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CC SR 20171108 05 - SB 649 and ADUsRANCHO PALOS VERDES CITY COUNCIL MEETING DATE: 11/08/2017 AGENDA REPORT AGENDA HEADING: Regular Business AGENDA DESCRIPTION: Consideration and possible action relating to state imposed standards for accessory dwelling units and newly enacted housing legislation. RECOMMENDED COUNCIL ACTION: (1) Provide direction regarding weather City should join Take Back Our Community Coalition. (2) Provide direction regarding forming or joining coalition to lobby state for greater local control of housing projects. FISCAL IMPACT: Legal costs are too speculative to realistically estimate at this time. Amount Budgeted: N/A Additional Appropriation: N/A Account Number(s): N/A ORIGINATED BY: Elena Q. Gerli, Assistant City Attorney REVIEWED BY: Gabriella Yap, Deputy City Manager -'s APPROVED BY: Doug Willmore, City Manager ATTACHED SUPPORTING DOCUMENTS: A. Documents from "Taking Back Our Community" Coalition (page A-1) BACKGROUND AND DISCUSSION: In recent years, the State of California has increasingly encroached on cities' ability to govern their own affairs. The State's encroachment on local government's ability to manage its own affairs is an important issue for the City Council, and the City Council feels that it is time for the City to take some action to limit this trend. Some of these changes have affected the criminal justice system in AB 109 and Propositions 47 and 57, which have led to early release of prisoners and threaten public safety. But other community values are threatened. Two recent examples are new State legislation and regulatory requirements regarding accessory dwelling units and small cell wireless facilities. In the midst of a large number of applications to the City for wireless antenna sites, Senate Bill 649, would have made the placement of small cell wireless facilities in the public right-of-way ministerial. However, this was vetoed by the Governor following massive local opposition by cities and through the League of California Cities. Though vetoed, the threat will not go away. The State has also adopted laws that impose 01203.0001/412071.6 1 accessory dwelling units development standards on cities, and just this year the Governor has signed a spate of housing bills, some of which affect cities' ability to govern their own affairs. Accordingly, the City Council may wish to consider creating or joining a coalition(s) of local government agencies with common goals. An example of an existing coalition is the "Taking Back Our Communities" coalition, spearheaded by the City of Monrovia, which is concerned about the unintended consequences of the criminal justice realignment, and has formed a coalition and is inviting other cities to join. The City Council may wish to allocate resources to this effort, and including litigation if needed. Several recent examples of state overreach which threaten the community character of Rancho Palos Verdes are discussed below. A. Accessory Dwellina Units In 2016 certain amendments to Section 65852.2. of the Government Code were enacted, which rename "Second Housing Units" as "Accessory Dwelling Units" (ADUs), and required cities to update their development codes to conform to State guidelines. Effective January 1, 2017, the statute invalidated local development codes related to ADUs not in conformance with these provisions. Changes from the City's current zoning are summarized in the chart below: City of RPV State Gov't Code Minimum setbacks of 20' front, 5' side and Reduced 5' rear yard setbacks if ADU 15' rear setbacks. constructed over an existing garage. Served by sanitary sewer Private sewage disposal may be allowed with approval of Local Health Officer. 1 enclosed parking space required Minimum 1 parking space can be "tandem on existing driveway", which means unenclosed on existing driveway. Over certain SF, any second story, Ministerial (over-the-counter) approval inclusion of balconies 80SF or larger, and within 120 days of application submittal. height over 16' requires discretionary review. Coastal Development Permit required for No public hearings for CDP most improvements seaward of the 1 st public road, some requiring public hearings. The new law's intent is to support infill and affordable housing development." The statute intends to "ease and streamline" current statewide regulations, encourage the building of ADUs, and create more housing options. The statute also "improve[s] and 01203.0001/412071.6 2 incentivize[s] the creation of ADUs as ways to create more rental property and incomes for families to stay in their current homes." However, these standards make no concessions for the particular character of local communities. Of particular interest to the City, for example, is that parking and setback requirements for accessory dwelling units are significantly less restrictive than what the City has in its development code now, and a recently passed bill reduces those requirements even further as of January 1, 2018. The City will be required to permit conversion of covered garage space into habitable units, thus increasing density in single family zones and reducing parking. B. New Housing Bills The Legislature passed, and the Governor signed into law, a number of new housing bills, all focused on making approval of housing developments easier and more streamlined and pushing local governments to meet their regional housing needs. Here we briefly summarize the ones that our office believes will be the most onerous to Rancho Palos Verdes. 