01_20141111_PC_SR_Operational_Review_Green_HillsCITY OF RANCHO PALOS VERDES
MEMORANDUM
TO: CHAIRMAN & MEMBERS OF THE PLANNING COMMISSION
FROM: JOEL ROJAS, COMMUNITY DEVELOPMENT DIRECTOR
DATE: NOVEMBER 11, 2014
SUBJECT: OPERATIONAL REVIEW OF GREEN HILLS MEMORIAL
PARK CEMETERY MASTER PLAN (CASE NO. ZON2003-
00086); Location: 27501 Western Avenue
Project Manager: Eduardo Schonborn, AICP, Senior Planner
REVIEWED BY: CAROLYNN PETRO, ACTING CITY MANAGER AND CAROL
LYNCH, CITY ATTORNEY.
RECOMMENDATION
Adopt P.C. Resolution No. 2014-_, that:
1) Imposes a moratorium on ground burials/interments and sales of burial plots on
the rooftop of the Memorial Terrace Mausoleum building located in Area 11 of the
Master Plan, and imposes a moratorium on above -ground burials and other above-
ground structures within the 5 -foot setback area along the western property line in
the area south of the Pacifica Mausoleum building, which shall remain in effect
until final action is taken by the City to approve a Variance application for the
Memorial Terrace Mausoleum building and on the issues of said interments and
structures in the required setback along the western property line;
2) Directs Green Hills Cemetery to submit a Variance application within 30 -days to
seek approval to: a) allow the existing Memorial Terrace Mausoleum building to
remain encroaching 32 -feet into the required 40 -foot property line setback;
b) allow, within the 16 -foot setback in the northwest corner of the cemetery site
between the west property line and the maintenance yard, only the 13 existing
below -ground interments and 6 companion spaces identified in Exhibit B of the
Resolution; and c) allow existing structures and above -ground burials within the 5 -
foot setback area along the western property line in the area south of the Pacifica
Mausoleum building,
3) Imposes a number of conditions on the cemetery to avoid/minimize impacts to the
adjoining neighbors from burial activity on the roof of the Memorial Terrace
Mausoleum building in Area 11 of the Green Hills Master Plan, assuming that the
November 11, 2014
Page 1
MEMORANDUM:
Operational Review of Green Hills Memorial Park Cemetery Master Plan
November 11, 2014
Page 2
moratorium on said burials is rescinded; and,
4) Allows Green Hills to proceed with submittal of construction plans into Building and
Safety plan check for the administration building addition that was approved by the
Planning Commission on July 22, 2014.
BACKGROUND
On August 12, 2014, the Planning Commission reviewed and considered Staffs
recommendation contained in the August 12, 2014 Staff Report that the Planning
Commission impose specific mitigation measures to address the observed visual, privacy
and noise impacts associated with the rooftop burials and to amend the Green Hills
Master Plan to prevent further expansion of the Memorial Terrace Mausoleum. In
addition, the Commission considered Staff's oral recommendation made at the meeting
that the submittal of a Variance application was necessary to allow the mausoleum to
encroach into the Code -required, 40 -foot setback.
After hearing public testimony and discussing the cemetery operations, the Planning
Commission directed Green Hills Cemetery to submit an after -the -fact Variance
application to seek approval to allow the existing Memorial Terrace Mausoleum building
to remain encroaching 32 -feet into the required 40 -foot property line setback and directed
Staff to review Green Hills' existing Master Plan, including the conditional use permit and
variance, to make sure that Green Hills is in compliance with all of their conditions of
approval. This motion was approved on a 7-0 vote. The Planning Commission also
agreed to close the public hearing and directed Staff to bring back a Resolution on the
consent calendar at the next Planning Commission meeting to impose a number of
operational conditions on the cemetery to avoid/minimize impacts to the adjoining
neighbors from burial activity on the roof of the mausoleum. This motion was supported
by a 6-1 vote, with Commissioner Gerstner dissenting. The Resolution implementing this
directive was presented to the Planning Commission on August 26, 2014.
