Rancho Mirage City Council
October 19, 2023

Underestimate of Basic Trip Generation of Non-residential Component The DEIR estimates the trip generation of the non-residential component of the Project as if these land uses were aggregated in a single mega-shopping center of 3,139,000 gross square feet (lTE Trip Generation, 8th Edition land use category 820). One of the characteristics of the trip generation function for this shopping center category is that the trip generation per thousand square feet of gross leasable area declines with the size of center. For example, based on the trip rate function for this use category, the total daily trips for a 3.139 million gross square foot shopping center is 63,800 (as reported in the DEIR Appendix G).

However, if the total non-residential use in the Project were considered as two independent shopping centers each half that size (each 1,569,500 gross square feet for the same aggregate total of 3,139,000 gross square feet), according to the reference source relied on by the DEIR, each of these 'half-sized' centers would have a trip generation of about 40,000 daily trips or an aggregate of 80,000 daily trips. This is over 25 percent more trips than estimated by assuming the non-residential uses are lumped into a single unrealistically gargantuan mega-shopping center.

In all reality, the non-residential uses in the Project will be developed as a number of separately functioning components that may probably include a neighborhood retail center focused on a grocery store; a moderately large shopping center (say 1.0 million gross square feet) focused on two or three major department store anchor tenants and possibly including such uses as a bank, cinema and modest amount of office space; freestanding office development; freestanding big-box retail (such as say Home Depot or I KEA) , freestanding discount superstores (such as Walmart); and freestanding membership discount superstores (such as Costco). Such a likely mix of development would have even more trip generation than the 80,000 daily trips we estimated by treating the entire non-residential development as two independent shopping centers instead of one hugely oversized one. While the exact composition and configuration of the non-residential component of the development cannot currently be known, it is evident that the assumption of a single mega-shopping center made by the DEIR preparers grossly understates potential trip generation of the non­ residential component. Hence, this assumption is not consistent with the good faith effort to disclose impact that CEQA demands.

Overestimate of Intemal Trips
One of those assumptions is the presumption that 15 percent of the trips generated by the residential component of the Project would remain entirely internal to the Project and offset an equivalent number of trip ends generated by the non-residential components of the Project. Since these trips are presumed to travel only on streets intemal to the Project, they are assumed to not impact 53] J Lowt"\, Rnad, Union City. CA 9+587 tel: 51O.-J-89.9+77 f:l.I:: 51O.-/-1N.l)-I-7fi 60 61

2.0 Responses to Comments
Letter No. 7
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-244
12-3021
Mr. Richard Drury
January 15,2015

streets and highways outside the Project and are erased from the analysis at the trip generation stage.

The problem with the notion 15 percent of the residential-generated trips in a mixed use development might be completed close to home, is that this is considerably discrepant form actual traveling behavior in the Coachella Valley area. The Coachella Valley Association of Governments 2004 Origin / Destination Survey, a document referenced in the DEIR's Appendix G Traffic Study, shows that for all of Rancho Mirage, an area of 24.8 square miles, only

30.6 percent of trips generated at residences within the City are completed within City limits. In other words, an average only 1.23 percent of trips per square mile are internalized locally in Rancho Mirage. Contrast this with the Project area, an area of only about 1 square mile. Assuming 15 percent of the residential trips are completed internally in this Project area - 15 percent in a square mile - is more than twelve times the average rate per square mile in the City as a whole.

Other data from the Coachella Valley Origin / Destination Survey also points to the unreasonableness and insupportability of the DEIR's 15 percent internalization assumption. Average trip duration in the area for work trips is 24.5 minutes, 15.7 rninutes for home-to-shop trips, 15.0 minutes for home to school,

19.6 minutes for home-to-other and 20.3 minutes for all trips. In the Project area, the longest internal trip possible is a trip from one corner of the Project site to the diagonally opposite corner. Such a trip would be a distance of 1.41 miles. At a reasonable speed for internal streets of 30 miles-per-hour, such a trip would be completed in 2.83 minutes. That is only about 13.9 percent of the average trip duration in the general vicinity. And this is the longest possible internal trip in the Project area. If one assumes the average internal trip in the Project area is about half the longest possible one, then the average internal trip length would be 1.42 rninutes and about 0.71 miles. In a region where, according to SCAG data, only about 3.7 percent of all work trips are one mile or less, the 15 percent internalization assumption seems all the more implausible.

Overestimate of Attracted Passerby Trips
The DEIR estimates that 15 percent of trip generation for the non-residential component of the Project will be attracted from passerby traffic. It presents various rationalizations for this. However, if fails to account for a crucial consideration - whether existing passer-by traffic can reasonably sustain the assumed level of passerby attraction. In brief, the question is whether the numbers of existing passers-by can reasonably be expected to visit the uses in the site frequently enough to justify the actual numbers, not just the percentage, of attracted passers-by. Much of the data regarding attracted passer-by percentages is drawn from urban sites bounded from very high volume arterial roadways. Although some of these data confirm that various uses attract high percentages of their trip generation from traffic already passing the site, those rl~;\I·I'I(- • TR \NS!'\)RT.-\TI,)i'-.: • l\lANAGE!\ILr" I 531 I LowlY Road, Union Cit~·, CA l)-I-SS7 lei: 5lO.-!-S9.9+77 (a,\; 5ll1.-I-S9.9478 61 62

2.0 Responses to Comments
Letter No. 7
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-245
12-3022
Mr. Richard Drury
January 15,2015

percentages are as much driven by the amount of traffic passing the site as by the character of the land uses. So the sheer percentage of passer-by attraction is not transferrable to other sites purely based on land use characteristics, contrary to what the DEIR analysis assumes. To cite an exaggerated example, it would be ridiculous to claim that a regional shopping center generating 200,000 trips sited on two country roads each carrying an existing 100 trips per day in the existing condition would draw 15 percent of its traffic from passer-by traffic. To be sure, other growth in the area would increase the pool of traffic from which passers-by could be drawn, but assuming that is simply blaming the Project's traffic generation on other developments, which is an unacceptable assumption under CEQA.

In this case, the existing traffic on roadways abutting the Project is approximately 64,500 daily vehicles in peak season. In order to attract the assumed 9180 daily vehicles from passer-by traffic, about one of each seven drivers passing the site each day would have to call on some on-site use while passing the site on a trip to somewhere else. If the non-residential uses on the site were primarily gas stations, fast food restaurants, banks, mini-marts and groceries, such a frequency of visitation might be plausible. But if a substantial portion of the commercial usage of the site is office, specialty retail, research and development, flex-use and similar, this rate of passer-by visitation is unsustainable.

The preparers of the DEIR may attempt to assert that future traffic growth should be considered as part of the sustaining traffic base for attraction of passers-by.

However, much of the predicted traffic growth over the period of this Project's development remains, at this point in time, speculative. And presuming that the traffic from other projects will be there to be intercepted is in essence a blaming of the Project's traffic on other potential concurrent projects. Taken to extreme over multiple projects, this logic leads to a situation where nobody generated the traffic, they all just intercepted it.

Extent of Degradation of Traffic Conditions Concealed by Assumption of Rise in Peak Hour Factor to 1.0
DEIR page 5.14-18 and DEIR Appendix G page 5-5 both state that the peak hour factors used in the intersection Level of Service (LOS) calculations that form a primary basis for determining traffic impacts were as observed in the existing traffic counts for the peak hour operational analysis of existing and year 2022 conditions. However, the narrative also indicates that the horizon year 2035 analysis a peak hour factor of 1.0 was assumed instead. The importance of this subtlety may not be obvious to the layman.

