HomeMy WebLinkAboutDTS-10-094 - Storm Water Management Utility & Rate ImplementationI,
KlTcHF,NF-R
Development &
Technical Services
REPORT TO:
DATE OF MEETING:
SUBMITTED BY:
PREPARED BY:
WARD(S) INVOLVED:
DATE OF REPORT:
REPORT NO.:
REPORT
Finance and Corporate Services Committee
May 10, 2010
Grant Murphy, Director Engineering Services
Grant Murphy, Director Engineering Services - 741 -2410
All
May 5, 2010
DTS -10 -094
SUBJECT: STORMWATER RATE BY -LAW AND UTILITY
IMPLEMENTATION
RECOMMENDATION:
1. That the ten (10) year capital and operating forecast for the stormwater
management program be approved as outlined in staff report DTS -10-
094 , subject to revision through the annual budget process;
2. That the stormwater rate schedule as specified in Appendix B of staff
report DTS -10 -094 be approved and come into effect on January 1,
2011;
3. That the by -law enacting the stormwater rate be approved as an
amendment to the fees and charges by -law;
4. That a reduction in the following base budgets be implemented as of
fiscal 2011 resulting from a shift to a stormwater utility model:
Tax supported operating budget of $6,204,228
Water utility of $256,677
Sanitary utility of $259,414
Gas utility of $278,184
Federal gas tax revenue of $1,908,000
5. That staff provide a report related to a stormwater rate credit policy for
Council's consideration prior to January 1, 2013;
6. That staff report to Council prior to January 1, 2013 on the viability of
transitioning non - residential properties from the approved "tiered flat
fee" stormwater rate structure to a method where these properties are
9 -1
charged according to their actual measured impervious area;
7. That one (1) engineering manager position (full- time), one (1) operations
supervisor (full- time), one (1) engineering project manager position
(full- time), and one (1) revenue analyst position (full -time) be hired
beginning in June 2010 so as to enable the implementation of the
stormwater utility and advancing related stormwater projects and
further;
8. That $100,000 be transferred from the Grand River Erosion Control
project (account numbers 11619 and 7367) and that $129,000 be
transferred from the Victoria Park Lake Environmental Assessment
project (account numbers 52000039 and 207) into the Stormwater Utility
Implementation Plan (account number 701204027);
EXECUTIVE SUMMARY:
Staff are recommending that a stormwater rate structure be implemented on January 1, 2011.
The rate methodology provides for a fair and equitable approach allocated costs associated with
stormwater management to all property owners in the City of Kitchener.
The funding would support the proposed 10 year capital and operating forecast for stormwater
programming based on the concept of attaining a sustainable level of service.
A rationalized fee structure has been developed and is presented for Council's consideration,
along with the enacting by -law for implementation of the stormwater rate starting on January 1,
2011.
BACKGROUND:
In November 2004, Council directed staff to proceed with undertaking a Stormwater
Management Program and Funding Review Study (Study) collaboratively with the City of
Waterloo as part of the Shared Services Initiative. The purpose was to identify the City's current
level of service, compare this to the legislated requirements and guidelines, develop a
suggested level of service, and to evaluate appropriate funding mechanisms to support the
stormwater program needs. The Study recommended that a utility structure and user rate
approach be implemented in order to fully fund stormwater management programming within
the City of Kitchener.
Council approved the principle of shifting stormwater management programming from the tax
base to a rate based approach on January 18, 2010 (DTS Report 10 -016 and 10 -023). As well,
Council approved an annual sustainable level of service for stormwater management of
$9,910,590 (2007) and directed staff to present additional information on a preferred rate
methodology for their consideration. On February 8, 2010, Council approved the "tiered flat fee"
stormwater rate model as the basis to charge property owners for stormwater programming.
Council directed staff to present a stormwater rate and utility implementation plan and present
recommendations for consideration on or before May 31, 2010.
9 -2
REPORT:
The stormwater rate and utility implementation plan includes the stormwater programming 10
year operating and capital forecast, the stormwater rate schedule, the enabling by -law, staffing
requirements for implementation in 2010 and a summary of consultation process with "places of
worship ", the Waterloo Region District School Board and the Waterloo Region Separate School
Board.
Stormwater Program - 10 Year Capital and Operating Forecast
As per direction from Council, the ten (10) year capital and operating forecast for the stormwater
management program has been recently updated to reflect current program costs as the original
study was based on 2007 program information. Table 1 compares 2007 program costs with the
2010 updated information. The current service level estimate has been revised from $5.8M to
$8.9M annually. Based on the approved Council increase in the service level of $4.1M, the
sustainable level of service has been revised from $9.9M to $13.OM annually,
Table 1 — Stormwater Program Comparison of 2007 Estimated Expenditures and 2010 Updated
Expenditures
The updated program costs of $13M includes inflationary adjustments, refined construction cost
estimates not originally considered in the 2007 Feasibility Study, and the inclusion of
administrative and support service overheads. The City allocates administrative overheads to
operating units to better reflect the full cost of providing service and to assist in setting
appropriate user fees and charges. To be consistent, in developing the operating projections for
the stormwater utility, staff have allocated a reasonable share of corporate overheads to the
Utility consistent with the approach for other enterprises.
These allocations do not reflect new costs to the rate payer; rather they are reflected in the shift
from the tax or utility base and the corresponding reduction in the property tax rates and other
utility rates. These overheads amount to approximately $1 million and pertain to the following
existing functions: billing, collecting, customer service, facilities management, dispatch,
9 -3
Current Service Level
Council Approved
Sustainable Service
for Stormwater
Service Level
Level for Stormwater
Management
Increase
Management
Programming
(January 18th, 2010)
Programming
(A)
(B)
(A + B)
Stormwater Management
Feasibility Study based on
$5.8M
$4.1 M
$9.9M
2007 financial information
Updated stormwater
programming based on
$8.9M
$4.1 M
$13.01VI
2010 financial information
Change due to Program
$3.1 M
$0.0M
$3.1 M
Costs Adjustments
The updated program costs of $13M includes inflationary adjustments, refined construction cost
estimates not originally considered in the 2007 Feasibility Study, and the inclusion of
administrative and support service overheads. The City allocates administrative overheads to
operating units to better reflect the full cost of providing service and to assist in setting
appropriate user fees and charges. To be consistent, in developing the operating projections for
the stormwater utility, staff have allocated a reasonable share of corporate overheads to the
Utility consistent with the approach for other enterprises.
These allocations do not reflect new costs to the rate payer; rather they are reflected in the shift
from the tax or utility base and the corresponding reduction in the property tax rates and other
utility rates. These overheads amount to approximately $1 million and pertain to the following
existing functions: billing, collecting, customer service, facilities management, dispatch,
9 -3
engineering management, human resources, finance /accounting, purchasing, information
technology, etc.
It should be noted that the forecast takes into consideration the proposed remediation and
upstream stormwater management works, identified in the Victoria Park Lake Class EA Study
Report, starting in 2011 with completion in 2015 and ensures that this remains a priority project
for Council. Refer to Appendix A which provides details associated with the revised annual
program forecast over the next ten (10) years. The forecast will be reviewed as part of the
annual budget process by Council.
Stormwater Rate Schedule
In November 2004, Council directed staff to proceed with undertaking a Stormwater
Management Program and Funding Review Study. On October 5t", 2009, Council received the
Stormwater Management Program and Funding Review (DTS Report 09 -042) and concluded
that an equitable and defendable rate structure for stormwater is feasible.
A rational nexus was established between the amount of the user fee and the cost of the service
being provided — in that the more impervious area an individual property owner has, the greater
the amount of runoff and pollutant loading from the property and, consequently, the greater the
demand on the City's stormwater management system, either for flood control or water quality
treatment purposes.
Under the authority of sections 9, 10 and 11 and part XII of the Municipal Act, 2001, the City has
the authority to pass a "fees and charges" by -law for the purposes of funding stormwater
management. A user fee may be charged to cover the cost of a service and a key component is
to ensure that there is a nexus between the amount of the user fee and the cost of the service
being provided, such that it is not categorized as a tax.
On January 18, 2010, Council approved the principle of shifting stormwater management
programming from the tax base to a rate based approach. On February 8, 2010, Council
approved the "tiered flat fee" stormwater rate model and directed staff to review the proposed
rate categories structure, so as to ensure that the principles of fairness and equity are achieved.
This "tiered flat fee" structure is consistent with what is being considered by the City of
Waterloo.
The proposed rate structure would enable an approximate 17.9% shift in overall stormwater
program costs from residential users to the non - residential sector, where both taxable non-
residential and tax - exempt non - residential properties would be paying their fair share of
stormwater services, due to the amount of stormwater run -off generated from their properties.
It ensured that stormwater program costs are equitably and fairly distributed amongst four (4)
broad property classes in accordance with the recommendations of the 2007 Feasibility Study
(i.e. 42.4% residential single detached, 13.8% multi - residential, 33.9% taxable non - residential,
and 9.9% tax - exempt non - residential).
9 -4
Figure #1 — Existing Distribution of Stormwater Program Costs (Tax Levy Model)
Figure #2 — Proposed Distribution of Stormwater Program Costs (Tiered Flat Fee Model)
Staff have now completed further analysis and details are provided in the attached technical
memo from AECOM dated May 5, 2010 (refer to Appendix D). The preferred option is made up
of thirteen (13) rate tiers and each is assigned a unique Rate Code. The stormwater rate
schedule is shown in Appendix B. The rate schedule also reflects the updated 10 year
stormwater program capital and operating forecast of $13.OM annually, less $1.44M of federal
gas tax funding, and as such the rate structure is calculated using $11.56M annually.
The stormwater rate schedule includes three tiers for residential single- detached homes (small,
medium, large). The rate a single- detached residential property owner pays will be assessed
9 -5
based on the building footprint of the property, from the City's existing geographical information
system (GIS) database.
About 80% of the single- detached residential properties in the City will be charged according to
Rate Code 2 at $10.50 per month or $126.00 per year; with the remaining 20% being split
between "small" and "large" properties (Rate Codes 1 and 3 respectively in Table 2).
Table 2 — Residential Stormwater Charges
Type
Number of
Monthly Charge
Annual Charge
Number of
Code
Description
Basis for Charge
Dwelling Units
per Property �
per Property '
Customer S2
Code
Detached homes with building footprint
Dwelling Units
per Property
per Property
Customer S2
1
Residential Single Detached Small
z
size of 105 M2 less
1
$6.30
$76
4.180
5
Residential Condominium
Detached homes with building footprint
1
$4.20
$50
8,840
2
Residential Single Detached Medium
size between 106 -236 m z
1
$10.50
$126
33.450
6
Multi- Residential (2 -5 Units)
Detached homes with building footprint
Triplex
$12.60
$151
260
3
Residential Single Detached Large
size of 237 M2 or more
1
$13.80
$166
4,180
Notes:
1. Monthly stormwater rate charge per propertyto generate $11.56M/yr. Federal gas tax revenue contribution is $1 .441vyr.
Assumes 95% collection rate. Al charges rounded to the nearest 300.
2. Approximate count as of May 5, 2010.
For other multi - residential properties the charge would be based on a fraction of the base unit
calculation for an "average" single- detached residential property and is charged on a per
dwelling unit basis, such as townhouses, condominiums, duplexes, triplexes, four - plexes, five -
plexes, and apartment buildings (refer to Table 3).
Table 3 — Multi -Unit Residential Stormwater Charges
Type
Number of
Monthly Charge
Annual Charge
Number of
Description
Basis for Charge
'
'
Code
Dwelling Units
per Property
per Property
Customer S2
4
Residential Townhouse
Per property(per Tax Roll ID number)
1
$7.50
$90
6.390
5
Residential Condominium
Per property(per Tax Roll ID number)
1
$4.20
$50
8,840
Duplex
$8.40
$101
1,400
6
Multi- Residential (2 -5 Units)
Per building
Triplex
$12.60
$151
260
Four -plex
$16.80
$202
150
Five -plex
$21.00
$252
30
Charge = (# units)
Charge = (# units)
7
Multi- Residential ( >5 Units)
Per property (according to number of
varies
x ($2.10 /month)
x ($25.20 /year)
1.190
dwelling units)
See Note 3
See Note 3
Notes:
1. Monthly sto rmwate r rate charge per property to generate $11.56M/yr. Federal gas tax revenue contribution is $1.441VI/yr.
Assumes 95% collection rate. All charges rounded to the nearest 30¢.
2. Approximate count as of May5, 2010.
3. Example: 10 -unit apt. = $21.00 /mo ($252 /yr); 25 -unit apt. = $52.50 /mo ($630 /yr); 100 -unit apt. = $210.00 /mo ($2,520 /yr).
Commercial, industrial and tax - exempt properties have a high degree of variation in the amount
of impervious area, due to their property size and land use. All non - residential properties would
be charged based on actual measured impervious area (i.e. $10.50 per month per 259 m2 of
impervious area) and the rate charged to the property would be based on one of six (6) rate
categories according to Rate Codes 8 -13 in the rate schedule (refer to Table 4).
9 -6
Table 4 — Non - Residential Stormwater Charges
Type
Code
Description
Basis for Charge
Number of
Dwelling nits
g
Monthly Charge
per Property
Annual Charge
per Property
Number of
Customer z
Non - Residential Smallest
26-1,051 m2 of impervious area
n/a
$20.10
$241
1.080
9
Non - Residential Small
1,052 - 1,640 m2ofimpervious area
$53.70
$644
300
10
Non - Residential Medium -Low
1.641 -7,676 m2ofimpervious area
$140.70
$1,688
950
11
Non - Residential Medium -High
7,677 - 16,324 m2 of impervious area
$410.70
$4,928
200
12
Non - Residential Large
116,325 - 39,034m2ofimperviousarea
$995.40
1 $11,945
1 110
13
Non - Residential Largest
139,035 m2or greater of impervious area
$2,136.90
$25,643
40
Notes:
1. Monthly stormwater rate charge per propertyto generate $11.56Mtyr. Federal gas tax revenue contribution is $1 .44Myr.
Assumes 95% collection rate. All charges rounded to the nearest300.
2. Approximate count as of May 5, 2010.
3. Non - Residential tiers (Billing Codes 8 -13) include both Taxable and Tax - Exempt properties.
4. Non - Residential properties with less than 26.0 sq. m. of impervious area are not charged.
Tax - exempt properties would also be charged the stormwater rate according Rate Codes 8 -13
in the rate schedule. Tax exempt properties include governmental parcels (e.g. municipal,
regional, provincial, and federal buildings) as well as institutional parcels (e.g. schools,
hospitals, and places of worship) and other charitable organizations that are registered with the
Canada Revenue Agency and therefore exempt from property taxation under the Income Tax
Act.
It is recommended that the rate schedule as proposed in AECOM's May 5th technical memo be
adopted by Council (refer to Appendix D) and enacted through the stormwater charges by -law
(attached in Appendix C).
FINANCIAL IMPLICATIONS:
Shift from Tax Levy to Rate Base
A reduction in the following base budgets can be implemented as of fiscal 2011 resulting from a
shift to a storm utility model:
• Tax supported operating budget of $6,204,228
• Water utility of $256,677
• Sanitary utility of $259,414
• Gas utility of $278,184
• Federal gas tax revenue of $1,908,000
These shifts include both the operating and capital costs relating to storm activities. These costs
will be removed from the tax supported budget and transferred to the new budget for the
Stormwater Utility. These costs include operational costs such as preventive and reactive
maintenance, spill response, stormwater monitoring, operation and maintenance costs,
administration and environmental compliance costs. Capital costs include system rehabilitation
projects, accelerated infrastructure renewal projects, software upgrades and CMF related
expenses.
The shift from the tax supported operating budget will be partially offset by stormwater utility
internal recoveries and eligible grants to places of worship.
9 -7
The revised estimation in the reduction of the 2011 tax levy for an average single- detached
residential property owner is approximately $5.50 per month or around $66 for the year
(pending Council approval). The stormwater monthly rate for the average single- detached
residential property is $10.50 or $126.00 per year (an increase of about $5.00 a month or $60 a
year).
Staffing Requirements
The City of Kitchener current stormwater management (SWM) program consists of four general
components — operation and maintenance, environmental compliance, capital improvement
projects, and planning and management. During 2010, resources will required to be deployed in
order to advance the delivery of certain components of the 2011 stormwater management
program, which are listed below, in order of priority:
• Oversight of the stormwater utility implementation activities, development of
supporting policies and business practices, and reporting to Council as needed,
• Revenue and collections business functions including rate payer liaison and
public communications in order to ensure that the stormwater billing is
implemented on January 1, 2011,
• Victoria Park Lake remediation relating to the dredging and reconfiguration of the
lake and upstream water quality facilities (DTS Report 09 -096) in order to begin
construction in 2011,
• Stormwater pond retrofits for water quality improvements which includes detailed
design, tender document preparation, construction and commissioning of new
facilities in order to meet infrastructure stimulus funding deadlines and other
ongoing pond retrofits,
• Development of operation and maintenance programs, facility monitoring and
environmental compliance, including program schedules and delivery modes,
• Develop a business plan to coordinate stormwater management and wastewater
services that are currently spread across multiple departments.
In summary, it is recommended that one (1) stormwater utility manager position (full- time), one
(1) operations supervisor (full- time), one (1) engineering project manager position (full- time),
and one (1) revenue analyst position (full -time) be approved so as to enable the implementation
of the stormwater rate and related stormwater programming in 2010.
In light of these program needs Table 5 identifies a requirement to fund a stormwater utility staff
complement of approximately $229,000 beginning in June 2010 (seven months only). These
expenditures would be funded from existing stormwater related capital projects and would be
transferred to the Stormwater utility implementation capital account.
It is also recommended that $100,000 be transferred from the Grand River Erosion Control
project (account numbers 11619 and 7367) and that $129,000 be transferred from the Victoria
Park Lake Environmental Assessment project (account numbers 52000039 and 207) into the
Stormwater Utility Implementation Plan (account number 701204027).
Table 5 – Stormwater Utility Staff Requirements for 2010 (7 months only)
COMMUNICATIONS:
Communication Plan — Stormwater Rate Implementation
A communications plan has been developed and will have four (4) phases through the
implementation of the stormwater rate. The first phase is an additional consultation phase
during which staff solicits feedback from the Waterloo Region District School Board and the
Waterloo Region Catholic School Board and "places of worship" sector, as directed by Council.
An open house for the "places of worship" sector provides an opportunity for stakeholders to get
more information about the rate and how it may affect them; to provide feedback and influence
how the rate could be implemented; and to share perspectives the City has not considered.
Refer to the next section for more details on the consultation process — tax exempt sector.
The second phase will be getting specific details of the rate out to the public and how and when
it will be implemented. It will occur between September and December 2010 and educate
property owners about what the rate is, how it's calculated, why we switched, when it will take
effect. Staff will also be educated about the changes in order for them to effectively answer the
public's questions.
The third phase includes a public education sustainment effort, once the rate is actually
implemented in January 2011. It will provide key messaging and frequently asked questions for
staff that will start receiving calls from customers who didn't know this was taking place until it
appeared on their bill. It is planned that stormwater rate will appear as a separate charge on the
monthly water and natural gas bill for Kitchener Utilities customers.
There will be a public awareness and education component that will run throughout all phases
that will build on the work that started in 2007, educating residents about stormwater — what it is,
how it is managed, why they should care and how they can reduce the amount of stormwater
they contribute to the system. This phase started in March 2010 and will be ongoing until at
least March 2011.
