Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
266 CANAL STREET_B-24-271 4.4.24
Michael Wynkoop Development Manager Criterion Development Partners 70 Wells Ave,Suite 201 Newton,MA 02459 April 4,2024 City of Salem Commission on Disability 93 Washington Street,31 Floor Salem,MA 01970 To whom it may concern, The Commonwealth of Massachusetts Architectural Access Board requires that all MAAB Variance Applications be shared with the local Commission on Disability.You are receiving this copy of the application,submitted to the Board on April 01,2024,because the ownership of 266 Canal Street has applied for a variance seeking relief from section 43.3.2 of the Massachusetts Architectural Access Code which requires the sink depths in all Group I Units be no deeper than 6 i/2". If you have questions or would like additional information, please contact Michael Wynkoop at mwynkoop@criteriondp.com. Sincerely, Michael Wynkoop C R I T E R 1 0 N D E V E L O P M E N T P A R T N E R S DALLAS 14160 NORTH DALLAS PARKWAY, SUITE 750 DALLAS, TEXAS 75254 (0) 214.393.4100 (F) 214.393.4110 BOSTON 70 Wells Ave.. Newton, MASSACHUSETTS 02459 (0) 781.890.560C (F) 781.209.5553 Commonwealth of Massachusetts Docket Number Division of Occupational Licensure Office of Public Safety and Inspections Architectural Access Board (Office Use Only) 1000 Washington St., Suite 710 • Boston • MA• 02118 V: 617-727-0660• www.mass.gov/aab APPLICATION FOR VARIANCE INSTRUCTIONS: 1) Answer all questions on this application to the best of your ability. a. Information on the Variance Process can be found at: https://www.mass.qov/.quides/applying-for-an-aab-variance. 2) Attach whatever documents you feel are necessary to meet the standard of impracticability laid out in 521 CMR 4.1. You must show that either: a. Compliance is technologically infeasible, or b. Compliance would result in an excessive and unreasonable cost without any substantial benefit for persons with disabilities. 3) Sign the certification on Page 8. 4) If the applicant is not the owner of the building or his or her agent, include a signed letter from the owner granting permission for you to apply for variance. 5) Serve copies of the completed application and all attachments via electronic or physical delivery based on the recipient's preference to: a. Local Building Department, b. Local Commission on Disability (if applicable in the town where the project is located) (A list of all active Disability Commissions can be found at: hftps://www.mass.-gov/commissions-on-disability), and c. The Independent Living Center (ILC) for your area. (Your ILC can be found at: hftp://www.masilc.org/findacenter.) 6) Complete the Service Notice included with the Application and sign it. 7) Deliver the completed Application and all attachments to the Board via electronic or physical delivery: a. Electronic: i. Applications should be sent via email to will iam.ioyice(&-mass.gov & mol ly.g riffi n(a-mass.goy. ii. The email submission must have the subject line: Variance Application - <Address>, <City> iii. The application and all attachments must be in .pdf format iv. The application and all attachments should be included in a single email, except where that email would exceed 15 megabytes in size. v. Please submit the $60 filing fee via check or money order via mail to the mailing address listed above with either a cover letter or, "Variance - <Address>, <City>" in the memo line. b. Physical i. Applications should be sent to the mailing address listed above and must include: 1. The completed application and all attachments. 2. A copy of the application and all attachments on a CD/DVD (Thumb Drives will not be accepted), 3. The completed and signed Service Notice. 