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Resolution 331-1986 ,-. RESOLUTION NO. 331-1986 A RESOLUTION AUTHORIZING THE MAYOR OF MONROE COUNTY TO EXECUTE ON BEHALF OF MONROE COUNTY AN AGREEMENT WITH THE FLORIDA DEPARTMENT OF COMMUNITY AFFAIRS FOR THE COUNTY TO PERFORM CERTAIN TASKS IN CONNECTION WITH THE IMPLE- MENTATION OF THE NEW COUNTY LAND USE PLAN. WHEREAS, the Department of Community Affairs, State of Florida, has funding available in the amount of $1,050,000 in order to aid Monroe County in implementing its new Comprehensive Land Use Plan; and WHEREAS, it is desired to take advantage of such funding; and WHEREAS, the Department of Community Affairs, State of Florida, has made certain administrative and auditing changes to the previous agreement authorized on October 17, 1986; and WHEREAS, these changes require a new authorization to accept the available funding; and WHEREAS, it is also necessary to authorize the Planning Director, with the direction of the Clerk of Court and the County Administrator, to specifically implement overtime and salary provisions of this agreement consistently with Monroe County policies; now, therefore BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA: The Mayor is authorized to sign and execute, on behalf of Monroe County, Florida, an agreement with the Department of Community Affairs, State of Florida, whereby Monroe County shall perform certain tasks necessary to implement its new Comprehen- sive Land Use Plan and development regulations and the Department shall fund those tasks in the amount of $1,050,000. PASSED AND ADOPTED by the Board of County Commissioners of Monroe County, FloJida, at a -fd- day of ~~... !p..r- regular meeting of said Board on the , A.D., 1986. - , Resolution No. 331-1986 (SEAL) Attest: DANNY L. KOLHAGE, Clerk .~ BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA By /g:u,~ ~-?h~ MAYOR /J ~ ) ! ; ~ ~ ..} " ~ ~ ; fa . Lucien Proby, Esq( County Attorney ,"lr~, . [,j: 11';' r~l H PI U ErlER!:, 11I"f'lT 1'-14 F'CC MEMOR~ OF AGREEMENT This agreement is being entered into by and between the Department of Community Affairs (Department) and Monroe County (County) to provide for the implementation of th~ Mon~oe county Comprehensive Plan and land development regulations including a land use map in order to insure that future growth management in the Florida Keys will be coordinated, well planned and competently implemented. WHEREAS, the County has been declared an Area of critical state Concern pursuant to Section 380.05, Florida Statutes, and therefore, has pI"epared, and submitted a Comprehensive Plan and land development regulations approved by the Department and the Admtnistration Commission in accordance with Section 380.05, Florida Statutes. WIlERF:AS, the 1986 session of the Legislature provided an appropl- iation of $1,050,000 from the General Revenue Fund to the ~rea of Critical State Concern Trust Fund for implementation lissistance for compr'ehensi ve plans and land development ~egulations developed pursuant to and consistent with the area of critical state concern program within the Florida Keys area. WHEREAS, the county commission approved and submitted to the Department its comprehensive plan and land development r"egulations in accordance with Section 163.3161, et seg. and 380.05, Florida Statutes, on February 28, 1986. WHEREAS, the Administration Commission voted to accept these do<..:wnents, with changes, at its meeting of July 29, 1986, and subsequently established the effective date for the implementation of this comprehensive plan and land development regulations as september 15, 1986. (Hereinafter, as used in this agreement, the terms Monroe County Comprehensive Land Use Plan and Land Development Regulations refer to" and shall be interpreted to mean the Monroe County Comprehensive Plan and Land Development Regulations adopted by Monroe County on February 28, 1986 and adopted by the Administration Commission on July 29, t ",.,. ~----~.._-------- I .-'.-...-.-.....-- --- ....'4_.. _'____... t j'IJi ' l"J: ():=:: FLH Dr') HIEPG r'll-:.r'lT 14.../ PCl'-l 1986, and which Plan and Regulations became effective on September 15, 1986.) WHEREAS, both the Department and the County have committed to effort. provide staff and resources to support this cooperative planning NOW, THEREFORE, THE DEPARTMENT AND THE COUNTY DO MUTUALI~Y AGREE AS FOLLOWS: I. Covenant for Service The Department does hereby retain the County to perform the services described herein and the County does hereby agree to perform such services under the terms and conditions set forth in this agreement. II. Availability of Funds Subject to and conditioned Upon the release of authorized Payment of state funds pursuant to this agreement are Fund. appropriations from the Area of Critical State Concern Trust Ill. Def ini