The peak hour factor is the ratio of the actual peak hour volume to four times the volume in the busiest 15 minutes during that hour. If traffic at an intersection is intense and congested for about 15 minutes of the peak hour, but notably less r I{ ,\ I-j' j (" • TR.\ ~SPl) R T .-\ T I ,)0: • 1\1:\ ~ A(;E .~Il..: I' ! 531 J Lowry Ro;,d. Union Citr, CA l)4-5~7 tel: 510.-:1-89.,-)-1-77 r,1.\-: 5!OA({9.9-1-7;) 62 63

2.0 Responses to Comments
Letter No. 7
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-246
12-3023
Mr. Richard Drury
January 15,2015

intense and congested for most of the other 45 minutes of that hour, the intersection might have a peak hour factor (sometimes abbreviated PHF in computation sheets) of, for example, 0.85. If traffic at an intersection is almost constantly intense and congested during the peak hour, the peak hour factor at that intersection will be at or approaching 1.0. If traffic within the peak hour fluctuates considerably, a given hourly volume and mix of movements will produce considerably worse congestion and delay over a significant portion of that hour than if the same amount of traffic and movement mix is spread evenly over that hour. So by assuming a peak hour factor of 1.0 in the long range analysis, the analysis is eliminating from consideration the effects of traffic fluctuations and concentrations within the peak hour that are observed in the existing conditions, leading to computations of lower levels of delay and potentially better levels of service than computations at the presently observed peak hour factors would indicate. Since the peak hour factor is a divisor in the complex computational process that determines intersection delay and critical volume-to-capacity (critical vic) ratios, assuming it to be 1.0 rather than the lesser values observed reduces the delay and critical vic reported in the DEIR's 2035 traffic analysis below what would have been indicated had the observed PHF values been used. Hence, this assumption is inconsistent with the good faith effort to disclose impact that CEQA demands. Furthermore, CEQA Guidelines 15125(a) state (in part):
"An EIR must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced, from both a local and regional perspective. This environmental setting will normally constitute the baseline physical conditions by which a lead agency determines whether an impact is significant. "
Since the peak hour factor values observed are one of the physical conditions that constitute the ordinary baseline specified by the above article, the substitution of a peak hour factor of 1.0 in the 2035 analysis is a violation of CEQA guidelines.

What Impacts Would the Traffic Analysis Indicate If the Four Inappropriate Assumptions Described Above Were Corrected?
What would the traffic analysis conclude if the three inappropriate assumptions described above were corrected? The effects of the four inappropriate assumptions described above are compounding and the outcome of correcting them cannot be estimated without redoing the entire traffic analysis computations. This is not within the obligation of the concerned public nor the time and resources available during this comment period. The Project applicant should redo the traffic study addressing these considerations and resubmit this portion of the DEIR for review in draft status.
rH;\ I-I'! (- • TR -\ N SI'l)H T .-\ T [l)" • I\I"\:-.J AGE !'.llf'.: ! 531J Lowr:: RO;h.-i. Uninll Cit:" CA 9+587 lei: 51O.+StJ,L)-l-77 I~l\:: SIll.+H9.9478 63 64

2.0 Responses to Comments
Letter No. 7
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-247
12-3024
Mr. Richard Drury
January 15,2015

Claimed Mitigation of Impactful Condition at Ramon Road - Da Vall Drive Intersection In Doubt
The DEIR identifies the need to add an additional southbound left turn lane on the southbound approach of Da Vall Drive to its intersection with Ramon Road in order to mitigate unacceptable conditions that would exist in 2035 and it presumes these will be carried out in a timely fashion. However, development of this additional lane may be problematic since scaled aerial photography indicates there may be insufficient space for development of such a lane in the existing curb-to-curb width and the roadway appears confined to that existing curb-to­ curb width by the Desert Memorial Park cemetery on the west and the newly constructed multi-use trail on the east.

Furthermore, the DEIR blithely assumes that this potentially infeasible improvement will be funded by others because the roads are eligible for Measure A and TUMF funds (though none are committed) and because improvements to Da Vall Drive are identified in the Coachella Valley Transportation Project Prioritization Study, though admitting the improvement is not currently identified for funding. Under CEQA, such uncertain funding (in essence, being on the "wish" list instead of on the "do" list) does not qualify an impactful condition to be presumed mitigated.

The DEIR Includes No Analysis of Traffic Impacts On Freeways and Freeway Ramps
Although the DEIR acknowledges Caltrans jurisdiction over the 1-10 freeway and its ramp systems, other than analyzing operations at intersections between freeway ramps and the local roadway system, the DEIR utterly fails to conform to Caltrans requirements for traffic impact analysis. Those requirements are defined in a document entitled Guide For Preparation of Traffic Impact Studies (Caltrans, 2012). The portion of those guidelines detailing when a traffic impact study of Caltrans facilities under Caltrans procedures and guidelines must be performed includes the criterion that when a project generates over 100 peak hour trips assigned to a State highway facility, a traffic impact study of that facility is needed. Since DEIR Appendix G Table 4.2 indicates the adjusted trip generation of the entire Project would be 3524 inbound and 3433 inbound trips in the pm peak hour and Figure 5.14-4 indicates that 7.3 percent of those trips would utilize each direction of 1-10 west of Bob Hope Drive and 9.3 percent of those pm peak trips would utilize each direction of 1-10 east of Ramone Road, the Project's contribution to pm peak traffic on 1-10 would be about 1155 trips or more than eleven-fold the criterion requiring study.

Given the significant volume contributed to the freeway, Caltrans may require freeway segment analysis, weaving section analysis and ramp and ramp junction analysis to be performed. The DEIR preparers should consult with Caltrans r I{ A 1· F j C • -r R \ N S!' U R T .-\ T r 1.);-": • 1\1 A N A (; E .r..ll.: K r 5311 Lowry Road. Union City, CA 9-+5;:\7 lcl: 5[0.-+89.9-!-77 f;l.\:: 51O.-I-tN.9·~78 65 66

2.0 Responses to Comments
Letter No. 7
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-248
12-3025
Mr. Richard Drury
January 15,2015
Page?
officials, perform the required analysis and recirculate the traffic section of the DEIR in draft status.

The Evaluation of Alternatives To The Project Is Inadequate Since the DEIR has not performed an analysis of the Project's impacts on the 1- 10 freeway system, it cannot be known if any of the Alternatives to the Project would avoid significant irnpacts the Project may have on the freeway system.

Conclusion
This concludes my current comrnents on the DEIR for the Section 24 Specific Plan Project. In surnrnary, the DEIR is deficient in multiple ways that require significant new information be added to the docurnent. Consequently, the revised docurnent must be recirculated in draft status for a full 45 day comment period
Sincerely,
Smith Engineering & Management
A California Corporation
Daniel T. Smith Jr., P.E.

President
rl~ ,\ j-)'! ( • -I R.\ ~ SI'Ul{ T ,\ TIl)l'..: • )\.1 A 1'1 .-\(;1:: !I. I 1.: l' I 5311 Lowry Road, Union City, CA 9-!-587 tel: 510.-1-80.9-1-77 f:1X: SIO..-I-tN.9 ... 118 66 67
68 2.0 Responses to Comments
Letter No. 7
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-249
12-3026
Mr. Richard Drury
January 15,2015

Attachment 1
Resume of Daniel T. Smith Jr., P.E.
531 J Lowry Road. Union Citr, CA 94587 tel: 510.-189.9-+77 C1X: 510.·4-/'::0.9-+70

2.0 Responses to Comments
Letter No. 7
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-250
12-3027
Mr. Richard Drury
January 15,2015

.~ \1 : [ I: N ~ i I ~ .: I: J{ I :'- \~ f· 1\:1 A N ~ G E Ivl [. t'-." T DAl"'IIEL T. SMITH, Jr.

President

EDUCATION
B/lcbeloo" of Srimce, ~gmdAppMd Sdenr~, Yale UDi\'m!I:y.. i967 Mao;1l!rofSdell£.e, TIim~ Planning, Uo.i~'8'5ify ofCa!ifontia, .Bm:~r. 1968 PROIESSION.u'REGIR'I'RATION
ClltifomiaNG. 21913 (a ... il)
ClIlifomia No. 91B (Tt-affu.)
PROfESSIONAL EXPERlE."JICE
Newdi'l No.. 1959 (Civil) W~biDg:oonNo. 2!Jo311 (Ch,il} Arimm MG. 2-2131 (~"il)
Litig:ablm GlIlrslIltmg.. Priltidi!!i [Ons;ultlltion. ffi\'e;ti!!;~a;: Mlli e;pat wilne;s te51imooy ill highwil}' dl!s.ign. transit &s~ and traffic e!Jgl.Jl.eer.in,g. matters mrooliing: cOlld~mID;uOOim.v.\)MngtI:imsporta.!IDnZrCC1l!:;S hs.us: tri'lffk accidelln inVDWlllg rughway ID!s:fgn or trnffk enginMing ktors:; ];md me- i!OO lfta'!!l~ ma.tte:li IM'Ohiing ./Ic-[I!~s;md Irn~rt.llion impacts;.pIIOOllgimd other traffic wd jIlIn~1i{ffimnt'El".:L Urblln Conidor Sladii:!IAJantlllms: Aulysis. Princip~l-m-cbm:ge rorSj/lte Route, (SR) HI:! F~;!bilitySt'ildyT a:

J5-:r:W11! fr~ill' ilhgnmarl: ~ north of.SiKI"MllI!!!;I~. Cnmultlln1 aD 1-1110 ltrtffi1Mi! Tnns:f~ C"'oceptPro,grnm.

