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HomeMy WebLinkAbout06-17 CommentsI N MC CART tiY &AKE RS,,c ATTORNEYS AND COUNSELLORS AT LAW November 27, 2017 Board of Zoning Appeals of Frederick County, Virginia Via hand delivery 107 N. Kent Street Winchester, Virginia 22601 RE: Lot 72, Plat 4, Section 23, Shawnee Land Subdivision, Frederick County PIN 491302 123 72 (the "Property") Dear Members of the Board: This firm represents Rockwood 72, LLC ("Rockwood"), the owner of the above - referenced Property. This letter will serve to summarize the history of our client's attempts to receive permission from Frederick County to install an amateur radio tower (the "Tower") on the Property. This letter also will provide you with all documentation in support of our client's appeal. I. Rockwood's Status as an Aggrieved Party For the reasons stated herein, Rockwood is an aggrieved party for the purposes of Section 15.2-2311 of the Code of Virginia (1950, as amended). "In order for a petitioner to be `aggrieved,' it must affirmatively appear that such person had some direct interest in the subject matter of the proceeding that he seeks to attack." Virginia Beach Beautification Com 'n v. Board of Zoning Appeals of City of Virginia Beach, 231 Va. 415, 419, 344 S.E.2d 899, 902 (1986). As set forth herein, the adverse decision rendered by the County gives Rockwood a direct interest in this matter and standing to pursue this appeal. II. Timeline of Relevant Events By letter dated May 22, 2017, the County advised Rockwood of a complaint it had received on April 19, 2017, regarding the construction of the Tower. This May 22, 2017 letter advised Rockwood of inspection requirements from the Virginia Uniform Statewide Building Code which the County believes were applicable to the construction of the Tower and asked Rockwood to submit any documentation it believed exempted the Tower from said requirements. A true copy of this May 22, 2017 letter is attached hereto as Exhibit 1. Thereafter, on or about May 31, 2017, Beau Correll, Esquire, who represented Rockwood at that time, met with Mark Fleet, County Building Code Official, and Erin Swisshelm, Esquire, Assistant County Attorney. During this meeting, Mr. Fleet and/or Ms. Swisshelm, on behalf of the County, agreed to stay enforcement action and advised Mr. Correll of four items that Rockwood would need in order to have the Tower approved: 1. Building/electrical permits; 2. Statement of intent from Michael Wolff, President of a local amateur radio group; [)Ki 302 W. Boscawen St., Winchester, VA 22601 1 T: 540.722.2181 I F: 540.722.2381 j mccarthyakers.com Offices throughout Northern Virginia and the Shenandoah Valley Board of Zoning Appeals of Frederick County, Virginia November 27, 2017 Page 2 3. Opinion from structural engineer on foundation and fall radius; and 4. Engineering design documents. These four elements were presented to Mr. Correll as mere formalities and that there would be no problem with getting the proper approval provided these steps were followed. Mr. Fleet and/or Ms. Swisshelm also advised Mr. Correll that because the Tower is not for commercial use, a conditional use permit is not required. Mr. Correll is available to testify at the hearing of this matter to provide the Board with his summary of what transpired at this meeting. On June 13, 2017, Rockwood contacted Mr. Fleet by e-mail to determine what it would need to submit for approval of the Tower. By e-mail on June 14, 2017, Mr. Fleet advised that Rockwood would need "an engineer designed set of plans, a plot of the property showing the location on the property[,] ... a completed permit application[, and] ... an engineer's evaluation of the foundation that was put in place." A true copy of this e-mail correspondence is attached hereto as Exhibit 2. After receiving word from the County regarding which documents were needed, Rockwood set about engaging the proper professionals it needed in order to fulfill the County's requirements. Rockwood was delayed slightly in this process due to the schedule of its chosen engineer, Blue Ridge Design, Inc. ("BRD"). Rockwood ultimately met with BRD's engineer, Ned Cleland, on July 14, 2017, to review all documents pertinent to the Tower and the County's requirements. Rockwood engaged BRD's services and requested that Mr. Cleland contact Mr. Fleet to advise that BRD would be involved in the Tower project to provide the required engineering documentation. By letter dated July 18, 2017, Mr. Fleet advised Rockwood that it had five (5) days to submit the application for the building permit or else the matter would be turned over to the County Attorney for legal action. A true copy of this letter is attached hereto as Exhibit 3. In response, Rockwood contacted Mr. Fleet by e-mail on July 24, 2017, to advise of the delays in retaining BRD's services and of the status of the work on Rockwood's end. A true copy of this e-mail correspondence is attached hereto as Exhibit 4. In light of the circumstances detailed in Rockwood's e-mail of July 24, 2017, Mr. Fleet agreed to grant an extension to August 31, 2017. BRD's engineering work with respect to the Tower and the Property was conducted in August 2017. BRD submitted its evaluation report to Mr. Fleet on or about August 29, 2017; thereafter, Mr. Fleet contacted Rockwood to request a building permit application with a deadline of September 29, 2017. Rockwood, after incorporating BRD's engineering work, submitted its building permit application (#0000727-2017) on or about September 25, 2017, a true copy of which is attached hereto as Exhibit 5. In response to the building permit application, by letter dated October 26, 2017, Mark R. Cheran, Zoning Administrator, advised Rockwood of two alleged violations of the County Board of Zoning Appeals of Frederick County, Virginia November 27, 2017 Page 3 Zoning Ordinance's provisions on setbacks — one for the Tower and one for an accessory building located on the Property. A true copy of this letter is attached hereto as Exhibit 7. III. Legal Argument and Conclusion As outlined above, Mr. Fleet, as the County's Building Code Official, made certain representations to Rockwood and its attorney, Beau Correll, Esquire, regarding the procedure for obtaining proper approval from the County for the Tower. Chief among these representations was the statement that only the items enumerated above would be necessary to obtain approval for the Tower and that these items were mere formalities in light of the fact that the Tower had already been constructed. At no point during any of the discussions with Mr. Fleet and other County representatives was the issue of setbacks mentioned. Rockwood and its representatives, both verbally and in writing, requested the list of items