1. Assembly Bill 35. This bill curtails local authority with respect to housing projects that meet certain criteria and for infill developments in localities that have not met their regional housing needs assessments, and creates a streamlined process to approve these, including limiting cities' ability to include parking standards on these developments. 2. SB 167/AB 678. This bill requires, when a city wants to deny or decrease the density of a housing development, which meets all applicable development and zoning criteria, to provide written findings to be based on "a preponderance of evidence." The bill provides standing to sue to the applicant, to anyone who is eligible to reside in the housing project, or a housing organization to enforce these provisions. A court may require a city to comply with the statute, and if the court finds that the city acted in bad faith, may order the city to approve the development. The statute also imposes mandatory fines ($10,000 per housing unit) on cities that fail to comply with a judge's order within 60 days, and allows enhanced fines if a city acts in bad faith. 3. SB 166. This bill mandates that cities and counties implement a rolling requirement for adequate sites and rezoning requirement by income level, rather than total units. Continuous rezonings are an extremely onerous requirement for cities and counties. Specifically, the bill requires a city to make specified written findings if the city allows development of any parcel with fewer units by income category than identified in the housing element for that parcel. Where the approval of a development project results in fewer units by income category than identified in the housing element for that parcel and the remaining sites in the housing element are not adequate to accommodate the jurisdiction's share of the regional 01203.0001/412071.6 3 housing need by income level, the bill requires the jurisdiction within 180 days to identify and make available additional adequate sites. 4. AB 1515. This bill prohibits a local agency from disapproving, or conditioning approval in a manner that renders infeasible, a housing development project very low-, low-, or moderate -income households or an emergency shelter unless the local agency makes specified findings. Under the act, the local agency may disapprove or condition approval of a housing development project or emergency shelter if, among other reasons, the housing development project or emergency shelter is inconsistent with both the jurisdiction's zoning ordinance and general plan land use designation, as provided. This bill requires housing projects to be deemed consistent, compliant, and in conformity with an applicable plan if there is substantial evidence that would allow a reasonable person to conclude that the housing development project or emergency shelter is consistent, compliant, or in conformity. 5. AB 1397. This bill creates state -mandated local program, and restricts the use by right of sites that have been zoned to permit specified minimum density and development standards for low-income housing, and requires these sites to have sufficient utilities available or accessible. C. Small cell wireless facilities This bill, SB 649, was adopted by the California Assembly and the Senate, but thanks to a strong push by many local governments and the League of California Cities, the Governor vetoed the bill. The bill would have imposed ministerial approval by local agencies of applications for small cells "located in a public right-of-way in any zone or in any zone that includes a commercial or industrial use." The bill would also have restricted the amount of rent local agencies could charge telecommunication companies for placing small cells on city property, although it would have allowed cities to charge reasonable permit fees and obtain full cost recovery. Given that there are strong lobbying interests behind expanding wireless capability, this is not likely to be the last we have seen of a bill reducing city powers to approve cell towers. D. Criminal Justice: Monrovia Coalition Attached are materials received from the City of Monrovia concerning a coalition being formed called the "Taking Back Our Community," focused on the need for changes to the criminal justice system due to the impacts of AB 109 and Propositions 47 and 57 that are leading to increased local crime. The cities of Monrovia, Arcadia, and Glendora initially conceptualized forming a Coalition of local communities to combat state mandated policies which control issues of local concern. Monrovia now acts as the "lead agency" of the Coalition in organizing events, creating meeting agendas, hiring outside contractors for public education, marketing and public relations, and for overseeing a social media campaign and Coalition website. The Monrovia City Manager's Office staff 01203.0001/412071.6 4 dedicate between 10 and 30 hours a week toward Coalition activities. Depending on how the Coalition grows, the City may hire full-time staff dedicated to addressing