Sm FnllociS(o, an. AAlEIS fur COO1pl~tm oH-200, ID!amli1ioB of Embmndero mway. ~ub.stitute light Iilli and CDlIlUJIItI!r :mil projeds.. Prinrjpal-in-dmge. SR 2JS ronii.lm :freewllyfl!:!:pm'SWay dl!;ignle!il~iromne.l:...jDl srudy.

Hajn-.ud (Calif.) Project iI!ilIlllgef. SarnJmKl'to -N~t ~ mw.a-modai trnn.spona.titm co:rridor !,rudy.

TrampOJtUilm plroJn1!t for I-OON \V51:THmfrutI Study. mlHubor Dm.:~ Tr<l:ffic Study. Parlb.nd, Oregnn. Project 1!IlIlBgH fur de:;ign. of SIlIfue. 5egmaJf of WPOdmrd COIridoT LRTy Detroit. Micbig;m.. DiI&~l!d ~1aJf on 1-1:0 ~ooD!l. Snll1egic C~r StIDiy (S"~<1U Ftand~oo).. US 101-S000"Im~y operatilm!i itndy, sa 9} mmay ope1MIon'> 5I:\lliy, I-SR-fi fi"eewq' <!pm;lI.a!fi ;'ltuliy, SR lS:! alig:am.eR sttlltil!£, SlIcraJJlHIto R"fD lighl rm !i:F\EI!lS :mtdy. 'f;,,5ll:OO Corri(lm: LRT AAi'E1S, ~-WanD Spring;-BART ~lm plllniEIR. SR3 70'19!.1- fre2w.ly i!.J.~ 5lUdy. and llidlmUlld PlIikway (SR 93) d!!sign srudy.

Ar" llimpormfiml PllID!I. Prinripal-in d&1l:ge-fur1mJ5!lortuitm. e!enmu;f}f City of us AlJge]5 GenEral. Plilil.

Fli'IIID!\T(IIi, s~ing llllC-005 rugl!s.t d.ty two -dernii!!i moo ll'st Cl!wury. ~ m.wager fur tte t:rimspOItltiml. -£!lemmt of 301}-ac~Misillm Bi'Ij' IiB'ilDpIlU!Bt in downtown. Smmntisco. Lfu-;i-an B;ry> ID"'Ol\'5? miLiiooJ. ¢ offiri!!l'corn.m:w::ial ~ 85CD dwelling rurifi.l!lld (omnIImity far:ilLfie"i. TraIl5;lllltaEiDll:fe.lru:re:!; include re1ocat.ion -of (iJIlIlI:IIIW rail st.Uion; O:l.teniIDn.ofMUNI·Mmo LRT: itIUniti-modal. ternri:na.! forLRT • .commute! li'Iil MId 1"0[-111 bus; m!lD'L'lII of a qmmer mile: ~atl!d ~ repiManmt by M-i'V ramps: and a oollkwlIll: l!ll.:internal :roi'idway tl;!!\'ImEk: OVE![-I:~ C015lririn.t!l inIpnsed by im :immW tidal basin~ :fJ:eewa)' :'imocffiJes ;md rail. :facili£il!5~ mil mnrept pms f-lJ£ 10,000 5IIIIl:tifrI!d pllrlliDg spoc:e;. .PrinripaI-m.d!M@! fur cirruJatiOOl pWJ. to- lIC(OOIl:lIKIIBte [) million gsf of {Iiiie&'"~l ~h in.&nmtolm Bella'lli!: (\Jlaib.). PImcipa1·in-c~ for €4 ilCIe, 2 million J!,'5! mu.~-u'il! mmpl~ .. fur FMC 3~ fD Sm JC6e: Imi!ll1atiru!al AbpOlt Pi:Dj&t maBa~er for tIimspOrtation e~ of SiKIilIllI!Illi) Capiml Mea: P!m fDr the slilt-!! govmnnanal-(-omp!e~ and fDr Downtown SmimJen.tD Rede'\.-Mlpmeni Plan. Pmjed: mamger fur Napa (e!illf.) ~ Plm CirculaEicm Elw!.eDt and Dlrn'nIDwn.

Riverfront Redi!"!.~ Pllm, 00 piuki~ progmn for OOThU~o£m-u Vlallliill: Creclt, 00 OOwnroWEl tr1l!EpJffi-iIDn pllIn fM Sill!; M1iteo ml H!da~¢m fur-oowEltoWnMo1mtEn View (Calif.), rortf<lffit. tir0111tiOO il!I.d gfetr pLm. fur Califu-rnU riMs irl"Da\<B., ~:SIlM Hill ami HaywMd, ilIIII f« Salem, Orl!gon.

I'i< ',), 1'1' • I '. v "~I', I ,',', > ":.:;::'
r [{ A I·]' I ( '11{ \N~I'\JR T.-\TIOi': • !\1.·\;-..Ji\G!::!\!lf' I 5J!! Lowry Road, Union Ci(~', CA lJ-1-5S7 tel: 5!O.-W9.Y~77 ['ax: S IO.-l-iN.9-+7~

2.0 Responses to Comments
Letter No. 7
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-251
12-3028
Mr. Richard Drury
January 15,2015
Page \0
Transportation Centers. Project manager for Daly City Intermodal Study which developed a $7 million surface bus tenninai, traffic access, parking and pedestrian circulation improvements at the Daly City BART station plus development of functional plans for a new BART station at Colma. Project manager for design of multi-modal tennillal (commuter rail, light rail, bus) at Mission Bay, San Francisco. In Santa Clarita Long Range Transit Development Program, responsible for plan to relocate system's existing timed-transfer hub and development of three satellite transfer hubs. Performed airport ground transportation system evaluations for San Francisco International, Oakland International, Sea-Tac International, Oakland International, Los Angeles International, and San Diego Lindberg.

Campus Transportation. Campus transportation planning assignments for UC Davis, UC Berkeley, UC Santa Cruz and UC San Francisco Medical Center campuses; San Francisco State University; University of San Francisco; and the University of Alaska and others. Also developed master plans for institutional campuses including medical centers, headquarters complexes and research & development facilities.

Special Event Facilities. Evaluations and design studies for footballibaseball stadiums, indoor SPOIts arenas, horse and motor racing facilities, theme parks, fairgrounds and convention centers, ski complexes and destination res01ts throughout western United States.

Parking. Parking programs and facilities for large area plans and individual sites including downtowns, special event facilities, university and institutional campuses and other large site developments; numerous parking reasibility and operations studies for parking structures and surface facilities; also, rcsident prererential parking.

Transportation System Management & Traffic Restraint. Project manager on FHWA program to dcvelop techniques and guidelines for neighborhood street trafiic limitation. Project manager for Berkeley, (Cali C), Neighborhood Traffic Study, pioneered application oftmffic restraint techniques in the U.S. Developed residential traffic plans for Menlo Park, Santa Monica, Santa Cruz, Mill Valley, Oakland, Palo Alto, Piedmont, San Mateo County, Pasadena, Santa Ana and others. Palticipated in dcvclopment or photo/radar speed enforcement device and experimented with speed humps. Co-author ofInstitute of Transportation Enginecrs reference publication on neighborhood traffic control.

Bicycle Facilities. Project manager to develop an FHWA manual for bicycle facility design and planning, on bikeway plans for Del Mar, (Calif.), the UC Davis and the City of Davis. Consultant to bikeway plans for Eugene, Oregon, Washington. D.C., Buffalo, New York, and Skokie, Illinois. Consultant to U.S. Bureau ofRcclamation for development of hydraulically efficient, bicycle safe drainage inlets. Consultant on FHWA research on effective retrofits of undercrossing and ovcrcrossing structures for bicyclists, pedestrians, and handicapped.

MEMBERSHIPS
Institute of TranspOltation Engineers Transportation Research Board

PUBLICATIONS AND AWARDS
Residential Streef Design and li·affic Control, with W. Homburger et al. Prentice Hall, 1989.

Co-recipient, Progressive Architecture Citation, kfission Bay Master Plan, with LM. Pci WRT Associated, 1984.

Residential Traffic Management, Slate of the Art Report, U.S. Department of Transportation, 1979.

Improving The Residential Street Environment, with Donald Appleyard et ai., U.S. Department of Transportation, 1979.