4. A check or money order in the amount of$50 dollars, made out to the Commonwealth of Massachusetts. ii. Please ensure that all documents included are no larger than 11" x 17". ill. Incomplete applications will be returned via regular mail to the applicant with an explanation as why it was unable to be docketed. In accordance with M.G.L., c.22, § 13A, I hereby apply for modification of or substitution for the rules and regulations of the Architectural Access Board as they apply to the building/facility described below on the grounds that literal compliance with the Board's regulations is impracticable in my case. 1. State the name and address of the building/facility: Lore Apartments 66 Canal Street, Salem, MA, 01970 2. State the name and address of the owner of the building/facility: The Residences on Canal Street, LLP 70 Wells Ave, Suite 201 Newton, MA 02459 c/o Criterion Development Partners E-mail:mwynkoop@criteriondp.com Telephone: 978-758-5014 3. Describe the facility i.e. number of floors, type of functions, use, etc.): The apartment community will consist of five buildings and 250 Apartments. One building will be three levels, consisting of parking and a Leasing office on the round level with amenity space and apartments on the upper floors. The other our buildings will be five stories with ground level parking and apartments on levels two through five. Page 2 of 9 Rev, 2/24 4. Total square footage of the building/facility: 339,120 Per floor: varies a. Total square footage of tenant space (if applicable):230,629 5. What was the original year of construction for the building/facility: 2024 - 2026 6. Check the nature of the work performed or to be performed: ■Q New Construction ❑ Addition Reconstruction/Remodeling/Alteration ❑ Change of Use 7. Briefly describe the extent and nature of the work performed or to be performed (use additional sheets if necessary): Each building will be constructed with a steel & concrete podium for the ground level structure and wood frame construction on levels two and above. The associated sitework will involve the installation of new water/sewer lines, underground drainage/storage structures to prevent future flooding and the construction of a park, seating areas and a pool. 8. Is the building or facility historically significant? ©YesNo a. If yes, check one of the following and indicate date of listing: ❑National Historic Landmark ❑Listed individually on the National Register of Historic Places ❑Located in a Registered Historic District ❑Listed in the State Register of Historic Places ❑Eligible for listing (In which registry?) Page 3 of 9 Rev,2/24 b. If you checked any of the above and your variance request is primarily based upon the historical significance of the building, you must complete the ADA Consultation Process of the Massachusetts Historical Commission, located at 220 Morrissey Boulevard, Boston, MA 02125. 9. Which section(s) of the Board's Jurisdiction (see Section 3 of the Board's Regulations) has been triggered? 2.60 3.2* 3.3.1(a)o 3.3.1(b)[:] 3.3.2[:] 3.3.4[:] 3.4[:] 10. List all building permits that have been applied for within the past 36 months, include the issue date and the listed value of the work performed: Permit# Date of Issuance Value of Work B-24-271 $ 950,000.00 (Use additional sheets if necessary.) 11. List the anticipated construction cost for any work not yet permitted or for any relevant work which does not require a permit: $ 59,044,011 .00 12. Has a certificate of occupancy been issued for the facility? oyes No If yes, state the date it was issued: 8/21/20 13. To the best of your knowledge, has a complaint ever been filed with the AAB on this building or facility relative to accessibility? oYes of No a. If so, list the AAB docket number of the complaint 14. For existing buildings or facilities, state the actual assessed valuation of the BUILDING/IMPROVEMENTS ONLY, as recorded in the Assessor's Office of the municipality in which the building or facility is located: $ 334,600.00 Is the assessment at 100%? (F)Yes o140 If not, what is the town's current assessment ratio? 