Consultation Process - Tax Exempt Sector
9 -9
2010 Funding
Position Description
Requirement
Notes
Oversee and manage stormwater utility program, including the
implementation of the stormwater rate, policy development,
Stormwater Utility
annual stormwater audit, monitoring of the stormwater capital
Manager (Engineering)
$ 60,202.61
and operating budgets.
Design and manage stormwater utility capital projects,
Engineering Project
including Victoria Park Lake remediation, stormwater pond
Manager
$ 50,383.95
retrofits (ISF related) and drainage improvements.
Supervise the delivery of maintenance and operations of
Stormwater Operations
stormwater facilities and implement best management
Supervisor
$ 50,383.95
practices
To address customer inquires related to stormwater billing
Revenue Analyst
$ 29,866.67
and collections processes.
Sub -total =
$ 190,837.17
20% Contingency =
$ 38,167.43
Total =
$ 229,004.61
COMMUNICATIONS:
Communication Plan — Stormwater Rate Implementation
A communications plan has been developed and will have four (4) phases through the
implementation of the stormwater rate. The first phase is an additional consultation phase
during which staff solicits feedback from the Waterloo Region District School Board and the
Waterloo Region Catholic School Board and "places of worship" sector, as directed by Council.
An open house for the "places of worship" sector provides an opportunity for stakeholders to get
more information about the rate and how it may affect them; to provide feedback and influence
how the rate could be implemented; and to share perspectives the City has not considered.
Refer to the next section for more details on the consultation process — tax exempt sector.
The second phase will be getting specific details of the rate out to the public and how and when
it will be implemented. It will occur between September and December 2010 and educate
property owners about what the rate is, how it's calculated, why we switched, when it will take
effect. Staff will also be educated about the changes in order for them to effectively answer the
public's questions.
The third phase includes a public education sustainment effort, once the rate is actually
implemented in January 2011. It will provide key messaging and frequently asked questions for
staff that will start receiving calls from customers who didn't know this was taking place until it
appeared on their bill. It is planned that stormwater rate will appear as a separate charge on the
monthly water and natural gas bill for Kitchener Utilities customers.
There will be a public awareness and education component that will run throughout all phases
that will build on the work that started in 2007, educating residents about stormwater — what it is,
how it is managed, why they should care and how they can reduce the amount of stormwater
they contribute to the system. This phase started in March 2010 and will be ongoing until at
least March 2011.
Consultation Process - Tax Exempt Sector
9 -9
As directed by Council, staff have initiated additional public consultation with the school boards
and the "places of worship" during March, April and May 2010.
Both the Waterloo Region District School Board and the Waterloo Region Catholic School
Board have raised concerns as to a municipality's authority to apply stormwater rates to their
properties. As this relates to a legal matter, staff will address it in caucus with Council. In the
meantime, information about the proposed rate structure has been provided to the Boards for
their consideration and it is recommended that further dialogue with Boards be pursued in order
to resolve this matter.
A special open house for "places of worship" was held on April 14th at the Downtown
Community Centre. The open house provided information about the draft stormwater rate
schedule. Letters were issued to 171 "place of worship" properties on March 29th, inviting
property owners to attend the open house and 33 people attended, representing 25 "places of
worship." Feedback forms were provided and attendees were encouraged to return them by
April 28th. Additional letters were issued on April 18th, including a copy of their estimated rate
cost (a property SWM rate fact sheet), and also informing them that the stormwater rate
implementation report would be presented at the May 10th Financial and Corporate Services
Committee meeting. At the time of writing this report, approximately ten (10) feedback forms
have been submitted, along with 76 form letters from Forest Hill United Church (only one copy
attached) and a series of other inquiries were received by the City. These are included in
Appendix E of this report for Council's information.
It is apparent that there are concerns around the financial impact that the rate will have on the
congregations at these "places of worship ". Representatives from the "places of worship" sector
have reiterated that they provide certain community benefits, such as social support programs.
Most feedback either sought to reduce the stormwater charge, phase in the charge or eliminate
the charge completely.
Staff's recommendation to charge all property owners for their fair and equitable share of
stormwater programming is still a premise that should continue to be supported. As such, it is
recommended that the "places of worship" sector be charged the appropriate rate based on
measured impervious area according to the approved rate schedule.
Staff are not recommending an exemption exclusively for the "places of worship" from paying
the stormwater charge, as this would not be fair to other property owners in different rate
categories. The implication is that funding not generated from the "places of worship" sector
would have to be reallocated to the other rate categories, thus increasing the rates in those
other categories. Essentially, the utility would be viewed as subsidizing certain users within a
specific rate category, and would make the rate structure susceptible to legal challenges by
other users.
On May 3rd, Council directed staff to issue a written notification to all charitable organizations
such that they are aware of potential effects that the proposed stormwater rate may have on
their properties. At the time of writing this report letters were being prepared to be issued on or
before May 7th informing them of the special Financial and Corporate Services Committee
meeting to be held on May 171H
Stormwater Advisory Committee
In early 2005, a Stormwater Advisory Committee (SWAC) was formed consisting of various
stakeholders from across the Cities of Kitchener and Waterloo. Representation has included the
9 -10
school boards and universities, the Chamber of Commerce, other business representation and
members of the public. Eight meetings over the last 4 years have been held with the Committee,
as well as individual meetings with the various stakeholders to identify issues and concerns.
The project team circulated the Draft Final Report to the SWAC members on October 22, 2008
for their review and comments. At the December 4th, 2008 SWAC meeting, these comments
were addressed, the final study report was presented, and the consultation process formally
concluded. Additionally over the past eight (8) months, staff have also been providing e -mail
updates to the members of Stormwater Advisory Committee as reports go forward to Council on
matters related to the stormwater rate.
Staff have met with the Regional and Municipal Affairs Committee of the Greater Kitchener -
Waterloo Chamber of Commerce on February 91h and April 24th, 2010 to review the proposed
stormwater rate methodology and the draft rate schedule. A concern was raised about the lack
of credit policy for non - residential properties that have installed on -site stormwater management
facilities or have other best management practices. Staff indicated that typically non - residential
property owners would apply for the stormwater rate credit, certifying that their facilities are in
good operating condition and would not be eligible for more than 50% of their monthly charge.
Staff indicated that a credit policy is not being implemented on January 1, 2011 but that it is
intended to develop a credit policy within two (2) years.
CONCLUSION:
The purpose of the Stormwater Management Program and Funding Review Study has
demonstrated and concluded that an equitable and defendable rate structure for stormwater is
feasible.
A "tiered flat fee" method has been used to derive a stormwater rate structure which is
defensible, fair and equitable. This will provide a sustainable level of funding to enable the City
to meet its environmental and legislative obligations regarding stormwater management.
In the long term, the current rate structure can enable a smooth transition from the approved
"tiered flat fee" stormwater rate structure to a method where non - residential properties would be
charged according to their actual measured impervious area, if so directed by Council in the
future. Staff recommend returning to this matter in approximately two (2) years and presenting a
report to Council for their consideration.
It is proposed that the stormwater rate by -law and its accompanying rate schedule be adopted
such that the applicable stormwater rate can be applied to all City of Kitchener property owners
starting on January 1, 2011.
ACKNOWLEDGED BY: Jeff Willmer, General Manager, Development and Technical Services
List of Attachments:
Appendix A — Stormwater Program - 10 Year Capital and Operating Forecast (2011 to 2020)
Appendix B - Stormwater Rate Schedule `A' to City By -Law (May 10, 2010)
Appendix C - Stormwater Charge Bylaw
Appendix D — AECOM Technical Memo on Stormwater Rate Scenario Analysis (May 5, 2010)
Appendix E — Feedback from Places of Worship Sector
9 -11
a1
C
R
d
M
O
C
(,d
(a
S
R
U
GC L
4)
CR L
O V
L
IL
L �
N p
3 *'
� U
T
T
O
N
Q
X_
C
N
Q
S
Q
9 -12
W
O
r-
r-
N
@
W
O
OOD
ll�
a0
V
(
C O v
C r d
to
01
(f1
01
01
V
(f1
N
O
f1
CN
(f1
cli
(f1
41)
rl
00
O
O
M
O
N O M 7
O O O O
0 0 0 M 01
O O O
a
O
T N (n W
M 7 OD L
0 0 7 V
O O M M
r T i& r (f1
(n T D) (D
O (D to
0 7 V
O
N
O
r OD M lf)
(n a2 O N
(D O OD a
N A N O
O T O �
r N Cl) M
(D T r-
7 T (f1
0)
a
N
co 7EFT 01
NN
66, � HJ ON
� co rr- fD
ON
Cl) O
N
M
LL
�
UJ �
ui
ui
N N (f) 0)
O O (f) N
M O O O) N
O OD W
Cl)
01
(f) M T 01
(D D) M V
O O
O O W N
(D O EA W N
Ljl� O (D N
B co W
r r a
N
rl
O
OD N r 0)
OD W D) 0
(D M r N
N M N 0)
CO r M O
M M O W
(t) O fD
co M N
ro
(D
N
>-
N M W
N Ui N
61) (n ldJ (f)
613 6s
Tn T r M
N (D 01
M (D O
613 613
ro
LL
ER fPr
U3 H3 fPr
fPr
!fl
M 7 N
O O M M
(D O O OD V
O W
W
OD
N
W O N N
O) (D M 01
O O
0 0 r f`
D) O O T
W 0 0 0 0)
(D
(f) 'D fD
r (D M
01
O
T r (D (f)
N r OD OD
(D OD (D O
N N N ro
(D OD (n M W
(D D) 7 OD M
M O O
(n r Cl)
(f)
M
N
N co r-
EF CF
UT H
� N
� 7 (D W
� � UOco
(D O
N
v
LL
N
N
ui
7 T M M
O OLf) N
0 0 0 0 0
O r r-
O
r M r r-
N 7 0rl
O O co Cl)
O O D) 01
co O O (n ro
(f) O O D) V
T) OD CO
r O ro
Cl)
O
O
r N 0 a
(n r r O
(D O (n O
N T N f`
(n T (D OD r
7 ap W cD O
(D T r-
7 (n 01
N
lf1
N
>-
T UJ f`
N N
UJ H3
7 ap NFT (D N
N 7 W
Cl) ON
N
N
LL
EA fPr
EA EA fPr
N
OD M W
O O O O
r O O (D CO
O CO Cl)
7 0 7 01
7 7 T 01
O O W W
O O T
N O O (D 0)
7 0 0 7 W
(f) N r
r T ro
V
01
(D
v r v 0
O O (n N
Cl) M 0 M
(n N f`
O
O) (D (D N
O (D
N N (f)
U3 U3
O T (n 7 N
f`
7 N 7EFJ
T M V
co
(f1
W
N
i
;; CO
�
�
(D
U3 ON
(D a
LL
fA
OD N N CO
O O (D (D
0 0 0 0
O N N
Cl) Cl) 7 G
7 (f) (O N
0 0 7 V
0 0 7 8
(n 0 0 7 0
(n O O (A
T) T to
r r v
N
(f1
(f)
co N co 01
O T It (f1
N N r O N
O M V
M (D (f) V
O N
N O N*
U3 U3
O (D (A co (f1
(D 7�� Cl)
T T N
f`
Cl)
N
U3 �
NN
6 6
UJ 1& ON
61) 61) 6
O
LL
�
N OD (f) N
0 CD 7 V
Cl) 0 0 7 (D
O r d
Cl)
V
T D) 7 lf)
N r N N
O O CO CO
O O rrl
r O O a0 (f1
N O O T V
(R CO ro
r OD (f1
CO
O
O
7 r co (f1
r (n 7 r-
O D) co N
N OD N Cl)
(n r (D N O
N O CO T ro
M (f) 0)
T M O
ro
01
N
-- 61) 61) V
6s
Ef3 66, U3 N Lr)
T T � � �
i&�
� � ON
(D
LL
�
O N OD O
O O co Cl)
O O O co Cl)
O N N
01
fy
O It to
r N N-
0 0 7 V
O O O O
M O EA (n V
O O co V
(A OD CO
r 7 N
r-
ro
O
(D. M M O')
(n M O
0 6 M N
r N
W N 7 V
(M D r O
7 OD M
T r 0)
N
(M f1
N
M
i& EE C
EN A
UN 3
66, 6s
lM f1
� 4 � O61F1
� 6s
M
LL
N
N
ui
7 Cl (f1
O O N N
O O O N N
O co Cl)
N
N
OD It 7 fD
OD r (f) r
O O r f`
O O M M
O O O 7 a
O O O O O
(A M ro
r (D M
fD
01
O
O OD CO Cl)
(D 7 N M
O OD N O
N (D N G
r (f) M r N
(f) N O r (D
N T V
T (D r-
01
r-
N
OD EiJ CO Cl)
CF
Ef3 Itt U3
61)
0 N N 0 0
�� �
�
M OD W m
O O O O
O O O (f) N
O (f) N
01
OD O T O
(D 7 T N
O O N N
O O r r-
O O O M Cl)
7 0 0 N (D
O r d
(n C\! rl
Cl)
M
(D 7 7 (f)
0 M T O
CO OD 7 0 (f1
r (n N
a
O
N
CD 7 T (D
ap N
N (f) N O
66, 7
co (f) O (D N
r T 700
co 7 W
O
O
EFT
EFT
v
LL
�6
V
ui
Q
Q
Q
Q
O
O
O
O
H
H
H
H
N
N
N
N
N
U
N
O
co
N
O
R
o
()
>
Q
V
O
.�.�
Q
=
=
.°
L O N
O O
>
a d n
OY
CL
'
a co
o °
°
(o
>
D
a
C
cOY C
ci ay O
_
7 -°
N lz
OY
fd C
C
L a O
. r
.O >_
Q
tr
_ N
_
N
3
L
= E
(6
Z
° °
C —
J
U)
:°.U) a cc: 0
m Occ:
Q
N
>
M
C
H
O
w
V
C7
F-
9 -12
Appendix B — Stormwater Charges - Schedule `A' of City By -Law (May 10, 2010)
Type
Description
Basis for Charge
Number of
Monthly Charge
Annual Charge
Code
Dwelling Units
per Property'
per Property'
Detached homes with building footprint
1
Residential Single Detached Small
size of 105 m or less
1
$6.30
$76
Detached homes with building footprint
2
Residential Single Detached Medium
1
$10.50
$126
size between 106 -236 m
3
Residential Single Detached Large
Detached homes with building footprint
size of 237 m or more
1
$13.80
$166
4
Residential Townhouse
Per property (per Tax Roll ID number)
1
$7.50
$90
5
Residential Condominium
Per property (per Tax Roll ID number)
1
$4.20
$50
Duplex
$8.40
$101
6
Multi- Residential (2 -5 Units)
Per building
Triplex
$12.60
$151
Four lex
$16.80
$202
Five lex
$21.00
$252
Per property (according to number of
Charge = (# units)
Charge = (# units)
7
Multi- Residential ( >5 Units)
dwelling units)
varies
x ($2.10 /month)
x ($25.20 /year)
See Note 2
See Note 2
8
Non - Residential Smallest
26-1,051 m2 of impervious area
n a
$20.10
$241
9
Non - Residential Small
1,052 - 1,640 m2 of impervious area
$53.70
$644
10
Non - Residential Medium -Low
1,641 - 7,676 m2 of impervious area
$140.70
$1,688
11
Non - Residential Medium -High
7,677 - 16,324 m2 of impervious area
$410.70
$4,928
12
Non - Residential Large
16,325 - 39,034 m2 of impervious area
$995.40
$11,945
13
Non - Residential Largest
39,035 m2 or greater of impervious area
$2,136.90
$25,643
Notes:
1. Monthly stormwater rate charge per property to generate $11.56M /yr.
Assumes 95% collection rate. All charges rounded to the nearest 300.
2. Example: 10 -unit apt. = $21.00 /mo ($252/yr); 25 -unit apt. = $52.50/mo ($630 /yr); 100 -unit apt. = $210.00 /mo ($2,520/yr).
3. Non - Residential tiers (Billing Codes 8 -13) include both Taxable and Tax - Exempt properties.
4. Non - Residential properties with less than 26.0 sq. m. of impervious area are not charged.
9 -13
BY -LAW NUMBER
OF THE
CORPORATION OF THE CITY OF KITCHENER
(Being a by -law to levy and implement a Storm Water Charge)
WHEREAS municipalities are authorized to levy fees and charges
pertaining to a storm water system pursuant to sections 9, 10, 11 and 391 of the
Municipal Act;
AND WHEREAS City desires to create a separate storm water utility to
fund the operation, maintenance and capital projects pertaining to storm water
management;
AND WHEREAS the creation of a separate storm water charge to fund
such storm water utility will bring transparency to the actual costs of providing
and maintaining the extensive storm water management infrastructure within the
City;
AND WHEREAS effective January 1, 2011, the Corporation of the City of
Kitchener desires to impose a storm water charge on property owners;
AND WHEREAS in establishing the storm water charge rate structure in
this by -law, Council has had regard to differentiating between classes of
residential users based upon the approximate impervious areas of each
residential class;
AND WHEREAS in establishing the storm water charge rate structure in
the by -law, Council has had regard to differentiating between non - residential
users based upon the actual impervious areas of each non - residential property;
9 -14
NOW THEREFORE the Council of The Corporation of the City of
Kitchener enacts as follows:
1. Effected Lands — within City of Kitchener:
A storm water charge as set forth in Schedule `A' hereto is hereby
imposed upon all property owners within the City.
2. Rate structure — General Principles:
The classes and rate of storm water charge set out in schedule `A' shall
generally be based upon the impervious area of the property and its land
use.
3. Manner of invoicing:
Storm water charges shall be invoiced in the same manner as other
Kitchener utility charges and shall be itemized on the same monthly
invoice.
4. Amount owing added to tax roll:
Pursuant to section 398 (2) of the Municipal Act, any outstanding monies
owed with respect to storm water charges may be added to the tax roll of
the property in respect of the money is owed and shall collect them in the
same manner as municipal taxes.
5. Non - residential User Storm Water Charge Credit Policy:
Non - residential users may qualify for storm water charge credits where
such users can clearly demonstrate to the City that the user's storm water
facilities or best management practices provide the City with cost savings
that the City would otherwise incur as part of its efforts to manage storm
water. Qualifying criteria and the application process are outlined in
Schedule "B' hereto.
6. Amendments to Schedule `A':
A review of the rates and classes itemized in Schedule `A' shall occur
every year by council and may be changed on an annual basis without an
amendment to this by -law.
9 -15
7. Amendments to Schedule 'B':
A review of the non - residential user storm water charge credit policy and
its associated qualifying criteria and application process as outlined in
Schedule `B', shall occur at least once a year and may be changed on an
annual basis without and amendment to this by -law.
PASSED at the Council Chambers in the City of Kitchener this
day of 2010
Mayor
Clerk
9 -16
Schedule A — Storm Water Charges
9 -17
Schedule B — Non - residential User Storm Water Charge Credit Policy
Credit policy will be in effect starting on January 1, 2013.
9 -18
AXOM
Memorandum
AECOM
50 Sportsworld Crossing Road, Unit 290 519.650.5313 tel
Kitchener, ON, Canada N2P OA4 519.650.3424 fax
www.aecom.com
To Grant Murphy, City of Kitchener Page 1
cc Steve Sedgwick, CDM
Don Stone, CDM
Subject City of Kitchener Stormwater Rate Implementation
From Mike Gregory, AECOM
Date May 5, 2010 Project Number 60148170
The purpose of this memo is to summarize the rate analysis and development of the recommended
rate schedule for the City's stormwater rate implementation project.