Strategic Concepts in Residential Neighborhood Traffic Control, International Symposium on Traffic Control Systems, Berkeley, California, 1979.

Planning and Design of Bicycle Facilities: Pitfalls and New Db·ectiol1s, Transportation Research Board, Research Record 570, 1976.

Co-recipient, Progressive Architecture Award, Livable Urban Streets, San Fmncisco Hay Area and London, with Donald Appleyard, 1979.
r [{ ,\ [. [. I ( • T R \ ~ S l' lJ R T .\ T r I.)" • 1\.[..\ N :\ (J I: !\I l f"' 1 531 I Lo\Vr~· Road. Union Cit:·, CA 9-l5;)7 tel: 510A:)9.9-+77 (ax: :,)IOAIN.9-lfo

2.0 Responses to Comments
Letter No. 7
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-252
12-3029

2.0 Responses to Comments
Meridian Consultants 2.0-253 Section 24 Specific Plan Project 044-001-13 March 2015
Comment Letter No. 7

Laborers’ International Union of North America (LIUNA), Local Union No. 1184 Richard T. Drury
Attorney, Lozeau Drury LLP
410 12th Street, Suite 250
Oakland, CA 94607
Response to Comment 7-1
As discussed in Section 1.0, Introduction , the EIS for the Project is being prepared in accordance with the Agua Caliente Tribal Environmental Policy Act (TEPA) (Tribal Ordinance No. 28) because the Project Site consists of land that is part of the Agua Caliente Indian Reservation (“Reservation”) that is under the jurisdiction of the Tribe. The Tribe, which is a sovereign tribal government, is not required to comply with CEQA. The Tribe elected to prepare the EIS in compliance with both TEPA and CEQA, in accordance with Section 15221 of the CEQA Guidelines, titled “NEPA Document Ready Before CEQA Document”.

Section 15221 of the CEQA Guidelines states that when a project will require compliance with both CEQA and NEPA, state or local agencies should use the EIS rather than preparing an EIR or Negative Declaration if the EIS will be prepared before an EIR or Negative Declaration would otherwise be completed for the project, and the EIS complies with the provisions of the CEQA Guidelines.

To facilitate the potential future use of the EIS to comply with CEQA by any public agency required to comply with CEQA, the Tribe prepared the EIS in compliance with the provisions of the CEQA Guidelines by organizing the document like an EIR, including all required content required by the CEQA Guidelines, such as providing a separate discussion of mitigation measures and growth inducing impacts, and complying with all procedural requirements, such as providing the Draft EIS to the Governor’s Office of Planning and Research State Clearinghouse for distribution for review by state agencies.

The separate expert comments attached to this letter are addressed in detail below.

Response to Comment 7-2
The comment identifies the background of the Project. The Tribe prepared the Project Description in accordance with Section 15124 of the CEQA Guidelines in order to serve as a basis for the environmental analysis.
12-3030

2.0 Responses to Comments
Meridian Consultants 2.0-254 Section 24 Specific Plan Project 044-001-13 March 2015
Response to Comment 7-3
The comment is noted and all potential impacts to the surrounding residents were identified in the Draft EIS, with the appropriate Mitigation Measures to reduce potential impacts, and provided a discussion of alternatives to the Project to avoid or substantially reduce identified significant impacts.

Response to Comment 7-4
Pursuant to Section 15002(a) of the CEQA Guidelines, the fundamental purposes of CEQA a re to (1) inform governmental decision makers and the public about the potential, significant environmental effects of propose d activities, (2) identify the ways that environmental damage can be avoided or significantly reduced, (3) prevent significant, avoidable damage to the environment by requiring changes in projects through the use of alternatives or mitigation measures when the governmental agency finds the changes to be feasible, and (4) disclose to the public the reasons why a governmental agency approved the project in the manner the agency chose if significant environmental effects are involved.

The Tribe as the lead agency has prepared this EIS in compliance with both TEPA and CEQA in order to analyze the Project’s potentially significant environmental impacts. The Tribe has identified appropriate Mitigation Measures and an environmentally superior alternative to reduce these impacts to a level of less than significance. The Tribe will consider these findings within the Record of Decision for the Project, which will be disclosed to the public. Therefore, the EIS has met the fundamental purposes of CEQA.

Response to Comment 7-5(a)
As discussed in Section 1.0 , the EIS for the Project is being prepared in accordance with the Agua Caliente Tribal Enviro nmental Policy Act (TEPA) (Tribal Ordinance No. 28) because the Project Site consists of land that is part of the Reservation that is under the jurisdiction of the Tribe. The Tribe agrees that it is the proper lead agency for TEPA purposes.

However, the Tribe, which is a sovereign tribal government, is not required to comply with CEQA 1 and is not acting as the “Lead Agency” for any “Project,” as both are defined by CEQA, so any actions taken by the Tribe are not subject to CEQA compliance.

1 28 U.S.C.A. § 1360(b ); see also Segundo v. City of Rancho Mirage (9th Cir. 1987) 813 F.2d 1387, 1393 (“It is beyond question that land use regulation is within the Tribe’ s legitimate sovereign authority over its lands. ”); In re Humboldt Fir, Inc. (N.D. Cal. 1977) 426 F.Supp. 292, 296 aff’ d sub nom. U.S. v. Homboldt Fir, Inc. (9th Cir. 1980) 625 F.2d 330 (“Indian trust lands are a Federal instrumentality held to effect the Federal policy of Indian advancement and therefore may not be burdened or interfered with by the State … Where a dispute involves trust or restricted property, the state may not adjudicate the dispute nor may its laws apply.”).
12-3031

2.0 Responses to Comments
Meridian Consultants 2.0-255 Section 24 Specific Plan Project 044-001-13 March 2015
Because the Sec tion 24 Specific Plan area is located adjacent to the City of Rancho Mirage (“City”) and annexation of some or all of the Specific Plan Area may be pursued at some point in the future, the Tribe voluntarily elected to prepare the EIS in compliance with bot h TEPA and CEQA, in accordance with Section 15221 of the CEQA Guidelines, titled “NEPA Document Ready Before CEQA Document.” While compliance with CEQA is not required at this time, Section 15221 of the CEQA Guidelines states that when a project , or a portion thereof, will require compliance with both CEQA an d NEPA at some later date, state or local agencies should use the EIS at that later date rather than preparing an EIR or Negative Declaration if: (1) the EIS will be prepared before an EIR or Negative Declaration would otherwise be completed for the project; and (2) the EIS complies with the provisions of the CEQA Guidelines. Based on the foregoing, these responses will address the CEQA compliance issues raised in the comments, even though any actions taken by the Tribe with respect to the Project are not subject to CEQA. The Tribe is merely responding to such CEQA comments in an effort to ensure that the Final EIS provides a thorough and complete analysis o f the Project’s potential impacts on the environment, and so that the Final EIS will be useful to any public agency that may be required to comply with CEQA with respect to the Project.

To facilitate the potential future use of the EIS to comply with CEQA by any public agency required to comply with CEQA, the Tribe prepared the EIS in compliance with the provisions of the CEQA Guidelines by organizing the document like an EIR, including all required content required by the Public Resources Code and CEQA Gu idelines, such as providing a separate discussion of mitigation measures and growth inducing impacts, and complying with all procedural requirements, such as providing the Draft EIS to the Governor’s Office of Planning and Research State Clearinghouse for distribution for review by state agencies. The Tribe also consulted extensively with the City on the contents of the EIS, to ensure that the City’s input on the environmental document could be included in the EIS, prior to the Tribe considering approval of the EIS or the Project.

At such future time that any discretionary action is proposed that would require any public agency subject to CEQA to comply with CEQA, that agency, serving as Lead Agency as defined by the CEQA Guidelines, would be responsible for reviewing the Final EIS to independently determine that it complies with all the provisions of the CEQA Guidelines.

Response to Comment 7-5(b)
It is neither appropriate nor necessary to designate a CEQA lead agency at this time because (1) any actions taken by the Tribe are not subject to CEQA compliance (as discussed in Response to Comment 7- 5(a)); and (2) it is premature for any local agency to assume a lead agency role (as discussed in more detail below in Response to Comment No. 7-5(c) regarding the Amador and Parchester decisions). 12-3032

2.0 Responses to Comments
Meridian Consultants 2.0-256 Section 24 Specific Plan Project 044-001-13 March 2015
Responses to Comment 7-5(c)
This comment overstates the state or local agency permitting authority for projects on tribal land as well as the holding in County of Amador v. City of Plymouth (2007) 149 Cal.App.4th 1089, as modified on denial of reh’g (May 10, 2007).