tion, Scope and Quality of Service (A) Intent of the Agreement regulations, to undertake, perform, and complete the six tasks of this agreement and the applicable state and local laws and The County agrees, under the terms and conditions the Monroe County Comprehensive Land Use Plan and Land listed below which will help ensure successful implementation of Development RegUlations. (B) Scope of Services and Schedule of Deliverables below: The County agrees to complete the six tasks listed (1) ~ ~ ~ Administration: $336.000 These funds will be allocated for the below purposes: (a) Funding to cover the implementation requirements of the Monroe County Comprehensive Land Use Plan and Land Development Regulations for services including transportation planning, socio- r ;i~-il lOr::. . ,~_:~~, FLA D I l) E~'lEF'13 "l13I'IT 5 economic planning, general planning, environmental planning, environmental permitting, and enforcement of environmental regulations, secretarial assistance and civi.l engineering; (b) General administrative expenses, office expansion and outfitting authorizing the County to expend funds to properly equip offices as needed to accommodate the planning services described in (a) above. Said outfitting may be used for office equipment, telephones, supplies, space rental and office renovations as needed; (c) Staff development in the form of funds distributed to specified positions of the Monroe County Planning, Building and zoning Department (Planning Department) in existence on September 14, 1986. These funds are made available to recognize new responsibilities associated with the Monroe County Compr'ehensi ve Land Use Plan and Land Development Regulations, subject to the approval of the Board of County Commissioners. (d) overtime compensation in the form of funds made available 'to recognize additional hours required to assist in the implementation of the Monroe County Comprehensive Land Use Plan and Land Development Regulations. These funds will be distributed to the inspectors, building/planning/zoning coordinators, secretaries, aids and clerks positions within the Planning Department for compensation for all hours worked in addition to the normal 37-1/2 hour work week. The overtime rate of 1-1/2 times the employee'S base rate of compensation will be the determining rate of distribution of these funds. Compensation will be reflected in paychecks covering the period from the execution 'of this agreement through September 1 . - " 1,1: ,0 FL.H [I I I) Ef'lEF'Cl r'ICil'IT 1.j..j F'CII:, - I - - 30, 1987, and will be documented on forms provided by the County. ( 2) Monroe County Comprehensive Land Use plan and rJAnd Development Regulations Refinement: $359,000 In order to further the County's 'compliance with the 1985 Growth Management Act, the 1986 revisions to the act and the necessary update items identified by the Department in its review of the February 28, 1986 submittal made by the County, the County will complete the following activities: (a) Refine the land use district maps and the existing conditions maps from the current scale of 1" ;;; 600' to an improved scale of 1" := 200' in conjunction with the ongoing effort at the Monroe County Appraiser's Office and provide the Department with one sepia/mylar original and one paper copy of each map series; (b) Reassess and refine using field collected data from each habitat type the Habitat Evaluation Index (HEl) found in Volume 1 and Volume 2 of the Monroe County Comprehensive Land Use Plan and prepare in' repol-t format a sub/lli ttal to the Couu ty Commission for adoption consideration no later than the first six-month update of the Monroe County Comprehensive Land Use Plan and Land Development Regulations; (c) Review the environmental performance standards established in Volume 3 of the Monroe County Comprehensive Land Use Plan's Land Development Regulations to establish appropriate mitigation alternatives for adoption consideration by the County Commission during the second six-month update of the Monroe County Comprehensive Land Use Plan; (d) Complete the conaideration for adoption as an amendment, to the Monroe County Comprehensive Land ~ 1-): FLr~ [J I l) H1EPCi f'lCit'lT 1-l.' 1-- Use Plan of the North Key Largo Area of Critical County Concern and Habitat Conservation Plan by the County Co~nisslon and prior to adoption, the County will prepare and submit or cause to be prepared and submitted, an application to the State of Florida for an area-wide Development of Regional Impact as well as an Environmental Impact Statement; (e) Subcontract for a traffic impact model capable of projecting future levels of service and road improvement costs compatible with the County's computer system -- said model will be used as a basis for establishing compliance with the Monroe CounLY Comprehensive Land Use Plan's