CC - Item 8A - Proposed Underground District Project Walnut Grove Avenue - Rule 20AROSEMEAD CITY COUNCIL
STAFF REPORT
TO: THE HONORABLE MAYOR AND CITY COUNCIL
FROM: JEFF ALLRED, CITY MANAGER
DATE: APRIL 26, 2011
SUBJECT: PROPOSED UNDERGROUND DISTRICT PROJECT
WALNUT GROVE AVENUE — RULE 20A
SUMMARY
Rule 20A was developed to carry out a California Public Utility Commission (PUC)
decision to encourage local governments to underground overhead electric facilities.
The program requires public utility companies to set aside funds on a regular basis for
undergrounding of existing overhead facilities. To qualify a project for Rule 20A
funding, a city is required to determine that undergrounding of the subject overhead
facilities will be in the general public's interest. The City of Rosemead has an
approximate current cumulative balance of $1.5 million on deposit with Southern
California Edison (SCE), with a continuing annual allowance of $170,459.
A proposed location for the underground utility district has been identified along Walnut
Grove Avenue (from Marshall Avenue to Valley Boulevard). This location is a significant
entry point to the City from the Interstate -10 Freeway. It is expected that the
undergrounding project will provide both safety and aesthetic benefits to Walnut Grove
Avenue and adjacent areas.
Staff Recommendation
It is recommended that the City Council:
1. Hold the noticed public hearing and receive public comment;
2. Establish Underground Utility District 2011 -01 (Walnut Grove Avenue from
Marshall Avenue to Valley Boulevard) and adopt Resolution No. 2011 -20;
3. Direct staff to notify all affected property owners of the Underground Utility
District; and
4. Direct staff to file necessary documents with all affected utility companies.
DISCUSSION
Background
Rule 20A is a set of policies and procedures established by the PUC to regulate and
rMM NOo
APPROVED FOR CITY COUNCIL AGENDA:
City Council Meeting
April 26, 2011
Paae 2 of 5
fund the conversion of overhead electric equipment to underground facilities, a process
called " undergrounding". Under Rule 20A, undergrounding projects are financed by
certain monies set -aside for communities by utility companies. Funding is based upon a
CPUC formula. If needed, communities can supplement Rule 20A funds with other
funding sources.
Generally, Southern California Edison (SCE) owns and maintains most of the power
poles in the City. SCE operates two different types of overhead facilities, transmission
and distribution lines. The transmission line system provides high voltage service to a
large regional area. The distribution line system receives power from the transmission
system and makes electricity available at a usable voltage to smaller regional areas.
Telecommunication service lines and cable service providers are also found on SCE
distribution poles, and service the same parcels as SCE.
The process of placing the overhead utilities underground is the responsibility of the
respective utility companies involved. SCE, as lead agency, contracts for the
excavation of the necessary trenches within the public right -of -way, and installs the
conduit and lines for the transmission and distribution of electrical power to consumers.
Telecommunications and other service providers using the same poles follow suit by
placing their respective facilities in the same trench if it is practical to do so. The cost
for trench repair is paid for by the respective utility companies as a part of the
underground district costs. Existing overhead connections to adjacent parcels must be
done by providing a service lateral which is included in the underground district costs.
Connecting to a new service lateral also requires converting the customer /property
owners' service meter panel or service entrance to the underground service. The
customer /property owner can be responsible to pay for the conversion per Rule 20A
guidelines, although it is allowed and recommended that the conversion cost be
incorporated into the underground district cost to expedite the efficiency and completion
of the project. Once all underground facilities are activated, the respective utility
providers remove the overhead lines and the power poles are then pulled from the
ground.