As discussed above, neither the state nor any local agency has any land use or CEQA authority over the Tribe’s lands, and it is premature to invoke CEQA for any non -Tribal activity because no local agency has proposed to approve any action with respect to the Project.

Amador involved land for which an application had been made for the United States Secretary of the Interior to take the land in trust for use by the tribe to build a casino. County of Amador at 1093-1094.

The court in Amador conceded that there was no activity by the tribe to which CEQA applied because “neither the taking of the subject lands in trust nor the Gaming Development require the formal approval of the City.” County of Amador at 1100.

Instead, the only activity in Amador that fell under CEQA was activity which the city had approved by contractually agreeing to perform the work under a municipal service agreement (“MSA”). “The public works and road vacation constitute a project subject to CEQA and the MSA constitutes the approval or contingent approval of the project.” County of Amador at 1100. The “project” for purposes of CEQA consisted of only those things which the MSA committed the city to complete rather than anything the tribe had proposed to develop on its own. County of Amador at 1097, fn. 6.

The court in Parchester Village Neighborhood Council v. City of Richmond confirmed the narrowness of the decision in Amador.

In Amador, the appellate court found the acquisition of trust lands for a casino development was not the ‘project’ of the City of Plymouth within the meaning of CEQA precisely because ‘ neither the taking of lands in trust nor the [casino development] requires the formal approval of the City ’ ... Instead, the municipal services agreement involved in that case was deemed to be subject to CEQA because it unconditionally obligated the city to vacate a portion of a city road and to remodel the city’s existing fire station. The agreement also conditionally obligated the city to construct connections to the casino ’s sewer and water systems and to increase system capacity to meet the needs of the casino development. ( Cite.) The appellate court ‘made clear ’ that the project for purposes of CEQA consisted ‘of the things which the MSA commits the City to construct.’
Parchester Village Neighborhood Council v. City of Richmond (2010) 182 Cal.App.4th 305, 314, as modified on denial of reh’g (Mar. 25, 2010).
12-3033

2.0 Responses to Comments
Meridian Consultants 2.0-257 Section 24 Specific Plan Project 044-001-13 March 2015
After recognizing the narrowness of the Amador decision, the court in Parchester held that the development at issue in that case, also a casino, as well as the related MSA were both outside the scope of CEQA because CEQA did not apply to tribal land. “In our view, the Tribe’s casino development does not constitute a ‘project’ of the City under CEQA because the City has no legal authority over the property upon which the casino will be situated.” Parchester Village at 313. “CEQA applies only to ‘discretionary projects proposed to be carried out or approved by public agencies....’” Parchester at 311.

The tribe was not a public agency.

The MSA at issue in Parchester Village was also outside of the scope of CEQA because it did not rise to the level of a CEQA “project.” The MSA “set no timeline for the construction of physical imp rovements and d[id] not obligate the City to undertake any specified construction project.” Parchester at 317-318. “While the MSA does indicate that the City agreed to support the Tribe’s efforts to acquire the land and to obtain the requisite approvals fr om the BIA and the Governor, this expression of support does not transform the casino into a ‘project’ so as to trigger the City’s preparation of an EIR.” Parchester at 313.

In the present matter, just as in Parchester , the Tribe’s proposed development is not a “project” under CEQA because (1) no public agency has regulatory authority over the tribal land and (2) there is no MSA or related agreement with a public agency, nor any other action of a public agency, proposed for approval that could be subject to CEQA.

Response to Comment 7-5(d)
As discussed above, no CEQA review is required at this time. The Tribe has exclusive jurisdiction over tribal lands, and there is no pending approval of annexation into the City by LAFCo as no application for annexation has been filed. There is also no action under consideration regarding any of the various potential approvals by the City . Thus, it is premature for CEQA designation of a “lead agency” at this time.

Nonetheless, the Tribe will revise Table 3.0-2 as indicated on Page 3.0-2 in Section 3.0 of the Final EIS to clarify that the Tribe will serve as the Lead Agency for TEPA purposes and that the City and LAFCo are potential future lead and/or responsible agencies. The Tribe will also add the Coachella Valley Water District as a potential responsible agency.

Response to Comment 7-5(e)
Once again, CEQA is inapplicable to the Project at this time. There is no rubber-stamping when the Tribe has sovereignty over its own lands.

Gentry v. City of Murrieta (1995) 36 Cal.App.4th 1359, 1397- 1398, as modified on denial of reh’g (Aug. 17, 1995), is inapplicable. The case involved the issue of independent judgment by each public agency 12-3034

2.0 Responses to Comments
Meridian Consultants 2.0-258 Section 24 Specific Plan Project 044-001-13 March 2015
after one public entity handed off “lead agency” designation to a second public entity. “[W]here two public agencies successively are lead agency for a project, they could likewise engage in ‘cooperative efforts,’ provided each agency exercises an independent judgment on the matters which actually come before it for decision.” Gentry at 1398. The case involved CEQA applicability from the start rather than land immune from state and local regulation due to tribal sovereignty, for which CEQA could apply in the future. Nevertheless, the Tribe and the City have engaged in “cooperative efforts” with respect to the Project’s environmental review, and the Tribe recognizes that the City or another public agency may be required to exercise independent judgment on the adequacy of the Project’s environmental review in the future, if any aspects of the Project “actually come before it for decision.” Response to Comment 7-5(f)
As discussed above, there is no “project” under CEQA due to the Tribe’s authority to regulate land use on its own lands. Tribal sovereignty also means the situation is not analogous to the commenter’s reliance on authority involving development by a private party for which public agency approval was required.

Response to Comment 7-6
Acting as the lead agency under TEPA, the Tribe analyzed potential environmental impacts of the Project through the preparation of an Environmental Impact Statement (EIS). The structure of the EIS follows the structure typically found within an Environmental Impact Report (EIR), pursuant to Sections 15120 to 15132 of the CEQA Guidelines. The Project’s potentiall y significant environmental impacts are analyzed in accordance with CEQA with feasible mitigation and alternatives identified pursuant to Section 15002(a) of the CEQA Guidelines. Evaluation of impacts associated with the Active Adult Community followed a p roject-level analysis, while the evaluation of impacts associated with the Tribal Planning Areas followed a program -level analysis. Mitigation measures to be enforced by the appropriate jurisdiction have been identified within the Draft EIS to feasibly red uce potential impacts to a level of less than significance. All identified M itigation Measures for the Active Adult Community and Tribal Planning Areas, as well as alternatives analyzed for the Project can be found within Section 2.0, Summary of the Draft EIS.

Response to Comment 7-7
The commenter indicated that the Project will result in “the release of a phenomenal 94,104 metric tons of carbon dioxide equivalents (MTCO2e) per year” per page 2.0-33. The commenter mistakenly adds the results of the three modeled scenarios together to result in a vastly overstated 94,104 MTCO2e per year. The Project proposed is a Specific Plan that will permit the development of the 577 acre Project Site which is divided into 8 different planning areas. The Active Adult Comm unity is a defined portion of 12-3035

2.0 Responses to Comments
Meridian Consultants 2.0-259 Section 24 Specific Plan Project 044-001-13 March 2015
the Project, while the Tribal Planning Areas are conceptual with a maximum amount of 3,138,600 square feet of commercial retail, office, restaurant, hotel, and entertainment uses, and up to 1,406 residential units. As indicated on Page 2.0 -33 of the Draft EIS which summarizes the conclusions in Section 5.6, Greenhouse Gases, Project operational GHG emissions for the Active Adult Community, Tribal Planning Areas, and Combined Development would be 8,879.39, 39,326.09, and 45,899. 94 metric tons of carbon dioxide equivalents (MTCO2e) per year, respectively; not the 94,104 MTCO2e per year as claimed in the comment.

The comment also misstates the status of currently adopted significance thresholds for GHG emissions.