Coalition matters. The Coalition formed three months ago and has since grown to over 30 cities, with 50 additional cities in the process of joining or showing interest in joining in the coming months. The Coalition will likely meet once a month, with larger organizational meetings every three months. This month, the Coalition is will meet for the first time to formulate a governance structure and outreach plan. At the City Council meeting on September 5, 2017, the Los Angeles County Sheriff's Department made a presentation on the impacts of these measures, which are briefly summarized as follows. The state's population is growing but the state is not building new prisons which results in jail overcrowding; and through litigation, the courts have become involved. There are something like 125,000 beds in the state system and 85,000 in counties and cities, and 20,000 in County of Los Angeles. The state has pushed significant portion of their population down into the local level resulting in less space available at the local level. In LA County now, if you get convicted of anything involving less than a 120 day sentence, you are immediately released—and on longer sentences you only serve portion of your time. Additionally, convictions do not aggregate—a new one is treated the same as the first one. A chart shows that someone with 60 convictions for burglary will be treated the same as if they had one conviction. The result is that there are thousands of convicts walking the street in Los Angeles who should be in prison and many are committing repeat crimes. The recidivism rate is 60%. The State, which has saved money by these policies, has not put anything into programs to reform behaviors, and the early releases don't give incentives or opportunities to participate in programs. Another chart shows that while crime is declining nationwide, in California the trend is increasing—which is ascribed to the impact of these laws. E. City Council Action Attached for the City Council's information is a packet of information regarding the Monrovia coalition: it requires a financial commitment of $1,500 per year for as long a city is a member of the Coalition. Those funds are primarily used for a public relations firm to craft an initial outreach, including a website, informational materials and videos, and social media. Benefits of such a coalition include sharing of resources and ideas, lower costs in the event of litigation, and more clout with the State government. So far, at least 19 entities have joined the coalition. As a single, general law city, the City of Rancho Palos Verdes may not have a great deal of clout with the state but may have more as a part of a coalition of cities that share a common goal. Similarly, the City may wish to work with other cities to develop a political strategy with future housing legislation. At this time it is unclear how many other agencies would be interested in joining such an effort to roll back some of the housing development standard requirements, but a public relations effort here may be fruitful. It should be 01203.0001/412071.6 5 noted that the City is a general law city, and therefore control over its affairs can be curtailed to a greater extent that it could if it were a charter city, as discussed below. As mentioned, the City may end up in litigation over these issues. Even if the City takes no overt action against the State, unless it complies with the State's requirements, it is likely to be challenged and have to defend its actions in court. The City Council may wish to set aside a fund of up to $1 million dollars to take action to restore local control. This may involve legal challenges over the state regulations on secondary dwelling units. The Council could also initiate litigation, but may also be subject to litigation in these matters, and the fund would cover these costs as well. The City Attorney has analyzed various legal theories to challenge these state actions. There are a number of potential theories but as a general law city whose powers come from the state, the courts generally strictly construe the powers of a city, so any litigation option is difficult. Of course, it must be mentioned that the State is faced with significant shortages of affordable housing and the state legislature has been consistently mandating new restriction on local land use authority. The State may react to challenges to these programs by utilizing other mechanisms to threaten non-cooperative cities, including by manipulating state funding and other mechanisms. F. Charter City The City has previously considered adopting a charter but ultimately did not go forward. In light of the continuing threat to local control, this should be reconsidered. The City's position would be much stronger as a charter city. Charter cities have control over all matters that are municipal affairs whereas the State retains control over charter cities for matters of statewide concern. The City Council could consider exploring the adoption of a city charter to increase its likelihood of success in these matters, but also to have a greater degree of control over its affairs overall. We looked at whether the City would have the ability to ignore the new requirements if it were a charter city. Charter cities enjoy greater