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HomeMy WebLinkAbout07/05/1988, C-10 - UPDATE ON THE WASTE MANAGEMENT COMMISSION'S ACTIONS ON SOLID WASTE PLANNING ISSUES MEETING GATE: i� N qty Of San LUIS OBISPO ITEM INUM, 198 COUNCIL AGENDA REPORT FROM: Michael P. Dolder, Fire Chief SUBJECT: Update on the Waste Management Commission's Actions on Solid Waste Planning Issues CAO RECOMMENDATION: Receive and file. BACKGROUND: At the May 17th Council meeting, the Fire Chief was directed to provide an update on the Waste Management Commission's (WMC) actions on solid waste issues. The Waste Management Commission began considering solid waste issues in March, 1988. After completing its initial review of the Hazard Waste Management Plan. The first solid waste issue considered by the WMC was the closure of the Los Osos Land Fill. In July of 1987 without input of the Waste Management Commission, the Board of Supervisors took a position of not acting on a Los Osos Land Fill lease extension which expires in November, 1988. The Board's non-action, in fact, closes the existing landfill beginning December 1, 1988. The Los Osos Land Fill, if left open, has a two year capacity remaining. The Board's decision was based on both economic and liability issues. Continuing to use the Los Osos Landfill site for two years would cost an additional 2 to 3 million dollars since insufficient cover soil is available at the site. Operating the site per state standards would require importing soil on a daily basis. Compounding the situation, the landfill sits over a water aquifer and creates the potential for intrusion and additional site clean-up. In place of the landfill, county staff has proposed developing a transfer station with permanent disposal to take place at Cold Canyon. Alternative transfer station sites were presented to the WMC. Qunitana Rd. and Highway 1, just east of Morro Bay, was staff's recommended site. However, the Morro Bay City Council, for numerous reasons, objected to Quintana Rd. site. Irregardless of the chosen transfer station site, it will take approximately two years before any transfer station site can become operational. During the interim period, solid waste from San Simeon to Los Osos would be hauled directly to Cold Canyon. How often and on what routes remains an issue as well as the impacts on the roads used. The Waste Management Commission established a subcommittee to study the issue of the Los Osos Landfill and transfer stations further. The Subcommittee consisting of Chairman Jack Dewar, John Leman, Norm Etaugh and Michael Dolder met on several occasions-and made three general recommendation (Attachment 1) regarding: the Commission Makeup, Landfill Sites and Transfer Status. The subcommittee presented its recommendation to the full commission on June 2nd whereupon the WMC approved a motion to forward the subcommittee's recommendations directly to the Board of Supervisors. Additional solid waste items that are being considered by the Waste Commission include: 1. Establishing mandatory waste collection county-wide (Attachment 2). 2. Developing exclusive franchises for solid waste pick up (Attachment 3). i �►���buuuIIIIIII�pi���Ill city of Say < LUIS oslSpo COUNCIL AGENDA REPORT The commission, like the City Council, is concerned that the solid waste plan is only a framework document. A significant amount of work remains to be done. With this in mind, the Commission directed county staff to provide additional support materials to the commission so that it can begin the revision process of the solid waste management plan. Recommendation Receive and file the update on the Waste Management Commission's actions on solid waste planning. Attachments 1. Waste Commission's Subcommittee Recommendations 2. Mandatory Collection 3. Excessive Franchise/Contract ATTACHMENT #1 Subcommittee Recommendations Commission Makeup There should be two Commissions - one to deal with hazardous waste management - the other with solid waste management . The County Solid Waste Management Plan must be revised and made more proactive . Land Fill Siting There will be a need for land fills located in appropriate areas throughout the County for the foreseeable future . Additional sites must be selected and acquired soon so that the capability to handle solid waste will be unimpaired. The County should take an aggressive leadership role to acquire and operate land fills - not passively assume that commercial operators will adequately handle our needs. Transfer Stations The subcommittee believes that the Quintana Road site is not a suitable location for a transfer station . The Los Osos land fill should remain in operation for as long as possible so that the problems associated with a transfer station and/or direct haul operations can be worked out on other than a `crash' basis. A decision to close the Los Osos land fill this fall has apparently been made . The subcommittee believes that decision should be reconsidered. In the event the closure takes place as presently scheduled direct haul operations will be necessary for at least two years. Until suitable transfer facilities have beeen provided the subcommittee recommends that - the operator serving the area north of Cayucos should be required to haul to Paso Robles or Atascadero - the operator serving Morro Bay should