Residential Parcel Analysis
A stormwater rate charges customers a fee according to the runoff generated by the property owned
or used. Customer properties are identified and characterized with regard to the stormwater
management (SWM) impact through a land use analysis of parcels. A parcel refers to any contiguous
property, lot, or land tract under single ownership. The parcel characteristic that most affects the
quantity and quality of runoff is impervious area, which refers to surface cover that is highly resistant
to the infiltration of water (e.g., building rooftops, paved areas, and compacted gravel).
The parcel analysis from the Feasibility Study was revisited and updated based on new information.
Table 1 shows the revised Table 4 -4a (page 33) of the 2008 Feasibility Study report (Kitchener -
Waterloo Stormwater Management Program and Funding Review: Stormwater Funding Analysis,
Final Report; AECOM, October 2008).
Table 1 - Updated Parcel Analysis
Parcel
Type
Number
of Parcels
Dwelling
Units
Est'd Impervious Area (m)
SFU
Factor
Tiered SFU Distribution
Total
Avg /d.u.
Count
%
Single Detached (small)
4,181
4,181
702,374
168
0.6
2,508
3.0%
Single Detached (medium)
33,446
33,446
8,662,618
259
1.0
33,446
40.3%
Single Detached (large)
4,181
4,181
1,438,195
344
1.3
5,435
6.5%
Duplex
1,396
2,792
299,219
107
0.4
1,117
1.3%
Townhouse
6,393
6,393
1,238,963
194
0.7
4,475
5.4%
Residential Condominium
8,838
8,838
979,957
111
0.4
3,535
4.3%
Multi- Residential (3 -5 units)
440
1,519
143,713
95
0.4
608
0.7%
Multi- Residential ( >5 units)
1,191
18,244
1,129,304
62
0.2
3,649
4.4%
Residential Vacant
1 1,2611
01
0
01
0.01
0
0.0%
Right -of -Way
1 7,9911
01
0
01
0.01
0
0.0%
Kesiaentlal buntotal 69,315 79,594 14,594,343 153 54,773 ` ss.o;
qon- Residential 1 2,769 n/a 1 5,359,285 n/a I n/a 1 20,6921 24.90/
qon -Res'I (Tax Exempt) 1 923 n/a 1 1,952,074 n/a I n/a 1 7,537 9.10/
Total 73,010 21,905,702 83,002 100.0%
Single Family Unit (SFU) = 259 m2 (2,788 ft)
Kitchener_ Storm rateim plem entation_ Memo _5May2010_Mag.Doc 9 - 19
A=COM
Page 2
Memorandum
May 5, 2010
Table 1 follows the Single Family Unit (SFU) method in which the average impervious area of single
detached homes is used as the base billing unit. The average impervious area of single detached
homes was calculated to be 259 m2 (2,788 ft2) in Kitchener. The residential SFU factor relates the
average impervious area of each residential parcel type to this SFU base area.
Given the large amount of residential properties (i.e., 42,000 single detached homes, and over 18,000
multi - residential units), statistical sampling was necessary to define impervious area characteristics
for the purpose of defining a rate structure. The sampling procedures and residential parcel analysis
conducted in the Feasibility Study remains valid for the present stormwater rate implementation.
However, a new parcel type category (i.e., Residential Condominium) was added based on new
dwelling unit information provided by the City. A statistical sampling of this category indicated an
average impervious area of 111 m2 of impervious area per dwelling unit. This represents an SFU
factor of 0.4.
To implement the stormwater rate, single detached homes would be assigned to one of three tiers:
• Small: the smallest 10 percentile of impervious area is 168 m2 or less;
• Medium: the middle 80 percentile of impervious area is between 169 and 343 m2; and
• Large: the largest 10 percentile of impervious area is 344 m2 or more.
In order to determine the tier assignments for each single detached home, building footprint size will
be used as a surrogate indicator of impervious area. Building footprint values are available for all City
properties, both residential and non - residential. For the single detached homes that were sampled in
the Feasibility Study, the corresponding building footprint percentiles were determined:
• Small: the smallest 10 percentile of building footprint is 105 m2 (1,130 ft2) or less;
• Medium: the middle 80 percentile of building footprint is between 106 and 236 m2; and
• Large: the largest 10 percentile of building footprint is 237 m2 (2,550 ft2) or more.
For the stormwater rate implementation, the Duplex category was combined with the Multi- Residential
(3 -5 units) category, since they both have the same SFU factor and would therefore be charged the
same rate. Although the Residential Condominium category also has the same SFU factor, it was
kept as a separate billing category, since the charge basis is different. Multi- residential buildings are
charged based on the number of dwelling units per building, whereas residential condominium and
townhouse units are individually owned.
Non - Residential Parcel Analysis
While the imperviousness of residential properties generally falls within an expected statistical
distribution, the range for non - residential properties is highly variable. That is, a sampling of non-
residential properties cannot achieve the same statistical confidence as with residential properties. It
was not within the scope of the Feasibility Study to measure all non - residential properties, and
therefore the values presented in Table 1 were estimated.
In order to identify the recommended rate schedule, a more accurate estimate of non - residential
impervious area was needed. The stormwater rate implementation benefitted from non - residential
property measurements provided by City GIS staff. As of May 4, 2010, staff had measured over 40%
of the total 4,247 non - residential properties. The correlation between building footprint and impervious
area for the measured properties was applied to the un- measured non - residential properties.
Kitchener_ Storm rateim plem entation_ Memo _5May2010_Mag.Doc 9 — 20
C0� Page 3
A
Memorandum
May 5, 2010
Figure 1 shows a linear correlation, which suggests that 1 m2 of building footprint translates to 2.6 m2
of impervious area.
300,000
250,000
200,000
E
rr
R
M
Gl
i
Q 150,000
7
O
Gl
O.
E
100,000
50,000
0
Non - Residential Building Footprint vs Impervious Area
0 20,000 40,000 60,000 80,000 100,000 120,000
Building Footprint (sq.m.)
Figure 1 — Relationship of Building Footprint to Impervious Area
Non - Residential Rate Categories
A number of options were investigated to classify non - residential properties into distinct rate
categories or "tiers" for billing purposes, including:
• Option 1: Four tiers, combining both non - residential taxable and tax - exempt properties, with
equal revenue generated by each tier.
• Option 2: Four equal revenue non - residential taxable property tiers, and three equal revenue
non - residential tax - exempt property tiers.
• Option 3: Based on City staff review of preliminary results for these two options, there was a
concern regarding the difference in rate charges between successive tiers. As a result,
Option 3 was developed that identified six tiers, combining both non - residential taxable and
tax - exempt properties, which minimized the difference in rate charges between successive
tiers.
Kitchener_ Storm rateim plem entation_ Memo _5May2010_Mag.Doc M 21
C0� Page 4
A
Memorandum
May 5, 2010
Option 3 is the preferred alternative and the classification of tiers is illustrated in Table 2. The bottom
part of the table lists the non - residential rate categories ordered from largest to smallest impervious
area:
• Tier 1 - Largest: Properties with 39,035 m2 or greater of impervious area;
• Tier 2 - Large: Properties with 16,325 to 39,034 m2 of impervious area;
• Tier 3 - Medium High: Properties with 7,677 to 16,324 m2 of impervious area;
• Tier 4 - Medium Low: Properties with 1,641 to 7,676 m2 of impervious area;
• Tier 5 - Small: Properties with 1,052 to 1,640 m2 of impervious area; and
• Tier 6 - Smallest: Properties with 26 to 1,051 m2 of impervious area.
Table 2 - Non - Residential Rate Categories
Billing Unit Totals (SFU)
Residential: 54,800 56.2%
Non - Residential: 42,700 43.8%
Total: 97,500
Stormwater Rate Details
Annual SWM Program: $11,560,000
Est'd Collection Rate: 95%
Base Charge: $10.50 /SFU /mo
Non - Residential
Category
Billing Units (SFU)
Monthly Charge
Number of Customers
Annual Revenue
Upper Lower Median
Upper Lower Median
Ratio
Higher Lower Total
Amount %
Tier 1 - Largest
988.9
150.7
203.5
$10,384
$1,582
$2,137
2.1
20
20
40
$974,400
8.3%
Tier 2 - Large
150.7
63.0
94.8
$1,582
$662
$995
2.4
55
55
110
$1,248,200
10.7%
Tier 3 - Medium -High
63.0
29.6
39.1
$662
$311
$411
2.9
99
101
200
$936,100
8.0%
Tier 4 - Medium -Low
29.6
6.3
13.4
$311
$67
$141
2.6
472
478
950
$1,523,800
13.1%
Tier 5 - Small
6.3
4.1
5.1
$67
$42.64
$541
2.71
151
149
300
$183,100
1.6%
Tier 6 - Smallest
4.11
0.11
1.9
$43
$1.06
$20
-
1 5231
5561
1079
$245,4001
2.1%
Total: 42,700
2,679 $5,111,000 43.8%
The first set of columns shows the range of SFU billing units within each category. As noted above, 1
SFU is equal to 259 m2 (2,788 ft2) of impervious area. The number of billing units for the largest and
smallest properties within each tier is shown, along with the median value of all properties in this tier.
Note: properties with less than the minimum billing unit fraction (i.e., 0.1 SFU, or 26 m2 of impervious
area) would not be charged for stormwater.
With the median SFU value and the number of customers assigned to each tier, the total number of
Non - Residential SFU billing units was calculated (42,700). The summary of Total Billing Units is
shown in the top left corner of Table 2, which includes the Non - Residential and Residential billing
units, taken from Table 1. Values have been rounded to the nearest hundred and the percentage
distribution is shown.
The stormwater rate calculation is shown in the in the top right corner of Table 2. The annual SWM
program revenue to be generated by the stormwater rate is shown ($11.56 million dollars per year)
along with an assumed collection rate of 95% (i.e., 5% of revenue will go uncollected). The base
charge (expressed on a monthly basis) is then determined by dividing the required revenue by the
total number of billing units (97,500) and factoring in the collection rate.
The next set of columns in the bottom part of Table 2 shows the range in the monthly stormwater rate
charge for properties within each tier. These values are based on the number of billing units times the
base charge of $10.50 per SFU per month. The median value is the charge that would be applied to
Kitchener_ Storm rateim plem entation_ Memo _5May2010_Mag.Doc
C0� Page 5
A
Memorandum
May 5, 2010
all properties within each tier. The ratio of this median charge to next successive tier is shown. For
example, the properties assigned to Tier 1 would pay 2.1 times the charge for Tier 2 properties.
The next set of columns shows the number of customers in each tier. The number of customers that
would be paying a higher or lower charge under a true Tiered SFU rate structure (i.e., if all non-
residential properties were charged according to their impervious area, not assigned to a fixed tier) is
shown along with the total number of customers in the category. By assigning the median value to all
customers in a tier, an equal distribution of customers that would pay a higher or lower charge is
assured. Note: the feature of Option 3 was that the total number of customers in each tier was
optimized to keep the monthly charge ratio between successive tiers less than 3.0.
Of the 4,247 non - residential properties assessed, 2,679 properties would be assigned to Tiers 1
through 6. The remaining 1,568 properties have less than 0.1 SFU and would not be charged.
The last set of columns in Table 2 shows the annual revenue distribution generated by each tier, and
factors in the 95% collection rate. The revenue generated by non - residential properties would total
$5.1 million dollars per year. The remaining $6.45 million dollars per year (56.2% of the total revenue)
would be generated by the residential properties shown in Table 1.
Stormwater Rate Schedule
The proposed rate schedule is shown in Table 3. An integer Rate Code has been assigned to all of
the rate categories that have been described in this memo. The Rate Codes are grouped by the
broader ratepayer types, including:
• Residential Single Detached properties (Rate Codes 1 -3): The total amount of revenue
expected to be generated by these rate categories is $4.9 million dollars per year (42.4% of
the total).
• Multi- Residential properties (Rate Codes 4 -7): The total amount of revenue expected to be
generated by these rate categories is $1.6 million dollars per year (13.8% of the total)
• Non - Residential properties (Rate Codes 8 -13): The total amount of revenue expected to be
generated by these rate categories is $5.1 million dollars per year (43.8% of the total). As
noted earlier, these categories include a mixture of taxable and tax - exempt properties. Based
on a review of the taxing status of these properties, the approximate distribution of revenue
under the proposed rate schedule would be 77% from taxable non - residential properties and
23% from tax - exempt properties.
Figure 2 shows the distribution of SWM revenue contribution under the current tax levy system.
Figure 3 shows the distribution of SWM revenue contribution under the proposed stormwater rate
schedule. The stormwater rate implementation would thus reflect an 18% shift in revenue from
residential properties onto non - residential properties.
Kitchener_ Storm rateim plem entation_ Memo _5May2010_Mag.Doc 9 — 23
A=COM
Non - Residential
Taxable, 22.7%
Page 6
Memorandum
May 5, 2010
Non - Residential
Tax Exempt,
3.2%
Multi- Residential,
13.5%
Residential
Single Detached,
60.6%
Figure 2 - Revenue Distribution, Current Tax Levy
Non- Resident
Taxable, 33.9
Non - Residential
Tax Exempt,
9.9%
Multi- Residential,
13.8%
Figure 3 — Revenue Distribution, Proposed Stormwater Rate
Attachments:
" Kitchener_ Storm Rate Implementation _Memo_5May2010_Table3. pdf'
Kitchener_ Storm rateim plem entation_ Memo _5May2010_Mag.Doc 24
t
M
Q
E
O
vI
Q
N
O
Q
O
L
a
M
W
B
N
O
O
O
0
0
0
0
0
0
O
0
0
0
0
0
0
O L
00
LO
00
O
V
O
(O
LO
CO
O
00
O
LO
O
V
i N
y
V
T
C
V
CO
(O
00
00
V
N
O
c'7
O
N
O
E
co
N
7 U)
Z U
N
(0
(0
(0
O
O
N
N
F
V
00
00
LO
co
I—
N
O
O)
Lo
O
L(7
O
L'o
M
V
V
00
N
V
V
R �+
fA
fA
fA
fA
V
L(i
U)
p O
cf?
U
OL
II N Z
r d
N LO d
i
cm N d
)
C N
(6 y
a
�X
U
y
O
O
O
O
O
O
O
O
o
0
0
0
0
0
0
(h
LO
00
LO
N
V
O
00
O
=
I—
I--
I�
V
O
L
=a
0
O
0
I�
V
00
N
(O
(r)
O
0
O
O
6
(O
U)
6q
(A
(A
(A
(A
(A
=
(A
=
(A
N
(A
(1)
N
(A
LO
(A
V
=
IT
O
CO
U
0
(A
H)
A OL
O
II O Z
N
�)
i
U)
0) N d
� y
O
X
U
i
(0
O
CO
I—
V
V
V
V
V
N
O)
OR
Lri
LL
O
0
0
0
0
0
0
O
L6
Co
O
V
c'7
LL U
=
CO
O
O
(n ca
N
LL
N
w
C
N
X
X
N
U)
a)
N
N—
CL
N
7 y
0
~
Z ?�
LL
LL
0
O
O
(6
O
O
O
E
E
O
O
N
O)
O)
O)
C
C
E
t6
fn
7
O
Z)
7
O
O
C
C
C
0
0
7
N
'O
'O
'O
—
—
O
N
0
O
E
U0
O
a)
o
E-
O
L
s rn
s (O
s
x
o
E-
o
N
C
E
H
H
E
N
N
.N
a) o
o O
W O
o
o
O
U
o
O
NE
O
NO
E
E
a)
m
E
o
E
a�
� '�
E
v
m
co
�
o
o
c
Z)
_
(o
(o
(o
ch
NE
a)
a)
CO
a) N
o
O-
o
O-
'O
o
Q O)
LO
I�
i
N
O
O
'
O
O
LO
LO
U O
U-0
U O
Q
Q
Q—
N
I—
N
CO
O O
O O
O N
N
i
LO
V
1—
co
O
N N
.O
N N
.O
N N
.O
a)
a)
a)
a) ?:
0
0
0
(
(
0
0
0
0
O
N
1
CO
E
�
N
_0
0)
0
Cl)
J
_0
_0
_0
O
a0)
0
0
o
in
J
S
O
U
U
U
E
C:
'E
U)
E
E
U)
Z)
Z)
o
0
D
D
D
o
f
N
�A
E
E
-0
o
-0
0
ci
a)
N
N
0
(n
(n
J
J
N
a0)
0)
a0)
O
O
(6
(6
(6
(6
(6
(6
(6
(6
(n
(n
(n
�
U
C
C
C
C
C
C
0
0
0
0
0
0
c
c
c
c
c
U)
U)
Fn
U)
U)
U)
U)
U)
U)
O
O
O
O
N
N
N
N
N
O
O
O
O
O
O
O
ixR
(
(O
0
HFI
c7
U
O
c�
N
N
C
N
t
0
N T
c o
� N
O LO
O N
N �
O
(6
U p
O
Q O
O N
I I
C
O Q
U O
E N -O
OU :� N a
LO O 0 L
L(7
O Q U
N Q C
Z) O N N co
u) (A W
Q o X
O -O 7
0
LO LN
LO N
N X .
(6 H O
a.. L
c 'E o E
a) ?
°) LO a) U)
�O N _0 p
T
(0
a) N
E N (h m
O 00 O
0- N E N N
0) L�j C) �O L
(6 U
0
0
O II N
O Q i O
O (6 (6
O O N
O M 'O -O
> N N
i E
O Q X o o
o Q W Z Z
Z N cY) v LO
9-25
r �
A
a
e
t
i
~* F
C livet tAnlI
fecl Clxt4eck
Tuesday, April 27, 2010
Grant Murphy, P.Eng.
Director of Engineering
City of Kitchener
200 King Street West, 9th Floor
Kitchener, ON N2G 4G7
Re: Stormwater Rate Implementation - severe impact on Olivet United Church
Dear Mr. Murphy;
Olivet United is greatly concerned about the proposed stormwater rate being moved from property
taxes to a fee on the church water bill. In our opinion, this is drastic and a step in the wrong direction.
This seems to be in direct contravention of the purpose of tax exempt properties. It appears the City of
Kitchener no longer values the contributions made to this community by the churches, and is in process
of moving items from property taxes to bills which tax - exempt properties are paying. What comes
next, higher stormwater fees, then road fees, then? This is a very bad precedent.
This stormwater fee would severely impact work this church is doing in the community. Olivet is a
typical traditional church whose revenue budget has basically been the same for a decade (actually
revenues have been slightly in decline). What the City is asking for is nearly.4% of our budget to go to
a stormwater tax! This.money will have to come from program budgets such as our food box program,
mission and service fund, our benevolent fund (i.e. bus tickets & grocery gift cards), etc. That is just
plain wrong.
We would ask that the existing method of funding stormwater be maintained.
Attached are thirty -eight signatures from our congregation who wish to express their concern and
disagreement with the proposed stormwater funding model.
064 e-
Sincerely, on behalf of Olivet United Church,
PC;
Dave Potje
Chair of Council
47 ONWARD AVE., KITCHENER, ONTARIO N2H 3J8 TEL: 519 - 74292,9'26
PASTOR: RANDY BANKS B.A., M.Dw MINISTER@OLIVETUNITEDCHURCH.COM
•ii ..ar.a. r.r 1[ rr•rr ■s.NTT__. r■ rT l 9 -.
COMMENT SHEET — Public Meeting for Places of Worship, April 14, 2010
J
KiTCHENER
Stormwater Rate Implementation
The City of Kitchener is interested in hearing the community's comments, questions,
concerns and suggestions regarding the implementation of the proposed stormwater
rate.