Although the Resolution was placed on the Consent Calendar, it was removed from the
Consent Calendar. Since the public hearing was closed, the discussion on August 26th
was limited to the language in the draft Resolution and whether it accurately reflected the
motion that passed on August 12th. During the August 26th meeting, there were many
questions from Commissioners regarding additional potential violations of the Master
Plan. Since the public hearing was previously closed, the Planning Commission agreed
to continue the item to October 28, 2014, and directed staff to re -notice the public hearing
to allow for continued discussion of all aspects of the operational review of the Master
Plan.
November 11, 2014
Page 2
MEMORANDUM:
Operational Review of Green Hills Memorial Park Cemetery Master Plan
November 11, 2014
Paae 3
DISCUSSION
On October 28, 2014, the Planning Commission opened the public hearing and
considered additional public testimony, and also considered a CUP compliance report
prepared by a third party reviewer (Lilley Planning Group). The compliance report
confirmed previously identified CUP violations (i.e., the encroachment of the Memorial
Terrace Mausoleum within the required setback, and the below grade interments in the
northwest corner of the cemetery and on the roof of the Mausoleum within the required
sixteen foot setback), and revealed additional CUP violations consisting of large
structures, including structures that contain urns and trellises in connection with family
plots, that have been placed within the five foot structural setback area along the west
property line where the Master Plan only allows below -ground interments, low garden
walls (i.e., walls less than 36 -inches in height, which is further defined as such in revised
Condition 1 i) and tombstones no taller than 6 -feet in height. As a result of the additional
information revealed from the third party compliance report and deliberation by the
Planning Commission, the Planning Commission directed Staff to return on November
11, 2014 with a Resolution that memorializes the following actions:
1) Impose a moratorium on ground burials/interments and sales of burial plots on the
rooftop of the Memorial Terrace Mausoleum building located in Area 11 of the
Master Plan, and impose a moratorium on above -ground burials and placement of
other large structures within the 5 -foot setback area along the western property
line in the area south of the Pacifica Mausoleum building, which shall remain in
effect until final City Council action is taken on the issue of said interments and
structures in the required setbacks,-
2)
etbacks;
2) Direct Green Hills to submit a Variance application within 30 -days to seek approval
to: a) allow the existing Memorial Terrace Mausoleum building to remain
encroaching 32 -feet into the required 40 -foot property line setback; b) allow the
existing 13 below -ground burials and 6 additional burials in companion spaces that
are located within the 16 -foot setback in the northwest corner of the cemetery site
between the west property line and the maintenance yard; and, c) allow existing
structures and above -ground burials within the 5 -foot setback area along the
western property line in the area south of the Pacifica Mausoleum building;
3) Impose a number of conditions on the cemetery to avoid/minimize impacts to the
adjoining neighbors from burial activity on the roof of the Memorial Terrace
Mausoleum building in Area 11 of the Green Hills Master Plan (Condition 1.3), if
the moratorium on rooftop burials is lifted by the City Council; and,
November 11, 2014
Page 3
MEMORANDUM:
Operational Review of Green Hills Memorial Park Cemetery Master Plan
November 11, 2014
Page 4
4) Allow Green Hills to proceed with submittal of construction plans into Building and
Safety plan check for the administration building addition that was approved by the
Planning Commission on July 22, 2014.
The Planning Commission continued the public hearing to November 11, 2014 to allow
continued discussion of the proposed actions. Based upon the Planning Commission's
discussion, Staff has prepared the attached Resolution for consideration by the Planning
Commission. As such, Staff recommends that the Planning Commission adopt the
attached P.C. Resolution No. 2014-_, which memorializes the Planning Commission's
decision of October 28, 2014.
ADDITIONAL INFORMATION
Conditions of Aooroval:
Green Hills has submitted maps showing the location of proposed interments in the
northwest corner and along a portion of the western property line where interments have
occurred in violation of the conditions of approval. (See the two attached maps that were
submitted by Green Hills documenting the location of plots and the placement of the
above -ground structures.) In addition, City resident Diane Smith obtained copies of maps
that are on file with the County, and those maps also are attached to the report. New
Condition No. 52 has been added to require Green Hills to submit all of the maps depicting
the locations of all proposed interments within the Park within thirty days of the date of
approval of the resolution. In addition, although the Resolution has language requiring
submittal of the required Variance application within 30 -days of adoption, Staff has also
included that requirement as new CUP conditions of approval (Nos. 53 through 55 and
revised Condition No. 7).