be required to haul to Atascadero - the operator serving Los Osos should be required to haul to Cole Canyon . Subcommittee Status It is suggested that the subcommittee be maintained to develop more definitive recommendations to the Commission about siting for transfer station(s) and future land/f f i 1 1 s. a./d —3 � M ATTACHMENT #2 County of San Luis Obispo Department of Public Health MEMORANDUM To County Waste Management Commission Date : 5/17/88 From : Tim Mazzacano/John Scholtes, County Health Department 9� SUBJECT MANDATORY COLLECTION Mandatory solid waste collection means that every waste producer in a specified area would be required to subscribe to and pay for collection service. Charges for such service can be collected in several ways: (A) by direct billing from the collection company, (B) by a fee charged on improved parcels, (C) by billing in combination with utility charges or (D) by other means. Currently all but one of the incorporated cities have mandatory collection. In unincorporated areas mandatory collection has been established only within the Cayucos Sanitary District and Cambria Community Services District. The neighboring counties of Santa Barbara, Kern and Monterey do not have mandatory collection in the unincorporated areas. However, representatives of Santa Barbara County Public Works Department and Monterey County Health Department expressed a desire to see mandatory collection instituted and indicated that plans for such requirements are being considered. Our 1986 County Solid Waste Management Plan recommends the evaluation of mandatory collection in the more densely populated unincorporated areas. We would encourage such an evaluation by the Commission and submit the following preliminary list of advantages/disadvantages for your consideration: Advance 1. Could provide a more uniform and convenient disposal method than does individual disposal. 2. Could reduce the potential for illegal dumping and excessive waste accumulations. 3. Could reduce roadside litter, air pollution and fuel consumption due to fewer vehicles traveling to the disposal site. 4. Could establish a larger, more consistent waste stream for the collection company which may provide economies of scale and improve the potential for recycling. 5. May reduce landfill space and handling costs due to wastes being compacted by collection vehicles prior to disposal. Disadvantages: I. May be perceived by some residents as a restraint of free choice in their disposal methods. 2. May be viewed as more expensive by residents who currently dispose of waste on an irregular or unapproved basis. 3. Collection companies may be unable to provide service to the more sparcely populated areas of the county at a reasonable rate. 4. No county staff currently exists to administer the system or provide enforcement. Should the Commission wish to recommend mandatory collection in the future, we would suggest that consideration be given to establishing a pilot project area to evaluate the program. TM/JS:mt MANDATORY COLLECTION Many Counties in California have instituted mandatory solid waste collection. With this system all property owners and/or tenants are provided with waste collection services as part of the County services. Regardless of whether or not the service is used, each property is served and charged a fee. Collection charges may be added to utility or tax bills or sent separately. ADVANTAGES OF MANDATORY COLLECTION The positive impacts of mandatory collection include the following: Illegal dumping will be eliminated or greatly reduced. Fewer private citizens at landfills and transfer station. Energy efficient since there would be fewer vehicles hauling waste. DISADVANTAGES OF MANDATORY COLLECTION High cost to provide the service in remote rural areas. Difficulties in the collection of payment. Administration needed to set up and operate the system. Network of private haulers or County owned vehicles needed to provide the service. REC OMMENDATI ON Mandatory collection is in force in each of the incorporated cities in the County with the exception of Atascadero and within the boundaries of the Cambria CSD and the Cayucos Sanitary District, and could be successfully instituted in many of the more densely populated unincorporated areas. These areas include Avila Beach, San Simeon, Baywood, Los Osos, Santa Margarita, Templeton, Oceano, San Miguel, Shandon, Creston, Nipomo and others. Rural parts of the County with sparse population would not be suited to this type of program and should not be considered. During the short term planning period, the County should evaluate the feasibility of a mandatory refuse collection program in the more denseley populated portions of the County. If proven feasible, selected pilot mandatory collection programs should be implemented and monitored. -57- The collection permit program is currently administered by The Environmental Health Department. All refuse collectors operating within the unincorporated areas of the County or transporting wastes through the unincorporated areas are required to possess a valid collection or transport permit. Under the present system, the County is divided into seven permit areas as shown in Figure VII-1. A commercial waste hauler must apply for a permit in each area of intended operation. As part of the