0° 15. State the phase of design or construction of the facility as of the date of this application: Currently finalizinq desiqn. Construction to beqin end of April 2024. Page 4 of 9 Rev, 2/24 16. Please list specific technical sections, not 521 CMR 3. Request#1 Types of Attachments for this Request: 43.3.2 ❑✓ Floor/Site Plans,❑Cost Estimates, Section(s) for which you are seeking relief: ❑Photographs,❑Test Drawings, Are you seeking temporary relief: 0 Yes 0 No ✓❑ Other(s):Sink Specification If yes, what date do you propose to be in compliance by: ? Please describe in detail why compliance with the Board's regulations are impracticable (as defined in 521 CMR 5) for the subject of this request, and attach whatever documents are relevant to support your argument that compliance is impracticable (attach additional pages if necessary, please identify which request each attachment is in support of): See attached response to question #16. Request#2 Types of Attachments for this Request: 43.3.2 ❑✓ Floor/Site Plans,[:]Cost Estimates, Section(s) for which you are seeking relief: ❑Photographs,❑Test Drawings, Are you seeking temporary relief: 0 Yes O No 0 other(s)Sink specification If yes, what date do you propose to be in compliance by: ? Please describe in detail why compliance with the Board's regulations are impracticable (as defined in 521 CMR 5) for the subject of this request, and attach whatever documents are relevant to support your argument that compliance is impracticable (attach additional pages if necessary, please identify which request each attachment is in support o : See attached response to questions #16. Page 5 of 9 Rev, 2/24 Request#3 Types of Attachments for this Request: ❑Floor/Site Plans, cost Estimates, Section(s) for which you are seeking relief: ❑Photographs,❑Test Drawings, Are you seeking temporary relief: 0 Yes 0 No ❑ other(s): If yes, what date do you propose to be in compliance by: ? Please describe in detail why compliance with the Board's regulations are impracticable (as defined in 521 CMR 5) for the subject of this request, and attach whatever documents are relevant to support your argument that compliance is impracticable (attach additional pages if necessary, please identify which request each attachment is in support of): Request#4 Types of Attachments for this Request: ❑ Floor/Site Plans,E]Cost Estimates, Section(s) for which you are seeking relief: ❑Photographs,❑Test Drawings, Are you seeking temporary relief: 0 Yes 0 No ❑ other(s): If yes, what date do you propose to be in compliance by: ? Please describe in detail why compliance with the Board's regulations are impracticable (as defined in 521 CMR 5) for the subject of this request, and attach whatever documents are relevant to support your argument that compliance is impracticable (attach additional pages if necessary, please identify which request each attachment is in support o : Page 6 of 9 Rev, 2/24 If you require more than 4 requests, please use the Additional Request Sheet and complete the Large Variance Tally Sheet, both of which are available on the "Forms and Applications" page of the Board's website (http://www.mass.gov/aab). 17.State the name and address of the architectural or engineering firm, including the name of the individual architect or engineer responsible for preparing drawings of the facility: ICON Architecture 101 Summer Street Boston MA, 02110 Nancy Ludwig E-mail:nludwig@iconarch.com Telephone: 617-451-3333 18. State the name and address of the building inspector responsible for overseeing this roiect: Stavroula Orfanos 93 Washington Street, Salem, MA 01970 E-mail:sorfanos@salem.com Telep hone: 978-619-5640 Page 7 of 9 Rev, 2/24 I DECLARE UNDER THE PENALTY OF PERJURY THAT THE INFORMATION PROVIDED IN THIS APPLICATION AND SUPPORTING DOCUMENTATION IS TRUE AND CORRECT Date: 4/4/24 Signature of owne r authorized gent (required) PLEASE PRINT: Michael Wynkoop Name The Residences on Canal Street, LLP Organization (If Applicable) 70 Wells Ave Address Suite 201 Address 2 (optional) Newton, MA 