Staff also is proposing new and revised conditions that require construction of silhouettes
for any new mausoleum building and that review and approval of the mausoleum
buildings will be conducted by the Planning Commission at a duly noticed public hearing
(See new Condition 1 j and revised Condition AQ -1).
Finally, Staff proposes that Condition 38 be revised to delete the reference to the "average
finished grade at the front of the building to the highest point of the building" and revise it
to include the language that currently is used for measuring the height of buildings from
adjacent grade so that condition now will read: "With the exception of the mausoleum
building on Inspiration Slope, which is established by Condition 37, and the Pacific
Terrace Mausoleum in Area 11, which shall be established by Planning Commission
approval of a revision to the conditional use permit, all mausoleum buildings shall not
exceed 20 -feet in height as measured from the highest finished grade elevation covered
by structure to the highest point of the structure, and shall not exceed an overall height of
November 11, 2014
Page 4
MEMORANDUM:
Operational Review of Green Hills Memorial Park Cemetery Master Plan
November 11, 2014
Paae 5
30 -feet as measured from the lowest finished grade adjacent to the building to the highest
point of the structure."
The conditions of approval regarding the height of the Memorial Terrace Mausoleum in
Area 11 will require further amendment when Green Hills applies for the variance and
conditional use permit revision for that building, since the height of the building does not
appear to comply with one of the requirements in former Condition 38 regarding the
twenty foot maximum height as measured from the average finished grade at the front of
the building.
Security Cameras:
After the October 28, 2014 Planning Commission meeting, Staff received an email and
photos regarding the security cameras used on the Green Hills site, expressing concerns
that the cameras appear to be positioned in the direction of the condominium complex.
This was a point of discussion by the Planning Commission during the October 28th
meeting; however, no final action was taken with regards to regulating the security
cameras. Further, according to Green Hills, the security cameras are not directed at the
condominium complex, but are used to monitor key areas throughout the cemetery site
for suspicious activities that may occur during the day or after hours when the cemetery
is closed. Nonetheless, Staff has reached out to Green Hills personnel to obtain
panoramic footage of what the security cameras capture. Staff has not yet received any
information about this issue from Green Hills. Staff will report on this matter at the
meeting. Notwithstanding, Staff has drafted a new condition of approval (No. 56 in Exhibit
A of the attached Resolution) that requires any security camera on the cemetery site to
not be oriented towards the condominium complex, or that appropriate shielding be
installed that screens the condominium complex and its common areas from being
recorded.
Grading and Retaining WaNlAccess Ramp:
After the October 28, 2014 Planning Commission meeting, Staff received an email
regarding the access ramp and grading associated with the Memorial Terrace Mausoleum
building, indicating that Area 11 was illustrated to have a net cut according to the Green
Hills 2007 Master Plan update. Staff approved a grading permit in 2008 and 2009 that
allowed the below ground interments outside of the 16 -foot setback area for the northwest
corner and the construction of the retaining wall for the access ramp to the top of the
Memorial Terrace Mausoleum. Subsequently, Staff also approved a grading permit in
2011 that allowed the construction of the Memorial Terrace Mausoleum building. These
approvals cumulatively included approximately 3,500 cubic yards of cut and
approximately 800 cubic yards of fill, resulting in approximately 2,700 cubic yards of net
cut, which is consistent with the CUP conditions of approval and Master Plan.
November 11, 2014
Page 5
MEMORANDUM:
Operational Review of Green Hills Memorial Park Cemetery Master Plan
November 11, 2014
Page 6
There was also a question from the public regarding the height of the retaining wall/access
ramp being upwards of 13 -feet tall. The 2008 grading permit also approved a 12 -foot
retaining wall to support the access ramp. The access ramp was ultimately constructed
in 2010. According to the approved plans, although fill was used to re -contour the area
(i.e., the transitional slope between the internal street in front of the Memorial Terrace
Mausoleum building and the ramp), the net cut in this area far exceeded the net fill, which
resulted in the project still being consistent with the approved Master Plan.
New Information Regarding the Interments in the Northwest area:
As discussed above, in May 2008, Green Hills submitted a Grading Permit application to
the Planning Department for the preparation of the northwest area for ground interments.