Developing a New Underground District
To qualify for funding, projects must produce a benefit to the general public, not just
customers in the affected area, by satisfying one or more of the following criteria:
• The location has an unusually heavy concentration of overhead facilities in public
and private properties
• The location is extensively used by the general public and carries a heavy
volume of pedestrian or vehicular traffic
• The location qualifies as an arterial or collector road in a local government
general plan
• The overhead equipment must be located within or pass through a civic,
recreational or scenic area
City Council Meeting
April 26, 2011
Page 3 of 5
The above criteria provides for considerable latitude in identifying potential projects to
be funded by Rule 20A. SCE allocates funding to communities based on previous
allocations, the ratio of customers served by overhead facilities relative to all customers
within the community, and the ratio of customers in the community in comparison to all
customers serviced by the SCE. Currently, Rosemead's annual allocation is $170,459,
but could slightly vary from year -to -year. Due to limitations of funds, local municipalities
usually wait and accumulate their allocations for years before starting an
undergrounding project.
Previous City Underground Districts
Historically, City undergrounding projects funded with Rule 20A funds have
concentrated on major thoroughfares or near areas of public interest. A good candidate
for undergrounding is a street that will be enhanced for both safety and aesthetics.
Since establishing the City's Underground Utility Ordinance (Attachment 2), the City has
established 8 underground districts as follows:
Underground
District Number
Year
Established
General Vicinity
1
1973
Mission Boulevard
2
1978
Garvey Avenue
3
1985
Garvey Avenue
4
1986
Valley Boulevard
5
1995
Del Mar Avenue
6
1995
Walnut Grove Avenue
7
1995
San Gabriel Boulevard
8
1995
San Gabriel Boulevard
Selection of Walnut Grove Avenue
Staff met with SCE representatives regarding Rule 20A and requested an initiation of a
study for the formation of an underground utility district. The study targeted Walnut
Grove Avenue from Marshall Avenue to Mission Drive due to the following reasons:
• Undergrounding will enhance safety and have a positive aesthetic impact in the
area.
• The estimated project timing will coincide with planned street rehabilitation work
in the area.
• The area serves as a major entry point into the City and has already undergone
traffic and beautification improvements.
Staff requested that SCE prepare a rough order of magnitude (ROM) cost estimate for
this project. The ROM cost estimate is $2.70M, based on 2009 prices. Because the
project construction will not begin until around 2014, this cost was forward estimated by
SCE to be $3.45M, assuming a cost escalation of about 28% for the next four (4) years.
City Council Meeting
April 26, 2011
Page 4 of 5
However, staff considers that the 28% cost increase is extremely conservative and
adjusted this rate to a more reasonable and yet conservative rate of 15 %. This
adjustment placed the estimated project cost at $3.10M by the year 2014.
Rule 20A allows communities to initiate construction projects based on their projected
allocation accrual, up to the start of construction. In addition, the Rule also allows the
,'mortgaging ", or the use of anticipated annual allocations, of up to five (5) future years
from start of construction. Following is a cost projection and analysis for the Walnut
Grove Avenue project:
City of Rosemead Allocation Analysis
Estimated Construction Cost
2009 Estimate ............................ ...............................
2014 Estimate ............................ ...............................
(Assumes a 15% increase from 2009)
Estimated Rule 20A Balance
Current Balance ............................ ...............................
Projected Future Allocation... ..........................................
Annual Allocation $170,000
Projected Start Date 2014 x 4 years
$680,000
Projected Mortgaged Allocation ........... ...............................
Annual Allocation $170,000
5 -Year Allocation Beyond Start Date x 5 years
$850,000
Projected Total Allocation ................ ...............................
Potential Differential in Cost ......... ...............................
(Shortage Represents City Contribution to Project, if needed)
$ 2,700,000
$ 3,100,000
$ 1,520,000
i.•:1 111
$ 3,050,000
$ (50,000)
Process
Outreach flyers (Attachment 4) were hand delivered to all affected properties adjacent
to the proposed underground utility district. In addition, SCE representatives and staff
held an informational meeting for the project on March 30, 2011 at 6:30 PM at the
City Council Meeting
April 26, 2011
Paqe 5 of 5
Rosemead Community Recreation Center. If approved by the City Council, staff will
initiate the process with SCE and utility companies to proceed with the underground
district. It is estimated that construction will take place in spring 2014 (approximately 3
years from now).