constitutional freedom than general law cities to govern their "municipal affairs," even if a conflict with State law may exist. (See Article XI, section 5 of the California Constitution.) There is no exact definition of the term "municipal affair" other than those areas expressly stated in section 5. Whether a subject area is a municipal affair (over which a charter city has sovereignty) or one of "statewide concern" (over which the Legislature has authority) is an issue for the courts that depends on the facts and circumstances of each case. Land use and zoning decisions however, have been consistently classified as a municipal affair and charter cities are exempt from various provisions of the Planning and Zoning Law unless the city's charter indicates otherwise. (See e.g. Gov. Code §§ 65803, 65860(d); City of Irvine v. Irvine Citizens Against Overdevelopment (1994) 25 Cal. App. 4th 868, 874.) 01203.0001/412071.6 6 ALTERNATIVES: In addition to the Staff recommendation, the following alternative actions are available for the City Council's consideration: 1. Join the Monrovia Coalition and seek to broaden the issues being pursued by the Coalition. 2. Set aside significant funds for these efforts including for litigation. 3. Instruct the City Attorney to initiate litigation. 4. Seek additional cities to join in litigation or political efforts. 5. Explore reinitiating a Charter adoption process asking the City Attorney to bring back a report. 01203.0001/412071.6 7 TARIN OUCpgI COMMUNITY September 13, 2017 Hello! Thank you for your interest in joining an important new statewide coalition called Taking Back Our Community. Taking Back Our Community is a growing coalition of California cities coming together to establish a unified message to advocate for common sense changes to California's criminal justice system to help address the public safety impacts resulting from Assembly Bill 109, Proposition 47, and Proposition 57. This coalition aims to engage and educate our constituents on the reasons why crime is increasing and build public support for legislative changes at the State level. Similar to many jurisdictions in the San Gabriel Valley, the cities of Arcadia, Glendora, and Monrovia have all been experiencing significant increases in crime during the past few years. As we worked to develop a response to the public safety issues at hand, we came to the conclusion that unless State legislative changes are made, we are facing an uphill climb when it comes to reducing crime levels — no matter how many more police officers we hire. Given the scale and scope of the public safety challenges we face in California, we felt it was important to invite all cities and other stakeholders across California to join our efforts. Included on this USB drive is a flyer with more information on reasons to join the Taking Back Our Community Coalition (see "Join the Coalition Flyer"). There are two ways a city may join the Taking Back Our Community coalition, depending on whether or not City Council authorization is required. To assist you in your review of the program, we have prepared the following template documents for your consideration: Sign the Taking Back Our Community Coalition Agreement (see "City Manager Authorization — TBOC Agreement"); or Ask your City Council to adopt a formal resolution authorizing your City to join the coalition. A sample staff report and related attachment is included for your reference and use (see "Sample Staff Report — TBOC" and "Sample Staff Report - Exhibit A - TBOC Resolution"). Cities wishing to join the coalition will be mailed an invoice for $1,500 / year to further the coalition's objectives. These membership dues will be used to coordinate the development of an overall public education and outreach campaign. Currently, the majority of the funds will be used to fund our initial outreach efforts through a public relations firm to create the following: An infographic video that provides an overview of the public safety issues impacting communities and directs individuals to the www.TakingBackOurCommunityCA.com website that will have Calls to Action to contact your State representatives A-1 • Multiple in-depth videos interviewing individuals and businesses impacted by the adverse effects related to this legislation • A stand-alone coalition website for residents and businesses to learn about these issues to ensure consistent, fact -based messaging across agencies • A coalition logo • Setting up social media accounts on Facebook, Twitter, and YouTube, and organizing campaign posts to raise awareness Additionally, the funds will be used for outreach materials to assist at future conferences and related events. The Taking Back Our Community Coalition is quickly growing to include many cities in our region, as the response to the initiative has been overwhelming and positive. To date, we have 19 agencies that have agreed to join the coalition, including: 1. Alhambra 2. Arcadia 3. Claremont 4. Covina 5. Duarte 6. Glendora 7. Irwindale 8. La Canada Flintridge 9. La Verne 10. Monrovia 11. Monterey Park 12. Pasadena 13. San Marino 14. Sierra Madre 15. West Covina 16. Whittier 17. San Gabriel Valley Council of Governments 18. California Police Chiefs 19. Association of Deputy District Attorneys You can learn more about this coalition by visiting www.TakingBackOurCommunityCA.com. If you have any questions, please feel free to let us know directly, or you can contact Brittany Mello, Senior Management Analyst, at bmello anci.monrovia.ca.us or (626) 932-5571. We hope that you will be interested in participating in this important venture, and appreciate your time and consideration! Best regards, Chris Jeffers City Manager City of Glendora cieffersaci.alendora.ca.us (626) 914-8201 Dominic Lazzaretto City Manager City of Arcadia domlazz anarcadiaca.aov (626)574-5401 Oliver Chi City Manager City of Monrovia ochi@ci.monrovia.ca.us (626) 932-5585 A-2 i •`4 X 1 sv b_' F .. SiF' Yai3{.:y� �� ril�.'