As explained in th e Draft EIS, the SCAQMD has not officially adopted a threshold of significance for greenhouse gas (GHG) emissions, and therefore, there is not “a duly adopted CEQA significance threshold” for GHG emissions. Rather, CEQA Guidelines sections 15064 and 15064.4 calls for the lead agency to use “careful judgment…, based to the extent possible on scientific and factual data,” and “a lead agency should make a good faith effort, based to the extent possible on scientific or factual data, to describe, calculate or estimate the amount of greenhouse gas emissions resulting from a project. CEQA Guideline section 15064.4 also provides that the lead agency “shall have discretion” to determine the appropriate approach for assessing the significance of the project’s GHG emissions, which may include “a qualitative analysis,” “performance based standards,” or “a model or methodology to quantify greenhouse gas emissions.” Finally, CEQA Guidelines section 15664.4 states that the lead agency should consider, among other things, the following three factors:
“ (1) the extent to which the project may increase or reduce greenhouse gas emissions as compared to the existing environmental setting; (2) whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project; and (3) the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions.”
Here, even though the Tribe is not subject to the requirements of CEQA, its analysis of the Project’s GHG emissions carefully tracks and complies with the requirements specified in CEQA Guideline section 15064.4. First, the Draft EIS quantifies and discloses the amount of GHG emissions that will result from the Active Adult Community (8,879.39 MTC02e /year), the Tribal Planning Areas (39,326.09 MTC02e/year), and the combined total for the entire Specific Plan (45,899.94 MTC02e/year), and compared those emissions to the existing baseline environmental setting (no current GHG emissions).

However, this analysis alone is not sufficient to determine significance because impacts from GHG emissions are cumulative in nature on a nearly global basis, and therefore, all such GHG e missions assessments must be made relative to large- scale plans and programs designed to reduce impacts from GHG emissions. Accordingly, the Tribe considered the various plans, programs and standards, that have 12-3036

2.0 Responses to Comments
Meridian Consultants 2.0-260 Section 24 Specific Plan Project 044-001-13 March 2015
been proposed or adopted for analyzing the si gnificance of a project’s GHG emissions, and determined that the tiered approach proposed by SCAQMD provides the most appropriate model because it parallels the state’s commitment to reduce GHG emissions by an additional 15 percent from current levels by 2 020. Finally, the Draft EIS evaluates whether the Project complies with the climate action plans adopted by the City and the County of Riverside to reduce or mitigate the effects of GHG emissions.

As set forth in the Draft EIS, the Active Adult Community, the Tribal Planning Areas, and the entire Project as a whole were determined to not have a significant impact as a result of GHG emissions because under all three scenarios, the Project’s GHG emissions will be below the threshold of significance establishe d by the Tribe (as recommended by SCAQMD) and will be consistent with the climate action plans established by the City and the County of Riverside, after taking into account the Project Design Features and Mitigation Measures set forth in the Draft EIS.

In particular, the comment misinterprets the regulatory setting surrounding GHG emissions. The 3,000 MTCO2e annual threshold that the comment references is not published in SCAQMD Thresholds of Significance for CEQA projects, but rather, is suggested as an initial screening threshold for certain types of projects. In fact, the 3,000 MTCO2e per year is a screening threshold for residential/commercial projects whereas a screening threshold of 3,500 MTCO2e per year is suggested for mixed use projects.

The tiered level of GHG analysis presented by the previously organized GHG CEQA Significance Threshold Stakeholder Working Group (“ Working Group”) requires additional analysis if an individual project exceeds the initial screening threshold, as described in detail on page 5.6-14 in Section 5.6 of the Draft EIS. The initial screening thresholds are not the same as the ultimate threshold for determining whether a project has significant impacts from GHG emissions, it is merely the start of the analysis.

Here, the Draft EIS contains that additional analysis recommended by SCAQMD.

By way of background, SCAQMD organized the Working Group to evaluate potential strategies to establish a tiered threshold approach for land use development projects. The Working Group convened on fifteen occasions to deliberate on assigning a metric against which to compare a project’s GHG emissions, but ultimately the group discontinued its meetings without arriving at a conclusive solution.

The Working Group reviewed 798 Environmental Impact Reports (EIRs) and Mitigated Negative Declarations (MNDs) for projects submitted to the Office of Planning and Research (OPR). During the review, the Working Group excluded general, master, and specific plans from the analyses, “because they are comprised of large regional multiuse projects as opposed to individual projects undertaken at 12-3037

2.0 Responses to Comments
Meridian Consultants 2.0-261 Section 24 Specific Plan Project 044-001-13 March 2015
the local level.” 2 The Working Group analyses were specifically focused on individual residential, commercial, and mixed use projects. Therefore, even if the SCAQMD had dec ided upon a final threshold of significance for GHG, it would not be applicable to the Section 24 Specific Plan Project. The comment demonstrates a misinterpretation of the SCAQMD review process pertaining to the adoption of a quantitative CEQA threshold of significance for GHG emissions.

The comment did not identify the first two tiers to determine GHG significance. The first tier determines if the Project is exempt from CEQA, which the Project would not be if it were subject to CEQA . The second tier of analysis is to determine consistency of the Project with an adopted GHG reduction plan.

The Draft EIS and the responses below contain further discussion and clarification of consistency analysis with the County of Riverside Climate Act ion Plan and the City Sustainability plan, both of which are adopted, consistent with tier 2. The fourth tier of analysis proposed by the Working Group identifies three options: (1) achieve some percentage reduction in GHG emissions from a future, hypothetical base case scenario, including land use sector reductions from AB 32, (2) for individual projects, achieve a project-level efficiency target of 4.8 MTCO2e per year per service population by 2020 or a target of 3.0 MTCO2e per year per service population by 2035; for plans, achieve a plan -level efficiency target of 6.6 MTCO2e per service population year by 2020 or a target of 4.1 MTCO2e per service population by 2035, or (3) early compliance with AB 32 through early implementation of CARB’s 2008 Scoping P lan measures.

The GHG analysis provided in Section 5.6 utilized Tier 2 and Tier 4, Option 1. Further clarification related to GHG analysis is presented in the response to comments below demonstrating consistency of the Project with a GHG reduction plan (p er Tier 2 of the Working Groups tiered series of thresholds).

Emissions of GHGs from the Project do not exceed any applicable or adopted threshold and remain less than significant as determined in the Draft EIS, after taking into account the Project Design Features and Mitigation Measures specified in the Draft EIS.

Response to Comment 7-8
The comment incorrectly states that the GHG analysis in the Draft EIS is based upon reducing GHG emissions from the maximum level possible with buildout of the Project Site under the existing Riverside County and Rancho Mirage zoning and General Plan designations. To the contrary, the Draft EIS calculates and discloses a realistic assessment of the amount of GHG emissions the Project will generate, as compared to the existing conditions. Then, the Draft EIS analyzes the significance of the Project’s GHG emissions by using a “business as usual” comparison approach to determine consistency with the

2 Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #12. Wednesday, July 29, 2009. SCAQMD. 12-3038

2.0 Responses to Comments
Meridian Consultants 2.0-262 Section 24 Specific Plan Project 044-001-13 March 2015
SCAQMD guidance and AB 32, as discussed above. This comparison requires analy zing construction of the Project as proposed, including meeting 2008 Title 24 residential and non -residential building standards, but without implementation of Project Design Features, Mitigation Measures, or current (2014) applicable SCAQMD and CARB rules and regulations (i.e., SCAQMD Rule 403, Rule 403.1, CARB Tier 4 off-road engine requirements, etc.) designed to reduce GHG emissions to a level of less than significant. This analysis determined after the incorporation of Project Design Features, Mitigati on Measures, and exceedance of 2008 Title 24 standards by 15 percent, the Project would substantially reduce GHG emissions from the business as usual scenario, consistent with State goals, County of Riverside reduction goals, and the City goal of 19.8 percent reduction in City GHG emissions by 2020.

Response to Comment 7-9
The comment suggests that the Draft EIS uses an approach to analyzing the significance of the Project’s GHG emissions that “has been rejected under both CEQA and NEPA.” The comment both misstates the applicable authorities and mischaracterizes the analysis in the Draft EIS. The Draft EIS analyzes and discloses the GHG emissions from the Project as compared to the existing baseline of no GHG emissions.

Then, the Draft EIS utilized the appr opriate “business as usual” comparison identified in the Riverside County Climate Action Plan and the City of Rancho Mirage Sustainability Plan. In order to determine if a project is consistent with the Riverside County Climate Action Plan, a project must either incorporate project design features and mitigation measures that total or exceed a score of 100 points from the checklist, or a project must compare the business as usual year 2011 emissions to the project emissions utilizing an adopted air quality model to quantify GHG emissions. If quantified emissions are reduced by a minimum of 25 percent with Project buildout when compared to the business as usual scenario, then the Project would be found consistent with the Riverside County Climate Action Plan and less than significant. As further clarified in response to comments below, the appropriate baseline according to the Riverside County Climate Action Plan is year 2011 emissions, with which the Project was properly compared in order to determine GHG significance.