The plan approved by the Planning Department included a notation by Staff on the plan
stating that below -ground interments shall maintain a 16 -foot setback from the north
property line, consistent with the CUP conditions of approval. Further, the Grading Permit
approval also included a condition that memorialized this 16 -foot setback requirement.
Although these plans illustrated the access ramp, the Planning Department approval did
not specify that the access ramp was part of that approval. Nonetheless, after Planning
Department approval, Green Hills submitted grading plans to the Building and Safety
Department for "plan check" (the precursor to obtaining a permit to conduct construction
and/or grading activities) in 2009 that included both the ramp and the interments in the
northwest corner. Prior to Building Department permit issuance, the plans were returned
to the Planning Department so that its approval could be revised to acknowledge the
location and approval of the access ramp. These plans were stamped to acknowledge
the access ramp, and all conditions of approval remained the same, including the
condition that requires the 16 -foot setback for below -ground interments.
In comparing the plans that were submitted to the Planning Department in 2008 with the
plans that were submitted to the Building Department in 2009, it is interesting to note that
the plans submitted to the Building Department in 2009 depicted ground interments within
the 16 -foot required setback area, which was not consistent with the conditions of
approval or the plans that were approved in 2008 by the Planning Department.
Unfortunately, when the plans were later returned to the Planning Department in 2009 for
acknowledgement of the access ramp, Staff did not realize that the new row of burial plots
within the 16 -foot setback had been included on that plan, and the building and grading
permits were issued. Nonetheless, the 16 -foot setback requirement still was a condition
of the project, and the Grading Permit issued by the Planning Department in 2009
expressly contained this condition, even though the additional row of plots within the
sixteen foot setback had been added to the grading plan by Green Hills.
As the Commission knows, the 16 -foot setback requirement for below -ground interments
along the north property line between the west property line and the maintenance yard
has been a requirement of the project approval since the City Council approved the
November 11, 2014
Page 6
MEMORANDUM:
Operational Review of Green Hills Memorial Park Cemetery Master Plan
November 11, 2014
Paae 7
master plan in 1991. Interestingly, on December 31, 1990, after the public hearing had
been closed, Mr. Resich requested certain proposed conditions of approval be changed,
including a reduction of the 16 -foot setback in the northwest corner to an 8 -foot setback.
The public hearing subsequently was reopened to address his request, and the City
Council rejected that revision request in 1991.
Despite that the condition of approval requiring the 16 -foot setback in this area has been
in place since 1991, as discussed above, in 2009, Green Hills submitted a grading plan
that added a new row of burial plots in the required setback and proceeded to sell plots
and inter people within the 16 -foot setback area. In addition, the compliance review has
disclosed that Green Hills has allowed large trellis structures and walls that are designed
to contain human remains within the five foot setback on the west property line in violation
of that setback requirement.
These actions by Green Hills demonstrate a pattern of disregard for the conditions of
approval that govern the development of the cemetery, which have been in place for
many years. In light of this pattern, in combination with the experience with the adverse
impacts caused by the construction of the Mausoleum in Area 11 and the rooftop burials
associated with it, as discussed above, Staff recommends that silhouettes be required
to be constructed for any mausoleum that has not yet been constructed and that any
new mausoleum must be reviewed and approved by the Planning Commission before
any grading or building permits can be issued for these structures. (See new Condition
1 j and revised Condition AQ -1).
In addition, Condition 1 f has been amended to prevent any additional mausoleums or
additions to and existing mausoleum from being constructed in Area 11. This condition
memorializes Green Hills' prior statement to the Commission that Green Hills would not
construct a new mausoleum or an addition to a mausoleum within Area 11 of the Park.
Finally, new paragraph o was added to Condition 1 to eliminate the last row of plots that
is adjacent to the north property line on the roof of the Memorial Terrace Mausoleum so
that no below -ground interments will occur within the sixteen foot setback from the
northern property line adjacent to the Vista Verde Condominiums, to comply with the
sixteen foot setback requirement for below -ground interments that is set forth in Condition
6.
