. Kolhage Clerk of Circuit Cowt Monroe County 500 Whitehead Street, Suite 101 Key West, Florida 33040 Attention: Isabel C. DeSantis, Deputy Clerk Dear Mr. Kolhage: Pursuant to the provi'sions of Section 125.66, Florida Statutes, this will acknowledge receipt of your letter dated May 10, 2006 and certified copies of Monroe County Ordinance Nos. 014-2006 through 016-2006, which were filed in this office on May 17,2006. Sincerely. ~\;~. t~~,-~. ~J \.~",- Liz Cloud Program Administrator LC/mp 3. c ~ ~ ::Oo:Z: or-:Z; ~~-< n. r- 0("):"- C:-"---' :&: ?=fe. -lei' -<-I:J: . . J:'" .." C') .- 1"'1 ~ 8 ..., - ~ f;; :s !C 0 -rt N 0 N :::0 ~ ::0 m (") '!1 0 5 ClD [JSTATE LIBRARY OF FLORIDA R.A. Gray Building. Tallahassee, Florida 32399-0250 . (850) 245-6600 FAX: (850)488-2746. TOO: (850) 922-4085. http://w_.dos.state.n.us [JLEGISLA TIVE LIBRARY SERVICE [J RECORDS MANAGEMENT SERVICES [JFLORIDA STATE ARCHIVES (8~Q)48lH8J;l. fAX; (8:;Q) 488-9879 (8~0)487-218o. FAX: (850)413-7224 (850)245-6700. FAX: (850)488-4894 I:JADMlN1STRATIVE CODE AND WEEKLY (850) 245-6270. FAX: (850) 245-6282 ENDER CQ,1ilPLETE THI:> :;,ECT/ON . Complete items 1. 2. 8nd 3. Also complete item 4 If RestrIoted DelIvery Is desired. . ?rint your name and address on the I'Il'VllfSEl $0 thai we can retum tile card to you. . Atta/;Jh this card to tile back of the mailpiece. or on the front if epace permits. 1. Melt> Addres&ed to: Ms. Liz Cloud, Program Admin. Administrative Code & Weekley R.A. Gray Building 500 S Bronough Street Tallahassee FL 32399-0250 (Ord. 014,015&016) A. Signature X o Agent o Addressee C. Data of Delivery a. Recelved by ( Printed Name) O. 18 deIlw1y aadree8 different 110m item 1? "l!JEPraeeF~ MAY 1 7 2006 OV88 ONo 3. ~ Flegi!rtemd t:J Return Receipt for Melt;l1andl... OIIlSUllld Mall a C.O.D. 4. Res1tic:ted Oelively? (EJ<tl8 Fee) 0 Yes 7002 2030 0001 2bb8 9b17 2. Arllcte Nllmber (r11lmfer tmm wvIc& IIIbeI) PS Fonn 3811. February 2004 Domeetlc Return Recelpt 102595'02.M.11 -:"' \111 l .... 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