needed for final approval of the Tower. In response, Mr. Fleet advised of the documents enumerated above and listed in the attached Exhibit 2, with the representation that these items were all that were needed to gain final approval of the Tower. Given the representations of its building code official, Mr. Fleet, that the required items were mere formalities and the lack of discussion regarding setbacks, we believe that the County is estopped from now arguing that the setback requirements are violations of the Zoning Ordinance. While the estoppel argument detailed above is our client's primary basis for arguing that the adverse decision be overturned on appeal, we also believe that the fact that the Tower is not a commercial tower and is for amateur use only should count in Rockwood's favor. Rockwood acknowledges that Section 165-201.03 of the Frederick County Zoning Ordinance does not distinguish between commercial and amateur radio towers (as it appears to for "telecommunication facilities"). However, this tower is designed to be used by amateur radio enthusiasts throughout Frederick County and the surrounding areas and not by any commercial groups. Attached hereto as Exhibit 7 is an e-mail letter from Michael Wolff, President of the Blue Avalanche Communication Group and a member of many other local and national amateur radio organizations, in support of the Tower and what it represents to the area. On behalf of our client, thank you for your consideration of this matter. We look forward to addressing these matters at an upcoming hearing of the Board. MSA/aph Enclosures as stated cc: Client Very truly yours, Matthew S. Akers EXHIBIT 1 Certified May 22, 2017 Rockwood 72, LLC 2979 Valley Avenue Winchester, Va. 22601 Re: Shawneeland lot 72, Tax map number 49802-123-72 Dear Property Owner, COTINTV of FRYMPRICIZ Inspections Department Mark A. Fleet, Building Official 540-665-5650 Fax 540-678-0682 On April 19, 2017 our office received a complaint that a radio tower had been constructed without the proper permits or Inspections. Upon arrival it was noted by our code enforcement inspectors that a tower had been constructed. Virginia'Uniform.Statewide-BuildingCode, Section 108.1 When applications are required. Application for a permit'shall b6made°to the building official and'a permit shall be obtained prior to the commencement of any ofthe following,'activities, •except that applications for -emergency construction, alterations or equipment replacement shall be submitted by the end of the first working day that follows the day such work commences. In addition, the buiidirig official may authorize work to commence pending the receipt of an application or the issuance of a permit 1. Construction or demolition of a building or structure. Installations or alterations involving (i) the removal or addition of any wall, partition or portion thereof, (ii) any structural component, (ill) the repair or replacement of any required component of a fire or smoke rated assembly, (iv) the alteration of any required means of egress system, (v) water supply and distribution system, sanitary drainage system or vent system, (vi) electric wiring, (vii) fire protection system, mechanical systems or fuel supply systems or (viii) any equipment regulated by the USBC. 2. For change of occupancy, application for a permit shall be made when a new certificate of occupancy is required under Section 103.3. 3. Movement of a lot line that increases the hazard to or decreases the level of safety of an,existing building or structure in comparison to the building code under which such building or structure was constructed. 4. Removal or disturbing of any asbestos containing materials during the construction or demolition of a building or structure, including additions. UNIFORM STATEWIDE BUILDING CODE, SECTION 113 INSPECTIONS 113.3: Minimum inspections: The following minimum inspections shall be conducted by the building'officlal when applicable to1he construction or permit: Page 1 of 2 1. Inspection of footing excavations and reinforcement material for concrete footings prior to the placement of concrete. 2. Inspection of foundation systems during phases of construction necessary to assure compliance with this code. 3. Inspection of preparatory work prior to placement of concrete. 4. Inspections of structural members and fasteners prior to concealment. 5. Inspection of electrical, mechanical and plumbing materials, equipment and systems prior to concealment. 6. Inspection of energy conservation material prior to concealment. 7. final inspection. If you feel your this tower is exempt under The Virginia Uniform Statewide building code section 102.3 exemptions, please submit documentation to verify the tower meets the exemption within ten (10) days frem,thel receipt of -this letteror appiyrferthe•proper permits and schedule the proper -inspections. Please,be aware that the above is subject to appeal under Section 119 of the Virginia Uniform Statewide Building Code. if you have any questions, please do not hesitate to contact me. Sincerely, Mark A. Fleet Building Code Official CC: Mark Cheran; Gary Lofton Page 2 of 2 EXHIBIT 2 Andrew P. Hill From: David Williamson<dwilliamson@CustomComputersVA.com> Sent: Wednesday, November 22, 2017 2:16 PM To: Andrew P. Hill Subject: FW: Tower From: Mark Fleet [mailto:mfleet6Ifcva.us] Sent: Wednesday, June 14, 2017 2:04 PM To: David Williamson Subject: Tower Mr. Williamson, You will need an engineer designed set of plans, a plot of the property showing the location on the property as well as a completed permit application. Since the project was started before any permits were issued you will also need an engineer's evaluation of the foundation that was put in place with no footing inspection. Mark A. Fleet Building Code Official Frederick County, Va. 107 N. Kent St. Winchester, Va. 22601 (540)665-5650 EXHIBIT 3 Certified Second Notice July 18, 2017 Rockwood 72, LLC 2979 Valley Avenue Winchester, Va. 22601 Re: Shawneeland lot 72, Tax map number 491302-123-72 Dear Property Owner, Cnr'NTY ofLFnELEn�CK Inspections Department Mark A. Fleet; Building Officia! 540-665-5650 Fax 540-678-0682 On April 19, 2017 our office received a complaint that a radio tower had been constructed without the proper permits or inspections. Upon arrival it was noted by our code enforcement inspectors that a tower had been constructed. Virginia Uniform Statewide Building Code, Section 108.1 When applications are required. Application for a permit shall be made to the building official and a permit shall be obtained prior to the commencement of any of the following activities, except that applications for emergency construction, alterations or equipment replacement shall be submitted by the end of the first working day that follows the day such work commences. In addition, the building official may authorize work to commence pending the receipt of an application or the issuance of a permit. 