November 11, 2014
Page 7
MEMORANDUM:
Operational Review of Green Hills Memorial Park Cemetery Master Plan
November 11, 2014
Page 8
Additional revisions to the conditions of approval that the Commission may wish to
impose:
It should be pointed out that in addition to Conditions AQ -14 and N-3 regarding the
Commission's authority to amend conditions during the annual review, Condition 50 of
the conditions of approval provides as follows:
"Failure to comply with and adhere to all of these conditions of approval may be cause to
revoke the approval of the project pursuant to the revocation procedures contained in
Section 17.86.060 of the City's Municipal Code."
This information is being presented to the Commission so the Commission will be aware
of this condition in connection with additional options that it may wish to pursue, which
could include additional revisions to the Green Hills Master Plan and the revocation of
certain components of the Master Plan. For example, rather than imposing a moratorium
on burials on the top of the Memorial Terrace Mausoleum, the Commission could decide
instead to adopt a condition of approval precluding any additional interments on the roof
of that Mausoleum, which will resolve that issue definitively, unless overturned on appeal.
The Commission also could direct Staff to file a report with the State documenting Green
Hills' failure to comply with all of the existing conditions of the Master Plan.
CONCLUSION
Based upon the Planning Commission's discussion and direction on October 28, 2014,
Staff has prepared the attached Resolution for consideration by the Planning
Commission. If the Commission wishes to give additional direction to Staff, including
revisions to the conditions of approval, the public hearing still is open, and the
Commission may do so, if it so chooses.
Attarhmpntc
• P.C. Resolution No. 2014-_, memorializing the Planning Commission's October
28, 2014 decision
• Maps showing the location of plots and structures within the required setbacks
• Correspondence received since the October 28, 2014 Planning Commission
meeting
November 11, 2014
Page 8
ex * 6
November 11, 2014
Page 9
w
ULLJ
Lu
z
4=,
z z
❑ w
J
.*.,
V
o-0
�
� N
�
z
�C
November 11, 2014
Page 9
44
November 11, 2014
Page 10
a
a
O
p
d
yy��
1�fjJ
<
6
t
Q
Q
4
G
O
Q
a
p
p
O
A
a
p
O
U
N
U
U
u
�
m
m
6
4
d:.
a
4
a
O
a
[!
Q
O
o
N
e
U
—
V
U
U
L,
U
a
a
d
O
a
a
syr
V
U
U
U
U
U
w
L
In
6
U
in
U
�m
T!
L,1
of
V
m
b
(p
m
O
LI
R
A
II
tqQ-
4
4
4
4
Q
{.
a
d
n
A
a
II
m
ea
a
m
Q
a
m
in:
a
Ls
er
a
.0.
a
tt
41
u.
pf.
u
N
AL1
u
_
�
bi
.�
m
•aT
• m
!7.'
.E9 '
N
'm'
•Yr.
+A.
G
-p
4
,a
it
' S
-
.1
n
a
A
lb
�rym
m
vAiN
4
i
m
.61
Y
1b
IQ
')
dt
Y�
ffi
44
November 11, 2014
Page 10
MAPS SHOWING THE LOCATION OF PLOTS AND STRUCTURES WITHIN THE
REQUIRED SETBACKS
November 11, 2014
Page 11
aI
ua
L
S
ad,,
C i �' 4.LNx.Illlvi vudro''.f
08, � at! t j�-�$����
h` A € e
q �� ���•a �h`��•$��`� � �5���g���`€,tea
omes�2zC°"
tho 'lim
mUQ4-
uit k—
•g meg,
O
Q Ok Ey,
ti^
R
h
+:1
r k
I
November 11, 2014
Page 12
R
h
+:1
r k
I
November 11, 2014
Page 12
2|
f *c-
] \
m
U
'&
§
2
!
4 — ktD
§ I I|
2
2 §§
| \ I■
b
�&
*
§ § §
8 'T
-
\
�
|
2
§,
2
!
4 — ktD
-
,
/ §,
X22{\
kf�2
§ § §
8 'T
-
,
■
� f
n
,
|
�
� I■I
��
�
\
§
2
4 — ktD
i�§\gk�
$k
/ §,
X22{\
kf�2
November 11, 2014
Page 13
\
w
k
2
i�§\gk�
$k
/ §,
X22{\
kf�2
§ § §
8 'T
2g§$
L�2
cu
§$
n
,
November 11, 2014
Page 13
\
w
k
4
W
Q
0.