adequate facilities provisions, and the Florida Department of Transportation will be requested to review and comment on all aspects and phases involving the development of the model; (f) Complete the focal point planning program~ established for the Holiday Isle and Sunshine Key Areas of Critical County Concern to replace the existing interim rules no later than the second six-month update of the Monroe County comprehensive Land Use Plan; (g) Develop a usable procedure to register fishermen according to the requirements of Volume 3, Section 9-225 of the Monroe County Comprehensive Land Use Plan's Land Development Regulations within 90 days of September 15, 1986; (h) Develop a usable procedure for the registration of all non-conforming uses no later than the second six-month update of the Monroe County Comprehen~ive Land Use Plan; (1) Develop and implement a Transferable Development Right accounting program for use on the County's ., I I~h~:, . :~-'I--: l..~: 1 1 FLA [l I l) aIEF'G f'IGrn 144 pm:: I computer system by the first six-month update of the Monroe County Comprehensive Land Use Plan; (j) Recodify the land development regulations found in volume 3 of the Monroe co~nty - Comprehensive Land Use Plan's Land Development Regulations for use in the County Code Book no later than the completion of the first six-month update of the Monroe County Comprehensive Land Us~ Plan and transmit two complete copies to the Department; (k) Develop, in conjunction with the South Florida Water Management District, Department of Environmental Regulation and the South Florida Regional Planning Council, a stormwater runoff ordinance for adoption consideration by the County commission during the first six-month update of the Monroe C~unty Comprehensive Land Use Plan; (1) Prepare a survey of archaeological, historical and cultural sites for adoption consideration by the County as landmark designations no later than the second six-month update of the Monroe County Comprehensive Land use Plan the County and the Department agree to request the assistance of the Florida Department of State in this effort; (m) Develop a sign program according to the requirements of Volume 3, Chapter 9, Division 13, Section 9-1308 of the Monroe County Comprehensive Land Use Plan's Land Development Regulations to implement the prohibition of off-premises and portable signs no later than the second six-month update of the Monroe County Comprehensive Land Use Plan; (n) Prepare a handbook ~nd/or pamphlet explaining landsoaping and bufferyard requirements no later than the first six-month update of the Monroe Count V Comprehensive Land Use'Plan; tJ .-...-..--.- , (~,I I Clt;, . '::,r' 1 -~: 1~: FLH D I I) E~lEF'G t'lGrn -'0'3 (0) Implement an impact fee accounting and tracking procedure no later than the first six-month update of the Monroe County Comprehensive Land Use Plan; (p) Develop and implement a conditional use monitoring program compatible with the C6unty's computer system no later than the first six-month update of the Monroe County Comprehensive Land Use Plan; (q) Review the Destination Resort requirements and prepare a report describing possible refinements for adoption consideration by the County Commission during the second six-month update of the Monroe County Comprehensive Land Use Plan; (r) Prepare a report for adoption consideration by the County Commi.ssion during the second six-month update of the Monroe County Comprehensive Land Use Plan which reviews the status of live-aboard vessels and include reconunendations for corrective action; (s) Develop a focal point planning program for the Marathon urea for adoption consideration by thQ County Connission during the second six-month update of the Monroe County Comprehensive Land Use Plan; (t) Review the Mixed Use District and prepare a report for adoption consideration by the County Commission durinq the second six-month update of the Monroe ~ounty Comprehensive Land Use Plan which describes the suitability of eXisting standards and recontnend appropriate changes; and (u) Within six months of the effective date of the Monroe County Comprehensive Land Use Plan, the County will implement, in cooperation with the Department of EnVironmental Regulation and other state and federal agencies, a water quality monitoring program to ensure that the individual and cumulative impacts of development, especially 'if . ~,t~ 1 ~) : FLH [I I () E~1ERfl 11hllT l'~~ 14~' wastewater treatment systems, commercial water dependent activities and live-aboar"d vessels, do not degrade nearshore water quality. The County will invite the Cities of Key West, Key Colony Beach and Layton to participate in the development of this water quality monitoring program; sampling stations for these Cities shall be included in th~ program and the cause of any water quality problem(s) ahall