1. Construction or demolition of a building or structure. Installations or alterations involving (i) the removal or addition of any wall, partition or portion thereof, (ii) any structural component, (iii) the repair or replacement of any required component of a fire or smoke rated assembly, (iv) the alteration of any required means of egress system, (v) water supply and distribution system, sanitary drainage system or vent system, (vi) electric wiring, (vii) fire protection system, mechanical systems or fuel supply systems or (viii) any equipment regulated by the USBC. 2. For change of occupancy, application for a permit shall be made when a new certificate of occupancy is required under Section 103.3. 3. Movement of a lot line that increases the hazard to or decreases the level of safety of an existing building or structure in comparison to the building code under which such building or structure was constructed. 4. Removal or disturbing of any asbestos containing materials during the construction or demolition of a building or structure, including additions. UNIFORM STATEWIDE BUILDING CODE, SECTION 113 INSPECTIONS Page 1 of 2 113.3 Minimum inspections. The following minimum inspections shall be conducted by the building official when applicable to the construction or permit: 1. Inspection of footing excavations and reinforcement material for concrete footings prior to the placement of concrete. 2. inspection of foundation systems during phases of construction necessary to assure compliance with this code. 3. inspection of preparatory work prior to placement of concrete. 4. Inspections of structural members and fasteners prior to concealment. 5. Inspection of electrical, mechanical and plumbing materials, equipment and systems prior to concealment. 6. Inspection of energy conservation material prior to concealment. 7. Final inspection. This office hereby directs you to apply for the proper permits within five (5) days upon receipt of this letter. Failure to comply will result in this matter being forwarded to the County Attorney for appropriate legal action. Respectfully, Mark A. Fleet Building Code Official CC: Mark Cheran; Gary Lofton Page 2 of 2 EXHIBIT 4 Andrew P. Hill From: David Williamson<dwilliamson@CustomComputersVA.com> Sent: Wednesday, November 22, 2017 2:16 PM To: Andrew P. Hill Subject: FW: Re: Tax Map 49802-123-72 Attachments: 0158_170724134937_001.pdf Importance: High From: David Williamson Sent: Monday, July 24, 2017 2:20 PM To: mfleetCaafcva.us Cc: beau correllfirm.com; Cleland, Ned Subject: Re: Tax Map 491302-123-72 Importance: High Mr. Fleet et al, I am in receipt of your letter dated July 18, 2017. As was stated in your previous email to me on June 14, 2017, "You will need an engineer designed set of plans, a plot of the property showing the location on the property as well as a completed permit application. Since the project was started before any permits were issued you will also need an engineer's evaluation of the foundation that was put in place with no footing inspection." On June 27, 2017 1 sent an email to Betty Cleland with Blue Ridge Design, a local structural engineering firm that I have used for other previous projects. The purpose of my email was to engage their firm for the purposes highlighted above from your email correspondence. On July 4, 2017 1 received a reply from Mrs. Cleland, informing me that due to staff vacations and her husband, Ned Cleland, being out of the country for another project, it would be a little while before someone would be available to meet with, and potentially assist on this project. I replied to her email on July 5, 2017 and thanked her for the reply and asked her what the next step would be and told her I felt most comfortable engaging their firm since I knew the quality of work produced. On July 6, 2017 1 received a reply back from her with the following information: From: Cleland, Betty rmailto:bfclelandiabrd-inc com] Sent: Thursday, July 06, 2017 11:48 AM To: David Williamson Subject: RE: Structural analysis David, I just spoke with Ned and il you ;runt him to do this, he will try to get to it this month. Since I do not check nny email c drnedC@brd-inc.com He will address this asap. Betty I then sent an email directly to Ned Cleland on July 13, 2017, requesting a meeting at his earliest available time. He replied back to me on July 14, 2017 with the following information: ------ Original message -------- Froze: "Cleland, Ned" <dxned er:brd-inc_com> Date: 2017.07214 7:09 Ansi (GNr-OS:00) To: David Williamson <dwillam sort6KUstomComtautersVA corr> Subject: RE: Structural. analysis Daxid. I am traveling to a project this morning; and I expect to be back in the office by 2:30_ so we could meet atter th On Monday, I have an opening after 3:30. 1 can schedule for anv time on Tuesday. Ivied M. Cleland, Ph -D-, P.E. Blue Ridge Design_ Inc. Glearock House 3 West Piccadilly St; are Floor NVinchester_ VA 22601 540-723-0900 office I then replied back to Mr. Cleland on July 14, 2017 stating that I would come to his office later that same afternoon. I then arrived at his office around 413M on Friday, July 14, 2017, for our in-person meeting. I brought the following to that meeting to provide to him: 1. A copy of notices sent from Frederick County. 2. A copy of the complete FOIA request on this complaint. 3. A copy of the email from you, Mark Fleet, stating what was required to proceed. 4. A copy of a confidential email I received from my attorney, Beau Correll, summarizing his meeting with you and your attorney on May 31, 2017. 5. Information pertaining to the concrete footing and application process for installation of the tower. At that time I also asked Mr. Cleland to send a notification to your office that I had engaged him and his firm for the purposes of completing the required structural analysis information that was to be a prerequisite to me being able to apply for a building permit. So, one week later, Friday July 21, 2017, 1 receive the certified letter from your office, attached to this email, stating I had 5 days to apply for a building permit or your office was turning the matter over to the County Attorney for legal action. As I have clearly outlined above, I have done everything in my power to move this in the direction requested by your office on May 31, 2017. If you wish for me to come apply for a building permit before the required structural analysis work has been completed, I will come down to your office and file the application, however, I will not have the structural analysis data to accompany it. Mr. Fleet, how would you like me