0
0
m
d
N
4
CSV
N N
pp
N T
T
wn
T T
i
T Ts
01
01
L�1
r ' w
o<CDO
6n
W
W ¢O
U
—
z-enmmmm:
LOON
.OS cz
Oo
�
0
N 0 4�
�N.
> I
L�1
r ' w
o<CDO
;
W
W ¢O
U
BZL
5W
J
}
z
1
c°Ci
Z
=
i7C
W
O
—
W 1�y�
O
0
W
N
S;it
O
I
Oct
5£1
m
—
z-enmmmm:
LOON
.OS cz
Oo
�
0
N 0 4�
�N.
> I
�02J
r ' w
o<CDO
^'
'❑
I
—
z-enmmmm:
LOON
m
0
Z
Z Um
-00
0
N 0 4�
�N.
> I
r �7
r ' w
-jS
JO Lu
^'
'❑
I
W
W ¢O
U
w
5W
J
}
z
1
c°Ci
m
0
F
V
U
f' ai j
Z
=
Z W
O
W
O
—
W 1�y�
O
0
W
N
O
i
ir
m
O
O
ro
w
o
4
O
T
O
W
p
W J
l j
n
W (n
W
N W
w
r
r�
U,z
Z O
W
I _� U
l Ej La
L-
0 .J In
z¢?
Page 14
r
I
O,
0
M
V
ICCff
.... �
inns
-
INS mom]
i■nfr�i
I■■ ■■I
In.C�■■I
;
I■■■■■I
I■n■■■■I l
I■ ■■■■I
I■m■n
I�■■■■■INowmom
ON wim
J
I Sagami
MEN is
■■coil
■uI
ion■■■1
- Iso■ ■
[NONE
MOVES
son I
IIIIIIIIIIIIIII■■
Islas■■I
I■■�■�■I■r■■■■I
I■■■■■■f'
I■■■■■■I
■■■■■■I
INN ■�■I
I■■■ ■I
In■no■■I
I■■■■■■1
i ■■■■
I■■■■■wl
10■■■E I
I■■■■■■I
IaA■1■I
V
V�
In
ICCff
.... �
inns
-
INS mom]
i■nfr�i
I■■ ■■I
In.C�■■I
;
I■■■■■I
I■n■■■■I l
I■ ■■■■I
I■m■n
I�■■■■■INowmom
ON wim
J
I Sagami
MEN is
■■coil
V�
In
November 11, 2014
Page 15
=1■■■■■■1
inns
-
INS mom]
i■nfr�i
sono■
ilii■i
■■coil
ion■■■1
[NONE
Islas■■I
November 11, 2014
Page 15
m 1
D
� s$
YwaimnM 30VUU31
I ownwi 3anlnd
S
l
''
_ Dano 141w I —
60£< Z L£ < l££ < v££ £S£ Q 9Sf�5L£ < 91£ <
r;�Mm
Mm Mm
Mm,
aD u AMY
r% m
_.
Ove In u Nu r -u .! Y O[Y
r
rte] m
ray m r1 �.M m m M m M m
_1
uu l CO u M u - O u I
November 11, 2014
L
Page 16
� r�
m, Mm Mm
r;�Mm
Mm Mm
Mm,
O N -
- M— —�fi —
.n 1�
t0
Oi
a
� :"!m:
[rym Mm
r�]m Mm
r7m hm
Mm
enm
,w•t
•
u I-, u
co u 00 u
0. u
N u
M u
y
a
•-
Mrn
m M m
m
M m MnM
M m
N] m
a0
N
Of
N
-�t
�m
0.
u
N u
N
yZ w
y i {
—�
+'gym—�
_Mm
Mm r7m
I+1m
.I'7m
tl
OILJ
B Q
V
0 cn
Mi
M m'
N
V
0
O
0 H
J
.Ep, Y Y
u Y�e7
u u
`i
o u
C3 u
I 60.
n m w�r�, m
m m
ai ml M m
t7 m
M m
V
O 9 Y
NY
u
r'7 r7
e�7
Ig NItMN
�
�
HLNON �" .09'Cf
-,t
n V
Z,L'
HLMS—
-zo to
pVIA90
7m--,YO116%r61{IigN
1
-\,.LiC1YUH1MDNT
Mt17tOSlriY[
m� �r
Y
I
f
O
g ~
November 11, 2014
L
Page 16
IT
rpjm
_! o LjC��17 I O
it
te �; Y d
I
I 1
��I w
1
I 11
3
nn,.�,,.e.ovwva
JIFTY 3f�W I
-.M9M-z�
�q �I
Az. 4.ArM�l .S
_
a..