be identified and corrective measures are to be recommended. (3) ~egal Assistance: $100,000 These funds are hereby committed for the following purposes: (a) The preparation of a revised "users' manual" fOl~ the Monroe County Comprehensive Land Use Plan and Land Development Regulations. Such manual shall be in booklet or notebook form and shall provide to the general pUblic the following: a description of the Monroe County Comprehensive Land Use Plan, the Land Development Regulations and permitting process; a description of how to utilize the procedures of the Monroe County CompI'ehensive Land Use Plan, Land Development Regulations and permitting process; and any necessary graphics or charts which would aid in citizen understanding of the Monroe County Comprehensive Land Use Plan, Land Development Regulations and permlttinq process; (b) The preparation of a report that analyzes the legal issues raised by the Monroe County Comprehensive Land Use Plan, Land Development Regulations" and the permitting process, including, but' not limited to: claims of vested rights under any Florida statute, constitutional provision or case law or claims of vested rights under any federal statute, 6 ---'_.-----...--~ , ,I!~I:: l-:)~, . :~;t= 11.1) FUi D F) HlERe; t'H1T :'11 constitutional provision or case law; claims that the Monroe County Comprehensive Land Use Plan and Land Development Regulations do not bear a substantial relationship to the public health, safety and welfare; claims that the Monroe County Comprehensive Land Use Plan and Land Development Regulations deprive affected persons of due process, procedural and substantive, and of equal protection of the law; and claims that the Monroe County Comprehensive Land Use Plan and Land Development Regulations effect a regulatory taking. The analysis will be designed to provide the County Attorney, or other designated County legal representative, with a comprehensive legal research reference to serve as a basis for: required interpretations of the Monroe County Comprehensive Land Use Plan and Land Development Regulations, administrative proceedings under the Monroe County Comprehensive Land Use Plan or Land Development Regulations, and legal challenges to the Monroe County Comprehensive Land Use Plan and Land Development Regulations. An analysis shall also be prepared of any ordinances, resolutions or other regulations serving as a gap or bridge between the land development regulations in effect on July 14, 1986, and the Monroe County Comprehensive Land Use Plan and Land Development Regulations; (c) The implemehtation of the area of critical county concern designation for North Big pine Key, including: the design of a planning and legal methodology for the required focal point planning program; preparation of, and taking part in, a citizen participation program, coordination of data collect.ion and consultation analysis regardinq future land use in areas of !J I I 'h~, .. -----~--_._..._... l' , , " , FLI:t D I (I El'lEF'C-i 11c;r'1T environmental resources such as, by way of illustration and not limitation, the endangered Key Deer; preparation of amendments to the Monroe County Comprehensive Land Use Plan and Land Development Regulations; and participation in the amendment process; (d) The providing of professional assistance in the Monroe County Comprehensive Land Use Plan and Land Development Regulations update at the six-month review period with particular attention to implementation of the adequate facilities provisions of the Monroe County Comprehensive Land Use Plan and Land Development Regulations and the incorporation of the North Key Largo Habitat Conservation Plan; (e) Any other services authorized by the Board of County Commissioners which are directly related to implementing the Monroe County Comprehensive Land Use Plan, provided that items (a) through (d) shall be completed. (4) Special Study Qy PropertX' Appraiser: $50,000 The County's Property Appraiser will prepare and submit a report documenting that office's review of the property assessments affected by the Monroe County Comprehensive Land Use Plan and Land Development Regulations no later than June 1, 1987. (5) Hearing Offic~ Costs: $25.000 Based on the beneficial use and vested rights provisions of Chapter 8, Volume 3, of the Monroe County Comprehensive Land Use Plan's Land Development Regulations, the County will subcontract with Hearing Officers who are members of the Florida Bar for the purpose of reviewing claims for beneficial use and vested rights. Hearing Officers will be retained on an hourly contract basis. Eligible costs shall include time 1~ 'i>~ -h 1--1:' ~ FLt4 D HI EI'lERC:' f'll3r'lT 14~t T"7 to prepare recommended conclusions of law and findings of fact for consideration by the County Commission, document reproduction and preparation, court