to proceed at this point? Mr. Cleland, would you please send an official notification to Mr. Fleet's office, if you have not already done so, informing his office that I have already engaged your firm to work on this project? Mr. Correll, if you feel I have missed anything pertinent to this matter, please feel free to contact me offline to discuss and advise as needed. Thank you all for your time and attention to this matter. Regards, David Williamson Rockwood 72, LLC 2979 Valley Avenue Winchester, VA 22601-2631 EXHIBIT 5 (revised 8/30/17) DATE: PERMIT # APPLICATION FOR PERMIT (please complete the DeckApplication Pcrinit if applying for a deck only) Owner's are allowed to act as their own contractor provided DPOR Title 54 Owner Contractor Definition is met. *Contractor's Name: Address: Phone Number: *NOTE: If you have never obtained permits in Frederick County please attach a copy of your state contractor's license. Any jobs over $25,000 will also need a Frederick County Business License unless you are building in the Town of Middletown or the Town of Stephens City. You would then need that town's business license. All businesses in Frederick County are required to have a Frederick County Business Licenses regardless of the job value. LOCATION OF OBSITE Subdivision: _ �� y� � � Lot Number— Street Address: Tax Map Identifica�slte: mber of the Property: .,� .. Directions to the jo—' SETBACKS Please indicate the actual distance measured from the structure to the property lines) Front, -.1") Rear 0 L431 Lett _ A�_t Right X E OF PIERIWiil T PLYING FOR: Building Electrical Mechanical Plumbing TE Ander I l" etl0M of 1003'rr;ation Actplans can be secured upon request. PERMIT FOR: I hereby agree to cornI with all Ordinance as ttcinnt�cllh�� xhp t n� Applicant (,vigna, (print) Sign of the Virginia Uniform Statewide Building Code and the Zoning Applicant is: Contractor _ Owner Agent* *Agents, please note that a signed authori ation from the owner or contractor must enattached rchitect *Agent Name (print) *Agent Contact Number *Agent Address (print) Natpe and daytime telephone number �r gUcstiOns on the permit application and/or construction documents. Permit Application Page Two BUILDING INFORMATION NEEDED FOR PERMITS WATER SUPPLY/SEWAGE DISPOSAL SYSTEM �� ❑Public Water/Sewer System ❑Private Well/Septic ' ' MECHANICS LIEN AGENT: yes i10 (if yes, please complete below) Mechanics Lien Agent:. t I M Address: Phone Number JOB VALUE: _4>r��,, ❑New One & Two Family Dwelling ❑New Mobile/Manufacturer Home ❑New Modular/Industrialized Home ❑Residential Remodeling []Residential Addition ❑ sidential Demo ion requires a letter from the utility providers (gas/electric) confirming the electric/gas has been removed) Master Plan Nuns (if applicable) Building Size (Dimens' ns) Total Square Footage of • ing Space First Floor Second Floor Bonus Room Total Square Footage of Base Unfinished Square Footage Finished Square Footage Number of Stories Number of Bedrooms Number of Bathrooms Total Number of Rooms Garage ❑Detached []Attached Size of Gard Deck 1 — Length Width Total Square Footage Deck 2 — Length Width _ Total Square Footag+r Porch — Length Width _ Total Square Footage Masonry Chimney/Fireplaces MOBILE HO S Make _ Model Year erial Number Length _ _ Width Number of Bedrooms Number of Bathrooms Type of Heat COMMERCIAL.., JOB VALUE: ❑New ❑Addition ❑Remod ting ❑Demolition (requires a letter from the utili y providers (gas/electric) confirming the electric/gas has been removed. Additionally, Demolition/Additions/Remodeling permits on buildings constructed prior to January 1, 1985 requires Asbestos affidavit) Total Square Footage of Building Building Size Number of Stories Number of Bathrooms Total Number of Rooms Use Group Occupant Load Upon request, Technical Review Committee meetings for projects with site plans and pre -permit evaluations of existing structures prior to renovations, additions and change of use are available Permit Application Page Three �J SIGNS (please provide the following information for each sign) JOB VALUE TOTAL! 1 " Type of Sign ❑Wall Sign Size (Dimensions) Square Footage of Front of Structure (if wall sign) CJFreestanding* (provide height measured from ground to top of sign) feet Sign Size (Dimensions) (*Freestanding signs require a plat/drawing showing the location of the sign and the distance from the property line/roadway(s) Marking & Listing Number LEGTRICAL PERMIT JOB VALUE: ` RESIDENTIAL Amp Service EXE D New ❑Upgrade ❑Reconnection For Additions/Remodeling: Numb • of Switche§iy.pL Lights Receptacles Size of sub -panel if adding one COMMERCIAL (please list equipment below and provide 2 sets of plans*) JOB VALUE:` Amp Service Number of Switches Lights Receptacles (Quantities are required for permit submittal and shall be received prior to review of plans) Size of sub -panel if adding one ❑Fire Alarm (please provide 4 sets of plans* and equipment specifications) (Commercial - List all equipment, motors, and wiring — attached sheet if needed) PLUMBING PERMIT: JOB VALUE: _ 11 ❑Residential ❑ Commercial (please provi e 2 sets of the plans* for Commercial applications (list number of fixtures by each) Bath Sink/Basins Dishwasher Floor Drains Fountains Garbage Disposal Grease Traps Laundry Tub Lawn Faucets Sewer Pump Sewer Service Shower Stall Kitchen Sinks Sutnp Pumps Whirlpools Tubs Urinals Wash Machine Toilet/Water Closet Water Heater Water Service Well Pump Other MECHANICAL PERMIT JOB VALUE: _ ❑RESIDENTIAL ElCOMIVIERCIi� (list number of fixtures & provide 2 sets of plans*) Heat Pump Gas Furnace A C Unit Gas Piping Gas Range Gas Logs Gas Water Heater Other Size of Tanks Under 500 Gal. Sprinkler System (list type) (please provide 4 sets of plans* and equipment specifications) (list all equipment giving btu's and tons) 'NOTE: All commercial jobs for building, signs, electrical, plumbing and mechanical will need to submit 2 sets of plans. Please separate plans by trade. Sprinkler plans and fire suppression systems require 4 sets. Residential building permits for residential permits will need to submit I set of plans. LOT 72 PLAT 4SC-C710N 23 -1 AND BACK CREEK DISTRICT F0 -X INST, 10-7783, FREDERICK COUNTY, VlkGtNIA ,� F�h RECORD: PLAT !]8r 376., r -T.;. IfRS N 34-35a,'�;[ E 77.42).' " POCKA00-D TRAIL -6-&' R.//W. CURRUT OXAPEP, LLC~ tAZ' I FF"Me INS -T. FA -42O,i iAW TITLE' Arpofir FUAff!jjSHBDz ------------- to L.S. N M 'kV'E'V'W-r A'*0 PLANNENG-CO %S - TXfl0 w T4 -V, 1'520 Co"MaACR ViNGINIA 226wf IL FURSTENAU; VAIM JVjVZ 2.7, 21)ra Uc. Ub. 2727 f."3" Tt)' 09&TTPY THAT ON AME 27. 2916' NMI" I A&LOF AN, ACVIYR;&.TR Or. 7?ffF PRews'RS .9frowv AX !Mt`'. ti MERAVONAND MA T TH!P-RP-' AMP M - ON TMF 0ROUND'DTIMR THAW SlHoWm pppRgoM JPF S 3'4'30'5.7" W 77.4:2' IRF IRF LOT -7 '2$ 20.004.], Sly. FT icl 0 ,� F�h RECORD: PLAT !]8r 376., r -T.;. IfRS N 34-35a,'�;[ E 77.42).' " POCKA00-D TRAIL -6-&' R.