FINANCIAL REVIEW
SCE will fund this project from the City's current and future accumulated Rule 20A
allocation balance, which will amount to approximately $3.05M by the construction date
of 2014. Rule 20A provides monetary credit to the City account but this allocation
should not be viewed as hard cash that can be used for anything other than utility
undergrounding purposes. The City has an annual allocation of approximately
$170,000. The Rule 20A program allows the City's to "spend ahead" (mortgage) for five
accrual years, allocating an additional amount of $850,000. This will provide a total
allowance of approximately $3.05M for this project by the year 2014. Other existing
overhead facilities belonging to ATT Communications Inc., Charter Communications
Inc. and other private utilities will be relocated underground at the companies'
expenses.
ENVIRONMENTAL REVIEW
The project is categorically exempt from the California Environmental Quality Act
(CEQA) pursuant to Section 15304 (a) and (f) of the CEQA Implementing Guidelines.
This exemption covers projects involving minor alterations of land that do not have a
significant effect on the environment.
Prepared by:
a 341.
4_c
— ?4 Rafael Fajardo
Associate Civil Engineer
Submitted by: _
(..L
Chris Marcarello
Public Works Director
Attachment 1 —Resolution 2011- 20
Attachment 2 — Rosemead Municipal Code Section 13.20
Attachment 3 — ROM (Rough Order of Magnitude) Letter
Attachment 4 - Community Meeting Outreach Flyer
Lucien J. LeBlanc
City Engineer
RESOLUTION NO. 2011- 20
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROSEMEAD
TO ESTABLISH UNDERGROUND UTILITY DISTRICT NO. 2011 -01 ON WALNUT
GROVE AVENUE BETWEEN MARSHALL AVENUE AND VALLEY BOULEVARD
WHEREAS, Chapter 13, Section 13.20 of the City's Municipal Code establishes
a procedure for the creation of underground utility districts and requires as the initial
step in such procedure holding a public hearing to ascertain whether public necessity,
health, safety, or welfare requires the removal of poles, overhead wires, and associated
overhead structures and the undergrounding installation of wires and facilities for
supplying electric, communication or similar service in any such district; and
WHEREAS, it has been recommended that such an underground utility district,
herein after called District 2011 -01; and
WHEREAS, a public hearing was held by the City Council on April 26, 2011 in
the City Council Chambers at 8838 East Valley Boulevard, to ascertain whether public
necessity, health, safety, or welfare requires the removal of poles, overhead wires and
associated overhead structures and the underground installation of wires and facilities
for supplying electric, communication or similar services as more fully shown on the
attached Exhibit "A "; and
WHEREAS, notice of such hearing has been given to all affected property
owners as shown on the last equalized roll and utilities concerned; and
WHEREAS, such hearing has been duly and regularly held, and all persons
interested have been given an opportunity to be heard.
NOW THEREFORE BE IT RESOLVED that the City Council of the City of
Rosemead hereby declares and finds the following:
Section 1. That the City Council of the City of Rosemead hereby finds and
determines that the public necessity, health, safety, and welfare requires the removal of
poles, overhead wires and associates overhead structures and the underground
installation of wires and facilities for supplying electric, communication or similar service
in the areas shown as properties within this area more fully shown on the map as
Exhibit "A" and said area is hereby established as Underground Utility District No. 2011-
01.
Section 2. That the following exceptions in said Underground Utility District
No. 2011 -1 are permissible and are hereby authorized:
1. Equipment appurtenant to underground facilities, such as surface
mounted transformers, pedestal mounted terminal boxes and meter
cabinets, and concealed ducts.
2. Temporary poles, overhead wires and associated overhead structures
used or to be used in conjunction with construction projects.
Section 3. That the removal and underground installation is scheduled to start
in approximately spring 2014 and to be completed in reasonable time thereafter.
Section 4. That the Southern California Edison Company has agreed to
charge against the City of Rosemead's Rule 20A allocations all costs of converting to
underground each customer's service lateral, and of converting and relocation, as
necessary, the overhead service entrance to accept the underground service lateral.
Section 5. The City Clerk shall certify as to the adoption of this Resolution.
PASSED, APPROVED and ADOPTED by the Rosemead City Council this
26th day of April, 2011.