application procedures, the collector must provide detailed information to the County regarding the type and level of service to be provided. Collectors may operate anywhere within the designated boundaries of the area for which they are permitted. No specific collection area franchises are issued for the unincorporated areas. Thus more than one permit could be issued for any given area and additional areas could be established at the discretion of the County. In contrast to the County permit system, the incorporated cities issue exclusive franchise agreements to the private haulers. The two systems have operated successfully to date since each hauler holding a County permit also has the franchise agreements with the respective cities within each service area. Problems could however arise in the future if additional haulers are granted permits or franchises for the same service areas. This could disrupt the economic balance of collection to some parts of the service areas and possibly cause a disruption of service to some areas. An additional problem with the present non-franchise system is the lack of commitment of the waste stream to private industry for the development of recycling activities such as waste-to-energy or composting projects. Recommendation During the short term planning period, the County should explore options for converting its present permitting system to a franchise system to be compatible with the incorporated cities. These franchises should be structured to ensure uninterrupted collection throughout each service area and provide the waste stream commitment needed for the development of alternative disposal options. § 4271 GARBAGE AND REFUSE DISPOSAL Div. 5 § 4271. Legislative findings and declaration The.Legislature finds and declares-as follows: Although local agencies are empowered to furnish solid waste handling services, in extensive parts of thestate solid waste enter- prises are furnishing all or substantial portions of necessary solid waste handling services. It is in the public interest to foster and encourage solid waste en- terprises to that, at all times; there will continue to be competent en- terprises willing and financially able to furnish needed solid waste handling services. (Added by Stats.1976,c.430,p. 1101, §2.) § 4272. Continuation of service by solid waste enterprise; lim- itations Where a local agency has authorized, by franchise, contract, or permit; a solid waste enterprise to provide solid waste handling serv- ices and such .services have been provided for.more than three pre- vious years, the solid waste enterprise may continue to.provide such services up to five years after mailed notification to such enterprise by the local agency having jurisdiction that.exclusive solid waste han- dling services are to be provided or authorized, except that if the sol- id waste enterprise has an exclusive franchise or contract then the solid waste enterprise shall continue to provide such services and shall be limited to the unexpired term of.the contract or franchise or five years, whichever is less. A solid waste enterprise.providing solid waste handling services shall be subject to the provisions of this sec- tion only-if: (a) The services of the enterprise are in compliance with the terms and conditions of any such franchise, contract, or per- mit, and meet the quality and frequency of services required by the local agency in other areas not served by the enterprise. (ti) The rates charged by the enterprise may be periodically re- viewed and set by the local agency. Nothing'in this chapter shall be construed to affect the right of a city following annexation to terminate for cause a franchise, contract or permit held by a solid waste enterprise authorized by the county- (Added ounty(Added by'Stats.1976, c.430,p. 1101, §2.) 560 A Report of Betty R. Sanders , Attorney for San Luis Obispo County Garbagemen ' s Association to the Solid Waste Management Commission Thursday, May 5, 1988 Ladies and Gentlemen : The Commission should note that the Summary of the Solid Waste Management Plan states at Page 8, the 2nd and 3rd asterisks are: * Evaluate franchising * Evaluate mandatory collection Both of these items are addressed in your list of short term tasks . If I may, I would like to address them in reverse order . Mandatory Collection On Page 57 of the Plan ( see Attachment A) the issue of mandatory collection in unincorporated areas of the County is addressed. The first paragraph raises a useful point - that garbage collection charges can be added to utility or tax bills . I think it may be unrealistic to think that mandatory collection will eliminate illegal dumping, but I believe it is safe to say that it would substantially reduce it. An advantage not listed is the reduction of "per customer" expense thereby lowering, or stabilizing, or at the very least, slowing the rate of increase of "per customer" cost . -1- The disadvantages listed include only one which bears discussion at this time, and that is the first one. The others - "difficult collection" is addressed in the first paragraph. The next, Administration to operate the system, leaves me hardpressed to see that much of an administration overlay beyond what is presently in existence would be required. In the last disadvantage listed, the network referred