//W. CURRUT OXAPEP, LLC~ tAZ' I FF"Me INS -T. FA -42O,i iAW TITLE' Arpofir FUAff!jjSHBDz ------------- to L.S. N M 'kV'E'V'W-r A'*0 PLANNENG-CO %S - TXfl0 w T4 -V, 1'520 Co"MaACR ViNGINIA 226wf IL FURSTENAU; VAIM JVjVZ 2.7, 21)ra Uc. Ub. 2727 f."3" Tt)' 09&TTPY THAT ON AME 27. 2916' NMI" I A&LOF AN, ACVIYR;&.TR Or. 7?ffF PRews'RS .9frowv AX !Mt`'. ti MERAVONAND MA T TH!P-RP-' AMP M - ON TMF 0ROUND'DTIMR THAW SlHoWm pppRgoM 3 West Piccadilly Street, 31' Floor Winchester, VA 22601 540-723-0900 540-723-0901 fax ' 1 1: , Memo Tim David Williamson, Rockwood II LLC From Ned Cleland Date: August 29, 2017 Re: Ham Radio Tower U NED M. UC. No. 9940 jONAL I have made an evaluation of the foundation and anchorage of the latticed tovyier as placed on Lot 72 on North Mountain. The following is a summary of that evaluation. I have attached documents and calculations that were used or developed with my evaluation of the tower base support. I visited the site to make measurements and to verify conditions and to make measurements of the foundation and anchorage on Monday, August 28th. Photo 1 shows the foundation view from the northwest comer. The base measures 10'-3u by 11'-10" in plan. I understand that the total thickness is four feet. An e-mail from Craig Holman dated May 10, 2017, the weight of the tower base was stated to be 66,000 lbs„ which would be equivalent to 3.62 ft. depth, so the base is checked for this 1 range. There are piles of spoil from the excavation that are consistent with the size of the excavation, and also show that the base is weathered shale with some well - distributed clay fines. I also verged the field -installed base anchor size (5/e in. dia.) and locations to permit evaluation of the anchorage to concrete. I have reviewed the drawings and prepared calculations for the tower wind loads. The first six pages of the attached material are the drawings with layout and member sizes of the tower sections that were assembled to form your tower. I have used these to determine the exposed areas for wind loading. The assembly of five sections of 20 ft. length makes the tower. These segments are labeled 7N, 6N, 5N, 4N, and 3N. The drawings provide the diameter of the three comer pipes and the angle leg widths or rod diameters for the cross bracing for each of the three tower faces. The sizes are increased based on ASCE 7 wind resistance factors based on section shapes and a ratio, E, of net area to gross area and include a factor for the effects of the resistance of the tower faces at angle with a flat face. The second six pages are from my evaluation of the location of the tower lot from the tax maps and from Google Earth. I use the Google Earth location to determine the topographic elevations to determine the effects of placement downhill from the North Mountain ridge on the wind loading. With the longitude and latitude of the site determined, I used the new ASCE 7 Hazards assessment program to determine the design wind speed and ice accretion for the site. I used a low hazard category for wind speed since this structure is isolated and has low risk for loss of life or damage to property from failure. Pages from the Hazard Report are also attached. The ice accretion for this site is 1 in., but the wind speed associated with the ice event is only 30 mph and so the enlarged exposure area does not control the wind design loading. ASCE 7 includes the calculation of a topographic factor for conditions where the location of the structure may cause higher pressure. I used topographic data derived from the Google Earth program, and verged with the ASCE 7 Hazard Tool to determine the ridge and valley distance and elevations on both sides of the ridge. I verified the offset of the ridge peak from the tower site when I visited the site. The governing value for the topographic effect was 2.84, increasing the base wind pressure to 82.6 psf on the effective exposed areas of each tower. segment. This wind force calculation gives a base shear of 7,892 lbs. and an ultimate base overturning moment of 211.5 ft. -kips. From this moment calculation and the spacing of the legs, the calculated potential uplift ultimate force at each leg is 37,200 lbs. You have provided an e-mail stating that the anchor holes were drilled 18 in. and the anchors were installed with Epcon C6+ structural epoxy in accordance with the manufacturer's written instructions. Product data for this material indicates 22.6 kips per rod with 7'/sin. embedment in 2,000 psi concrete. This indicates that the design strength of the epoxy bond for four anchors is 67.9 kips, including a strength reduction factor of 0.75. For anchorage to concrete, the epoxy bond strength may not be the controlling limit to the base anchorage. The anchorage strength also depends on the strength of the bolts and the depth of anchorage and strength of the concrete into which the anchors are set. The approximate strength of the four anchor rods at each corer base limited by steel (A35 or A307 threaded rods) is 76.5 0 Page 2 kips. For the rods embedded at 7'/ in. for comparison with the epoxy strength rating, the concrete break-out strength would be 29.5 kips in 3,000 psi concrete. With 9 in, embedment, the design strength is 37.4 kips, which is greater than the ultimate load. The lholes were reported to be drilled 18 in. for anchorage. Installation greater than 9 in. is sufficient. The base is 10'-3' by 11'-10" in plan. For a total thickness of four feet, the base weight would be 72,800 lbs. Using the short width of the base for the critical condition, the resistance to overturning with a 10% reduction in effective base dead load is 336 ft. -kips, about 1.6 times the ultimate base moment. For the service load moment, the overturning safety factor is greater than 2.5. The maximum calculated ultimate bearing pressure under the edge of the footing is 1.95 ksf. The service load maximum is 1.16 ksf. For a base weight 66,000 lbs., the minimum resistance to overturning with 10@ dead load reduction is 304 ft. -kips, about 1.44 times the ultimate base moment. For the service load moment, the overturning safety factor is about 24. The maximum calculated ultimate bearing pressure under the edge of the footing is 2.13 ksf. The service load maximum is 1.12 ksf. The soil pressure calculations give bearing pressures greater than allowed for unclassified soil, but the weathered shale base in evidence at the side would have a s'gnificantly higher allowable bearing value. The moment from the tower base adds stress tot eh base concrete. I understand that the footing base is reinforced, but I have not seen the size or placement of the steel. Based on an analysis of the section as plain concrete, the maximum ultimate stress for the moment is 61 psi, tension and compression. Following the chapter in ACI 318 for plain concrete, the maximum tension stress is limited to 164 psi for 3,000 psi compression strength concrete and 134 psi for 2,000 psi concrete. The loading, then, is well within the code limits. Based on my site inspection, analysis, and evaluation, the concrete footing and field - installed anchorage to concrete meet the requirements of the building code for loading imparted by the radio tower. 