MAYOR
ATTEST:
CITY CLERK
RMC
Chapter 13.20 UNDERGROUND UTILITY DISTRICTS
Sections:
13.20.010 Short title.
13.20.020 Definitions.
13.20.030 Hearing to establish need for underground utility district.
13.20.040 Designation of underground utility districts.
13.20.050 Unlawful acts.
13.20.060 Exception, emergency or unusual circumstances.
13.20.070 Other exceptions.
13.20.080 Notice to property owners and utility companies.
13.20.090 Responsibility of utility companies.
13.20.100 Responsibility of property owners.
13.20.110 Responsibility of city.
13.20.120 Time extension.
13.20.010 Short title.
This chapter shall be known as the "Underground Utility District Ordinance of the City of
Rosemead."
(Prior code § 11000)
13.20.020 Definitions.
Whenever in this chapter the words or phrases hereinafter in this section defined are used,
they shall have the respective meanings assigned to them in the following definitions:
"Commission" means the Public Utilities Commission of the state of California.
"Person" means and includes individuals, firms, corporations, partnerships and their
agents and employees.
"Poles, overhead wires and associated overhead structures" means poles, towers,
supports, wires, conductors, guys, stubs, platforms, cross -arms, braces, transformers,
insulators, cutouts, switches, communication circuits, appliances, attachments and
appurtenances located aboveground within a district and used or useful in supplying
electric communication or similar or associated service.
"Underground utility district" or "district" means that area in the city within which poles,
overhead wires and associated overhead structures are prohibited as such area is
described in a resolution adopted pursuant to the provisions of Section 13.20.040.
"Utility" includes all persons or entities supplying electric, communication or similar or
associated service by means of electric materials or devices.
(Prior code § 11001)
13.20.030 Hearing to establish need for underground utility district.
The Council may from time to time call public hearings to ascertain whether the public
necessity, health, safety or welfare requires the removal of poles, overhead wires and
associated overhead structures within designated areas of the city and the underground
installation of wires and facilities for supplying electric, communication or similar or
associated service.
Prior to holding such public hearing, the City Engineer shall consult all affected utilities
and shall prepare a report for submission at such hearing containing, among other
information, the extent of such utilities' participation and estimates of the total costs to
the city and affected property owners. Such report shall also contain an estimate of the
time required to complete such underground installation and removal of overhead
facilities.
Upon receipt of the report, the City Clerk shall prepare petitions which briefly summarize
the Engineer's report for the proposed district or districts. Upon receipt of a petition
signed by more than sixty (60) percent of the owners of property as shown on the last
equalized assessment roll within a proposed district, the City Council may set a date for
the public hearing described herein.
The City Clerk shall notify all affected property owners as shown on the last equalized
assessment roll and utilities concerned by mail of the time and place of such hearings at
least ten days prior to the date thereof. Each such hearing shall be open to the public and
may be continued from time to time. At each such hearing all persons interested shall be
given an opportunity to be heard. The decision of the Council shall be final and
conclusive.
(Prior code § 11002)
13.20.040 Designation of underground utility districts.
If, after any such public hearing the Council finds that the public necessity, health, safety
or welfare requires such removal and such underground installation within a designated
area, the Council shall, by resolution, declare such designated area an underground utility
district and order such removal and underground installation. Such resolution shall
include a description of the area comprising such district and shall fix the time within
which such removal and underground installation shall be accomplished and within
which affected property owners must be ready to receive underground service. A
reasonable time shall be allowed for such removal and underground installation, with due
regard for the availability of labor, materials, and equipment necessary for such removal
and for the installation of such underground facilities as may be occasioned thereby.
(Prior code § 11003)
13.20.050 Unlawful acts.
Whenever the Council creates an underground utility district and orders the removal of
poles, overhead wires and associated overhead structures therein as provided in Section
13.20.040, it shall be unlawful for any person or utility to erect, construct, place, keep,
maintain, continue, employ or operate poles, overhead wires and associated overhead
structures in the district after the date when the overhead facilities are required to be
removed by such resolution, except as the overhead facilities may be required to furnish
service to an owner or occupant of property prior to the performance by such owner or
occupant of the underground work necessary for such owner or occupant to continue to
receive utility service as provided in Section 13.20.100, and for such reasonable time
required to remove the facilities after the work has been performed, and except as
otherwise provided herein.