reporter services and other heariRg related costs. (6) Special Counsel/Legal Defense: ~180,000 The county will subcontract with Special counsel to act as its general legal representative concerning litigation involving the County's implementation of the Monroe County Comprehensive Land Use Plan and Land Development Regulations. The Special c'ounsel and/or members of the firm as appropriate will be expected to advise the County in matters of state and local law, including changes and proposed changes, involving administrative and policy decisions made during the implementation of the Monroe County comprehensive Land Use Plan and Land Development RegUlations ,and on such other matters as the county deems appropriate at the discretion of the County Attorney. The Special Counsel will coordinate these responsibilities with the Planning Department and the County Attorney. The Special Counsel will prepare, within six months after selection, impact fee ordinances and other appropriate legal instruments such as inter local agreements for adoption consideration by and between Monroe County and the Cities of Key West, Key Colony Beach and Layton for the collection of impact fees from new development in those Cities and ensure the transfer of fees collected to the ~ounty for those services impacted. Compensation shall pe as specified in a subcontract which will specify hourly rates ' , , expenses, costs and modification proviSions. it I ;--- --,.-..,._"-"::":,,.._...,,...--...:--.~,,,---- ~J6 . ':=:r=. 1--' FLA D II) E~lERG ~lCir'IT 1.: IV. Consideration As consi.deration for work satisfactorily performed under this agreement, the Department agrees to pay an amount up to $1,050,000. This is a fixed fee agreement. , V. Method of Payment The total expenditure authorized under this agreement is $1,050,000, and no amendment shall result in a greater expenditure. The Department agrees to pay the County upon submittal of the proper documentation, as follows: (A) Initial payment of $262,500 to the County upon the signing of this agreement, (B) A second payment of $262,500 upon the submittal and the Department's acceptance of the following worK products from section III B(2) of this agreement: (a), (b), ( g), (j), (K), ( n), ( 0), (p), and (u) and the Department's acceptance of a progress report demonstrating satisfactory progress on all remaining work products. These work products and progress report are due no later than March 15, 1987. (C) A third payment of $262,500 upon the submittal and the Department's acceptance of a progress report demonstrating satisfactory progress on all remaining tasKs is due no later than June 30, 1987; (D) A fourth payment of $262,500 upon the submittal and the Department's acceptance of all remaining worK products and tasKs. These work products and tasks are due no later than December 1, 1987. VI. Receivables and Acceptances If all required receivables, prescribed in the scope of services above, are not sent to the Department or are not completed in a manner acceptable to the Department, the Department shall withhold further payments until they are completed and accepted. The Department has discretion to approve or reject the receivables submitted to it pursuant , J. 2 I _. -.-..-----..-.,.- ...---'-.........~~ ,I I ,~ I" . " 1 . 1 . 1,- FU=l DIU ErIEG'Cl l'ILil'IT 1 I to this agreement. Within fifteen (15) working days after the Department receives a receivable~ it will review the receivable and respond in writing to the Director of Planning, BUilding and Zoning, with a copy to the County Clerk and the County Attorney, either approving the receivable or rejecting the receivable and specifying the reasons for rejection. The County has ten (10) working days after notice of the reason for the Department's rejecting the receivable to correct and resubmit the receivable or receivables. "Acceptable to the Department" means that the work products and tasks are completed and submitted as a professional product the contents of which are consistent with the scope of services. VII. Audit Requirements (A) The County agrees to maintain adequate financial procedures and adequate support documents to account for the expenditure of funds under this agreement. (B) These records shall be available at all reasonable times for inspection, review, or audit by state personnel and other personnel duly authorized by the Department. "Reasonable" shall be construed according to Cil"CUmstances, but ordinarily shall mean normal business hours of 8:00 a.m. to 5:00 p.m., Local Time, Monday through Friday. (C) The County shall, also provide the Department with the records, reports or financial statements upon request for the purposes of auditing and monitoring the funds awarded under this agreement. The Planning Director shall be responsible for all docwnent submittals, with the County