0 Page 3 Ell G� Yi M a Ell l iKil: tC P O { D Ik �° I gi i ID E� O0P ern n n« Q`2� P kkm Lx i oo .fin. i�SYA�i M i �w e x �R a 1 t£ k ar�y�y,ggri aq�fi��&{gkg skxkx @8j�j �.sT3°� �a k�y3 ¢�k4igllg tzo Coq a a II ','sJ!!!!snJ swwrrs a �M69 �t b ti ?x x T(p TQ a - � c Y n L�. y< 6u d o� n ar�y�y,ggri aq�fi��&{gkg skxkx @8j�j �.sT3°� �a k�y3 ¢�k4igllg 4a� � a � ava E� 15 ¢y 6A3 r� e+',. � F g �, ■�i iii = iY i � �pbe. f¢..P,ii / ->fi iP 4' sky '� i ,'y? �,• r Jr _._ Py �+ „�j lop �'y, tl1 y,f�4� 1A F r ♦ �,.' 0 , �F 66 wis vWg t �t ", IlL C • �}.. � � ifs �. i v � ; X (4_' t �� 3 a • :. -h�n' X2..'.3 r d t # P i � f MWI N a e el ASCE NaRl w sa:. u -rnx 5 r es No Address At this Location ASCE 7 Hazards Report Risk Calaegory: Standard VA?rs;on: Elevation: 2223 ft 1 AscErsEl 7-16 Lat. 39.1999 Soil' Cia1r's; Long: -78.35793 B Estimated stimated (see Section B Est Elevation R-AfQrence Oata;m- North American Vertical Datum of 14RR (1.0X\8 RR T (" Results: Wind Speed: 103 Vmph Data Source: ASCE/SEI 7-16, Fig. 26.5-1A Date Accessed: Tue Aug 15 2017 Value provided Is 3 -second gust wind speeds at 33 ft above ground for Exposure C Category, based on linear interpolation between contours. Wind speeds are interpolated in accordance with the 7-16 Standard. Wind speeds correspond to approximately a 15% probability of exceedance in 50 years (annual exceedance probability = 0.00333, BFRI = 300 years). Mountainous terrain, gorges, ocean promontories, and special wind regions should be examined for unusual wind conditions. A)h IlC?JO.o 01,ne P8991 of 4 Tue Aug 15 2017 ASCE Miffil(W4 SME r( OF GSE ENGINEERS Ice Results: Ice Thickness: 1.00 in. Concurrent Temperature: 15 F Gust Speed: 30 mph Data Source: Standard ASCE/SEI 7-16, Figs. 10-2 through 10-8 Date Accessed: Tue Aug 15 2017 Ice thicknesses on structures in exposed locations at elevations higher than the surrounding terrain and in valleys and gorges may exceed the mapped values. Values provided are equivalent radial ice thicknesses due to freezing rain with concurrent 3 -second gust speeds, for a 500 -year mean recurrence interval, and temperatures concurrent with ice thicknesses due to freezing rain. Thicknesses for ice accretions caused by other sources shall be obtained from local meteorological studies. ice thicknesses in exposed locations at elevations higher than the surrounding terrain and in valleys and gorges may exceed the mapped values. Snow Results: Case Study Required Elevation: Data Source: Date Accessed: 2223.0 ft ASCE/SEI 7-16, Fig. 7-1. Tue Aug 15 2017 In "Case Study" areas, site-specific case studies are required to establish ground snow loads. Extreme local variations in ground snow loads in these areas preclude mapping at this scale. Ground snow load determination for such sites shall be based on an extreme value statistical analysis of data available in the vicinity of the site using a value with a 2 percent annual probability of being exceeded (50 -year mean recurrence interval). Values provided are ground snow loads. In areas designated "case study required," extreme local variations in ground snow loads preclude mapping at this scale. Numbers in parentheses represent the upper elevation limits in feet for the ground snow load values presented. Site-specific case studies are required to establish ground snow loads at elevations not covered. hftp. aIgN, ?ha rdtaol online/ Page 3 of 4 Tue Aug 15 2017 ,G �, t t� A' >tj{ t .S�•tt - YF� K` St :. .t (A A{ 41 `i W ? 1 vt en rj sr' ryNi61 i7 til :JAM ---------- ................ ym �G" Wnm - low VIj.A 1 vt en rj sr' ryNi61 i7 til ---------- ................ ym �G" Wnm - low David Williamson From: Sent: To: Subject: noreply@homedepot.com Wednesday, September 27, 2017 8:08 AM David Williamson Order Status Update Please keep this email for your records. Please add HOMOReAol@homedepot.com to your address book. Learn how. a Order Status Update Mnraetnin- 0 FREE SHIPPING* + � FREE IN STORE PICK UP + JR FREE RETURNS" Order Number: H4618-33115 Order Date: 09/23/2017 Dear DAVID, Your Order Status Has Changed We have a status update for one or more items on your order. Please review your order details and keep this email for your records. Product Description Qty Fulfillment Status S01 EDGELEY RTF MATTE 2.00 1 PROFESSIONAL CABINET WRITE SOL In production storeSKU# 1001529201 Ship to Location: 2350 LEGGE BLVD Expected Arrival WINCHESTER, VA 22601 Date: (540) 723-0619 11/11/2017 Check your oder history online at any time. Thank you again for visiting hMn depot com. Sincerely, The Home Depot WINCHESTER #4618 2350 LEGGE BLVD WINCHESTER, VA 22601 (540) 723-0619 Z CLACK TO vIEW YOUR G -at Top Viii t F 7 u9-XJS for arc e� aj ur �p Save Big with Our CENTER Shop Top Online Promotions on Populw Products for Your Homo and Gar4an SAVING CENTER LOCAL AD STORE FINDER THE HOME DEPOT CREDIT CARD MANAGE MY SETTINGS Please do not reply to this email. To contact us, please call the store at (540) 723-0619. For all other store -related customer service needs: In the U.S., call 1 -800 -HOME -DEPOT (8AM to 8PM ET, Monday through Friday, 9AM to 6PM ET, Saturday and 12 PM to 6 PM ET, Sunday) View our return policy. Local store prices may vary from those displayed. Products shown as available are normally stocked but inventory levels cannot be guaranteed. NOTE:AII offers may not be available in all areas. Products are currently only available for delivery to street addresses in the 48 contiguous United States. Select parcel items can ship to Alaska & Hawaii. We cannot ship to APO/FPO, P.O.Boxes or U.S. Territories. Prices are in U.S. dollars and are subject to change without notice. 2012 Homer TLC, Inc. All rights reserved. Privacy & Security Statement ron1'i&! rti;tl rind may be 1e4'-:br J:;. r l Ir; i tl..nf r?Ci r((it {�i r..ry di!;cit Son Cul ryi !y uiSl,ibl i!i07 Or +r n i irc > c I to o .r U ei d. any opinion C lC :;r,i. ent-lit C. I in thvc t , 1aA errs Suojor'+ to IN: I rms it I ordientE'ruia(1Gm8n[iCltF( }i@I, 1111,t.)C�U f MI �.,r.0 (A of lc Sr- iri ;pK'(rolli any ni'iC;iif)-.ICS 6nurS Vilust t j NCinYIS, t;Ljlrl hur- :Ir ) q .I , ! ,: : n tr•,cri to INS, itta hr ,r-nt an,] sha! ncJI tar' liar ": f(ir direct, indiref,-I r,, r,,,. quc:nUa! nr r J;, ., Jr! ,u;atinr: in t! ds It d::Fnet f.:rnatl !