02459 City/Town State Zip Code mwynkoop@criteriondp.com E-mail 978-758-5014 Telephone Page 8 of 9 Rev,2/24 SERVICE NOTICE Michael Wynkoop as Representative (Name) (Relationship to the applicant) HEREBY CERTIFY UNDER THE PAINS AND PENALTIES OF PERJURY THAT I SERVED OR CAUSED TO BE SERVED, A COPY OF THIS VARIANCE APPLICATION ON THE FOLLOWING PERSON(S) IN THE FOLLOWING MANNER: NAME AND ADDRESS OF PERSON OR AGENCY METHOD OF DATE OF SERVED SERVICE SERVICE Stavroula Orfanos USPS 93 Washington Street, Salem, MA '` • r �(,� Building Department 01970 ` 2 Commission on Disability USPS Local 98 Washington Street, 3rd floor Commission on Disability Salem, MA 01970 is Applicable) 3 Disability Resource Center USPS Independent 27 Congress Street, Suite 107, Salem, Center MA 01970 4-4-2024 Signature Date Page 9 of 9 Rev, 2/24 Question #16 variance Request #1 -Sink Death-521 CMR 43.3.2 "In all Group 1 Dwelling units, kitchens shall be designed so that when a unit is adapted a person in a wheelchair has access to the sink." CMR 521 43.3.2 state: "Sink Depth:The sink bowl shall not exceed 6 1/2 inches in depth...." Kitchens We are requesting a variance to allow installation of 11" deep sinks (10" bowl depth + 1" countertop) at first occupancy in all Group 1 units, with an adaptation process for installation of a 5 3/8" deep sink (4 3/8" bowl depth + 1" counter top) when requested by a resident. This application includes the plumbing fixture schedule for the proposed sinks (see attached). Marketing Advantage of a Deeper Sink Owner and marketing experience demonstrate that deeper sinks are more comfortable for an average height, standing person, and are preferred by most potential tenants. The increased depth provides for more comfortable cleaning and washing-up, can hold more items, and better facilitates the filling of bottles, vases, and other tall containers. Overall, when presented with a choice, most prospective tenants prefer a deeper sink and would want their sink replaced if a shallow sink is initially installed. Modification of a 5 1/2" Deep Sink to a Deeper Sink If 5 1/2" deep sinks are initially installed in the (192) Group 1 units, it is very likely that most tenants would want to change the sinks to a deeper sink. As a result, several of the shallow sinks will have to be replaced. Alternatively, if deeper sinks are installed initially, a lesser number of sinks are expected to be replaced, thus economic impact is reduced. Proposed Compliance Strategy We are proposing the following: The deeper sinks will be installed in all Group 1 units at the time of construction. All leasing agents will be formally instructed to alert prospective tenants of the availability of shallow sinks and the procedure for requesting a shallow sink will be included in all leases. The sink swap-out process will be included in the Standard Operations Manual for the facility. Upon receipt of a request for a change to the 5 3/8" deep sink (4 3/8" bowl depth + 1" countertop), the property manager will swap-out the sink at no charge to the tenant. The Residences on Canal Street, LLP will purchase and store at the property ten (10) 4 3/8" deep sink bowl so that the conversion can occur within one week. 04-03-2024 Conclusion We believe that full compliance with CMR 521 43.3.2 is impracticable as it will result in excessive cost without substantial benefit to people with disabilities. We are therefore requesting a variance to allow initial installation of I I" deep sinks (10" bowl depth + 1" countertop) in Group 1 dwelling units. Our proposed adaptability procedure is compatible with the adaptability principal stated in 521 CMR 43.1 and will ensure shallow (5 112") sinks will be installed in kitchens when requested by a tenant (at no cost to the tenant). This approach increases the overall usability of the kitchen sinks for most tenants. We respectfully request that the Board grant our Request for Variance on sink depth. Variance