to already exists . The County ordinance requires each permitted hauler to pick up garbage if a request is made. Let me address the first disadvantage listed -- the high cost of collection in remote areas . We believe this is a valid concern and it may be reasonable to exempt specific remote rural areas . We have few such areas left in our county. We have recently had rather substantial rate increases granted in unincorporated areas . The experience seems to be in those areas that service drops off for a while and then over time is reinstituted . In the meantime the garbage goes somewhere. Either the individual takes it to the landfill or buries it or dumps it on his own land, or on somebody elses land or beside the road. Regarding Baywood/Los Osos Area With the imminent closing of the Los Osos landfill the distance to a landfill for a large group of individu als becomes greater and the tendency to illegal dumping becomes greater- -2- 6 reater_ -2- 6 - to-- Unless mandatory collection is instituted I believe the increase in illegal dumping will be substantial, thereby making the job of the enforcement authority a prodigious task . The Plan recommends pilot programs be implemented in the densly populated ares , listed therein . We would suggest that such pilot programs would be more difficult to administer than to implement mandatory collection County-wide and then exempt certain remote areas for a limited period,. subject to review. Exclusive Franchises or Permits The Solid Waste Management Plan recommends exploring an exclusive franchising system, and sets forth the basics of the present permit system. (See Attachment B) Our present system divides the County into seven areas with one company holding a permit to operate within each area. As the Plan states , it is possible under the present system for more than one permit to be issued in any given area. In order for that to happen, the applicant must show that the permit is in the public interest and that there is a need for such a permit to be issued . (Co. Govt . Code §8 .12 . 100(10) ) The Plan states that "problems could arise in the future if additional haulers are granted permits in the same service area" . Unfortunately, the future is with us . -3- We have some evidence in this County that the granting of a second permit in a service area can have a destabilizing effect on a garbage company. I believe the legislature in its mandate to local authority clearly meant to avoid such problems . In that regard, I would direct you to SS4271 . 72 of Health and Safety Code, attached hereto. (See Attachment C) In this County we have virtually no history of problems with solid waste collection. This may be attributed to the fact that many years ago the Health officer and the haulers in the County sat down together and worked out territories and areas of responsibility. Since that time the haulers , mainly through their Association, have worked out any internal problems among themselves . The Association has long recognized that an exclusive permitting system was not only in the best interest of the Association members but the general public as well . The public is not well served by the economic destabilizing of a company charged with garbage collection in the County. Any given area may. include economically unprofitable areas . A second permitted hauler may come in and apply for an area of dense population within a larger area. Even if the second permit were granted for the entire area including the economically unprofitable areas , you would then have 2 companies competing in an area which could only support one. The war of -4- L - Ia - I ; attrition would be waged to see which company could lose money the longest. The County sets the rates . How can rates logically be determined if the hauler cannot estimate with some degree of exactness the number of customers , their locations and the amount of solid waste they will generate. The whole issue of competition has been addressed by the courts and it is well settled that a local authority may displace competition in order to carry out a state policy mandate. Further, without some reasonable assurance of a continuing defined service area, the economic stability of the hauler is substantially threatened . In 1985 Mr. Cattaneo and I began a dialogue with the County offices with regard to the matter of exclusive permits or franchises . It was your CAD ' s position that there was no need at that time. Since then, the Plan recommends converting to a franchise system to insure uninterrupted collection throughout each service area. We believe there is a strong need now, and that implementing an exclusive permit or franchise system is clearly in the best interest of the general public . s / MANDATORY COLLECTION Many Counties in California have instituted mandatory solid waste collection. With this system all property owners and/or tenants are provided with waste collection services as part of the County services. Regardless of whether or not the service is used, each property is served and charged a fee. Collection charges may be added to utility or tax bills or sent separately. ADVANTAGES OF PANDATORY COLLECTION The positive impacts of mandatory collection include the following : Illegal dumping will be eliminated or greatly reduced. Fewer private citizens