Clerk and County Attorney assisting as appropriate. All correspondence concerning this agreement and the Director of Planning, BUilding and Zoning shall be copied to the County Clerk and County Attorney. c~ , ,~!, ~ '".,: 1 -~: 1 7 Fu=i DIU Ef'lERCl 111=il1T 14.1 l1''::' (D) The County shall include an accounting of these funds in the local audit prepared by the county for the 1986-87 and 1987-88 fiscal years as applicable. (E) The County shall retain all financial records, supporting documents, statistical reco~ds, and any other documents pertinent to this agreement for a period of three years after the date of submission of the final expenditure report, or if an audit has been initiated and ~udit findings have not been resolved at the end of three years, the records shall be retained until resolution of the audit findings. VIII. Public Records The County shall allow public access to all documents, reports, papers, letters or other material, subject to the provision of Chapter 119, Florida Statutes, prepared or received by the County in conjunction with this agreement. It is expressly understood that upon receipt of substantial evidence of the county's refusal to comply with this provision, the Department will have the right to terminate this agreement for breach. IX. Subcontracts (A) If the County subcontracts any or all of the work required under this agreement, the County agrees to include in the subcontract that the subcontractor is bound by the terms and conditions of this agreement with the Department. (B) The County agrees to include in the subcontract that the subcontractor shall hold the Department and the County harmless against all claims of whatever nature by the subcontractor arising out of the performance of work under this agreement. (el Prior to entering into any subcontracts, the County shall forward a copy of the proposed subcontract to the Department for review and approval by the Department. Each S4bcontract shall. contain the phrase "Funding for this contract is contingent upon approval of this . 14 I "','-..., """<-,;" ."" ".,'~..,"'.~ ......._-,,'_.._-~...,.,..- ._---'-~--.-................ ~ .j'e, . :~:I,c I.l' 1 'C FLH D I () E~IEF'C; r'!Cir'lT ..., , contract by the Florida Department of Community Affairs." (D) Both parties further agree that any State institution or agency may be subcontracted with directly to perform the work tasks authorized by this agreement. x. Contract Term (A) This agreement shall become effective on the last date of signing by the parties involved. No cost may be attributed to this agreement prior to that date. (B) All activities performed pursuant to this effort shall be completed on or before December 1, 19B7. The agreement shall terminate on the same date or upon the last payment to the County, whichever comes first. XI. Modification of this Agreement Modification of the provisions of this agreement, including any extension of the termination of this agreement, shall only be valid when they have been reduced to writing, duly signed by the parties hereto, and attached to the original of this agreement. XI!. Terms and Conditions Nothing in this agreement shall be construed to require County performance on any of the tasks described herein if the funds specified in this agreement for that task are not available from the Department. The Department likewise finds that nothing in this agreement shall be construed as a commitment for future funding. This agreement contains all the conditions and terms agreed upon by the parties. Attached to this agreement is the fOllowing: (I) Addendum A, Work Program Costs. :t.b 1 .l. --..III.' ~ --~ ~...- .....-...---- , .1':-, l,1 FLH D I l.J Er'IER!:i f'lCiflT 1.;.1__ IN WITNESS WHEREOF, the parties have caused this 17 page clgreement to be executed by their undersigned officials as duly authorized. ~'*/ / L(Ltltw' It Lt r ,D1 Di sion of Resourc and Management Department of Community Affairs State of Florida Mayor, Board of Commissioners Monroe county, Florida Date 1(' ?- j(, Date II 7'~ ror;r,~ % S ,.0 .. ,C"{. ~i/' '-"'/\' ~"E:O /1... c.i-.I(,!,;l. ... ./'? . '/ ...t,V "'1(1://. ) p"f' . :), . ~ _' A '!2'i/t ,~;(;l\'- , --' (1\:" .. ",.......... _ .-.~_." ." ',1/1' "-~:,"ill.' r"-;:7 LC;>-_~.,. V/) ,-- D',: ' , .n~. I ,.,,{' - ,.tF!' ...-'.'-.,-.-",---.,.-.......-. -- I~I".' '=:,= 1 " FLJ~ [I I II Er'lEf'(:i rlc,r IT ~ PROGRAM COSTS 1. LAND USE PLAN ADMINISTRATION 2. MONROE COUNTY COMPREHENSIVE LAND USE PLAN AND LAND DEV'ELOPMENT REGULATIONS 1. LEGAL ASSISTANCE 4. SPECIAL STUDY BY PROPERTY APPRAISER ). HEARING OFFICER COSTS 6. SPECIAL COUNSEL/LEGAL DEFENSE - -_._----~_._-_.... 1" I $336,000 $359,000 $100,000 $ 50,000 $ 25,000 $180,000 TOTAL $1,050,000 o rOr.r.n \lED .AS 1 '. C'l. APPRO . "orFIr.I1.. tl:GAl ~ .AND . .__ __.-' __---~-;i~~- ..----:: " < ,.', (3'1 .- Att",."e', . 17