As discussed and analyzed in Section 5.6 of the Draft EIS, the City of Rancho Mirage Sustainability Plan established a framework for the development and implementation of policies and programs that will reduce the City’s emissions to 1990 levels by 2020, consistent with statewide reduction goals. The Sustainability Plan identifies 82 measures to be implemented over 8 years to reduce GHG emissions by

19.8 percent from business as usual by 2020. The Project’s identified Project Design Features and Mitigation Measures are consistent with the following “Spheres” identified in the City’s Sustainability Plan:
12-3039

2.0 Responses to Comments
Meridian Consultants 2.0-263 Section 24 Specific Plan Project 044-001-13 March 2015
• Where We Live: energy efficient residential lighting (LIVE -6), household efficiency Audit (LIVE -8), solid waste diversion (LIVE -9 and LIVE -10), development planning (LIVE -11), and water efficient landscaping, drought tolerant landscaping (LIVE-12, LIVE-13, and LIVE-14). • Where We Work: energy efficient commercial lighting (WORK -3), integrated lighting systems (WORK-4), car -pooling and mass transit (WORK -10), telecommuting (WORK-11), and the CVWD water efficient landscape ordinance (WORK-12).
• Where We Build: sustainable parking lots (BUILD -1), cool roofs (BUILD -2), new and efficient construction (BUILD-3), plan check and permit (BUILD-4), and green building program (BUILD-5). • How We Get Around: electric vehicle charging stations (MOBILITY -4), biking and walking (MOBILITY- 6), bike, walking, NEV CV Link (MOBILITY-7), van pools (MOBILITY-9), and car sharing (MOBILITY-11). • How We Govern: transit oriented development (GOVERN -16) and water feature efficiency (GOVERN-17).
• Where We Visit and Plan: resort management (RECREATE -4), visitor shuttles (RECREATE- 7), neighborhood electric vehicles (RECREATE -8), and water efficient system controls and drought tolerant landscaping (RECREATE-9 and RECREATE-10).
• How We Teach and Learn: commercial sector green business (LEARN-2) Implementation of Project Design Features, compliance with regulations, and incorporation of Mitigation Measures would ensure that the Project is consistent with the above identified City of Rancho Mirage Sustainability Plan GHG reduction measures to reduce emissions by 19.8 percent by 2020, as discussed in Section 5.6.

Moreover, none of the cases cited in the comment address the CEQA requirements for analyzing GHG emissions, including the “business as usual” comparison utilized in the Draft EIS to determine consistency with the applicable climate action plans. In the authorities cited in the comment, the lead agencies erred in comparing a Project’ s impacts to a more intense permitted use on the site, to determine that the Project would have a reduced impact as compared to the more inten se permitted use. That is quite different from the GHG analysis in the Draft EIS, which compares the GHG emissions and reduction measures to the goals and requirements of two adopted climate action plans to determine consistency with those plans.

Response to Comment 7-10
This comment refers to analytical review of the Draft EIS conducted by a subcontracted consulting firm, “SWAPE,” and provides an overview of their findings with regards to greenhouse gas emissions assessment. The comment addresses the methodology for determining whether a project’s greenhouse gas emissions are significant under Section 15064.4 of the CEQA Guidelines. Most notably, the comment recommends using the same tiered analysis proposed by SCAQMD, including the “business as usual” 12-3040

2.0 Responses to Comments
Meridian Consultants 2.0-264 Section 24 Specific Plan Project 044-001-13 March 2015
comparison the commenter asserted is inappropriate in the preceding comments. The comment goes on to assert that a d ifferent option under the SCAQMD’s recommended tiered analysis would be more appropriate. As discussed above, the Tribe determined that the Tier 4, Option 1 analysis was the most appropriate option for assessing the significance of GHG emissions for this P roject, and the CEQA Guidelines plainly give the lead agency the discretion to make this determination under CEQA.

The comment cites excerpts from two CEQA cases, Friends of Northern San Jacinto Valley v. County of Riverside and Center for Biological Dive rsity v. Department of Fish and Wildlife , related to the characterization of a GHG baseline and proper definition of BAU emissions scenario. Neither case involves a published decision finding any error in the approach to analyzing GHG emissions used in the Draft EIS. The Center for Biological Diversity v. Department of Fish and Wildlife litigation is currently being considered by the Supreme Court of California . The Supreme Court has not yet reached a final decision on the ruling, and therefore speculation about the validity of the GHG baseline assessment in that case is unfounded at this time. The evaluation of GHG emissions in the Draft EIS is consistent with the current regulatory framework, which is not undermined based on a possible future Supreme Court ruling. To the contrary, there is not one CEQA authority, in the Public Resources Code, the CEQA Guidelines, or case law, stating that the approach used in the Draft EIS is invalid. As such, the discussion of GHG emissions significance presented in Section 5.6 of the Draft EIS remains valid.

The comment goes on to suggest that comparing emissions of GHGs from Project implementation to a realistic BAU scenario would result in non -compliance with the GHG emission reduction goals of AB 32.

This claim is not s upported by calculations to demonstrate that the Project would in fact violate AB 32 objectives. The comment does not make reference to any local or regional Climate Action Plan to verify that Project emissions exceed local GHG emission inventory projectio ns for achieving compliance with statewide policies.

As discussed in Section 15064.4 , it is the lead agency’s discretion to determine the methodology and model during the preparation of GHG impact analysis. The commenter only states one option identified in the CEQA Guidelines a lead agency may use when assessing GHG impacts, which is the initial screening threshold of 3,000 MTCO2e/year (which SCAQMD has indicated would not apply to specific plans because it is intended to screen individual residential pro jects). The commenter fails to identify the other two options identified in Section 15064.4(b) that identifies, “whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.” Or “the extent to whi ch the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions.” As noted in Response to Comments below, the Tribe determined that consistency with the Scoping Plan and Updated Scoping Plan reduction percentages is the appropriate threshold for this Project. The Project 12-3041

2.0 Responses to Comments
Meridian Consultants 2.0-265 Section 24 Specific Plan Project 044-001-13 March 2015
was found consistent with this threshold based on a reduction of GHG emissions with incorporation of Project Design Features, regional and state regulations, and implementation of Mitigation Measures to the Project. (GHG M itigation Measures are provided in the Draft EIS as MM 5.6 -1 through MM 5.6-10, discussed in Section 2.0 and Section 5.6 of the document). The reductions exceed the Statewide goals of reducing GHG emissions by 2020, as specified in AB 32. Furthermore, as discussed in Response to Comment 7 -8, the Project was also found to be consistent with the City of Rancho Mirage’s Sustainability Plan that identifies implementation measures to reduce the City’s GHG emissions by 19.8 percent by 2020. The Project was also determined to be consistent with the County of Riverside’s Climate Action Plan for unincorporated areas in Riverside County.

Response to Comment 7-11
As discussed previously, the Tier 3 threshold referred to in this comment (3,000 MTCO2e/year) was not adopted by the SCAQMD and is not applicable to the Project. The Project is a specific plan, comprised of several types of land uses, and encompassing 577 acres. The SCAQMD acknowledged that general, master, and specific plans should not be analyzed for GHG impacts in the same way as individual projects due to their scale. As such, the Project does not exceed an applicable regulatory threshold established by the SCAQMD and does not cause any significant, unmitigated impacts with regards to GHG emissions. Consequently, the Project is not required to obtain emission reduction credits – or carbon offsets – to qualify for implementation under CEQA.

Response to Comment 7-12
The building design features discussed in Section 3.0 of the Draft EIS will be implemented as aspects of the Project. The language has been clarified in this Final EIS to reflect that the Project incorporated these features into its analysis of GHG emissions. This comment suggests mitigation measures that are discussed in the Draft EIS, such as passive solar achieved through building configuration (Draft EIS p age

3.0-27), LED lighting installation (Draft EIS p age 5.1-11), and stormwater retention/infiltration (Draft EIS page 5.5-11). Many of these measures are imposed on the Project as enforceable Mitigation Measures, as set forth in the Draft EIS at pages 5.6 -32 through 5.6 -35. The comment also mentions several Mitigation Measures that are clearly infeasible for the Project (i.e., wind turbines and solar panels in open spaces), reflecting a lack of familiarity with the design objectives discussed in the Draft EIS.