(Prior code § 11004)
13.20.060 Exception, emergency or unusual circumstances.
Notwithstanding the provisions of this code, overhead facilities may be installed and
maintained for a period, not to exceed thirty (30) days, without authority of the Council
in order to provide emergency service. The Director of Public Works (City Manager)
may grant special permission on such terms as the Director of Public Works (City
Manager) may deem appropriate, in cases of unusual circumstances, without
discrimination as to any person or utility, to erect, construct, install, maintain, use or
operate poles, overhead wires and associated overhead structures.
(Prior code § 11005)
13.20.070 Other exceptions.
The provisions of this chapter and any resolution adopted pursuant to Section 13.20.040
shall not apply to the following types of facilities, unless otherwise provided in such
resolution:
A. Any municipal facilities or equipment installed under the supervision and to the
satisfaction of the City Engineer;
B. Poles or electroliers used exclusively for street lighting;
C. Overhead wires (exclusive of supporting structures) crossing any portion of a district
within which overhead wires have been prohibited, or connecting to buildings on the
perimeter of a district, when such wires originate in an area from which poles, overhead
wires and associated overhead structures are not prohibited;
D. Poles, overhead wires and associated overhead structures used for the transmission of
electric energy at nominal voltages in excess of thirty -four thousand five hundred
(34,500) volts;
E. Overhead wires attached to the exterior surface of a building by means of a bracket or
other fixture and extending from one location on the building to another location on the
same building or to an adjacent building without crossing any public street;
F. Antennae, associated equipment and supporting structures, used by a utility for
fiirnishing communication services;
G. Equipment appurtenant to underground facilities such as surface mounted
transformers, pedestal mounted terminal boxes and meter cabinets, and concealed ducts;
H. Temporary poles, overhead wires and associated overhead structures used or to be
used in conjunction with construction projects.
(Prior code § 11006)
13.20.080 Notice to property owners and utility companies.
Within ten days after the effective date of a resolution adopted pursuant to Section
13.2,0.040, the City Clerk shall notify all affected utilities and all persons owning real
property within the district created by said resolution of the adoption thereof. The City
Clerk shall further notify such affected property owners of the necessity that, if they or
any other person occupying such property desire to continue to receive electric,
communication or similar or associated service, they or such occupant shall provide all
necessary facility changes on their premises so as to receive such service from the lines
of the supplying utility or utilities at a new location, subject to the applicable rules,
regulations and tariffs of the respective utility or utilities on file with the Commission.
Notification by the City Clerk shall be made by mailing a copy of the resolution adopted
pursuant to Section 13.20.040, together with a copy of this chapter, to affected property
owners as such are shown on the last equalized assessment roll and to the affected
utilities.
(Prior code § 11007)
13.20.090 Responsibility of utility companies.
If underground construction is necessary to provide utility service within a district created
by any resolution adopted pursuant to Section 13.20.040, the supplying utility shall
furnish that portion of the conduits, conductors and associated equipment required to be
furnished by it under its applicable rules, regulations and tariffs on file with the
Commission.
(Prior code § 11008)
13.20. 100 Responsibility of property owners.
A. Every person owning, operating, leasing, occupying or renting a building or structure
within a district shall construct and provide that portion of the service connection on his
or her property between the facilities referred to in Section 13.20.040 and the termination
facility on or within the building or structure being served. If the above is not
accomplished by any person within the time provided for in the resolution enacted
pursuant to Section 13.20.040, the City Engineer shall give notice in writing to the person
in possession of such premises, and a notice in writing to the owner thereof as shown on
the last equalized assessment roll, to provide the required underground facilities within
ten days after receipt of such notice.