Please take a few minutes to complete this brief comment sheet. All comments will be
carefully considered as this project- proceeds.
1. What do you believe are the most critical stormwater issues in Kitchener (e.g., flood
protection, erosion control, operations and maintenance, pollution prevention, minimizing
environmental impacts, etc.)?
2. What do you see as the advantages /disadvantages of the proposed stormwater rate?
3. Do you agree in principle with the concept of funding the City's stormwater management
program with a stormwater rate?
4. Do you have stormwater management facilities on your property (e.g., rain garden, green
roof, vegetated swale /ditch, pond, wetland, etc.)?
5. Are there any other funding options or incentive programs that the City should consider?
- 27
COMMENT SHEET Public Meeting for Places of Worship, April 14, 2010
6. Please provide any additional comments, concerns, questions or suggestions related to the
stormwater rate implementation project.
A I
t
Contact Details
Name:
Address
Phone N
4 i� ;
NOTE: Personal information requested on this form is collected in accordance with the Freedom
of Information.and Privacy Act. All comments will become part of the public record. If you
do not wish to have personal information (Name, Address, Telephone, Email).on this
comment form included in the final report, please check the box below:
141please withhold personal information
Please return this completed Comment Sheet to the project team. Alternatively, you can
fax it or mail it by April 28"', 2010 to:
Project Contact:
Grant Murphy; P.Eng.
Director of Engineering
City of Kitchener
200 King StreetWest, 91h Floor
Kitchener, ON N2G 4G7-
Tel: (519) 741 -2410
Fax: (519) 741 -2747
E- mail: grant. mu rphy@kitchener. ca
9-28
All 1
-
Contact Details
Name:
Address
Phone N
4 i� ;
NOTE: Personal information requested on this form is collected in accordance with the Freedom
of Information.and Privacy Act. All comments will become part of the public record. If you
do not wish to have personal information (Name, Address, Telephone, Email).on this
comment form included in the final report, please check the box below:
141please withhold personal information
Please return this completed Comment Sheet to the project team. Alternatively, you can
fax it or mail it by April 28"', 2010 to:
Project Contact:
Grant Murphy; P.Eng.
Director of Engineering
City of Kitchener
200 King StreetWest, 91h Floor
Kitchener, ON N2G 4G7-
Tel: (519) 741 -2410
Fax: (519) 741 -2747
E- mail: grant. mu rphy@kitchener. ca
9-28
COMMENT SHEET— Public Mesting for Places of Worship, April 1,4, 2010 .
Stormwater Rate Im lementation
SNOWS
The City of Kitchener Is Interested In hearing the community's comments,'questians,
concerns and suggestions regarding the implementation 'of the proposed stormwater
rate, '
Please take a few minutes to complete this brief comment sheet. All comments will be
carefully considered as this project proceeds,
1. What do you believe are the most Critical stormwater issues in Kitphener (e:g.; flood
protection, erosion control, operations and malntenence, pollution,prevention, minimizing
environmental lenpacts, etc.)?
2. What do you see as th anteges /disedyaritages of the proposed stormwater rate?
3. Do you agree in principle with the concept of funding the City's stormwater management
program with a stormwater rate? Aid
4. Do you have Stormwater management facilitles on your property (e.g., rain garden, green
roof, vegetated swalelditch, pond, wetland, eto.)?
5. Are there any other funding options or incentive programs that the City should consider?
0
9 - 29
COMMENT SHEET- Public Meeting for Places of Worship; April 14, 2014
6, Please•provide any additional comments, concerns, questions or suggestions related to the
stormwater rate implementation project.
2my
Name
Add re
Phonc
Email
NOTE: Personal information requested on this form Is collected in accordsn ca. with the Freedom
of Information and.Prlvacy Act. All comments will become part of the -public record. If you
do not wish to have personal information (Name, Address, Telephone, Email) on this
comment form Included in .the final.repod, please check the box below:
( Please withhold personal information
Please return this completed Comment Sheet to the project team. Alternatively,, you can
fax It or mail it by_Aar>II_28Lt ,_2010 to:.
Project contact;.
Grant Murphy, P,Eng,
Director of Engineering
City of Kitchener
200 Ding Street West, 9r' Floor,
Kitchener, ON N2G 407
-Tel: (519) 741 .2410
Fax: (519) 741 -2747
E -mail, grant.murphy @kitchener.da
-30
COMMENT SHEET— Public Meeting for Places of Worship, April 14, 2010 .
J
RT( i-'ENAR
Stormwater Rate Implementation
The City of Kitchener is interested in hearing the community's comments, questions,
concerns and suggestions regarding the implementation of the proposed stormwater
rate.
Please take a few minutes to complete this brief comment sheet. All comments will be
carefully considered as this project proceeds.
1. What do you believe are the most critical stormwater issues in Kitchener (e.g., flood
protection, erosion control, operations and maintenance, pollution prevention, minimizing
environmental impacts, etc.)?
,7:01 � 1..0 -e AU10,
2. What do you see as the advantages/disadvantages of the proposed stormwater rate?
�.,.
C. S tea .fit.^
R
3. Do you agree in principle with the concept of funding the City's stormwater management
program with a stormwater rate?
4. Do you have stormwater management facilities on your property (e.g., rain garden, green
roof, vegetated swalelditch, pond, wetland, etc.)?
S. Are there any other funding options or incentive programs that the City should consider?
-31
MUM
COMMENT SHEET — Public Meeting for Places of Worship, Apra 14, 20 +0
n additional cOrnrner►ta, concerns, Questions or suggestions related to the
a. Please provide any
stormwater rate lmplgmentatian project.
Name: —
Address:
Phone Number:
Email: tE
NOTE: Personal information requested on this form is oollectod in accordance with the Freedom
of Information and Privacy Act. All Comments will become part of the public record. If you
do not wish to have personal Information (Name, Address, Telephone, Email) on thi9
comment! orm Included in the final report, please check the box below:
[ ] Please withhold personal information
Please return this wmpleted Comment Sheet to the project team. Alternatively, you can
fax it or mail It .by Aril 2 sr 20.10 to:
Pry ct Contact:
Grant Murphy, P.Eng,
Director of Engineering
City of Kitchener
200 King Street Weet, go Floor
Kitchener, ON N20 4G7
Tel: (519) 741 -2410
Fax: (510) 741 -2747
E-mail: grant.murphyQ_kitchener.on
2
9 -32'
Community Christian Reformed Church of Kitchener (CCRC) appreciates the opportunity to provide input relative
to the new Clty of Kitchener stormwater management funding model.
At the public meeting hosted by the City — on April. 14, 2010 — places of worship were invited to submit oomment%
suggestions and concems. Thank you for your invitation; this Is our submission.
In the design and construction of our Facilities at 4275 Bleams (Road, including a subsequent expansion of our
parking lot, it was very important to us that we set and meet high, modem stormwater management objectives.
Our location Is designed to ensure that important stormwater principles are supported and continuously practiced.
Our overall stormwater treatment plan includes the following;
• A sizable portion of our property has been set aside as a dedicaN infiltration basin — so that stormwater
may be directed to groundwater through the underlying pemneable soil.
• An extensive system of grassy swales, created and implemented so that stormwater runoff is directed and
managed, pollutants aro filtered and rainwater infiltration is increased. The vegetation within and around
these swafes is maintained to ensure optimal water runoff and the overall eftcoveness of the swales.
• Minimal use of winter -time salt and/or do- icers. We are very oognizar t of the detrimental manner In which
safflde -ioers afted groundwater. We have worked hard to ensure a decreasing dependence on these
methods.
• No curbs. There are no curbs that can obstruct the movement of rain or "wit water into our swales or
catch- bar3ins.
Underground, dry- wells. Designed to contain and slowly direct stwmwater to groundwater.
• Rip -rap as required, to protect against erosion. We regularly inspect our ttp•rap and it is cleaned and
maintained as required.
• Planting and maintenance of all vegetation necessary to ensure excellent filtration of all water coming
from catchment areas.
• Planting and maintenance of green belt around the perimeter of the property thereby ensuring no erosion
of soil and minimal flow of sediment or'siit into stoimlgroundwater,
• Claaning and maintenance of the parking lot surfaoe and surrounding areas. This ensures minimal
slitfsedimentatian and other debris entering our stormwater management system.
CCRC is committed to mitigating the effects of stormwater runoff. We have spent significant sums of time and
money to control the level and type of development on our property — In such a way — that runoff hardly exists.
A --I AL- 1. --•- L.--� _ ..m ...
9 -33
AIIU,OIt;j V 11ave vwt w oinicuntes or impairments to our Knott system. We have done our very best to show a
strong commitment to the health and well -being of the area's groundwater and the optimal quality of our streams,
lakes and aquatic life.
Kindly consider our situation. Please take into accoynt the following; It is our submission that the amount of
stormwater generated frond our property is substantially less than the amount that would be determined from an
Indiscriminate application of the relationship between building size/footprint, property size and impervious area,
We are �erefore requesting your kindest consideration for relief from your proposed estimated annual charge of
$10,289.
Our property is new, and our property includes a modem and very effective approach to stormwater management,
As a Congregation, we are strongly committed to the continuation of ongoing, excellent stormwater management
contributions of our individual members. The wail -being of the many programs offered by our church, depend
heavily on the continued availability of our members' existing contributions - coupled to the. lowest possible levels
of expense. Your proposed estimated annual charge of $10,289 will be a heavy cost to us. This charge would
have a detrimental effect on our programs. We ask for relief from this significant impairment.
Your consideration of our excellent stormwater management system and practices; and, your acknowledgment of
our organization as a non -profit institution solely dependent on individual contributions - is very much appreciated.
Thank you,
9 -34,
COMMENT SHEET - public Meeting for Places of Worship, April 14, 2010
J
Stormwater Rate Implementation
RECEIVED
APR 2' 6 Z010
DEVELOPMENT &TECHNICALS'IRVICES CUM
The City of Kitchener is interested in hearing the community's comments, questions,
concerns and suggestions regarding the implementation of the proposed stormwater
rate.
Please.take a few;minutes to complete this brief comment sheet. All comments will be
carefully considered as this project proceeds.
1. What do you believe are the most critical stormwater issues in Kitchener (e.g., flood
protection, erosion control, operations and maintenance, pollution prevention, minimizing
environmental V6--
mentaal impacts, etc.)?
2. What do you see as the advantages /disadvantagps�yo�f the pro
d stormwater rate?
I
H l
3. Do you agree in principle with the concept of funding the City's stormwater management
program with a storfJ71water rate?
A /_.. L / - -.r 1 - y° -/vo-
4. Do you have stormwater management facilities on your property (e.g., rain garden, green
- 35
1
COMMENT SHEET -- Public Meeting for Places of Worship, April 14, 2010
6. Please provide any additional comments, concerns, questions or suggestions related to the
r
/ i 1
Contact Details
Name: -J°C - I tit �� c I � l a r � Vl_ - - - - -.
Address: 1 �V ct a c�r� ) t r VAPIaPC_' ON).
). _- �i a�(� I
Phone Number•• 1
Email: 1�C1S` (c�S ;ce l04 1 S I
NOTE: Personal information requested on this form is collected in accordance with the Freedom
of Information and Privacy Act. All. comments will become part of the public record. If you
do not wish to have personal information (Name, Address, Telephone, Email) on this
comment form included in the final report, please check the box below:
] Please withhold personal information
Please return this completed Comment Sheet to the project team. Atternatively,e you can
fax it or mail it by Aril 28th 2010 to:
Project Contact:
Grant Murphy, P.Eng.
Director of Engineering
City of Kitchener
200 King Street West, 91h Floor
Kitchener, ON N2G 4G7
Tel: (519) 741 -2410
Fax: (519) 741 -2747
E -mail: grant.murphy @kitchener.ca
9 -36
P
RRMM R
Stol'mwater
COMMENT SHEET — Public Meeting for Places of Worship, April 14, 2010..
e Implementation
Oil.
The City, of Kitabe.ner is interested in hearing.the- community's cornments,'questiorls,
concerns and suggestions regarding the implementation of the proposed stormwater
rate.
Please take a few minutes to complete this brief comment sheet. All comments will be
carefully considered as this project proceeds.
1. What do you believe are the most critical stormwater issues in Kitchener (e.g,, flood .
protection, erosion control, operations and rnaintenance, pollution prevention, minimizing
environmental impacts, etc.)?
2. What do you see as the advantages /disadvantages of the proposed stormwater rate?
I Do you agree. in, principle with. the concept of funding the City's stormwater management
program with a stormwater rate?
4. Do you have stormwater management facilities on your property (e-g., rain garden, green
.roof, vegetated swale /ditch, pond, wetland, etc.)?
5. Are there any other funding options or incentive programs that the City should consider?
-9, 37
COMMENT SHEET— Public Meeting for Places of Worship, April 1a', 2010
6. Please provide any additional comments, concerns, questions or suggestions related to the
stormwater rate implementation project.
:11c'm ac- r.IL z.Lnf kti_*T1,Wia�r�i!ai1
_ - ti..r_. .. •_ ,� __ ___ rn
MW WE
w
C cnt- act_ Details
.
ell�
Address:.]
Phone Number: (.J]9)'z\a -py L,.a _
Email:
NOTE: Personal information requested on this form is collected in accordance with the Freedom
of Information and Privacy Act. All comrnents will bedome part of the public record. !f you
do not wish to have personal information (Name, Address, Telephone, Email) on this
comment form included in the final report, please check the box below;
( ) Please withhold personal information
Please return this completed. Comment Sheet to the project team. Alternatively,, you can
fax it or mail it by April 28"', 2010 , to:
Proiect Contact:
Grant Murphy, P.Eng.
Director of Engineering
City of Kitchener
200 King Street West, 9'%h Floor
Kitchener, ON N20 4G7
Tel: (519) 741 -2410
Fax: (5 19). 741.2 747
E -mail: grant.murphy @kitchenerca 9-38
COMMENT SHEET— Public Meeting for Places of Worship, April 14, 2010 .
Stormwater Rate Implementation
The City of Kitchener is interested in nearing the community's comments, questions,
concerns and suggestions regarding the implementation of the proposed stormwater
rate.
Please take a few minutes to complete this brief comment sheet. All comments will be
carefully considered as this project proceeds.
1. What do you believe are the most critical stormwater issues in Kitchener (e.g., flood
protection, erosion control, operations and maintenance, pollution prevention, minimizing
environmental impacts, etc.)?
2. What do you see as the advantagesldisadvantages of the proposed stormwater rate?
►rr 1 :.�
LIi
lIL i.�'
' t`,lL.� ■.N x..,.. . ��
.1f
A c [ %a
�"►
3. Do you agree in principle with the concept of funding the City's stormwater management
program with a stormwater rate?
4. Do you have stormwater management facilities on your property (e.g., rain garden, green
roof, vegetated swalelditch, pond, wetland, etc.)?
5. Are there any other funding options or incentive programs that the City should consider?
�d
- 39
COMMENT SHEET -Public Meeting for Places of Worship, April 14, 2010
6. Please provide any additional comments, concerns, questions or suggestions related to the
stormwater rate implementation project.
hail i-WWr7VAr,0
Contact Details CouMGa_ UI+3,-, kcr4 ufftwt AUAeVt>w ahz
Na
Ad
Ph
Email:
NOTE: Personal information requested on this form is collected in accordance with the Freedom
of Information and Privacy Act. All comments will become part of the public record. If you
do not wish to have personal information (Name, Address, Telephone, Email) on this
comment form included in the final report, please check the box, below:
( ] Please withhold personal information
Please return this completed Comment Sheet to the project team. Alternatively,. you can
fax it or mail it by Aril 28en 2010 to:
Prolect Contact:
Grant Murphy, P.Eng.
Director of Engineering
City of Kitchener
200 ring Street West, 9`" Floor
Kitchener, ON N2G 4G7
,Tel: (519) 741 -2410
Fax: (519) 741 -2747
E -mail: grant. mu rphy@kitchener,ca 9-40
COMMENT SHEET— Public Meeting
1
r t ..•
I Tc H Eti� R
Aprilll4, 2a10
APR 9 ZUl[f t
�E9�l.�P�"�N1LT G tiIG LSF�Y #utSUP]
Stormwater Rate Implementation
The City of Kitchener is interested in hearing the community's comments, questions,
concerns and suggestions regarding the implementation of the proposed 'stormwater
rate.
Please take a few minutes to complete this brief comment sheet. All comments will be
carefully considered as this project proceeds.
1. What do you believe are the most critical stormwater issues in Kitchener (e:g., flood
protection, erosion control, operations and maintenance, pollution prevention, minimizing
environmental impacts[, etc.)? `� t
.~"�1�..+¢ nr, crr ►rt-ic x � rrr�e�hc�- Q,r is %-u
2. What do you see as the advantages/disadvantages of the. proposed stormwater rate?
3. Do you agree in principle with the concept of funding the City's stormwater management
program with a stormwater rate?
4. Do you have stormwater management facilities on your property (e.g., rain garden, green
roof, vegetated swalelditch, pond, wetland, etc.)?
5. Are there any other funding options or incentive programs that the City should consider? -
i�
41
COMMENT SHEET —Public Meeting for Places of Worship, April 14, 2010
6. Please provide.any additional comments, concerns, questions or suggestions related to the
stormwater rate implementation project.
Contact Details
Name:
Address:
.Phone Number:
Email:
NOTE: Personal information requested on this form is collected in accordance with the Freedom
of Information and Privacy Act. All comments will become part of the public record. If you
do not wish to have personal information (Name, Address, Telephone, Email) on this
comment form included in the final report, please check the box below:
IA Please withhold personal information
Please return this completed Comment Sheet to the project team. Alternatively,-you can
fax it or mail it by April 28kh, 2010 to:
Project Contact:
Grant Murphy, P.Eng.
Director of Engineering
City of Kitchener
.200 King Street West, 9th Floor
Kitchener, ON N2G 4G7
Tel: (519) 741 -2410
Fax: (519) 741 -2747
E -mail: grant.murphy @kitchener.ca 9-42
COMMENT SHEET — Public Meeting for Places of Worship, April 14, 2010
Stormwater Rate Implementation
11260014M,
APR 2 2 1010
DEVELOPMENT & TECHNICAL SERVICES DEPT.
EfISINEER1613 SERVIUS
The City of Kitchener is interested in hearing the community's comments, questions,
concerns and suggestions regarding the implementation of the proposed stormwater
rate.
Please take a few minutes to complete this brief comment sheet. All comments will be
carefully considered as this project proceeds.
1. What do you believe are the most critical stormwater issues in Kitchener (e_g., flood
protection, erosion control, operations and maintenance, pollution prevention, minimizing
environm ntal impacts, etc. )?
s
K
2. Wha do you see as the advantages/disadvantages of the prop sed stormwater rate?
P
3. Do you agree in principle with the concept of funding the City's stormwater management
4. Do you have stormwater management facilities on your property (e.g., rain garden, green
roof, vegetated swalelditch, pond, wetland, etc.)?
5. Are there any other funding o tions or incentive programs that the City should consider?
--43
1
COMMENT SHEET —Public Meeting for Places of Worship, April 14, 2010
6. Please provide any additional comments, concerns, questions or suggestions related to the
stormwater rate implementation proj,e .