at landfills and transfer station. Energy efficient since there would be fewer vehicles hauling waste. DISADVANTAGES OF MANDATORY COLLECTION High cost to provide the service in remote rural areas. Difficulties in the collection of payment. Administration needed to set up and operate the system. Network of private haulers or County owned vehicles needed to provide the service. REC OMMENDATI ON Mandatory collection is in force in each of the incorporated cities in the County with the exception of Atascadero and within the boundaries of the Cambria CSD and the Cayucos Sanitary District, and could be successfully instituted in many of the more densely populated unincorporated areas. These areas include Avila Beach, San Simeon, Baywood, Los Osos, Santa Margarita, Templeton, Oceano, San Miguel , Shandon, Creston, Nipomo and others. Rural parts of the County with sparse population would not be suited to this type of program and should not be considered. During the short term planning period, the County should evaluate the feasibility of a mandatory refuse collection program in the more denseley populated portions of the County. If proven feasible, selected pilot mandatory collection programs should be implemented and monitored. -57- The collection permit program is currently administered by The Environmental Health Department . All refuse collectors operating within the unincorporated areas of the County or transporting wastes through the unincorporated areas are required to possess a valid collection or transport permit. Under the present system, the County is divided into seven permit areas as shown in Figure VII-1 . A commercial waste hauler must apply for a permit in each area of intended operation. As part of the application procedures, the collector must provide detailed information to the County regarding the type and level of service to be provided. Collectors may operate anywhere within the designated boundaries of the area for which they are permitted. No specific collection area franchises are issued for the unincorporated areas. Thus more than one permit could be issued for any given area and additional areas could be established at the discretion of the County. In contrast to the County permit system, the incorporated cities issue exclusive franchise agreements to the private haulers. The two systems have operated successfully to date since each hauler holding a County permit also has the franchise agreements with the respective cities within each service area. . Problems '- ' could however arise in the future if additional haulers are � - granted permits or franchises for the same service areas. � This could disrupt the economic balance of collection to some parts of the service areas and possibly cause a disruption of service to some areas. An additional problem with the present non-franchise system is the lack of commitment of the waste stream to private industry for the development of recycling activities such as waste-to-energy or composting projects. Recommendation During the short term planning period, the County should explore options for converting its present permitting system to a franchise system to be compatible with the incorporated cities. These franchises should be structured to ensure uninterrupted collection throughout each service area and provide the waste stream commitment needed for the development of alternative disposal options. -55- x' wr rS S . 1 , i § 4271 GARBAGE AND REFUSE DISPOSAL Div. ;, § 4271. Legislative findings and declaration The.Legislature finds and declares as follows: Although local agencies are empowered to furnish solid waste handling services, in extensive parts of the state solid waste enter- prises are furnishing all or substantial portions of necessary solid waste handling services. It is in the public interest to foster and.encourage solid waste en- terprises so that, at all times, there will continue to be competent en. terprises willing and financially able to furnish needed solid waste. handling.services. f (Added by Stats.1976,c.430,p. 1101, §2.) i § 4272. Continuation of service by solid waste enterprise; lim- itations 7 Where a local agency has authorized, by franchise, contract, or permit, a solid waste enterprise to provide solid waste handling serv- ices and such services have been provid"ed for more than three pre- /1�y�u kC vious years, the solid waste enterprise may continue to provide such services up to five years after mailed notification to such enterprise by the local agency having jurisdiction that exclusive solid waste han- 1"I�� dling services are to be provided or authorized, except that if the.sol- id waste enterprise has an exclusive franchise or contract then the solid waste enterprise shall continue to provide such services and shall be limited to the unexpired term of the contract or franchise or five years, whichever is less. A solid waste enterprise providing solid j waste handling services shall be subject to the provisions of this sec- tion only if: (a) The services of the enterprise are in substantial compliance with the terms and conditions of any such.franchise, contract, or per- mit, and meet the quality and frequency of services required by the . i local agency in other areas not served by the enterprise. a (b) The rates charged by the enterprise may be periodically re- viewed and set by the-local agency. Nothing in this chapter shall be construed to affect the right of a city following annexation to terminate for cause a franchise, contract, or permit held by a solid waste enterprise authorized by the county. (Added by Stats.1976,c.430, p..1101, §2.) 