B. The notice to provide the required underground facilities maybe given either by
personal service or by mail. In case of service by mail on either of such persons, the
notice must be deposited in the United States mail in a sealed envelope with postage
prepaid, addressed to the person in possession of such premises at such premises, and the
notice must be addressed to the owner thereof as such owner's name appears, and must be
addressed to such owner's last known address as the same appears on the last equalized
assessment roll, and when no address appears, to General Delivery, City of Rosemead. If
notice is given by mail, such notice shall be deemed to have been received by the person
to whom it has been sent within forty -eight (48) hours after the mailing thereof. If notice
is given by mail to either the owner or occupant of such premises, the City Engineer
shall, within forty -eight (48) hours after the mailing thereof, cause a copy thereof, printed
on a card not less than eight inches by ten inches in size, to be posted in a conspicuous
place on said premises.
C. The notice given by the City Engineer to provide the required underground facilities
shall particularly specify what work is required to be done, and shall state that if the work
is not completed within thirty (30) days after receipt of such notice, the City Engineer
will provide such required underground facilities, in which case the cost and expense
thereof will be assessed against the property benefited and become a lien upon such
property.
D. If upon the expiration of the thirty (30) days period the required underground
facilities have not been provided, the City Engineer shall forthwith proceed to do the
work, provided, however, if such premises are unoccupied and no electric or
communications services are being furnished thereto, the City Engineer may in lieu of
providing the required underground facilities, authorize the disconnection and removal of
any and all overhead service wires and associated facilities supplying utility service to the
property. Upon completion of the work by the City Engineer, he or she shall file a written
report with the City Council setting forth the fact that the required underground facilities
have been provided and the cost thereof, together with a legal description of the property
against which such cost is to be assessed. The Council shall thereupon fix a time and
place for hearing protests against the assessment of the cost of such work upon such
premises, which time shall not be less than ten days thereafter.
E. Upon the City Council's fixing of a time and place for the hearing of such protests,
the City Engineer shall immediately give a notice in writing to the person in possession
of such premises, and a notice in writing thereof to the owner thereof, in the manner
hereinabove provided for the giving of the notice to provide the required underground
facilities, of the time and place that the Council will pass upon such report and will hear
protests against such assessment. Such notice shall also set forth the amount of the
proposed assessment.
F. Upon the date and hour set for the hearing of protests, the Council shall hear and
consider the report and all protests, if there be any, and then proceed to affirm, modify or
reject the assessment.
G. If any assessment is not paid within five days after its confirmation by the Council,
the amount of the assessment shall become a lien upon the property against which the
assessment is made by the City Engineer, and the City Engineer is directed to turn over to
the Assessor and Tax Collector a notice of lien on each of the properties on which the
assessment has not been paid, and the Assessor and Tax Collector shall add the amount of
the assessment to the next regular bill for taxes levied against the premises upon which
assessment was not paid. The assessment shall be due and payable at the same time as the
property taxes are due and payable, and if not paid when due and payable, shall bear
interest at the rate of six percent per annum.
(Prior code § 11009)
13.20.110 Responsibility of city.
The city shall remove at its own expense all city -owned equipment from all poles
required to be removed hereunder in ample time to enable the owner or user of such poles
to remove the same within the time specified in the resolution enacted pursuant to Section
13.20.040.
(Prior code § 11010)
13.20.120 Time extension.
In the event that any act required by this chapter or by a resolution adopted pursuant to
Section 13.20.040 cannot be performed within the time provided on account of shortage
of materials, war, restraint by public authorities, strikes, labor disturbances, civil
disobedience or any other circumstances beyond the control of the actor, then the time
within which such act will be accomplished shall be extended by the City Administrator
for a period equivalent to the time of such limitation.
(Prior code § 110 11)
SOUI III UN ( : 4IJr0)1111
EDISON
an !'UlM Ll ! A 7 fRG1'I ]iD it � Cmi:pam
February 8, 2010
Rafael Fajardo
City of Rosemead
Public Works Department
Subject: Preliminary Rough Order of Magnitude Cost Estimate
Rosemead Rule 20A — Walnut Grove Ave between Marshall Avenue to Valley
Blvd.