�`, Z4 //
Contact Details
Name-
Address-
Phone Number:
Email:
NOTE: Personal information requested on this form is collected in accordance with the Freedom
of Information and Privacy Act. All comments will become part of the public record.. If you
do not wish to have personal information (Name, Address, Telephone, Email) on this
comment form included in the final report, please check the box below:
jvf"Please withhold personal information
Please return this completed Comment Sheet to the project team. Alternatively, you can
fax it or mail it by April 28th, 2010 to:
Proiect Contact:
Grant Murphy, P.Eng.
Director'of Engineering
City of Kitchener
200 King Street West, 9th Floor
Kitchener, ON N2G 4G7
Tel: (619) 741 -2410
Fax: (619) 741 -2747
E -mail: grant.murphy @kitchener.ca
9 -44
COMMENT SHEET— Public Meeting for Places of Warship, April 14, 2090 .
f
11,�iTCHi�NNE.R
Stormwater Rate Implementation
The City of Kitchener is interested in hearing-the community's comments, questions,
concerns and suggestions regarding the implementation of the proposed stormwater
rate.
Please take a few minutes to complete this brief comment sheet. Al comments will be
carefully considered as this project proceeds.
1. What do you believe are the most critical stormwater issues in Kitchener (e.g., flood
protection, erosion control, operations and maintenance, pollution: prevention, minimizing
environmental impacts, etc.)?
__Prul a
2. What do you see as the advantagesldis-advantages of the proposed stormwater rate? ,
j. uo you agree in principle with the concept of tunding the City's stormwater management
nroornm with a Stnrmwatar rnfp7
4. Do you have stormwater management facilities on your property (e.g., rain garden, green
roof, vegetated swale /ditch, pond, wetland, etc.
5. Are there any other fundin o tions or incentive programs that the Cit should consider?
J
4;1�
i
0-M.1119-0101M ! •
COMMENT SHEET - Public, Meeting for Places of Worship, April 14, 2010
6. Please provide any additional comments, concerns, questions or suggestions related to the
Gfnrmwafpr rata imnlomontatinn nrniPrt
Contact Details
N
A{
Phone Number:
Email:
NOTE: Personal information requested on this form is collected in accordance with the Freedom
of Information and Privacy Act. All comments will become part of the public record. If you
do not wish to have personal information (Name, Address, Telephone, Email) on this
comment form included in the final report, please check the box below:
[ +�] Please withhold personal information
Please return this completed Comment Sheet to the project team. Alternatively, you can
fax it or mail it by April 28th, 2010 to:
Proiect Contact:
Grant Murphy, P.Eng.
Director of Engineering
City of Kitchener
200 King Street West, 9t" Floor
Kitchener, ON N2G 4G7
Tel: (519) 741 -2410
Fax: (519) 741 -2747
E -mail: grant.murphy @kitchener.ca 9-46
Page 1 of 2
Grant Murphy
From:
Amichai
Sent:
Wednesday, April 28, 2010 U6 AM
To:
Grant Murphy
Cc:
'Beth Jacob Synogogue
Subject:
Storm Water Rate Comments
Importance: High
Good morning Grant,
I hope that I find you well.
I was able to attend the meeting on April 14th and have a good discussion with you regarding the proposed
storm water rate charges. Specifically, how they related to my congregation, Beth Jacob Synagogue. Your time
was appreciated. In any case, please review my comments as per the questions sheet you provided me. I have
not included the questions, just my responses:
1. 1 believe that the most critical storm water issues facing Kitchener are twofold, based on what I
learned: ensuring the system can meet the current and future needs coupled with the city's ability to
pay for the services. With the city's recent growth, there are new funding challenges to ensure that the
quality and services that we as a community have become accustomed to and expect can be maintained
without additional revenues for the city to help deliver these services.
2. The main advantage of the proposed storm water rate, from the city's perspective, is that it may be
able to source funding for budget shortfalls from 'untapped' resources. Secondly, it would seem more
equitable to levy the tax on organizations that are using the service, but not 'paying' directly for the
service fait could be argued that through membership of the organisation, the taxes they pay on their
property would cover the tax could be used). However, the advantages in my opinion are
overshadowed by the disadvantages of the system of charging the currently proposed rates. Primarily,
most, if not all, religious organisations barely have the money in their budget to cover their own
operating expenses for religion services, education, programming, building costs, etc. Our community
for one, has been running a deficit for a number of years and based on my conversation with other
communities, we are not alone. Secondly, the rate charged, appears excessive. I don't think in principle
one could argue that there should not be some allocation of the storm water rate charges to a church,
but these levy's should be not only assessed on the size of the building /property, but on that
community's ability to pay.
3. As mentioned in point 2, 1 agree in principle with the concept of funding the City's storm water costs
with a levy on organisations that are currently exempt from these costs. However, my caveat is that
these costs must be reasonable and assessed on a community's ability to fund the proposed tax. As per
our discussion at the meeting, I indicated that the rate appears high and that perhaps a laddered
approach to the fees over a number of years would enable communities to absorb the cost in their
budgets — ie. Say our levy would be $1000 — allow a community say 5 years to reach the full amount, say
charge the church 20% a year, so year 1 the levy is 200, year 2 the levy is 400, etc....
4. Yes, there is a stream behind our Synagogue and there is some trees and parks within the compound
and surrounding the compound.
5. It is easier for the .city to tax residents directly, through user fees, property taxes, etc. than it is for them
to indirectly tax residence through churches. 1 would propose that the city look towards direct taxation
first. Should there be actions that churches can do to help mitigate the impact of the drainage, they
perhaps specific programs tailored to the unique footprint of each church could be applied on a case
Page 2 of 2
case basis.
6. Essentially, my main concern regarding the storm water rate issue is whether religious communities can
absorb this cost. I can tell you specifically that the rate, as it is currently proposed, will put undue
financial hardship on our communities ability to operate. I implore your committee to review how the
rates are proposed and to take into account a community's ability to pay. A more simple approach, like
a nominal user fee (say $500 per church) would be easier for most communities to absorb. As I
indicated above, I don't disagree in principle with charging currently exempt organisations a rate, .
however, direct taxation on city residence is a better approach, coupled with a modest charge to
churches would be a better way to achieve the finding shortfall that the city currently faces.
My name is Amichai Tsarfati
Blessed Sacrament Church
.2010
K. Grant Murphy
Director of Engineering
Engineering Services
City Hall, P.O. Box 1118
200 King Street West
Kitchener, ON N2G 4G7
RECEIVED
MAY 03`1010
UEVELOPMEW & TECHNICAL SERVICES DEPT.
ENGINEERING SERVICES
Re: City of Kitchener Proposed Stormwater Rate Implementation
Dear Sir,
On behalf of the parishioners of Blessed Sacrament Parish I would like to express our
opposition to the proposed stormwater management fees to be assessed to Blessed
Sacrament Parish.
As we are a tax - exempt property along with other Places of Worship we would suggest
that this management fee is in fact a tax and as such, Places of Worship should be exempt
from it. A true "user fee" for stormwater services is not accurately reflected in a simple
calculation of impervious area and then assigning a flat fee for a certain range of values.
Also the calculation that the city is using is grossly unfair to those properties at the lower
end of each type code range. For example, if you are at the low end of type code 9 you
will be paying $1.1029 ($10,288.8019329) per square metre on an annual basis whereas a
property with 26,753 square metres will only be paying $0.3846 ($10,288.80126753) per
square metre. Does this seem reasonable to you?
If indeed the new proposed tax is implemented we would strongly suggest that the city
use a more equitable calculation and rate structure for this tax, something more in line
with a sliding scale rate structure like the calculations used by the Canada Revenue
Agency in calculating personal income taxes.
Another thought would be for the city to include incentive programs for property owners
so that they would be able to reduce this fee and at the same time reduce the amount of
water runoff from their properties. Blessed Sacrament has recently installed storm water
catch basins on our property which accumulates a majority of roof water run off and
diverts it from the city's stormwater system. Wouldn't it be reasonable to expect a
reduction in the impervious area calculation for Blessed Sacrament based on such an
action?
305 Laurentian Drive, Kitchener, Ontario N2E 2N6
Phone: (519) 742 -5061; Fax: (519) 742 -0982
In closing .1 would like to reemphasize my opening assertion that this "management fee"
is in reality a tax and tax - exempt properties such as Places of Worship should be exempt
from it.
Yours respectfully,
Michael J. Stephenso
Chairman
Blessed Sacrament Finance Council
CC: Kelly Galloway — Councilor South Ward
9-50
���• "' t ` I April 29, 2010
n r•
3 `r.
Y
Forest Hill
United Church
121 Wettmnunt 46,R,
Kitchener, Orimiio
N2M 4Y6
Pbone
(big) Ida -�dHl
Fax
(519) 744 -7674
Email Address
k%tLh hell
Websftae
farciWauntmLors
Grant Murphy, P. Eng.
City of Kitchener
200 King Street West 91" Floor
Kitchener, ON
N2G 4G7
Fax' 510.741 -2747
We wish to register our objection to the City of Kitchencr's proposed 9tormwater Management
Funding Model for tax - exempt properties, beglnning January 1, 2011.
We have serious concerns with this proposal and questlon the net value that will be generated
once 0 Is Implemented.
I. We question the costa of Implementing and maintaining a system that is property specific,
The tiered rate, based solely on property size, does not offer opportunities or Incentives for
property owners to reduce their steel of runoff nor does it recogn,Ze the efforts made by those
who have already engineered their own stormwater reduction meohanleme.
2. What portion of the funds will be used to administer the collection of this levy?
3. We feel strongly that adding fees to tax- exempt properties such as hospitals and charitable
orgaanisetions will result in an Increase In rates to users or a reduction in services. This will
also apply to schools and services run from municipal buildings as well.
4. We feel than stormwater funding should remain within the municipal budget process where it
can be discussed, prioritized and reviewed annually along current tax guidelines,
Forest Hill United Church donated In excess of $13,000 to local charities including the House of
Friendship. Out or the Cold, Waterloo Region Food Bank, and local breakfast programs, In 2002.
Other local churches also help the City of Kitchener by providing funds for those In now — people
for whom the City of 141tChener shares a responsibility to help. We understand churches to be tax -
exempt In order to relleve .tnem or that financial burden and allow them to Contribute to programs
and initiatives such as those outlined above. The proposed stormwater management foe is clearly
in opposition to that ideal
In order for a non - profit organii-ation ouch as Forest Hill to pay the projected 201.1 stormwater rate
of $284 per month ($3,408 a year), Money will have to be diverted from the Other worthwhile
causes we undertake and support each year. Our congregation already battles annual deficits just
to maintain the level or programming and support wo faal is naeded In our community. To
negatively Impact those services even further is simply unacoeptable.
Lastly, we ask you to consider that churches are funded almost entirely by donations from
members who realde In this community. Under this proposal, we will find ourselves being
assessed this fee twice - once for our homes and once as partial contributors to the life and work
of our church. We also find this unacceptable.
We respectfully request that you terminate the City of Kitehener's Stormweter Management
Funding Model proposwl for tar- exempt properties.
Chris Pietere,
Chair, .Church Board
Dennis Dechert,
Chair, Proparty Committee
9 -51
a'
C
F
a
f ;
�a
Forest .Mill
United Church
121 Westmount Rd.E.
Kitdiener, Ontario
N2M 4Y6
Phone
(519) 744 -34 81
Fax
(519) 744 -7674
Email Address
foresthilluc0bellnet.ca
Website
foresthillunited.ofa
7F 1A
S�
Grant Murphy, P. Eng.
Director of Engineering
City of Kitchener
200 King Street West, 9t" Floor
Kitchener, ON N2G 4G7�1� U
fax: 519 -741 -2747
As a member of Forest Hill United Church, I would like to register my
objection to the City of Kitchener's proposed Stormwater Management
Funding Model for all municipal properties, including those with tax - exempt
status, beginning January 1, 2011.
f=orest -Hill United Church donated in excess of $13,000 to local charities
including the House of Friendship, Out' of the Cold, Waterloo Region Food
Bank, and local breakfast programs, in 2009. Forest Hill willingly helps
families and individuals who call on us when they are in need of urgent
assistance. Other local churches also help the City of Kitchener by
providing funds for those in need = people for whom the City of Kitchener
shares a responsibility to help. I understand churches to be tax - exempt in
order to relieve them of that financial burden and allow them to contribute
to programs and initiatives such as those outlined above. The proposed
stormwater management fee is clearly in opposition to that ideal.
In order for a nonprofit organization such as Forest Hill to pay the
projected 2011 stormwater rate of $284 per month ($3,408 a year), money
will have to be diverted from the other worthwhile causes we undertake and
support each year. Our congregation already battles annual deficits just to
maintain the level of programming and support we feel is needed in our
community. To negatively. impact those. services even further is simply
unacceptable.
Lastly, I ask you to consider that churches are funded entirely by donations
from members who reside in this community. Under this proposal, I will
find myself being assessed this fee twice - once for my home and once as a
partial contributor to the life and work of my church. I find this
unacceptable as well.
Instead: of levying fees such as this, should we not be investigating other
means to maintain our infrastructure? Perhaps the funding should continue
to come from the current tax system. How can we collaborate with the City
of Kitchener to support the many essential programs offered in this
community rather than placing them in further jeopardy?
I respectfully request that you terminate the City of Kitchener's Stormwater
Management Funding Model proposal for tax - exempt properties.
a rd 5
AM . Z(- t-, I a
Dat
9-52
February 3, 2010
To Kitchener City Council: Carl Zehr, John Smola, Berry Vrbanovic,
John Gazzola, Kelly Galloway, Geoff Lorentz, Chris Weylie
From: Kitchener Area Monthly Meeting, Religious Society of Friends.
(Quakers), 298 Frederick St, Kitchener, ON N2H 2N5
Regarding: Proposed flat -fee storm water charge 'ra, T .
Dear Members of Kitchener City Council,
We are a small church (but call ourselves a Meeting) in an old house
on Frederick Street. We make our building available to a non - profit
organization at a low cost as a way to help the organization do its
work without large overhead expenses. Currently 'Project READ', a
literacy group, shares our space in return for paying for utilities
and contributing to a maintenance fund for upkeep of the building.
In the past we have helped other organizations, such as'Community
Justice initiatives' and the'John Howard Society'.
We are concerned about the proposed flat -rate storm water charge and
its application to Churches and Not - for -profit organizations. We do
not object to a storm water fee in general, believing that citizens
and organizations do have a responsibility to support their municipal
government and infrastructure. However, we feel strongly that
applying a flat -rate fee to a group of organizations with great
differences in land size, storm water management tools, and financial
abilities is inequitable. We urge you to investigate some sort of
tiered or sliding -scale mechanism which takes into account land -size,
building size, ground surface, etc, to apply this new fee.
The proposed cost of $81.66 per month would amount to more than a 20%
increase in the occupancy expenses for our non - profit tenants. If our
Meeting were to assume this cost, in the absence of a non- profit
organization, this fee would be almost 15% of our usual annual
income. We ask you to please find an equitable manner in which these
funds can be raised for our community, while not becoming a burden on
its constituent organizations, particularly the smaller ones.
Sincerely,
(signed)
Chris Springer, Clerk
Kitchener Area Monthly Meeting
of the Religious Society of Friends
(Quakers)
9-53
Page I of 1
Grant Murphy
From:
Sent: Wednesday, April 28, 2010 12:22 PM
To: Grant Murphy
Cc:. Fr. Earl Talbot
Subject: Stormwater Rate Implementation Comments
Attachments: Stormwater Rate Implementation.doc
Mr. Murphy,
Attached you will find a few comments regarding the proposed Stormwater Management
rate implementation for the City of Kitchener..
As I stated in the attachment, these comments do not represent an official St. Anthony
Daniel parish postion but are comments from some members of the Building and
Maintenance committee of the parish.
9-55
Stormwater Rate Implementation V-D
Comments Pat Ze) I
To Grant Murphy
Director of Engineering
City of Kitchener
grant.murphy @kitchener.ca
Mr. Murphy,
The following comments do not represent an official position taken by Saint Anthony Daniel Parish but
are comments from some members of the Building and Maintenance Committee of this parish.
1. The most critical issues are pollution prevention and minimizing environmental impacts. At St.
Anthony Daniel Church, we are attempting to minimize the use of salt during the winter months.
2. The goal of raising additional funds to repair and upgrade infrastructure is valid.
The method, the implementation of a. new and separate levy is not valid. Why create a totally new
system of collecting taxes — costly, wasteful and bureaucratic. If additional funds are required, have the
courage to raise the taxes in our existing property tax system or cut other programs if they are of a
lower priority.
3. No. Funding should be done through property taxes.
4. No special facilities or equipment.
5. Where are the incentives in this proposal? The literature I received did not describe any incentives for
individual properties. They may exist but 1 am not aware of them.
6. 1 believe the proposal is being justified partially by saying that it is more fair for all those who create
stormwater runoff to pay and this is the rationale for moving costs out of the general property tax
structure. Surely, this rationale could apply to countless services provided by the city such as fire
protection and police protection. We pay for the services for our safety, not because we use them.
Surely, we hope that we will NOT have to use them and yet are prepared to pay for them. In other
words, our taxation system is not based on "user -pay" but on the pooling of tax revenue to provide
those services which we as a community need and desire. Why should stormwater management be
treated any differently?
What will be the next municipal service to need a special levy?
In the interests of efficiency, use the existing tax structure, use the existing tax structure to generate the
necessary funds for effective stormwater management.
Contact details
9-56
9-
Page 1 of 1
Grant Murphy
From:' nNorbert W. Schmidtke/
Sent: Wednesday, April 28, 2010 10:47 AM
To: Grant Murphy
Subject: re: Stormwater Rate Implementation - Public Meeting for Places of Worship, April 14. 2010
Attachments: Kitchener Stormwater.doc
Dear Grant,
Attached are my comments for the comment sheet re the Stormwater Rate Implementation for places of worship.
I have numbered the comments to match the questions and trust that your staff will integrate them with the other
respondents' comments,
If there are any questions that require comment elaboration just drop me a note. Pleasure to have had an
opportunity chatting with you on the 14th.
Cheers!
Norbert
orbert W. Schmidtk
9-58
COMMENT SHEET — Public Meeting for Places of Worship, April 14, 2010
Stormwater. Rate Implementation
Comment Sheet Answers to questions i to 6.
1. Kitchener's most critical stormwater issues are: operational & maintenance financial
resources, flood protection, erosion control,
2. advantage: equitable rate structure
disadvantage: additional financial burden on already very tight church budgets
3. Yes. It provides a sustainable funding source. Stormwater charges collected and not
spent during a fiscal year must be placed and managed from a distinctly separate,
identifiable stormwater resource fund.
4. No.
S. & 6. Property owners should be encouraged to invest in rainfall harvesting strategies
.and techniques. This can be achieved by the City providing financial incentives of
reduced stormwater rates or a grant in accordance with reductions in impervious
surfaces, rainfall not ending up in the stormwater collection - and treatment systems.
Infiltration fosters groundwater augmentation, resource recovery, reduction in pipe
and treatment system size, and adverse environmental impacts.
Examples are: use of pervious pavement for parking lots, downspouts not connected
to the stormwater system but leading to infiltration wells and a host of other well -
known water resource recovery strategies. The onus of proof for rate reduction
eligibility must be placed on the property owner whose application must be supported
by a report completed by a Professional Engineer.
Implementation and success of any incentive program must guarantee two things:
1. the incentive will be such that the pay -back period will be less than 5 years.
2. City budget requirements for the stormwater program will decrease due to any
incentive and not have any shortfall passed on to the remaining property
owners.
All property owners should be encouraged to pursue stormwater recovery strategies
provided that a realistic financial incentive is available.