> confidential and may he legeal!v f+riviteghd It is intC 5Ae l sf%ieiy ft -.r thct addr-_s,t>c! Acr.;•. o. i :•i -� t! + r ! nu h< inlcndad ra,(;Ipient, any diz Cdo ;u F _ - += EXHIBIT 6 - vv.,vt i i. Vi.i 11J.�L L,Ll1\✓j� 1 ! Department of Planning and Development :ate. 540/ 665-5651 Fax: 540/ 665-6395 CERTIFIED MAIL October 26, 2017 Rockwood 72 LLC Attn: David Williamson 2979 Valley Avenue Winchester, VA 22601 RE Property Identification Number (PIN): 491302-123-72 Zoning District: R-5 (Residential Recreational Community) Dear Mr. Williamson: This letter is in response to Building Permit #0000727-2017 applied for on September 29, 2017, and submitted to this office regarding an amateur radio tower. This tower was constructed on the above -referenced property without a building permit. The building permit application stated the building setbacks for this tower to be: front 37 ft., rear 143 ft., right side 23 ft., and left side 49 ft. These setbacks for the 100 -foot tower are in violation of the Frederick County Zoning Ordinance for the R-5 Zoning District. Furthermore, the building permit application has included a house location survey that shows the outbuilding at 10 ft. along Ashwood Trail. This outbuilding is in violation of the setbacks for the R-5 Zoning District. In accordance with Section 165-201.03 B. (1). Height limitations; exceptions of the Frederick County Zoning Ordinance, allows for radio transinission towers within the R-5 Zoning District. Provided that subsection (8) of Section 165-201.03 B. is met: If any of the above exceptions exceed the height limitation of the proposed zoning district, the structure shall be required to be set back the normal setback or required buffer distance plus one foot for every foot over the maximum allowed height of that zoning district. The minimum setbacks for this structure are: 90ft. front, 90ft. right side, 70ft. left side, and 105 ft. rear. Therefore, this structure constr utes a yr lation of Section 165-201.03 B. (8) of the Frederick County Zoning Ordinance. In accordance with Section 165-502.04 A. Permitted uses of the R-5 Zoning District allows for accessory structures (outbuilding) within the district, provided that the setbacks of the RP (Residential Performance) Zoning District are met. The setbacks for 107 North Kent Street, Suite 202 • Winchester, Virginia 22601-5000 Page 2 Rockwood. 72 LLC Re: PIN 49B02-12-72 October 26, 2017 accessory structures along a right-of-way is 35 feet. Therefore, this accessory structure constitutes a violation of Section 165-502,04 A. of the Frederick Zoning Ordinance. This office will allow thirty (30) days from the date of this letter to resolve this violation. Specifically, the resolution of this violation may be accomplished by removing the two structures or placing the structures at the correct setbacks and resubmitting a building permit for review and approval by Frederick County. Failure to comply with the Zoning Ordinance will result in a criminal complaint being filed against you. You have the right to appeal this notice of violation within thirty (30) days of the date of this letter in accordance with Section 15.2-2311 of the Code of Virginia. This decision shall be final and unappealable if it is not appealed within thirty (30) days. Should you choose to appeal, the appeal must be filed with the Zoning Administrator and the Board of Zoning Appeals (BZA) in accordance with Article X, Section 165-1001.02 (A), of the Frederick County Zoning Ordinance. This provision requires the submission of an application form, a written statement setting forth the decision being appealed, the date of decision, the grounds for appeal, how the appellant is an aggrieved party, any other information you may want to submit, and a $300.00 filing fee ($250.00 filing fee and a $50.00 refundable sign deposit). Once the appeal application is accepted, it will be scheduled for public hearing and decision before the BZA. Please contact me regarding any questions that you may have at (540) 665-5651 Sincerely, r Mark R. Cheran Zoning Administrator MRC/dIw cc: Mark Fleet, Building Official EXHIBIT 7 Andrew P. bill From: David Williamson <customcomputersva@gmail.com> Semi: Wednesday, november 22, 2017 2:21 PM To: Andrew P. Hill Cc: David Williamson Subject: Fwd: Interest in use of Rockwood Trail Facility for Amateur Radio Repeaters Attachments: Projected KG4Y coverages from KG4Y Home Site.pdf, Projected KG4Y coverage from Rockwood Trail Site.pdf ---------- Forwarded message ---------- From: Michael Wolff <miuel lobos@Yahoo.com> Date: Mon, May 29, 2017 at 3:22 PM Subject: Interest in use of Rockwood Trail Facility for Amateur Radio Repeaters To: David Williamson @customcomputersva@gmail com> Cc: k4uss@arrl.net David, Thank you for reaching out to me and sharing your vision for the use of Winchester Wireless sites at high elevations in the county for the additional purpose of acting as amateur radio relay station locations. I, as the owner and operator of an amateur UHF repeater, am excited about the prospect of locating my repeater station and components at a location so well-suited at providing service coverage across Frederick and Clarke Counties in Virginia, as well as Jefferson, and a significant portion of Berkeley Counties in West Virginia, which would allow it to essentially blanket the northern Shenandoah Valley with coverage. I did take the opportunity yesterday to ride by the site and see the progress that has been made to -date on it. I was quite pleased with what I saw, and I also collected some GPS data at the location that enabled me to have some inputs into the tools used to calculate predictable coverage from that location. Speaking of which, I have included predicted coverage maps generated from on-line tools to show the projected difference in coverage from the repeater operating at the existing location (at my home in Frederick County east of Winchester) versus using such a well-suited location as the facility at Rockwood Trail. I can certainly get into some deeper level of detail and explanation of why the difference, but the key factors are: 1. line -of -site radio wave propagation — the vastly dominant mode of radio wave propagation at the frequencies that such repeaters typically operate 2. height above average terrain (HAAT) — determines the distance to the radio horizon which is the theoretical limit of propagation distance for line -of -site propagation mode Of course, there are other clubs, and other stand-alone VHF and UHF analog FM amateur repeaters situated along the North Mountain ridge at a variety of locations, and many of them have been there for years. To date, I have not been able to figure out how to approach any of these site owners and negotiate an agreement to