Dear Rafael:
SCE has reviewed the proposed district and finds the boundary to be operationally
acceptable for undergrounding existing overhead distribution facilities. However, to do
the length of the project and the amount of allocations available it would seem that two
options are the most reasonable at this time. Per the `options discussed' with the City,
either shorten the length of the subject undergrounding, or be prepared that construction
would not start until 2014.
SCE has also prepared a preliminary rough- order -of- magnitude (ROM) cost estimate for
the undergrounding of existing overhead facilities within the proposed district boundary.
The estimate was prepared without the benefit of any engineering. Therefore, it has an
expected accuracy of plus or minus 40 %, and the estimated cost is $3,130,000.00.
If further information is necessary, feel free to contact me at (323- 720 -5213) or Dave
Seeley at (714) 329 -9317.
Sincerely,
MARISSA CASTRO - SALVATI
Interim Local Public Affairs Region Director
0
J
m
W
IJ
J
3AV 3n_ 0b101nNIVM
-d
IN
J
J
Q
I
F-
a
w
0
Of
a
N w E
N
N
p
> p v
o
a �
o
Q
2
° av i
E
° @
0 0.
CL
O) p
a7
U
C
CA
V@ 7
_T 7 C
n
p Ur) W
C
C@
U
N
@(D O
—
U
a
°'
m
N
i O
a) d
N
)
_
c0
@ > a)
°
@
mD a
w U
E O
° L
C
N
'U O°
C
> C
N
al 7
c°
o
@
>
w
o O
t 3
0 C
c O
o a
C E
o.
@
°
°. c Q
a 3 C)
c°
'0 O 0)
�a N
O@ N
a
O O
°
N
@ a U d
E O
U N N
Q
@
m
N N
N
d 76
a -0 a
O M
@ C
N
W>
@
a
T
C
U
dt 7
of/1
D
Co m
L
o.
w
o
a) m
0
>
0
3 c
o
O N N
"O
O
>
C
=" C a
CL
co
O
0 s0)
a)
°
3
t w
j
p
L
'O N@
w
C
0
O 3
a) al k
Z
a)
U
O
a)
w
N
L
O a
a
'aa
V
O W C
0
a)
L
m
a)
N a
-O
•N
N O
m
c
3
d a)
Y
�°
a)
@°
�
.L..•
o
N
W Z
c
N
d
m
mom.
C
N
0
W O^
U
O
N N@
0)
O
U
@
a D C
d
O
E
N C@
0
N p V �?
t
2
U)
0)
@ m
'° 3 c°
a)
m- m
E
c
D .� o
a) 0 Y
w d 2 3
>
N
O@
@
U O�
U
> °@ N
L 0@
w
p
p N
c
@ co
O
5
E -o
o°
c F-
io
�
m
4
°-
w
m D
I aa)) w0
v
w
T
y@
N
c
0
m°
o
of _
>
ap
-
r o°
a °
v
a
o c o
C
7
O
a)
N
`D
Lp
N
o) Mn o
°
@ d
a)
E °_
°
@
m
)
p
@
c
C U
o
O
>
a)
U@
C_
C
0 a)
C
N
N°
Cl
r
!a
m
0)
(D a
r
J
Co
O)
O
O
N
> .N
0
co
0
O
U
-O
cc
0)
O C
L
U
d
T
"
O
N
C a)
O
O
U
d) O
C Na @ y
d o
@
N
w LL 0)-O
c(D a)
N N@ O
E
a)
� a
�
v
° a`)
c°))
w w
o E N a
E
w E
m
E
0>
NQm
oY
2
O
c
a)
--c
_m
°-`°_
•a- )r
O O
O
—]
Y
C
7 T 7
@
C
`p W@
@ w C
U
Q� CC
a)
C
cc
0 _a
N Y
L
N
7
E
O m
la
N
N y
N
J
+'
=
a) L C
(6
U a
E C E
V E
o
°
°)
�
c E
w
o m c
o T O N
S.
a) w
'o
N O
a)>
T
O
°
a) M O
O
a) O T
a)
H
m
U
L (D
—
d
Q
H 0) aa))
`o_
H 3
H w a