Request#2 -Sink Depth -521 CMR 45.4.5 "In all Group 2 Dwelling units, kitchens shall be designed so that a person in a wheelchair has access to the sink." CMR 521 43.3.2 state: "Sink Depth:The sink bowl shall not exceed 6 1/2 inches in depth...." Kitchens We are requesting a variance to allow installation of 11" deep sinks (10" bowl depth + 1" countertop) at first occupancy in all Group 2 units, with an adaptation process for installation of a 5 3/8" deep sink (4 318" bowl depth + 1" countertop) when requested by a resident. This application includes the plumbing fixture schedule for the proposed sinks (see attached). Marketing Advantage of a Deeper Sink Owner and marketing experience demonstrate that deeper sinks are more comfortable for an average height, standing person, and are preferred by most potential tenants. The increased depth provides for more comfortable cleaning and washing-up, can hold more items, and better facilitates the filling of bottles, vases, and other tall containers. Overall, when presented with a choice, most prospective tenants prefer a deeper sink and would want their sink replaced if a shallow sink is initially installed. Modification of a 5 1/2" Deep Sink to a Deeper Sink If 5 1/2" deep sinks are initially installed in the (13) Group 2 units, it is very likely that most tenants would want to change the sinks to a deeper sink. As a result, several the shallow sinks will have to be replaced. Alternatively, if deeper sinks are installed initially, a lesser number of sinks are expected to be replaced, thus economic impact is reduced. Proposed Compliance Strategy We are proposing the following: The deeper sinks will be installed in all Group 2 units at the time of construction. All leasing agents will be formally instructed to alert prospective tenants of the availability of shallow sinks and the procedure for requesting a shallow sink will be included in all leases. The sink swap-out process will be included in the Standard Operations Manual for the facility. 04-03-2024 2 upon receipt of a request for a change to the 5 3/8" deep sink (4 318" bowl depth + 1" countertop), the property manager will swap-out the sink at no charge to the tenant. The Residences on Canal Street, LLP will purchase and store at the property ten (10) additional 4 3/8" deep sinks so that the conversion can occur within one week. Conclusion We believe that full compliance with CMR 521 45.4.5 are impracticable as it will result in excessive cost without substantial benefit to people with disabilities. We are therefore requesting a variance to allow initial installation of 11" deep sinks (10" bowl depth + 1" countertop) in Group 2 dwelling units. Our proposed adaptability procedure is compatible with the adaptability principal stated in 521 CMR 43.1 and will ensure shallow 5 3/8" deep sink (4 3/8" bowl depth + 1" countertop) will be installed in kitchens when requested by a tenant (at no cost to the tenant). This approach increases the overall usability of the kitchen sinks for most tenants. We respectfully request that the Board grant our Request for Variance on sink depth. 04-03-2024 3 Elkay Crosstown@ 16 Gauge Stainless Steel 23-1/2" x 18-1/4" x erage ELKAY 10" Single Bowl Undermount Sink Kit ' ref SPECIFICATIONS Model(s) EFRU21151OTFG PRODUCT SPECIFICATIONS Elkay Crosstowns 16 Gauge Stainless Steel 23-1/2"x 18-114"x 10" Single Bowl Undermount Sink Kit with Filtered Beverage Faucet. Sink is manufactured from 16 gauge 304 Stainless Steel with a Polished `w+;, Satin finish, Rear Center drain placement, and Full spray sides and bottom with Sides and Bottom pads. R Installation T e: Undermount, Sink Kits Material: 304 Stainless Steel Finish: Polished Satin Gau e: 16 Sound Deadening: Full spray sides and bottom with Sides a and Bottom ads Number of Bowls: 1 Sink Dimensions: 23-1/2"x 18-1/4"x 10" Bowl 1 Dimensions: 21"x 15-3/4"x 10" Drain Size: 3-1/2" 89mm LKAV7IFLS Beverage Faucet Drain Location: Rear