Contact Details:
Highland Baptist Church
chair: Stewardship & Finance Board
Iiiew
9-59
m �
a�
�
o
cz
ECD
cz CD
E o
E }'
0
o �
cn r-
cz
Fl
1
O
N
O
cz
N
E
i
O
.0
J
O
C:
U
L
W
0.2
i
N
U
N
cz
W
LU
cn
N
}'
O
Q
O
O
O
U
Z�
4,
�
C'3
U
cz
C
CZ
�
U
Cz
U-
O
N
O
cz
i
c
L
O cz
a X
cz O LLI
4-a �+ -5
CU �--� O -0 4-a
cz
cz 0
a� +� cz E
m — -0 O
O o O O
c -� o c�� cz
CZ a� --- cz E CZ CZ
0 o c�
oC �, E 0
o
E 0 0
20 E
— Q O C) O O .,� o 4-a
4-a :�:� (1) cz 4-a 4-a �j U. cz oC cz E: C/)
�- cz
E
Z) a� a�
E o E O ._
O ��� >
°o°o.00
Fl
P*R�_
,gym
C�
Cz
^L
W
E
L
O
-1--+
C/)
Cl)
■ v /
C�
U.
_ cz
_0 O i
o
CD
+= O O= Qcn�
) i O
• (�
Nom}, �0 �p �c�
CNU_0 >1 a � 0 Np -0:= �
CU — > z
CUB - a) _0 C: �aCZ N Q E
U CZ -0 �0 �'0 =
On �p C 'UV p
� } )C: o CU
QLL U�� ��U CZ CZ C
woncz
_0U
�C) 0 - -max �o o�
U) �� N�� ��� oU) nn
�� C) (1) o 0) 0(Z U) cz�
�� N �U)p ��}, Cz +�Q
N� �� O�Q Q�� _�� ��
c���p� cep '� 0) �(Z
� � LO I--'+- CU . U � � Z3 � � O
� Op iONcn :3 (Ojc�Q0 -O
� N 0 0 p�'� O� CU , C N
0 CZ _ T
U p0 ���QU�cz 00� � zCO
�® a) (Z
E0� � N�E���
O � � c� (D -0 0) � 0
Ocz �Q. >Np. -N�Q c �O Vp�
Cif _0 cz C) CO C \j
� (D p � CU T CU U i O� Q 0
E �+��'C) �U�cz CZ :U) �
� pp�Z Pn-nc))- wOUM0
�
low
�_
Fe
4t
�ys .
C�
C�
0
a�
U
C�
LL
C�
a�
al-,
a�
c�
E
O
-1--i
Cl)
C:
�U) Ecz C
E�°)o
O ±1 " o
C)
0��� �cz
U O� Ocn
0
C OOUO O
2 > M Q
cd o a.0 r�
E � o
o E �
U E -0 U)
- --
cd �o
Z
cn j0U�
a���� 0 C
-0 >, Z3
L Z3 U) Q a)
CZ
�j0
E > ' }' U) C )
00 N
W N��� pCZ
U -Z3 b� N�
07 U) N�U
Fl
O
O
d7
O
U)
CD
cz
.w
D
0
Li
N
a�
U
.w
00
Q
a--j
N _I-e
cn N
cn
Q) U
cn
Q �
cd (n
E
C N
CLO
Q
O
W
C: C/)
_cz
U
��
o�
cz� ��
0,-:,
Q) co i C:
cz
�o Q)
J N
L]
a�
cd U }' cz
O-0 N-0
> U) Q cn
Rim
cd
O
0
cz
cd
U) a,
O
0
-04--,
N � U
�C�
N
czU) U)
0
(1)
Zv o
U) O
U N
0) cd
U � �
cu cn
Q U cn
a
T
dA
.O }+
cO E
G �
O
i
a
Q1
U
E
V
Ul
o
�..
cn
ca
qA
N
4-j
C6
t]A
L
ca
'E
M
qA
te
C 6
>
Ln
>
V
U
o
x
�Y6
Q
J
U
N
-0
w
,
CL
}i
V
a-J
a-+
U
-0
.O
C6
Cr6
a
z3
U
_
QU
`
C:
W
N
f6
U
U
O
W
4-1
O
Q
U
GJ
p
O
a--+
J
O
L
CL
O
�
cn
vi
U
C6
W
O
U
I
N
r
N
N
N
a- +
f6
C:
O
U
}'
D
ca
i
V
H
m
>
C6
>
N
Q
>
N
�
O
W
�
O
�
NO
O
-0
-0
M
aQQ���
+J
v
O
0
N
E
+j
ro
ca
E
Q
'Q
-0
O
�2�
0
��e
°
`"
vJ
CD
N
u
Ul)
O
�V
—
N
E
U
V,
GJ
Q
f6
^�++
a)
•U
. N
�-+
'>
W
i
ro
taA
ca
ca
W
U
ca
U
V
CZ
o6
v
a
o
0
�
. �
�
�
ate-+
ul
• �
ul
-0
Q
N
i+�+
-0
Q
ro
U
-0
T
dA
.O }+
cO E
G �
O
i
a
Q1
U
E
V
Ul
o
Ul
L
4-1
4-j
C6
t]A
L
ca
M
qA
O
Ln
ca
Ln
U
o
x
Q
J
U
N
-0
w
,
CL
}i
V
a-J
D
cr
-0
.O
C6
Cr6
a
z3
U
_
QU
`
C:
W
N
f6
U
O
W
4-1
O
Q
U
GJ
p
O
a--+
J
O
L
CL
O
�
cn
{%}
U
C6
W
O
U
I
N
r
w
N
4 -+
.Q
f6
D
ca
i
V
H
m
>
C6
>
N
Q
o
(n
4-1
4-j
C6
t]A
.n
O
O
U
U
x
J
O
O
-0
O
cn
a-�+
N
i
a--+
qA
f6
N
u
i
E
E
>
N
NO
O
-0
-0
M
aQQ���
c� �o Ui
CY) O -0 CO
> CZ CZ O U) �`� > Q)
O� CZ N -� OU- O p N
QL > CZ C: a) 0
CKI cn cZ000 O�OpU) -> C)
V CZ 0-7 - > (� (On i
i 02cz p U) ��NO N
LO (1) cz Nom' -0 - - CZ
cz cz 0 0 �-0� -_ ��+� cn
(Z �.— i �3 Q) U)
(n > +�
E > CZ
U) 0—
U) O > -0
c�
cn -
oc�n -> cn. : cz E a)s=
� •� " cz cz -0 cn a) -0 =
O 0-0--C cn -C CZ 0 LL CZ � CZ
Fl
�_
cz
E
+
�
cn
w
CD
CD
N
I,
1w,
O
cn
cz
Q
E
O
u
E
cz
O
i
i
cz
E
i
0
cn
i
0
Q
X
w
cz
Q
CD
CD
N
cz
cn
i
0
Q
X
w
i
o
N
i
C:
�
E
-C:
E
m
Q)
2
-
1
J
E
T
Q
m
C6
o
C
£
£
cf)
+r
C
cz
O
_0
O
>
N
O
O
>
N
O
O
C)
0-
Q
W
cz
W
00
T
T
T
O
'
'
U
>
C:
O
C/)
C:
U
cz
U
C
>
N
cz
O
E
--
E
C/)
�:
O
E
Q
0000
m
O
0
O
O
{f}
69-
{f}
C
C
U
C
O
-
a-- �
O
O
_
O cp
i�
0
Z
0 +r
O
O
cz
E
?>
cz
_0
U
C:
w
0
c�
N
"
�
O
0
U
0=
O
�
O
`�
O
c
cz
cz
O
- �
�
O
E
cz
"
(n
o
'
o
O
` —
�--'
U)
05
2 c
M
C
cz
cz
0)C:
°Q
U-
-0
CZ
_0
O
0
U
��
o
h
'gym
f
ar
,O
Q O CD
a
a N
0
U
O
CD
r
I-
O
C\
00
Nt
LO
L,n
CD
T
{p}
T
0
r
0
CD
M
6}
00
0
00
Cfl
0)
Lii
C
O
O
C\":i
N
{f}
O
O
N
O
LO
69
O
O
0)
N
{f}
O
O
LO
r
Lii
LO
Vj-
O
CY)
LO
T
0)
N
crj
T
T
O
LO
�
�
O
O
T
O�
�
{c}
CD
E
N
CD
6c}
N.
00
00
0)
1`
00
O
LO
M
N
�
{c}
r-
0)
O
N
CD
6c}
1`
RCT
B
LO
O
r
N
TT
Cfl
O
O
M
Q
Q
Q
Q
v�
O
O
O
O
O v
H
H
(f)
H
H
4-0
m
m
cn
c
cn
cn
Lp
L-
�_
�
N
ui
N
O
m
o
C
>
U
C�
4-0
4-j
0
Oct
V
�
N
-
�C:
c
O
�,
o
CD
>_
O
}'
0
i
c0
()
'ca
•�
0
O
j
c-0
cz
•�
a
��•�
U
��
��—
o
�•>
J
Q
N
N
>
N
=
cn
CZ
0
CZ
CZ
N
N
Z
N
Z
QO
=
N
j
=
•O
0
O
4-0
��
cc
O
�
cn
cn
0
cn
Q
Ir
O
a)
c)
I
Q
CL
_
m
o
O
w
U
H
B
�v
,e
Fl
r•
•
O
E
O
cn
U
O
P43
O
F•,
O
0-
cn
O
cz
U
O
9
cn
cn
X
P43
O
N
N
K
�I
�J
O
Q
Q
O
O
U-
.
W
U
co
L.L
W
cn
O
x
O
2
.
W I
O
E
cn
cn
O
cz
cz
O
Q
cz
U
cz
cz
0
cz
cn
O
W
P-
.cn
cn
cz
.0
U
O
.
Cz
�
O
�
�
C/)
U
4)
U
+
-0
LL
U
C:
cz
(L)
�
c�
CD
C/)
U
O
-0
°6
N
CD
C;)
�
4-a
O
_0
U
U
'5
<
(L)
'O
0
�
I
I
Fl
r•
•
O
E
O
cn
U
O
P43
O
F•,
O
0-
cn
O
cz
U
O
9
cn
cn
X
P43
O
N
N
K
�I
�J
O
Q
Q
O
O
U-
.
W
U
co
L.L
W
cn
O
x
O
2
.
W I
O
E
cn
cn
O
cz
cz
O
Q
cz
U
cz
cz
0
cz
cn
O
W
P-
.cn
cn
cz
.0
U
O
.
w,
^V,
W
L
cz
U
(1)
cz
IC
O
c
O
4-0
cz
CU
O
2
U)
cz°'a,
O
cn
0cz0
C
U
O
O
;
'i
c
O
CZ
Q
cz
cn
E
%+—
cz
L
cz
-0
0
Fl
c
.
O
cn
0cz0
O
--
;
O
'
CZ
cz
-1--'
cn
'
CZ
L
�a)
'cn
L
C/)
"
�
O
QL
O
O
O
c�
N
a�
i
C�
.o
C�
r�7
e
c�
N
0
2
•
0
U)
Z)
Is
cz
0
u
�O �
.0
a1
o
.cn
N
o
` J
0
' -
CZ
0
Cz
z
0
u
�O �
.0
a1
o
oC
u
�O �
0 O
N
�Tyy�� 00
♦^ 00 cz 0)
C) � T
U cn cz� II cz
4—a E ._ N O
C� o ^ =
.1--i }, , cz _
O 0
U �LO0�� O
cz N
cz
E > -o
p CZ Q
U o i
cz cn
Fn cn
Q CZ-0
cn
Cn cz - cz - 70
0
C
CZ
0O i
a- 5 o
E uo 1 I 75
0 0
O
0
c�
cn
II
0
0
cn
cz
E
cz
_0
�
O
cz
oZS
cz
cp
0
C:
0
0
.cn
cn
>%
�
O
O
CZ
cn
cz
cn
_0
CZ
70
Cn
U
N
- Cn
N
cz
cz
E
cz
cz
C)cz
U
cz
U)
C)
O
I
I
Z
I
I
f1
cz
cz
V
1--j
O cz
= cn
U O
cz
—a
n
W 70
+-r
70
Cn cn
E E
00 CO
O � C'7
V
I `—000
T cz
cz
W
T cz
`V
O
>
E \° -
.— o
X O o
0 0o O
C) W T
o
T �
^^ ,,
W
E
o
— � o
cz
E o cz
cn
I I I
Fl
i
`, s
O N
-i--r i%�
co N
U i N co
`~ CV O
O ^, � CV
C�
W '� - T V
cz O N
(D U E
- N LO N C'7
_ C: _O -0 N
._ o
' Q O X0° o
o O
O 00
� � T o
0) ' Cz 0 N
> a) 3: E
cz U) o
cz
cz c E o cz
> C
0
O
8 8 O
c-I
E
_.I
1 `•
O O O O O O (
O O O O O O
m N cI O 01 00 Il l0 Ln �
O
E
co
nV
00
CO
T
E
(-orbs) eaad snoinaadui
V
� N
o
0o
cz�N
J n
�
U)
o
a
EN
a
o E
a
=cy)
o E
CL
cz cy)
L.0 o
'
o -
N
w
� cz
O
o
O
Oo Co
Ln Ln
=
0
�
s
/11
� VJ
O
�
� N
o
�
0
m
�
i
cI'f
0
0
N
c-I
E
_.I
1 `•
O O O O O O (
O O O O O O
m N cI O 01 00 Il l0 Ln �
O
E
co
nV
00
CO
T
E
(-orbs) eaad snoinaadui
V
0
O
O
0 8
`�
•
O
0
O
01
0
O
N
00
N
—
�
'10
o
a
of
d
0
N
o m
O
Ln
O
s
o�
�-+
°o °
R n
}'
o
o
�
� Q
N
O LL
o
i
i
CO
O
M
O
O
'
T
V
V/
LT
70
cz
a)
e, f
�Mh
—
r_
70
1
W
r-
r-
T
N
M
CD
cz
O
Q
(1)
^
-0
cz
E
U
Cn
O
cz
`cz
:3
V J
_
00
0
N
CL
E
70\
L-L�
T
II
CD
cl)
.
�
CD
E
u-
cz
U
cl)
4-a
D
CZ
O
C;)
T
W
VJ
cz
Q�
E-
>.N
cz
co
W
CZ
ryT��
W
y
T
T
CD i
- —
O
cz
0
U-
co
Q
0
Cl)
O
z a
C
O
C/)
O
i
CO
O
M
O
O
T
T
V
V/
LT
r_
Q
W
r-
r-
T
N
M
CD
O
Q
CD
00
m
It
CL
E
T
N
CO
O
�
CD
Q
CD
E
Q
O
co
W
It
ryT��
W
y
T
T
CD i
,I-
M
M
co
Q
O
z a
E
ID
cy)
E
a)
E
Ez
aD
-0
-0
-0
Q Q
a)
a)
a)
O
~
i
Cz
Cz
cz
a
a)
a)
a)
c
o
o
a)
a)
a)
0)
CY)
CY)
P)
(7)
v
-� J
Fl
4A 6 -.7.
3
L
Cz
�y, U
O
4—a
Cz
QL
0 _ I
O
cz
U
c
4—a
LL
70 Cl)
QL
r
4-a i
Q-
0—
^0
W
70
70
C^z
Cz N
c / E
mV
O N
W/
it
u-
' W C/)
C;)
cz
T
O N_
U) CZ
0 L
O Cf)
CZ O
Er =
• •
Fl
mom
p
CD
CD
CD
CD
CD
�
�
cy)
cz
Q
c
.�
V
(D 1
Q
_
O
N
T
T
T
T
O
T
CD
p
Cz
Cz
L
N
'>
�
70
0
7
-C:
O
C:
O
O
+�
.
=
CD
T
T
I-
O
U-)
(A
N
(D
Q
E E
�
i
T
T
T
'cn
L
Q
CD
CU
�
�
�
U
a
Im
co
00
C\j
O')
Nh
0')
CO
0')
p
CO
00
N
T
00
=
T
p y
y/ L
CO
OB
M
(
00
00
C
CO
CO
T
O
qzj-
T
T
T
E C a
E
E
�
L9
CO
Lo
A
Q
O H
a
U
o
U
_0
_0
U
U)
�
cp
�
Q
o
mom
�
�
cy)
cz
Q
.�
V
(D 1
}�
O
Cz
Cz
O
'>
70
70
0
7
-C:
O
C:
O
O
+�
.
E
O
-CZ
-0
U
�
i
0
-0
O
'cn
Q
CD
CU
�
�
�
U
mom
i 10
C/)
QL
O
Q
Cn
^iW , X �
O (n cz
n (D ---a
�--r 06
L (D
cz
Q
X
C
���
■ V O
(n L0 O
N
r C/)
X 0
O 2
O U
z Q�
Q I
.
Fl
O
/Cn
W
i
O
O
L
70
C
cz
70
cz
Cn
O
E
O
0
cz
cn
U
O O
c
E
� O
O
cz i
_z
C Q
CZ
cz
CZ V)
cn CZ
(Z :3 -0
U O CZ
CO -i -0
E cz
cz - C: N -0 cz
cz
I I
T
L
N
cz E
� o �
CZ T 0-
`v O a)
(n N C/)
Q
i
Q � �
E O cz
. _
� cna)
E
O
�
O -0 O
cz
cn c _
-0 a) CZ
0 E U
0) o QL
CZ t W
� I I
U
W
L
O
0-0
O O
L
(n
.� CZ
Q
OE
L
.� 0
CZ
O cz
(n (n
O .LD
� O �
0-O
O E
O._ a
0
0
0
0
N
c-I
O
O
O
O
O
1-1.
E
a
4,
C
'i
O !Z
O C
O
LL
dA
C
00
0
0
0
0
0
0
O
0
N
E
cz
W
L
'cz
V )
Z3
0
L
Q
0
N
CD
N
11
. ^
Q1 --+
0
0
0
N
E
k�
cz
W
. U)
I..L
I
0
z
Q )
X Ln
i
Q
Ln
O0i
H
Ln
Ln O
O
II N
L
CL
E
in
�i
0
LL
tw
i
m
f0
Q)
H
Q
I
Z
i
• 9�
0 0 0 0 0 0
C C C C C 0
O O O O O o
o Ln o Ln o ui
M N N
(-w-bs) ea.ld snOin.ladwj
0
0
0
0
N
c-I
O
O
O
O
O
1-1.