. .. ..�. _ _ 2' a g' �r .,•yYy�� .f+Yd ��,�.r� •"'t'�yiY ..�u .-LW" �.. w.�. ,. � P �. STATE CHANGES AFFECTING OUR COMMUNITY INCLUDES: I ' y®� /' ASSEMBLY BILL 109 PROPOSITION 47 PROPOSITION 57 COALITION OBJECTIVES REASONS TO JOIN • To raise public awareness of why 0 Official Taking Back Our Community branding with your agency's crime is increasing in our state. logo • To provide a consistent message 0 Infographic video summarizing the issue and impactful stories told surrounding the facts and by the community impacts of AB 109, Prop 47, and 0 In-depth legislative tracking Prop 57. 0 Customizable outreach material including: • To advocate for State legislative • Comprehensive Fact Sheet changes to improve law • Sample letter to State enforcement's ability to respond legislators to crime. 0 Informational brochure HOW TO JOIN Contact the City of Monrovia at (626) 932-5571 or email bmello@ci.monrovia.ca.us for more information on how to join. MEMBERSHIP DUES $1,500 per year Find out more at www.TakingBackOurCommunityCA.com COALITION MEMBERS C�C • it •� � _ A[tca�[A City of .� GLZ 1 T r o f fAC%.ur'+ MONROVIA Dc�arzfe �PoRAT F^� [ I I 1 I[x_i 18 91 t IER C SGVCOG -3 TAKING BACK OUR COMMUNITY COALITION This Taking Back Our Community Coalition (hereinafter, the "Coalition") is entered into by and among municipalities and agencies within the State of California ("Members") for the purpose of establishing a unified message to advocate for common sense changes to California's criminal justice system that address the public safety impacts resulting from Assembly Bill 109, Proposition 47, and Proposition 57. RECITALS WHEREAS, Coalition members agree that recent State legislative changes — namely Assembly Bill 109, Proposition 47, and Proposition 57 — made some changes to California's criminal justice system that were needed and necessary; and WHEREAS, Assembly Bill 109, Proposition 47, and Proposition 57, have had negative public safety impacts that have affected cities, counties, and other public safety organizations throughout California; and WHEREAS, through a collaborative effort, the Coalition seeks to advocate for common sense legislative solutions that will enhance the criminal justice system in California more equitably. NOW, THEFORE, the Taking Back Our Community Coalition Members agree as follows: 1. The City of Monrovia shall act as the lead agency with respect to the administration of the Coalition, and shall act as treasurer for the Coalition, responsible for the collection of fees from Coalition members and the payment of costs incurred on behalf of the Coalition; and 2. In order to achieve the objectives of the Coalition, each Member agrees to pay one thousand five hundred dollars ($1,500.00) on an annual basis to the lead agency as long as the Member wishes to remain in the Coalition. 3. Each Member shall designate one or more representatives to be an active participant in Coalition meetings, and facilitate the exchange and dissemination of information to further the Coalition's objectives. IN WITNESS THEREOF, the City of Back Our Community Coalition as of signer below. does hereby join the Taking 2017, as authorized by the CITY OF XXXXXXXX Approved by: Name, City Manager on, SAMPLE STAFF REPORT TITLE: Request to Join the Taking Back Our Community Coalition to Support Public Safety Related Legislative Advocacy Efforts OBJECTIVE: To approve an agreement with the City of Monrovia to join the Taking Back Our Community Coalition. BACKGROUND: Taken together, Assembly Bill 109, Proposition 47, and Proposition 57 have reshaped how we approach public safety issues in the State of California. While the identified measures have certainly resulted in measurable and positive impacts to California's criminal justice system, the cumulative effect of these legislative actions have also had significant adverse effects resulting in public safety challenges. Most notably, municipalities across California are reporting increases in property and violent crime that law enforcement believe to be related to the legislative changes that have been enacted over the past several years. In September 2017, the City of Whittier brought forth a key resolution asking the League of California Cities to initiate and facilitate further discussion between the Governor, the State Legislature, and other key public safety stakeholders regarding the recent legislative changes that have been made to California's criminal justice system. During the past few weeks, staff has been engaged in discussions with the City of Monrovia regarding the development of the Taking Back Our Community