Center lnyJ '�Q and Filter with EFRU211510T Minimum Cabinet Size: 27" Sink, Mountin Hardware: Included CTXOBG1914 Bottom Grid, Tem late Included: Yes LKDD Deep Strainer Drain Cutout Tom late#: 1000001301 A Century of Tradition and Quality. Template is available for download at elkay.com. CAD software will be For more than years,Elkay has beenFWCE required to open the template. making innovative io products and providing exceptional customer care.We Special Note: Kitchen faucet sold separately take pride in offering plumbing products that make Irfe easier,inspire Menge and Fm16�:1���32023 leave the vrodd a better place. Product Compliance: ASME At 12.19.3/CSA B45.4 Installation Profile: Faucet: ASME A112.18.1/CSA B125.1 1/8"OVERHANG NSF 61 NSF 372(lead free) -- Accessory: ASME At 12.18.2/CSA 13125.2 NSF 42 NSF 53 CountertWe C Mounting Clip Sink Caulk Sink ff (notfumstwE) Clean and Care Manual(PDF) fFastener1/8" Installation Instructions(PDF)- 1000005239 (nolfmn'eeed) (3mm) Installation Instructions(PDF)-1000005235 drain Designed to affix to the underside of any solid sudace countertop. Installation Instructions(PDF)- Warranty(PDF) PART: OTY: PROJECT: CONTACT: DATE: NOTES: APPROVAL: In keeping with ourpolicy of continuing product improvement,Elkay reserves the right to change product specifications without notice.Please visit elkay.com for the most current version of Elkay product specification sheets. This specification describes an Elkay product with design,quality,and functional benefits to the user When making a comparison of other producers'offerings,be certain these features are not overlooked. Elkay REV 02152024 1-80OA76-4106 I CustCare(a-)Elkay.com ©2024 Page 1 EFRU21151OTFG Patent zum-elkay.com/patents EFRU21151OTFG_spec.pdf Elkay Lustertone Classic Stainless Steel E'LKAY 23-1/2" x 18-1/4" x 4-3/8" SPECIFICATIONS Single Bowl Undermount ADA Sink w/Perfect Drain Model(s) ELUHAD211545PD PRODUCT SPECIFICATIONS P-5B Eikay LustertoneT classic stainless Steel,23-1/2"x 18-1/4"x 4-318", Pmad , Single Bowl Undermount ADA Sink w/perfect Drain. Sink is manufactured from 18 gauge 304 stainless Steel with a Lustrous Satin finish, Rear Center drain placement,and Bottom only pads. Installation T e: Undermount Material: 304 Stainless Steel S facial Features: Perfect Drain I Finish: Lustrous Satin This ja Gau e: 18 Sound Deadenin Bottom onl ads Number of Bowls: 1 avail to any resident who Sink Dimensions: 23-112"x 18-1/4"x 5-718" Bowl ions: 21" 4"x4-3/8" requests a shallow sink. Drain Size:lze: 3-3/8"(86 86mm Drain Location: Rear Center Included with Product: One LKPD1 Perfect Drain and strainer Minimum Cabinet 51ze: 27" Mountin Hardware: Undermount brackets sold se aratel AMERICAN PRIDE. A LIFETIME TRADITION. Tom late Included: Yes Like your family,the Elkay family has values and traditions that endure. USA For almost a century.Elkay has been a family-owned and operated Cutout Template#: 1 1000001400 company,providing thousands of jobs that support our families and Template is available for download at elkay.com. CAD software will be communities. 17.1 required to open the template. Product Compliance: ASME A11C2.119.3/CSA B45.4 Buy American Act the Perfect Drain: Seamlessly welded si steel collar eliminates the Accessory: ASME At 12.18.2/CSA B125.2 gap between a traditional drain and the sinknk for a sanitary and gap free installation.An InSinkEratol®garbage disposer can be installed on either sink bowl for user convenience. Sinks are listed as meeting the applicable requirements U.S. Patent Nos 9,057,185 and 9,783,968. "`c the Uniform Plumbing Codes,International Plumbing Code°,and N c ® National Plumbing Code of Canada. ® Complies with ADA&ICC At 17.1 accessibility requirements when installed according to the requirements outlined in these standards. in Clean and Care Manual(PDF) Installation Instructions(PDF)-1000005239® Elkay PerfeLtDain` sinksaredesgnedand installation Instructions(PDF)-74180289 Disposer approved for compatible disposers manufactured by Warrinstallaty(PDtructions(PDF)-74180340-USA Drain Warranty(PDF) InSinkErator utilizing the Quick Locks mounting Similar models are available with: additional ADA depths configuration.Use of non-approved disposers may void Elkay warranty. IrSMkFnax,Widcl x ancidemounting - - mllar aretrademarksof , 1127m) (6fi4mm) 15314' 7*(40Dmm))(44mm) 21' 1537mm7 234R' (597mn) PART: QTY: PROJECT: THE RESIDENCES ON THE CHARLES 1314 0. 