E
a
4,
C
'i
O !Z
O C
O
LL
dA
C
00
0
0
0
0
0
0
O
0
N
E
cz
W
L
'cz
V )
Z3
0
L
Q
0
N
CD
N
11
. ^
Q1 --+
0
0
0
N
E
k�
cz
W
. U)
I..L
I
0
z
,e
i
V
.cz
4-a
70
.U)
0
Z
0
0
W
c}n U
CZ :tf
c
cz
70 QL
O
Q-
0—
cz
-- 70
• �J
Fl
.E
cn
0
cn
0
0
E
0
.N
O
C/)
0
0
E
0
.N
E
.cz
2
cz
N
O
Q
0
t
co
O
Q
0
N
N
O
U
N
0
-0
C)
cn
V
E
cn
O
U
Qcn
0
�--,
cz
cn
a)
0
.--
X
cz
a)
cn
�
0
cz
X
1
X
O
06
C�
�
0
0
�'
°6
cz
.Ln
>
C:
Z
X
>
CZ
-1--'
C
—
a)
im
v
CZ
0
0
0
=
�
��
>
0
:3
CZ
,
0
cr
0
LL
=
LL
a)
CT)
cz
N
0
r
I
N
I
co
I
co
O
Q
0
N
N
O
U
N
0
-inn
co
O
Q
0
N
N
O
U
N
0
0
W
n ,
Q � N 0)
cz
CD
L
._ Q O U
E N O
cz `
n � i —0
(� O . — O -1--r
4) -1--j E —o
70 C D C=
i .O cz LL 70
Q Cl) m
O Q T O
z cz O
7 .VJ W �\
n '
7 W Zi
n� cz
CZ cn
E v � 0 :3
E O U O
CZ >
O .CZ (D i i
U 70 jj= Q
o Q
CD O
Fe
44 16
O
E
2
N
O \ o
y p O
LOLO
6c}
T
� T
E a? a)
m
o p U
E a a)
O N
N m
O
in U
�a
C
Q
N 00
Co,
Ln �
.F O LO
y LO RT 0)
LO
r _m _m m
C O O H
� a a
in in
m 0
OR
00
M
RT
O
O
O
T
LL")
6F}
0
ti
O
N
0
O
N
m
H
CO
1 -
O
T
(D
T
00
O
00
co
T
N
T
T
`I_
0
0
0
0
0
0
RT
N
"
00
"
RT
O
Z3
00
a
M
M
LLB
C
O
I-
RT
M
N
00
RT
0)
N
0)
LO
_
04
O
O
O
O
O
rn
i
T
N
CA
C'7
O
0
Y0
T
E F
CO
VN
N
U)
C:)
1U))
O O
J
O
Ln
CA
N
T
C'7
�
E O
N
u)
O
I-
U)
C/\�j
'91-
T
L J
Z=
O
T
-tr
O
CG
I,
N
N
N
N
N
rI�
Lf)
T
T
O
m
M
O
T
RT
LC)
N
O
O
T
6F}
m
C4-
6F0-
6F0-
6F0-
m
60-
t
U
N
N
T
>+
00
O
T
(.0
O
O
U-)
N
T
C O
619-
619-
O J
fR
fR
�
N
N
T
I-
C'7
CMyO�
C4
�
^i
1C ^O
'C ^4
MT
^
O
T
VT
VT
T
f
p J
N
O
M
T
1-
O
CL
C')
T
T
L
O
O
LO
C'7
O
C)J
N
O
.4
O
O
�
O
T
�
J
•�
O
I�
O
O
C'7
T
m
co
Ln
co
N
T
Imy,
O i
O
E
E—
N
a O
0
0
n
-
CD
CD
O
O
T
N
C'7
',I-
U-)
O
Z
N
N
N
N
N
N
OR
00
M
RT
O
O
O
T
LL")
6F}
0
ti
O
N
0
O
N
m
H
�4
C-
0
4—a
4—a
U)
0
rr
C: CL
O E
_0 0
a)
U) X C\j Lu
X
0
Z
U) U)
cz o
a)
-0 cz
O C\i
C: C)
0-
CO
a)
0)
E
70
cz
-0 8-0—
0),
(D
C: +
_0
_0
C
0
a)
rr
z
Ir
z
0 10--o
10-0-
CL
0 co
-
C\l
-
M
-t
CD
Lo
C: CL
O E
_0 0
a)
U) X C\j Lu
X
0
Z
U) U)
cz o
a)
0
O C\i
C: C)
C\J-
a)
0)
E
cz
-0 8-0—
0),
(n
LU
_0
0
0
(D
z
Z
C�
0--o
'o-o-
C3)
-r--
L6
4
C\l
r,
a)
CZ
3--
CZ
U a) ' CO
D
C)
a)
Er C;)
U6)
C: CL
O E
_0 0
a)
U) X C\j Lu
X
0
Z
C: x
0
Z9
rte_ 11
U)
cz
C: x
0
op
C:
00
D C6
—
Z3
cc
U) U)
cz o
a)
0
O C\i
C\J-
a)
cz
C: x
0
Z9
rte_ 11
U)
cz
C: x
0
op
C:
00
D C6
—
Z3
cc
may,
W
cz
W
4—a
cz
Ir
4-a
cz
3:
E
L
O
4—a
U)
W
cz
O
U\
Q
O
L
U
CZ
cn
O
�
O
Q�
O�
00
--
O
C;)
�
.�
O
cn
(n
�cz
i
c�
N
cn
N
WE
e
Fl
3
E
N
x
W
x
cz
�i
LF
F-W
t1o"
cz
O
0
cn
O
O
z
uo
O
W
L
cz
O
Q
co 2
"r-
0
�i
..
0
O
N
O
N
T
T
O
N
^L
W
L
QL
x
c�S
C�
N
N
Q
2
'(D
L J
T
T
W
cz
E
O
L
W
N
x
cz
cn
cz
N
N
cz
O
U
N
O
U
0
LO
m
r Y
sd
W
cz
cz
rr
cz
3:
E
0
U)
—a
v
in
O
Z
L
It
��Tpp
v J
O
L
O
U
i
L
X
0)
cz
a)
I1� I —
M
c0 a)
L
��Tpp
v
c�
� O
O O
0) -0
O �
7
O
O O
Q O
O C;)
Q cZ
L
U U
Q —
O ZZ
C
L
U �
O
� U
L W
O
0
L L!
O M
CD
E
O
O
O
N
LO
i1
O
U
O
U
E
X
O
Q
I
T N
N
O L-
o
M
0
LO
0
M
L- N
T
T
'D E
't
co
It
E O
O N
Z O
U
�! A
�e
co
�I-p
oT
co
N
T
co
c0
T
L
m L
Q.
Ef}
H?
U O
� a
L
Q
a
Im >,
CD
Cl)
C)
Lq
C)
00
WQ
tcoo
O
co
vT
vT
O
70
s a
rt+ L
0 CL
W
G
U
0
IM
T
T
T
Z
0
L
L
L
O
O
O
O
O
O
0)
0)
L
_
E
O
N
�:
N
O L
O
O C)
O O
W
O E
O
O E
-0 O
-
-0 M
[w''
� T
�
� N
W
U O
U Q
U O
N
N
N
.
O cn
O cn
O cn
V ♦
�
O
E
U)
O
J
O
O
O
C
�
O
Q-
O
O
O
0
O)
O)
O)
s
ff.�,
VJ
VJ
VJ
• Fl
C�
T
N
co
V
in
O
Z
L
It
��Tpp
v J
O
L
O
U
i
L
X
0)
cz
a)
I1� I —
M
c0 a)
L
��Tpp
v
c�
� O
O O
0) -0
O �
7
O
O O
Q O
O C;)
Q cZ
L
U U
Q —
O ZZ
C
L
U �
O
� U
L W
O
0
L L!
O M
CD
E
O
O
O
N
LO
i1
O
U
O
U
E
X
O
Q
I
T N
N
U
0
0
WaIA
Rim
"r
z.
RIC-
Alk F� _
WI
w 5 +r
r\ r
�5 s
I
41N 000 R
low
Fl
s �
N
^
N
T
E
N
N
2
U
p
c
�
�L
o U
U
�
LO
0
T11
N
V
T
cz
.-
O
sd
W
cz
W
cz
rr
4—a
cz
3:
E
L
0
4-a
U)
0
Z
L L
\i
GG O
N
Lfi
�Tpp C\j
v J
CO
0 O
O
-0 o
N
H?
II
m '
Q
i
L
X O
O
cz
T
0
co cz CD
m
m --
LL fJ O
CD E
M D
CO O Lq
LO LO
T
� � Q
L O
0) -
O N
O i
L L i1
LO
O 2) N
Q cz O Ef}
L � T
0 U O O
0--
N
a) \ LO O
_O
O O II
� .� O
L m Q
c�
� o �
E ° o
L LC) a) o
o rn -(,� T
E ai
:E E x Q
= O E
cn
� cz � w
T N co
N
O L
O
O
O
B
0000
O
cD
LO
CO
O
O
O
M
o0
A
N
T
T
wL
^ E
cD
m
T
T
E
'Oqq
v/
Z
U
O
O
LO
T
O
T
LO
N
O
N
LO
}' i
rte+
H}
Q9,
T
T
N
N
o= cz M
L
69-
69-
69-
69-
a
U Q.
O o
OL
II N Z
a
a) LO Q)
a Q-
x
U
Im
0
LO
0
N
0
't
0
cD
0
00
0
O
R i
S O
r-
H?
-,t
H?
co
QS?
N
T
cD
T
T
N
C M
O O
U CL
���
E o
A
^0
L li
T W
o
cz � y
U
x
CL D
X
o
X
_0
_0
a^) CM
Lc =
T
T
Q
o
a
Q
L
a
a)
E -
O
L
7
o
>
U-
�eLf
Z
LL
L
a)
L
a)
O
E
E
L
/'�'{
c V
E
S
O
O
U
OC
OC
�
�
o
7
O
N
a)
a)
U
L
L
L
^`
�
Q
O
0
O
Q C
O C:
Q
Q
�o
Q
LL
LL
LL
LL
5�
E
4n
C
CD
U
C:
D
E
D
LO
LO
N
=
�
O
0
70
N
n
$
U
m
m
Fl
c,
70
-
-
t
LO
co
I�
_
U
0
Z
L L
\i
GG O
N
Lfi
�Tpp C\j
v J
CO
0 O
O
-0 o
N
H?
II
m '
Q
i
L
X O
O
cz
T
0
co cz CD
m
m --
LL fJ O
CD E
M D
CO O Lq
LO LO
T
� � Q
L O
0) -
O N
O i
L L i1
LO
O 2) N
Q cz O Ef}
L � T
0 U O O
0--
N
a) \ LO O
_O
O O II
� .� O
L m Q
c�
� o �
E ° o
L LC) a) o
o rn -(,� T
E ai
:E E x Q
= O E
cn
� cz � w
T N co
0
Cl)
Em
Fl
((.l
AA
74 IAL
An
C\j
C)
C\j
U)
LO
N
(1)
=
cz
_0
U)
(1)
C)
cz
(1)
C)
cq
0
a)
..I i
0
.
(Z
Z3
o
0
U
2
z
2!
aC
74 IAL
An
�
�
.��
le
�
�
cz
�
(1)
4—a
cz
rr
L
�
4—a
cz
3:
E
L
0
4—a
U)
cz
�
�
�
0
0
CD
�
I
�
0
z
e
�
» E
\ Fl
%
cli
m
C)
/
m
/
G
/
G
/
?
R
E
E
7
m
m
k
o
o
2
2
Q
N
Lo
�
cz
m
m
4) �
■
3 0
�
= a
0
2
/
It
I
I
e
m
»
N
7
7
m
m
k
o
o
e
e
N
Lo
�
cz
m
m
cz
Lo
j'\
Q9,
Q9,
=
cq
0
\.00.5;
m
7 a
=
22
a)
0-
E
°
_
2
�
§
-
2
0-
0-
«
.
y
E
§
.
._
4) �
■
3 0
�
= a
0
2
/
C)
c
c
c
o
»
»
»
#
m
C)
m
o
o
e
e
N
Lo
�
cz
$
/
cz
\
j'\
\
\
=
\.00.5;
m
_ 2
o a
2 E J
2 f =
�
@
�
2
Q
0
�
m
§
:
v
.�
\ �
P'o ° Gm
cc) I C)-) I
ƒ
7
�
.�
§
%
2
_
§
j § a
\ \ /
/ //
m
cz
\
k � �
L cz
% cz
�
3 cz
¥/ \§
± g @ o
e � 2 2
@ 2 a)
cz
E \ E
a)
% £ / E
/ ƒ
2
o k f R
§ .7 Co
ƒ f
/ /
0- @ 6 / \
% / 7 / /
/ k � 3 /
a » o k
f
2 C) 9 \
/
/ 7 £ / 0-
@
R o = — —
o / 3
[ \ % % \
£ C g 2 2
% %.§
7 E §_
6 / k � / /
2 2 & 6 It
cz
\
@
\
CZ
-
CZ
a)
cz
U)
cz
j'\
\
\
=
\.00.5;
=
22
a)
0-
E
°
_
_
�
§
-
2
0-
0-
§
.
y
E
§
.
._
9
0-
.
§
»
»
2
E
\
E
ƒ
ƒ
ƒ
ƒ
ƒ
ƒ
Co
E
?
/
o
/
/
�
CO-
7
/
E
Lo
Lo
/
/
/
m
CD
�
P'o ° Gm
cc) I C)-) I
ƒ
7
�
.�
§
%
2
_
§
j § a
\ \ /
/ //
m
cz
\
k � �
L cz
% cz
�
3 cz
¥/ \§
± g @ o
e � 2 2
@ 2 a)
cz
E \ E
a)
% £ / E
/ ƒ
2
o k f R
§ .7 Co
ƒ f
/ /
0- @ 6 / \
% / 7 / /
/ k � 3 /
a » o k
f
2 C) 9 \
/
/ 7 £ / 0-
@
R o = — —
o / 3
[ \ % % \
£ C g 2 2
% %.§
7 E §_
6 / k � / /
2 2 & 6 It
\
2
d
ƒ
ƒ
ƒ
ƒ
ƒ
2
ƒ
ƒ
ƒ
ƒ
ƒ
2
2
2
2
2
2
ƒ
ƒ
ƒ
ƒ
ƒ
ƒ
/
/
/
/
/
/
P'o ° Gm
cc) I C)-) I
ƒ
7
�
.�
§
%
2
_
§
j § a
\ \ /
/ //
m
cz
\
k � �
L cz
% cz
�
3 cz
¥/ \§
± g @ o
e � 2 2
@ 2 a)
cz
E \ E
a)
% £ / E
/ ƒ
2
o k f R
§ .7 Co
ƒ f
/ /
0- @ 6 / \
% / 7 / /
/ k � 3 /
a » o k
f
2 C) 9 \
/
/ 7 £ / 0-
@
R o = — —
o / 3
[ \ % % \
£ C g 2 2
% %.§
7 E §_
6 / k � / /
2 2 & 6 It
^Vol
17 cz
Fl
ti
OR
00
C\j
.0)
00
CY)
C)
lqzi
Cc)
Qg-
_0
<
2)
cz
2)
_0
U)
U�
C)
U
>1
"
U)
0
>1
C)
0
>
T—
cz
QL E
Uo
E
0
z
2!
<
,IJ ..
W
cz
W
cz
Ir
4—a
cz
3:
E
0
U)
—a
�/
Nn
O
O
O
0
0
0
0
0
0
O
0
0
0
0
0
0
O L
00
LO
00
O
H
O
CD
LO
CO
O
00
O
LO
O
T
L O
It
—
Cl)
00
�_
N
T
T
O_
M
O
N
T
^ E
.T
V
co
V
CO
�
T
i
T
T
L
7 Q
O 0
E
co
U
0)
T Q
E
O
cz
O X
CO �
cz
a)
'O^
N
Z
CO
E z
cz
U
O
cz
co
=
O (Z
O
U
L
LO L
cz
N :3
LO
a)
c
O
Iz
a9
co
co
co
O
O
T
T
N
N
T
0-
M
M
LO
M
01 A
I�
N
co
O
LC)
O
LO
O
LC)
�f
L
}
Q cz
L
00
N
O
a) U
L �,
O L
EF}
T
Q9,
T
Efl
(f}
6}
T
Q9,
T
69.
N
69.
N
69-
� (Z ('7
7 a)
N
69-
CO
Ef}
CD
T
O
It
O
T
CD
LO
V c
O
cz
V
O
O
II
. U
Q
L a)
w
Q
O
o C
cz —
Q
�
�
U
S=
S=
L LO
O O
a)
O O
T
a)
U (n
m
II N Z
U
a)
U
a)
L E
0
L
a
Qq
�J
�
cc�
C
L
W L
Z
O
a) LO Q)
Z T
N
co It
LO
c
�t y
a CL
x
U
O
O
O
O
0
0
0
0
0
0
0
0
0
0
0
0
01 j,
CO.
LO
00
LO
N
CO
00
O
T
I�
M
L i
co
O
co
I�
-,t
0o
N
CD
T
CM
O
M
O
O
LO
co
Ef?
Tp
Tp
Ef?
Ef?
Ef?
Tp
Tp
Np
O O
Np
Ups
It
—
O
M
UO
Q
H?
EF?
6)-
EF?
6)-
yy:y
T E Q
U?
69-
T
V
M
T
O
T L
II O Z
N
s a
a) T Q)
�}
c C
� y
U x
N
D
X
O
X
O
C
_a)
U
E
L
v
O
o
U
i
Z
LL
—
—
—
c�
O
Q
Q
Q
L
a)
L
a)
O
ref
ref
ref
♦V
�
eLf
O
O
O
-0
-C
U
a)
O
a)
O
O
C
C
C
c�
cZ
cZ
(n
7
O
S=
S=
C
u)
U
7
O
i
O
O
O
>
i
a)
Q
t
E
O
O
0
i
oi I-E
m
70
Cl)
cz
rr
O
Q.
Q.
El
LJ
O
0
n
O
E
m
Cl)
0
-1--i
Fl
0
Cl)
6 A
Atf
ti Ab
SOL
vI
cfl
147! 1
Fl
cz
U)
_0
QL
2)
ai
0)
C)
-1--1
0
cz
cz
0
m
>1
LL
C:)
>1 CY)
0
—C\j
LD
cz
o
U
co
<
N
U
0
0
WaIA
Rim
"r
z.
RIC-
Alk F� _
WI
w 5 +r
r\ r
�5 s
I
41N 000 R
low
Fl
s �
N
^
N
T
E
N
N
2
U
p
c
�
�L
o U
U
�
LO
0
T11
N
V
T
cz
.-
O
3:
O
m
6r
I
_ I)
WWI
Fl
17,
f Also, . �
l�
N
N
lqt
e
Q
Cfl
Cfl
T
N
2)
cz
J
};
.QL
2
N
U
p
c
cz
�C)
L°
Uo
U
cq
N
U
Is
i
I
Q
U)
O
i
n
low
N
Fl
6 e
" *j
O
07
N
U)
O=
0
2)
N
cz
i
D
C°
U
^a^y.-
o�
cz
�
U)
T
U
o
z
C
" *j
3
/V ,J
W
L
U
0
0
x
0
fy4
dd,
4p *`
O -
. 1
z _ _
O
U)
Z3
O=
2
2)
cz
D �Lo
Fl cz
o
cz N O O
rA
(Y^' `i
C)
70
r-
m "
m
'mw
IM
10
- .4.01 SOO, vw
W,
Fl
dY
F
QL
0
-0
D
C:
0
6
c)
cz
v0
C\j
cz
a)
0
()
QC
z
12
4-0
(D (f)
Fl
>1
0
cz
MIJ
E
0
_0
C:
0
0
U)
0
4—
0
6
z
bi
cz
> C)
1
C\j
{f)-
0
WE
i
\0
i
9
s V
If
fir
opt
a R
4
n l �
I
low
Fl
Nry`
T
O
U)
T
.rZ
D
LO
N
'rZ
rZ
r
N
=
cz
U)
N
�
v
D
>' o
U
0
0)
o
t
o6
cz
a�
N
()D-
�
cZ
o
0
U
z
2!
<
Nry`
I
0
Cl)
Em
Fl
((.l
AA
74 IAL
An
C\j
C)
C\j
U)
LO
N
(1)
=
cz
_0
U)
(1)
C)
cz
(1)
C)
cq
0
a)
..I i
0
.