Coalition. Taking Back Our Community is a new coalition of California cities advocating for the State to engage in further discussions to identify solutions for addressing the unintended consequences of changes made to California's criminal justice system through the enactment of Assembly Bill 109, Proposition 47, and Proposition 57. The Coalition is led by the Cities of Arcadia, Glendora, and Monrovia, with Monrovia acting as the lead administrative agency. ANALYSIS: The formation of the Taking Back Our Community Coalition represents positive steps to mitigate the emerging public safety issues related to changes to California's overall criminal justice system. The Taking Back Our Community Coalition is quickly growing to include many cities in our region looking to be part of a positive solution. All members of the Coalition will be required to pay the City of Monrovia $1,500 / year, and the funds raised will be used to coordinate the development of an overall public education and outreach campaign. Taking Back Our Community Coalition Objectives: • To raise public awareness of why crime is increasing in our state • To provide a consistent message surrounding the facts and impacts of Assembly Bill 109, Proposition 47, and Proposition 57 • To advocate for State legislative changes to improve law enforcement's ability to respond to crime Benefits of Becoming a Coalition Member: • Official Taking Back Our Community branding will include the City's logo • Infographic video summarizing the issue along with impactful video stories told by community members impacted by crime increasing • In-depth legislative tracking and analysis related to proposed State legislation • Access to customizable outreach material to share with community members, including: • Informational Brochure • Comprehensive Fact Sheet on AB 109, Prop 47, and Prop 57 • Sample Letter to State Lawmakers • Opportunity to regularly meet with regional members and guest speakers to further the Coalition's objectives ENVIRONMENTAL IMPACT: There are no environmental impacts associated with this action. FISCAL IMPACT: Membership dues for the Taking Back Our Community Coalition is $1,500 / year for each year that the City wishes to remain in the Coalition. Funding for this initiative is available in the City's Fiscal Year 2017/18 Budget. OPTIONS: The following options have been developed for City Council's consideration: 1. Approve the agreement with the City of Monrovia to join the Taking Back Our Community Coalition (Exhibit A). 2. Do not approve the agreement and provide staff with additional direction. RECOMMENDATION: Staff recommends that the City Council select Option 1, thereby approving the agreement with the City of Monrovia (Exhibit A) and joining the Taking Back Our Community Coalition. COUNCIL ACTION REQUIRED: If the City Council concurs, the appropriate action would be a motion to approve the attached agreement with the City of Monrovia, and authorize the City Manager or his/her designee to execute all necessary documents. Wo TAKING BACK OUR COMMUNITY COALITION This Taking Back Our Community Coalition (hereinafter, the "Coalition") is entered into by and among municipalities and agencies within the State of California ("Members") for the purpose of establishing a unified message to advocate for common sense changes to California's criminal justice system that address the public safety impacts resulting from Assembly Bill 109, Proposition 47, and Proposition 57. RECITALS WHEREAS, Coalition members agree that recent State legislative changes — namely Assembly Bill 109, Proposition 47, and Proposition 57 — made some changes to California's criminal justice system that were needed and necessary; and WHEREAS, Assembly Bill 109, Proposition 47, and Proposition 57, have had negative public safety impacts that have affected cities, counties, and other public safety organizations throughout California; and WHEREAS, through a collaborative effort, the Coalition seeks to advocate for common sense legislative solutions that will enhance the criminal justice system in California more equitably. NOW, THEFORE, the Taking Back Our Community Coalition Members agree as follows: 1. The City of Monrovia shall act as the lead agency with respect to the administration of the Coalition, and shall act as treasurer for the Coalition, responsible for the collection of fees from Coalition members and the payment of costs incurred on behalf of the Coalition; and 2. In order to achieve the objectives of the Coalition, each Member agrees to pay one thousand fife hundred dollars ($1,500.00) on an annual basis to the lead agency as long as the Member wishes to remain in the Coalition. 3. Each Member shall designate one or more representatives to be an active participant in Coalition meetings, and facilitate the exchange and dissemination of information to further the Coalition's objectives. IN WITNESS THEREOF, the City of Back Our Community Coalition as of signer below. does hereby join the Taking 2017, as authorized by the ��J ATTEST: Name, City Clerk City of XXXXXXX Name, Mayor City of XXXXXXX APPROVED AS TO FORM: Name, City Attorney City of XXXXXXX v/ J � H� f- O H H LU Fn te 2 a,. WW Qa w� O wa I.L UQ — w N a co N a E Z cuE 0 O LL a o y R r- u! 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