allow co -location of my repeater. One of the things that differentiates my repeater, making it worthwhile to put in such a location is that I have equipped it with the necessary pieces to link it to the Internet. This repeater offers the ability to function in analog FM mode, as well as a newer modulation technique (C4FM) allowing digital signal transmission, removing much noise with similar coverage characteristics. Further, the digital signaling protocols allow users of the system to control linkage to other repeaters and talk groups leveraging VOIP over the Internet. As far as I am aware, none of the repeaters scattered across the North Mountain ridge offer this at this time. Of course, for this to work, the repeater will require an internet connection available wherever it is located. The bandwidth needed to operate in this mode is typically less than I Mbps, using UDP packets for voice and signaling delivery. This repeater is branded as part of Yaesu's System FUSION, and the Internet Linking product is Yaesu's WIRES -X. I know that there are a number of amateur radio operators in the Shenandoah Valley that have Yaesu System FUSION capable radios, and would benefit from the experience of using the system with WIRES -X to link across the world via this repeater. One of the nice things about this repeater, is it will also work in analog FM mode, which has been the method of operation since the deployment of amateur radio repeaters started becoming common in the 1960s and 1970s. I would be remiss if I did not include one of the key purposes that many amateur radio repeaters serve — emergency communications. As fun as all of these things are for the amateur radio community, many of us choose to give back and make ourselves available as communication support resources to the various local, state and federal first responder and incident management entities. There are two widely recognized amateur radio - related organizations known nationwide for providing volunteer communication service response to disasters — RACES (Radio Amateur Civil Emergency Service), and ARES (Amateur Radio Emergency Service). RACES is spelled -out and defined in the Communications Act of 1934, where ARES is a sub -organization within the American Radio Relay League (the ARRL — best characterized as a national amateur radio advocacy organization that has been around for over 100 years now). Some of the amateurs in this area are affiliated with ARES, but I haven't heard much with regard to RACES in this part of Virginia. Organizationally, I can tell you that ARES has groups organized with leadership down to the county level, as I happen to know some of the office holders in this area for that organization. Full disclosure — I am a life member of the American Radio Relay League, and an ARES volunteer for both Frederick and Clarke Counties. Let me know if you have questions or wish more details on what any of this means. My intention is to register my repeater as an official ARES emergency repeater with coverage of Clarke, Frederick, and Jefferson Counties (the map projection shows coverage from Rockwood Trail over those counties as very good) Additionally, one of the area amateur radio clubs of which I happen to be a member in good standing (The Blue Avalanche Communication Group — I happen to be the current president of that club), has a VHF repeater on the air not too far from the Rockwood Trail location, but it is not in as good of working order as we had hoped would become the case in its current location. This repeater was designated as an ARES repeater, so we are hopeful that moving this repeater (also a Yaesu FUSION capable repeater, but currently without WIRES -X), with it's VHF frequencies, would cover any holes that my UHF repeater might leave for the projected coverage area. Options are always a good thing, and redundancy of systems typically means improved availability of services. I, and the Blue Avalanche Communications Group, are excited at the prospect of using the Rockwood Trail site to host two repeaters and associated equipment. In order for this to function as intended, here's what we envision happening — We would provide the equipment necessary to for the repeaters to operate. at the co -locate with the commercial interests at the facility, including the repeaters, duplexers, antennae and interconnecting cabling, and would arrange for the delivery and installation of said equipment. We would need for you: i. Space on the tower for two side -mounted antennas with sufficient clearance to avoid interference or hazards 2. Space in the shelter for our equipment (i.e. 19" rack -mount relay rack or 4 -post IT style cabinet) 3. Electric power to run the equipment (standard, common household AC power @ 120 VAC single phase, total current draw not to exceed 5 Amps) 4. Internet access via an Ethernet connection (10/100/1000 on copper), with bandwidth up to approximately 1 Mbps 5. Reasonable access control / security to the site to prevent unauthorized / unlicensed persons from gaining control of amateur radio apparatus (i.e. locked shelter / unauthorized climber prevention on tower) 6. Reasonable access arrangements for our technical people to get to the equipment for maintenance / repair activities Further, if you were to find that co -locating amateur radio services is possible at other locations, we'd be very interested to explore those possibilities as well. Diversity and redundancy of such facilities can be the difference between being able to communicate or not with critical stations in the wake of a disaster. Thank you again for reaching out to us and sharing your vision with me of additional uses of your sites! I am looking forward to moving forward with you on transforming the vision into reality. Best Regards and Happy Memorial Day, Michael Wolff President — Blue Avalanche Communication Group Amateur Radio Station KG4Y :)Iw 11 a- cl al 10 ;... MM -a Lz cd C'3 ialr.4lgl, > 1 O I � I cn 0 N 0 N 1 o 0 ci •U by � bA O N N Y ,?� Q' v 0 o +o O 06 0 � OAD a1 c7N 1 �i M + + Mi O :L. :)Iw 11 a- cl al 10 ;... MM -a Lz cd C'3 ialr.4lgl, > 1 O I � I cn 0 N 0 N 1 ci •U by � bA O C. N Y Q' v 0 o :)Iw 11 a- cl al 10 ;... MM -a Lz cd C'3 ialr.4lgl, > 1 O I � I cn 0 N 0 N 1 ci O v 0 o OAD c� Cc3 a O Q O C3 t3 V] WiIt O CA O kn 00 fA cc OIO O kn N N N O 00� i -, N N 00 QN y x :)Iw 11 a- cl al 10 ;... MM -a Lz cd C'3 ialr.4lgl, > 1 O I � I cn 0 N 0 N 1 U cl cl N V o ° a. a � tin � C/) O ctj ' C15 ci v 0 o OAD c� Cc3 U cl cl N V o ° a. a � tin � C/) O ctj ' C15 a 00 CA 211 . vim^ r � 4 44 J L J b'1 3 x 's z S � Na :h4� All wAM .. _ y J , '•�S �_ � iJ �4 O. Rd � sa Lev I'll II -e k 4•} 0. e s A it f 4 x 's z S � Na :h4� All wAM , .. RIZ+ I'll II -e k 4•} Z. 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