(Z
Z3
o
0
U
2
z
2!
aC
74 IAL
An
M
i
C�
70
AJ
T
' ^
u J
�1
T
U)
LO
I. /
i
W
o
0
`v
U
.c
low
�
Fl °
O
`-
_�
T
�V
o
-
U
z
2
C
^Vol
dop
V
Fl
1 .16
0
Zry
IK
I Mat
�
co
LO
LO
A
cm
CD
CD
c z
_0
CD
m
0
>' 00
�
0
C\j
CZ
C.0
(Z
0
0
U
z
2!
aC
h
'gym
fr
z
e
cz
Cl)
U
70
i
H
r
rr
m
i
U
Cn
Fl
T
lqt
ap
N
U)
N
c�
U)
Q
2
cz
N
v
>�
.o
>
°�j
O
o
c�
Cz
O
O
U
z
—
aC
0
0
cz
I
0
C
.0
W
rr
C3 0,51
Nk
"�M - ti5 ffS M
. '
n�
°
co
co
J Lid r
N
N
c� id � N
2
N Q Cz
U) o cz
o
0
Fl
i
cz 0
U Z � 0 Q
r
`�i,
s.
L
.�
4v
cz
CY)
co
Qc)
lqzi
Z3
_0
<
U)
_0
Z3
>
Fl 1! 7 CJ
QL
cz 0
() z E
zk
6 6
2)
2)
cz
C)
>1 C)
cz
o
<
OF
a
^z
W
L
cz
L
cz
z
0
L
U
70
0
0
6r
r �
O
O
U
.0
O
cz
U
3
of
At
AL
to �L
w
Y`* f
t�
t
1•��. F
' . Oo
r.
.Y.
+ e.
Fl
00
00
J
dY
r
N
{�}
N
Q
2
cz
N
U�
U
O
N
O
.�
�, O
N
QL
cz
0
O
U
z
aC
Ply" t.
s.
Cl)
W
Cz
AM
+,, '
so
r
4
W�
.fi $
Fl
i N l
N
i J
cz
O
U�
T
O�
►-
0
ti� ip
LCIIVIO
T
Qg-
W
2)
L
U
c�
0
qqt
J
LO
I
^0
5W
G
,
}+
i
a
^�
W
U)
"
—U) o
Z3
o
i
N
C�
O
Q
E
U
z
N
i J
cz
O
U�
T
O�
►-
0
ti� ip
LCIIVIO
T
Qg-
W
2)
L
U
c�
^Vol
i
0
0
Cl)
cz
H
. -
C4,
IN
It
4,
ri
-SN
41L
AL
tl
",,,Ooc)'D
co
C\j
0-)
C6
_0
a )
2!
id
0)
<
cz
0
>1 C)
p t
0
>
Nom--+
czFl
0
cz
0
z
^Vol
17 cz
Fl
ti
OR
00
C\j
.0)
00
CY)
C)
lqzi
Cc)
Qg-
_0
<
2)
cz
2)
_0
U)
U�
C)
U
>1
"
U)
0
>1
C)
0
>
T—
cz
QL E
Uo
E
0
z
2!
<
a
�4
70
0
0
QL
Cl)
t
A,
'i 4IN
ste
r
411p
6
2)
cz
C)
>1 C)
o
WE
m
•
6
2)
cz
21
C)
C)
C5
_0
id
<
U)
>1
U)
0
14
i
C\j
E
cz
0
E
(—)
z
ste
r
411p
6
2)
cz
C)
>1 C)
o
WE
m
•
6
2)
cz
21
h
0
0
U
CI)
U
CL
U
M
2
5W
G
00
rn
C
T
W
L
U)
0
.L N
l..L
N
2)
L
cz
O
U�
>, o
T
o
►—
7 Alp
W
2)
L
U
cz
�V
5
ee
o
'
cz
o
-
U
z
00
rn
C
T
W
L
U)
0
.L N
l..L
N
2)
L
cz
O
U�
>, o
T
o
►—
7 Alp
W
2)
L
U
cz
-WOO
Ir
2)
V J
Cl)
r
V )
4
M1
� 4
,b .A
�s
4
Fl
W
cz ,L�.�{
J
C�
N
cz 0
AMA:
es
C�
N
Q
0
N
Q
'a
�, k�.N "
6�4
1
a
ta,
i -
N
cz
O
U�
>, L6
—0-)
��
C0
G
T
T-
6
U
cz
W
L
cz
m
� ^-
V )
W
W
W
AM
rr
^L
W
Mcz
W
LO
lqt
N
d?
T
�o
W
T
Ni
N
N
CD
cz
J
,
C�
�
�
N
Q
2
cz
N
s
>+ LO
-
Fl
°! ' -
o
> N
—
� oY
�
Q
cz
U
o
z
E
�
aC
h
'gym
fr
rr
cz
W
CD
cV ,L�.�{
J
C�
N
a�
oC
0
z
N
CY)
T
lqi-
t' M
)
C�
N
Q
Z3
0
N
Q
'a
N
2)
Cz
C)
U�
>,L6
:E cy)
o
WE
L•�
T
T-
6
2)
U
cz
-
o
Fl
cz
-
U
W
CD
cV ,L�.�{
J
C�
N
a�
oC
0
z
N
CY)
T
lqi-
t' M
)
C�
N
Q
Z3
0
N
Q
'a
N
2)
Cz
C)
U�
>,L6
:E cy)
o
WE
L•�
T
T-
6
2)
U
cz
L
O
cz
C')
lqt
T�
co J
L ,
LO
N
U)
T
W
CD
cV ,L�.�{
J
,
2
Q
(Z O
CU
C7�
.� s,
i
o
�>
�, �
U
-
Fl u-
O
0
L N
— T
N
cz
Q�
+�
cz
cz
Uz
O
2
Q
3:
O
m
6r
t
V
x .
�a7 y
Fl !.
(l
ti ooto
PP
CY)
lqt
co
L
C'7
CV
CU
�
CD
cz
J
2
Q
(Z C
U�
U
>-
O
O
'i
�, C'7
O
N
N
cz
Q�
cz
O
O
U
z
2!
aC
PP
h
vz
�I
0
U
cz
0)
0
a�
0
a
i
U
Am
70
i
D
YIlk
N4-11
z
•� .• kit
r
W
O
J
V/r/�te�
!
o
T
T
^0
5W
�+
L
Q
2
c
21
U
O
$
�,.
-
O a�
�>
> O -
i
Nom--'
cz
T
cz O
o
ILL
0 Z
Q
4 r
i
(^0
1
i
D
N
-
: or
Ilkw
A
y
�f
}
1
W
0
CV
(D
J
00
r
N
N
c�
id
�
N
Q
2
cz
N
U)
o
cz
o
0
>1 o
-
i
>
C\j
cz
Cz 0
ILL
0 z
aC
O
0)
Cz
rn^
V )
ii
O
U
Cz
m
�I SF 41P
46
00
00
o aY
J � r
C'7
Z3
N
C� id � N
2
N Q Cz
o - >, O
o �> — T
i
�E
= U 0 Q
No
\A�
�I
W
m
�U
L
.cz
U
n�
W
AM
t:.'
N
a�
1
CA
L 7vN
0%
o
° L
k�
co
0
co
o
cfl
J
T
T
^0
5W
G.{
^^''
�+
L
Q
2
c
21
U
U�
cz
0
o
�>
o U
Fl -
Nom--'
cz
i
T
Cz O
U z
aC
a
N
Q
N
Q
cn
3:
O
N
LL
cm
O
r�rr
U
Cn
Q
cz
m
Cn
cz
Q
J
I
^0
5W
G
C)
L6J
W
L
U)
0
.L N
Q
'a
N
2)
L
O
U�
>, o
cz
O�
►—
T
Qg-
W
2)
L
U
cz
�V
5
ee
cz
o
U
z
C)
L6J
W
L
U)
0
.L N
Q
'a
N
2)
L
O
U�
>, o
cz
O�
►—
T
Qg-
W
2)
L
U
cz
C)
70
(1)
D
U♦♦ )
(1)
0
H
10,
ti rt�
I
A
Fl
..l
01-
0
_0
_0
>1
" U)
0
cz 0
() z
A V,
MPP'
vM&
L
LO
N
N
L6
U)
0
C\j
E
QL
'a
6
cz
= C)
C)
>1 C)
o
WE
0
W,
Qg-
6
21
f
C�
W
O
Cz
AM
_U)
i
cz
G
2
N
c�
N
Q
U)
0
.L N
l..L
N
2)
cz
� O
U�
>, o
T
O
►—
•
N
2)
U
cz
c�
ee
Cz
O
-
U
z
c�
N
Q
U)
0
.L N
l..L
N
2)
cz
� O
U�
>, o
T
O
►—
•
N
2)
U
cz
U
U
O
Q
w
i�
1
II
M'
00
�
N
Co
m
2
0
lqzi
co
Qg-
C
N
id
N
Q
2
cz
.�
�
cn
o
�
•>
-
>, o
-
Fl u-
p t
O
N--+
om T
cV
i
U
z
0
Q
=
i
U
cz
L
U
cz
C/)
_0
a)
Cn
Cn
m
1 le
Fl
s �
a
T CRT
Ilk
00
N
.0)
cy)
cy)
2
r�-
lqzi
cY)
Qg-
N
N
Q
2
cz
U�
U
O
O
.�
>c:)
N
cz
1..L
cz
`V
0
U
z
aC
U
i
-1--r
U)
-1--j
Q
Cz
m
4�
70
Cz
i
AJ
.P
N
cz
rr
��
C�
cr
W
:0 R*
c�
LL
O ^,••
CZ
}� W
-cn
C
E -0
00 C:
cn cz
5 4n
-0-0
cz
o -cn
�o
CZ
Qcn
.
Fl
O .
�T
O
�N
W T
CZ
cz
O C:
_ O
U�
CZ
O�
-1--j (n
-0 cn
Q o
cz >%
CZ CD
cz
E��
CZ
-0 —0
0— 0
4--j :3 E
cz 0 0
E 3:
cn a�
O .V O O
Cn>LO�
._ a) LO
cn 60-0-
L ^,
O
cnU +�
O
cn TZ
00
C:_ i
0— cn O
� (D U
�Occnn
(n }' CZ
o E-
0 O
o��
00 cn
T o i
cz C:
0
�E�
0 cz
O " O
.
.cn
cn -
O0
O
E
O -
0-
O
4--aO
cz "
%+—o
0 -1--a
O
}' o
�U
.
cz
O
O
O
O
cz-0
cn
O
O
O
-0-0
W
cn
CZ
CZ
cz
O
O
>
U
O
CZ
cz >%
CZ CD
cz
E��
CZ
-0 —0
0— 0
4--j :3 E
cz 0 0
E 3:
cn a�
O .V O O
Cn>LO�
._ a) LO
cn 60-0-
L ^,
O
cnU +�
O
cn TZ
00
C:_ i
0— cn O
� (D U
�Occnn
(n }' CZ
o E-
0 O
o��
00 cn
T o i
cz C:
0
�E�
0 cz
O " O
.
.cn
cn -
O0
O
E
O -
0-
O
4--aO
cz "
%+—o
0 -1--a
O
}' o
�U
.
i 10
1
-1--+
U)'+—
U)
_0 cz
(D O
c�
'O N
O T
O O
N
cz
.SC)
.20-0
O
-0 -
N N�
CZ
x0 Q O
Q- CZ
Q
Q� O
OD
r-�
�
�
CN
I--
—
OD
CI
QD
-T
-
-T
QD
9}
OD
0
m
4i a
I-�
N
N
CA
CN
LO
CZ
-0
x
CD
CD
m
zm
c
W L) m
x L
W
0 m
0 �
OD QD
00
CY) m
OD
CU
co
ps
low
Fl
Vow&..
0
m
�(1)
—00
U)
0
a
0
U)
Q
U)
U)
U
CZ
-0
x
0
U�
U
W
cz 0)
C
U
U i
(
-0
U)
12)
CZ (1)
N
N
'>
N2)
cz >
-_+ 0
cz cz
(1)
C-)
3
cr-
ps
low
Fl
Vow&..
0
�(1)
—00
U)
0
cz
U)
Q
U)
U)
U
CZ
-0
O-0
0
U�
U
O
cz 0)
C
U
U i
0
-0
U)
O
CZ (1)
N
N
0) U) Z3
N2)
cz >
-_+ 0
cz cz
(1)
C-)
3
Q��
0cz
�C�
a cz
U) -1--' 4- j
--
� O
czE.E
0E
UON
U -0 -C
(n��
N
N
ON.U)
OOi
U) O�
-0
O
: � cz
U)
-0
j�=O
C)
'. (1)
i 10
O O 70
W C �--i
�--+ V }' L5 E - +- T +
> X O -0 N },
4) (D .� E O
cn E O � E Q
O O O O Q) 070
> cn O C
Q� CZ 70 p r r r Cn cz
> -moo Apo �
cz _0 O 0— O
cz E o)O U�
06 m %+- C 0) C: CZ
-
�oncz mo a�
},�o� O�
o o cz C) cz
.�
CCU. >E cn O .
cz o }, O cz O O }, -p p
._ o�� cn
— CZ cn E
cz cp �_ O " 0
cz � � o
>., '70- > -0 E 0 0
U 0 CZ 70 Q O O >
cl) O -Ln %+2 c- (1) cz cn w on � (1)
W
1
i
`, s
im
0
-1--+
cz
Cn
c
0
u
U
N
U
N
C
0
Q
i
o .
3� E O
O
Cn `~
O
00
CZ CZ
� O
o�
o�
c�
mcz
0=.-,
T
0-0
OQ
O
N
U
N
O
U
O
CD
O N
E
cz Q
� Q
U�
CZ
cn i
}� L
o�
O O
� L.L
0
O N
N
U U
C/)
U0 Q
�--r CZ -0
cz
CZ N
.0 E"r-
0)
O O U
0 CZ
0 02
O
CZ
CZ 3: -"o
3: cz
0� o
-6--j cz m
",-o 0
CZ=
O U
ED C/)
C: O
O E
cz O
N
CZ
C -�
of
O �
O
CZ
CZ
U Q
00
C/)
QU
�OCZ
oU-
s=
C� 0 T
>CZ >
cz = cz
2
.
i
0
Cn
0
Q
cz
3:
E
0
-1--j
C/)
0
-1--j
N
CZ �
cz
E o
w
.
L
O Q
C) .-0
N — -0 cz
cn E .� o
!E 0 6 °� a) -0 ��� E
�+ �0- -�C�Z N� -1--U OC > -
Q c U �0) cn
cz N -o
U
QUQ -0 ���N �U� U.N
cz-- Q O 0 0 a) -C .� � 0)
O �Qa �.� O.LCZ �'icn O
U Q � � �� �: 0a,_
c� ��o
0-cz c: 3: -nE '
cn UN -0U0-- EOM Uu) cn � °°o cz X °O a�U
�cz° ---Q �
�'�'V 0U EUEO U
cZal = -0 " QU. —� ->0)" cn
Q
c0 Uc a) cn �� U-0 � �.�
�� ��� cn.— :3 U� °Q
� a�
U � 0
QQ° cz 6°�- "�' xa) � - cn z�
C� cn cn 0W� �
• • • • •
O
I
C)
Cl)
0
O
cz
N
O
U
N
N�
N
o
U CZ
O },
O)O
Q.-
cz
cz •>
O O
0E
c N
cz 0
:t–' Qcn
^
U+�
��czU)
U
czE0U)
X CU
O
cz
\ O)o
�1 cz T
O
0
O � VJ
Q
0
� �
N�Q�
CZ
O
QO
Q
O
Q
cn cn
cz
T
Fl �-
H
.•z
T
O
L
LL
N
U
X CU
O
cz
N
O
N
QO
Q
O
Q
E
Q .
Q
c z
.�E
cz
N�:
-0
-
. ^)
"
O
O U
O
•V�
N
c
0)
�
_0 cz
Q�
U)
�N
-0O
czo
"U
L-
C
ti
a)
E-C
-0U)
Z3 Q
_0
O
C)
cz
c-0
T
E
�
00
O
C)
cn ,
O
cn
—
�CY)
��
O
cz
�p
jN��
O
O
cz
VJ T
O
^'
W
0
- L
•�
U)
T
�QN
cz0
'0T
00
E
UN
:3—
N cz
N C)
N
NC:
cz cz
Ecz;-
U)
CZ
cz O
N
C'7
14
H
.•z
T
O
L
LL
N
N
O
N
CO
to
O
a�
C
ti
Lo
00
Nt
T
CL
�
00
O
O
O_
O
O
CL
U)
H
.•z
T
O
L
LL
�T
V ,
O
C)
Cl)
0
,gym
O
cz
N
O
rrU
N
U T
O O
cz
}, N
i T
CZ Z3
Ecz
L
O0
0
U) �--'
cz O
O'Q-
-0 C:
O
cz
N
�-0
o
Q
N o
CZ U)
- 'U
•> C:
00
QU
czo
U) >,
CZ U
Q
Li
i`
N N
O=
O
cz
.^
W
> CZ
N
000-
E
�CY)J
c� , o
-0 -0 cz
/1
�-- �= O
}� N
O
o
�Z-
O '
o N~
O�OU
-cz ,�
0Q�
L0
A`
U�
Z3
a)
O
U
(n C:
� ���
CZ 0
CCU
V�U)
cz
�CZ�QN�
°o���o
cz
O(D CZ�U)
C :) "
O Q°
C Y) �
E
{f} 0°
cY o
00
•�0E0.0
Quo
=�
�0TC:N
.UOU)
0�.Q
L
Z3
O
_0
CZ
00;;--
U)
0Z3
CZ
U)
O- cz
E
0-
Z3
cz >+0-0
U
U) 0
0
CZ
C'd
CZ
1--,5; cz
E r
r
.4
O O
ON��
E -0
0) O C:
}cz
0 0'� }+
O U
•� N
Q
o ��00
_ Q
000.00
CZ CZ CZ
cz
O)0c0�U)
Q
a� i'U) ._
�0) O�NC�
�QQ`~�N
a� U) CZ —0
r0 cncz .0
0��
cz E QL cz
C)-�
00•o U) CZ
cz
T 0 0
Q c� cn cz
-1--+
C= cz
O=
'U) -0
O
WczO^U)'
.^
W
> CZ
N
Cfl
E
�CY)J
O
-0 -0 cz
/1
�-- �= O
}� N
CZ CZ LL
L
T
�Z-
O '
o N~
O�OU
-cz ,�
0Q�
-0 E
U�
Z3
a)
O
U
(n C:
U O CZ
CZ 0
U)
V�U)
cz
�CZ�QN�
°o���o
C :) "
O Q°
C Y) �
E
{f} 0°
cY o
00
}, }, O
czcN
. �:: O N
>OQ
�0TC:N
U og-w
L
..
i 10
U) N
CIO
cz
C U) cz O
, w cm � � QL -0 cz � -� 0
cz -0
�
cz 0
(m N -1--i
■ '� -O -E O
r E 0-0
cz
cn cm In o �0 ,_�
0 �C/) cz o -00
cz
Co
�. 07 o
_ >, o
i�=U) oa'o�U,��� a�i�� cz
�, coo 0) CZ � � CD J
a� o
x � -��o�o CZ
cz 0 CZ
E� cz
CZ �� �� "CD E ��0.c�
CZ
E N cz E � N N cz p N
0 CZ ^ (n Q. ^^'' +� ^^ CZ CZ �� �� cz
l..L }� W l..L T cz E
�JOULL.��E ;v00NQ
Fl
w
�
�
Oft
�
�
0
�
�
�
�
I
�ok
.�
\ Fl �R
g
�\
-
:�
� / 1
�
i
�\
\ � \k