560 ATTACHMENT C /D� ATTACHMENT #3 County of San Luis Obispo Department of Public Health MEMORANDUM To County Waste Management Commission Date : 5/19/88 From Tim Mazzacano/John Scholtes, County Health Dept. IS SUBJECT : Exclusive Franchise/Contract All of the incorporated cities and the Cayucos Sanitary District and Cambria Community Services District have exclusive contracts with waste haulers. Our County is currently divided into seven (7) permit areas. (See map) Permits are issued by the Health Department and apply only to the unincorporated portion of the permit areas. All but one of the permit areas contain a city or district under an exclusive contract. Permits are non-exclusive and are issued for five (5) year periods. At this time only one permit is issued in each area. Under the present system, additional permits could be issued for any area if the Health Department could make a finding that permit issuance is in the public interest and that there is a need for such issuance. Such a finding would undoubtedly lead to considerable controversy and potential legal action by the existing permittee. One major problem with the present permitting system is that a permit is not legally binding on the waste hauler. If, for example, a waste hauler has a contract with a large city in his permit area, he could choose at any time to give up his permit to serve the unincorporated area and concentrate on the more densely populated and, perhaps, more profitable city area. It might not be possible for the County to find another waste hauler willing to service the remaining fringe area. Or again, a waste hauler could lose a city contract in his permit and choose to give up the remaining unincorporated area. The new waste hauler awarded the city contract has no obligation to service the unincorporated area. Our 1986 County Solid Waste Management Plan recommends evaluation of the s stem S of permits versus franchises or contracts to etermine the best approach. We encourage such an evaluation by ItNe Commission and submit the following preliminary 1 list of advantages/disadvantages for your consideration. 'IOU Advantages �L 1. Can provide a more assured waste collection system. 2. May improve a waste hauler's ability to finance and plan for future operation. 3. May allow for contracts which include improved recycling programs. 4. May allow improved waste management financing through a system of franchise fees. �y lcJh�i ✓� LlZiik:CfJIX� "' Disadvantages CC 1. May be perceived as further restraint of free competition and choice of service. 2. May be viewed as more expensive unless adequate rate control is assured. G, - Id- / 07 I SOL . .014 ON TIE' � t QST hT O f Compilaa by: NEVADA COUNTY DEPARTMENT I Group B — All Counties r The sample group consists of 34 jurisdictions. 3- 'tyre of agreement/contract administered by responding Counties: 15 exclusive franchises 3 nonexclusive franchises 3 contracts 13 permits 2 no regulatory involvement by local government 1 minor regulatory involvement by local government 1 license 4. 'Perm of agreement/contract: -----— ` Range: 0---#- 25 years 5 years Mean: 6.1 years Standard Deviation: 5.3 years 5. Nxmiber of independent collectors under single jurisdiction: Ranqe: 1----)45 i Median: 4 !Mean: 7.4 Standard Deviation: 4.4 • i Croup C - All Cities The sample group consisted of 43 jurisdictions. 3• Type of agreement/contract administered by r esoonding Cities: 29 exclusive franchises 2 nonexclusive franchises 6 contracts 4 permits 4 license 1 minor regulatory involvement by local government 1 no regulatory involvement 2 City pickup by local government 4- Term of agreement/contract: ----— ------ -- Range: 0--j30 vears Median: 5 years Mean: Standard Deviation: 8.0 years 5.8 years 5. Number of independent collectors under single jurisdiction: Range: ')---p340 Median: 5 Mean: 12.5 Standard Deviation: 0 OF 1�tI av In g. p�' Ga r• •� 1,2 ' ` �.rei ••.... •tib alyJr'�' 1\`•--' ..•... iii r/.y�y�f�l iI'caf ..'4 I •.a�� c.•i .r.•.::• } • • g/� .�...... �� �� .fir T'l� 1:� �I...ilr.: �iii.7ii • tl..:f �•' .�� R :tib `i�. pI � ,y• ...1 t��N Group C - All Cities The sample group consisted of 43 jurisdictions. 3. n'pe of agreement/contract administered by responding Cities: 29 exclusive franchises 2 nonexclusive franchises 6 contracts 4 permits 4 license 1 minor regulatory involvement by local government 1 no regulatory involvement by local government 2 City pickup 4. Term of agreement/contract: -— ---------- Range: 0—i 30 vears Median: 5 years Mean: 8.0 years Standard Deviation: 5.8 years 5. Nzrber of independent collectors under single jurisdiction: Range: g—►340 Median: 5 Mean: 12.5 Standard Deviation: 0 a rdacoeoe• _ y ` �' IFM1rr,J.PFPR lOyuv.ry'� p r �rn 19 ibis of IMM eJ-- lll at am= ljj®Rpffh� ZZ -47 13 �F18� "VV 41 1, • �e'i,s`si '�,'.�b¢ti�"e�n�t�l>a �'a�J"v�� �` v\ire• ���j., it3a1�-��. �a. .;^�xv5� �!'� a 1 •J NX�X,L � ' ►�,�ia NJ ...,. . �i.►�����a( ♦iii ����/" � /. c !Gr q,�, J ..la::• 11.. ill/...1.• 1 �l a: _fi���wl_.anru.rly. INS