43R 57111' �144nvn) — 1(111mm) (149mm) CONTACT: DATE: NOTES: APPROVAL: In keeping with our policy of continuing product improvement,Elkay reserves the right to change product specifications without notice.Please visit elkaycom for the most current version of Elkay product specification sheets. This specification describes an Elkay product with design,quality,and functional benefits to the user.When making a comparison of other producers'offerings,be certain these features are not overlooked. Elkay REV 09282021 1333 Butterfield Road, Suite 200 ®2021 Page 1 ELUHAD211545PD Downers Grove, IL60515 ELUHAD211D4s8Ia96,df --- --- — 26 TD< UZ< 0§ \ Or ! - ]a \ \ U| »Z «§/[ § @ �` � k 1 / kLU ` ` : | g � , ! � ! .,. » , |;,,,.,,,. . �.............. | ! , : ; � .. ...... . ---....... 9E § \ \ | � � r � 2fV6A0 D\\f FT ^ ^ • # ? i - f ©j ( # vim . ` \� § ( [ m { Zvo N w �F 5mqq EWWs H $ �w N zz N] OFK i oW �mpf� 4 9 DC r fA f—(n o K li �A 5AA@ '1 Y •• a a:S:ai i:ai a:i i::i i:a is Saaa p::Si i.: a:aaa as:aa a.a aaa ia•.a 0ia ka E6R 9RE Eibj.�' 3 E 9'lR9Bj'bia¢ 6 E E BEl Rii 3Ej'c F"s6 R4 Ei64bbii666 3 1'Eili i fi€3iF3i iii i i Fi FFI§€ 69fi.� FiiFFifi� ii! i E Eiiii i�Jf iii i FF.FF.� iii [� � � fe � 6r 4 4 . Lu 3ai3333i"3EasEE 15aSaa4a38 6 4 EE 5a+3?3i?3idei3ee E 5a3i3a`ee! aeEE i i$iB a • a -2 .:Re 8 e gq y4 € 33 33aq? ergE o a $ �a, i Ye i�� 1 S •r F F FF 6ii ii 9 wY o®o�00000 - 1 1 s In IBM In An In 1 Q i •i i Be I i � N i in in i � ® eFa a iai In Is Ea"{0 !� I •.r�4� rill N _ In In In lam g1 _ t.6I ------- ............ i e, N — Zw . u y M UQ� W Q Wf DULY W x 'asa;; '•an¢;m¢c 67Yl E¢¢,s^;a¢;xa ld�8ei 8ls¢¢a¢€Ei 6�DD e!!@4a¢c¢aca 'sDae!ltia38B'3€: 3Aii¢€: i@®$$._ 3AB33-¢ € �f A3A A3 €3A3$3 A3 3As iiiai 33333 ii 33A33 ii 3l33 :33:3 33 3$33363 �a ¢ sa 3 !if !!F �AAAAAAA 3El EEAE� B AAA EElEf lEIFAAAAAA E!!A EEA61A A A � L6 �€ i� $ �33333333e33.33ss33333 33e ;MIN 33333e3z•33ss '.33333333e3e"3 as a AI as zEl M 1111 El El El Ei 8 8B Y F -S S i AA1 !EE 6A 1 c9 a 3 °u F a & 7 aim 14 law Pm id lam am ri.. - ¢ aa® aa® a9 !a a� �$ _ = _ _ lam law galaaA1 a on. a r 6 M are e3,fl igg ell ® �q e� ! • ¢ ! ! ell n eam ON 1 1 um, 7 J o r.® e•® 9°e la !� s. eaAl a.A1 aim 14 5- ' �: « 2� ` Or ! , B [ \ \jw \ § ! 8 §\ \ E»� / • ' ! | } ( | - --- --- -- -- -- - --- | . , ]� m�mq Mm$% mRym Mm$Q , ! | [ mmQ: %*m m. m� Q; mmG- m| \ ) p ) / ! § ! )2 ( | ; ( , c■Aoano5 4 14, - � Ad , � (, � vim # \` (\vim * , »! d < . Ad # \ r . - . � \� 4 . g . 2 # c a _ « & a . � � Rig ° � @ a\ � � ® . 6 ` � I ^~ { ; / ^ # m | | , ^ «� } @ ? ® \ . \ : J . ! _ `k [ \ a ) k- m l ` j \ vimj ( ) � en Z. 9 W � 22 '< w¢ Uj E w� Up o� � w co Ma R f= £ m'o gII Q : z:::::aa:x:a ax::zaaa:xxa aaa azaa:a as saa:as aaa a:a €Ef£E FI;#Eff €.f£6IFFREEF Ecf£ IiF#F£6 Ff£d;FE#€£g § €€€€€€F€€€€a €€€€€€€€€€fa i"I€IIIII€€f €FII€€FI"€€' qq g6 3e i IIEa IIEEEE EEEIEEi€EI1€ filing EEFI EEE6611Eii a Sg - i€ $aaaa B"3aR�' �"Pxsxi3A? 6e F2esaaaa adPE- �ARdeta73aRE" � EB€� -3 k= = �; S R 3 - P Oxd� I€ a R6 as RaBEE k � -------------- i- _____--1 i ------------- r------.__-_ -------_-- eim tam iLm i Eiffl V E:m Nil E e, a i a _ EEm t Rim x I R=m jd j W d d� da R m d vim R m R� p vim Eem Av Ea. i ii :I* e� a� ,L E I i�aId •Nil Eam � t ..eAK !a i Jim Jim im vim ' V ;.m j 9R vim #4 i 9 ! vim ++m l �' Eim . a 9$ 9z —— €i CC E EE CE C SI fiff E A E Eg 6 EAE E E I I s g L^L^P R• •i P• i •P•• R {R �3 E � • E � `99`sJEEj9jE J4F f99eE99e [Ja !f�l9� sa•a •-- €-•9 ...... Li EI Li low Li d � IEE 3 EIE € Rai; aeeede