M { ori
1141 eZ6 p
rtIQ
s y e a
a a
saNilk$
a��8��k
� o ow�ogv 8\° Ep If!
F
spag �'yy•tti�m y v o p\g o\
IN
wort
I fiNcs R 4ilt � a
ti
November 11, 2014
Page 17
V
H
w l`�1 q
IS
�
ag
Fc
V ^V
4
0
•�
e
FF
� yeti
�q �I
Az. 4.ArM�l .S
_
a..
M { ori
1141 eZ6 p
rtIQ
s y e a
a a
saNilk$
a��8��k
� o ow�ogv 8\° Ep If!
F
spag �'yy•tti�m y v o p\g o\
IN
wort
I fiNcs R 4ilt � a
ti
November 11, 2014
Page 17
V)
O p p
- O
— C
p u N --CO,
u
ro
m m
s
m
H1nOS ,. 1403`x4"23-
HIMON
$
m
Hlnos_
m
11 Nj�
U_�
IWoi
0
W
0
-=,9L'£Z
H1nOS ,. 1403`x4"23-
m
m
m
November 11, 2014
Page 18
W
-=,9L'£Z
H1nOS ,. 1403`x4"23-
z
_ -
m
m
m
K
a
o
1$
0
a
a
¢
o
ups
U Q
U Q
_
in U
d m
3
��
l
a
a
a
z
W
U
U
y�
g
(D
Q
- rJ
Ll
uo
in
�
00
CD
m
d" m
F5
a
a
a
ti
s ao
ocD
o_rn
N p
4 II
w
�I.
u a
U d
3- L)
W
O
O
I
m (D
m )
p
NM
o
s J
n
Yl
a d
-
U
V)
r F1
\�
00-Q
�
V)
O
O
p
U
o
Ed—.Q
_
u
O
—N
_iL
U
r7
_
w
m It
m -
m
—
a
a
a
a
L
U
p
D
p
L)
Ud
U
_
Q V
00 O
m
m
p
O
p
s
(j
U N
0) U
O
CN
CN
Y
m
m
m
O
n
¢
a
a
j
o
p
p
•.
A
u N
u ro
OD u
'*
m O
m dN'
�t m
-t
a
a
a
p
o
o
U
O
N
N
m d
m
m
M AS r
3Ml .UH3dDHd
4
November 11, 2014
Page 18
in
November 11, 2014
Page 19
WnWp.-t� 2 n'I 'Riwak.. ; J�Ne i7, �oio 't�o�C: � t�'.ae: �
;to 100T—AO
5�8
haat
^1 �q9
d� �Q °°,ypS ��`I �$ p�4���gL3 �n�j;$iiio •115 �� 9�L'�[ , .
I{ ,'0�4� � Q�Q 8�$� ° o��±''.$ � g;.oa�5•d�� yry`� ,hu �� bi5��
. o s gS'd ��y "d'� �y&'���a �R �$�0 �� i $1''4'§,,8' � � '� •'.
°4 e° ge 3n
°�Issa�aol3R�*k3
g \
uk
s �
0 rT1
N Cl nED
AmFrl E j
z z < 1 zEl
Z Q Q m .ZlEj
f� .f.♦ r..
D f'1 <
O M
➢ h Z
_ s m m L11
zz
3 N9
C N V7 A-0
toil
�&`a
y3�e
a a m
� 71
H
November 11, 2014
Page 20
Map -* 119
��CmRLiEO�: yC.iNE 11, 2016
b ,O�ja
Ik
o
a
bna�°
a�1
jr•■■
p
���U�
1.
m
a
� 0
as
3
++
-
26i¢
��CmRLiEO�: yC.iNE 11, 2016
b ,O�ja
e
o
a
bna�°
a�1
m
a
� 0
as
b
November 11, 2014
Page 21
o
a
m
a
� 0
as
b
November 11, 2014
Page 21