Contrary to the assertions made in this comment, a new Draft EIS is not warranted as no substantial changes to the Project have been identified. The purpose of this Final EIS is to update and clarify certain aspects of the Project analyses that raised questions during the public review period. The suggestion that the Project has significant GHG emissions is inappropriately founded upon a threshold that has not been adopted by the SCAQMD, and would not apply to the Project if it were adopted. As discussed 12-3042

2.0 Responses to Comments
Meridian Consultants 2.0-266 Section 24 Specific Plan Project 044-001-13 March 2015
previously, the Project is comprised of several land uses and cannot be evaluated in the same manner as a small-scale, individual project.

Response to Comment 7-13
The Traffic Study prepared for the Project (Appendix G of the D raft EIS) utilized the Riverside County Transportation Analysis Model (RivTAM) to generate the Project’s forecasted trip generation. This forecasted trip generation was used to evaluate Project- related impacts as discussed in Section 5.14, Traffic and Transportation in the EIS. With the incorporation of the applicable Mitigation Measures and Project Design Features, these potentially significant impacts on traffic are considered to be reduced to a level of less than significance. Pursuant to Section 21166 of the CEQA Guidelines, a supplemental EIR is required when substantial changes to a Project or its circumstances have occurred, or if new information that was not previously known has become available. The analysis in Section 5.14 determined that the feasible Mitig ation Measures proposed in the Draft EIS reduced all potentially significant impacts to less than significant. No new feasible Mitigation Measures have been proposed, nor has any new or substantially greater traffic impacts been identified. Therefore, a su pplemental environmental document would not be needed.

Response to Comment 7-14
The Institute of Transportation Engineers (ITE) trip -generation rates for shopping centers were not used to determine the future horizon year 2035 daily traffic projections th at would reflect traffic conditions upon full development of the Project. As stated in the Traffic Study ( Appendix G of the Draft EIS) as well as thoroughly discussed in Section 5.14, the RivTAM was used by AFSHA Consulting, Inc. (a firm approved by Riverside County to modify RivTAM) to develop total traffic volume projections for the future horizon year 2035. RivTAM was used to ensure consistency with regional transportation modeling and to avoid the need for subjective assumptions regarding which trip -generation rates are appropriate and what percentage of the future site traffic would be pass-by trips and internal trips.

RivTAM is not a land use based transportation model and does not utilize ITE trip -generation rates for shopping centers or any other lan d uses. The trip generation component of RivTAM uses detailed socioeconomic input data for the Project Site, as well as multinomial nested logit vehicle availability model, census household classification models, cross -classification trip production models , and regression trip attraction models on household and North American Industry Classification System (NAICS) employment data to estimate total person trips, including non -motorized trips, divided into 14 trip types. The traffic analysis zones in RIVTAM reflect SCAG modeling by Census Tract. Base year and future land use forecasts provided by individual jurisdictions and Riverside County are used in developing the socio -economic input data required by RIVTAM. The 2035 SCAG population and 12-3043

2.0 Responses to Comments
Meridian Consultants 2.0-267 Section 24 Specific Plan Project 044-001-13 March 2015
employment growth projections were allocated by area, based on the existing and proposed future land use forecasts identified by each city. Riverside County planners provided estimates for Tribal lands and unincorporated areas. RIVTAM reflects the transportation network shown in the approved general plans of the jurisdictions within the Coachella Valley. The socioeconomic input parameters used by RivTAM for the Project Site are provided in Appendix 2 of the Traffic Study (Appendix G of the Draft EIS).

As discussed on page 5.14-17 in Section 5.14 of the EIS and on page 4 -12 of the Traffic Study ( Appendix G of the Draft EIS), RivTAM is approved by Riverside County and the members of the Coachella Valley Association of Governments (CVAG) as the regional source for future horizon year 2035 travel demand estimates. RivTAM is intended for use for transportation planning purposes throughout Riverside County by all levels of governmental jurisdiction and by private entities and as a tool to determine the potential impacts of large development proposals, General Plan land use changes, and forecasting for Transportation projects. RivTAM has been calibrated and validated for the entire six -county southern California region. Thus, the trip generation forecast that was utilized to evaluate the Project -related traffic impacts was based upon the numerous socio-economic parameters for each of the traffic analysis zones within the Project Site. Accordingly, the non -residential trips generated by the Project are based upon accurate and valid assumptions and a supplemental EIS is not warranted.

Response to Comment 7-15
Please refer to Respo nse to Comment 7 -14. RivTAM was used to avoid the need for subjective assumptions regarding what percentage of the future site traffic would be internal trips. The traffic impact analysis discussed in Section 5.14 in the EIS addressed all of the future yea r 2035 project-related external trips projected by RivTAM. As discussed on page 5.14 -19 in Section 5.14 and page 4 -5 in the Traffic Study, the internal capture rate between the proposed residential and non- residential uses on - site would be limited by the total number of residential trips. The residential trips for the Project represent approximately 14 percent of the total amount of trips generated by all the proposed uses, therefore, the conservative internal capture rate of 15 percent of residential trips was assumed for purposes of analysis. Accordingly, the traffic impact analysis, specifically the use of the internal capture rate of 15 percent, presented in Section 5.14 and in the Traffic Study ( Appendix G of the Draft EIS) addressed all of the future year 2035 Project-related external trips.

Response to Comment 7-16
Please refer to Response to Comment 7 -14. As noted above, RivTAM was used to avoid the need for subjective assumptions regarding what percentage of the future site traffic would be pass -by trips. The traffic impact analysis discussed in Section 5 .14 in the Draft EIS addressed all of the future year 2035 project-related external trips projected by RivTAM. As discussed on page 5.14 -20 in Section 5.14 and 12-3044

2.0 Responses to Comments
Meridian Consultants 2.0-268 Section 24 Specific Plan Project 044-001-13 March 2015
page 4-6 in the Traffic Study, pass -by trips will be attracted to the commercial uses in the Project Site from traffic passing the site on adjacent streets. While these pass-by trips would be turning in and out of the site access points, these trips would not be new trips on the roadway network. For this reason, these trips were deducted from the background traffic when the site traffic was assigned to the adjacent roadways. The proportion of pass -by trips has been found to decrease with the size of the shopping center. While very large shopping centers, those with more than a million square feet of gross leasable area, have been found to attract as little as 19 percent of their trips from passing traffic, small shopping centers, those with less than 100,000 square feet, have been found to attrac t between 51 and 72 percent of their trips from traffic passing on the adjacent roadways. 3 The average pass -by rate for
shopping centers is 34 percent. 4 Depending on the type of commercial uses developed, up to approximately 25 percent of the commercial trips could come from pass -by traffic on the adjacent streets. Since the commercial uses anticipated on-site have not been established, a conservative pass-by rate of 15 percent was assumed. Accordingly, the traffic impact analysis, specifically the use of t he pass- by rate of 15 percent , presented in Section 5.14 and in the Traffic Study ( Appendix G of the Draft EIS) addressed all of the future year 2035 Project-related external trips.

Response to Comment 7-17
Exhibit C of the Riverside County Transportation Department Traffic Impact Analysis Preparation Guide5 includes a series of signalized intersection analysis inp ut parameters. The final paragraph on Exhibit C states the following:
“Actual signal timing and peak hour factors should be collected in the field and utilized in the existing and near-term analyses… A peak hour factor of 1.0 shall be applied to buildout traffic conditions.” As discussed on page 5.14 -18 in Section 5.14, t he peak hour factors determined from the peak hour traffic counts at the existing key intersection were assumed for the existing and year 2022 operational analyses. The traffic analysis used a peak hour factor of 1.0 for full development of the Project consistent with the input parameters specified by the Riverside Country Transportation Department.

The higher peak hour factor reflects future conditions with heavier traffic volumes distributed more evenly during the peak hours.

3 Stover, Vergil G., Frank J. Koepke, Transportation and Land Development (Second Edition), ITE, (2002). 4 Institute of Transportation Engineers. Trip Generation Handbook – An ITE Recommended Practices, (March 2001), p. 48-57. 5 Riverside County Transportation Department, Traffic Impact Analysis Preparation Guide, (April 2008), Exhibit C, p. 16. 12-3045

2.0 Responses to Comments
Meridian Consultants 2.0-269 Section 24 Specific Plan Project 044-001-13 March 2015
Response to Comment 7-18
The Ca lifornia Department of Transportation (Caltrans) is responsible for monitoring freeway performance and developing plans and strategies to address any deficiencies on State Highways and other State- operated facilities, as stated on page 5.14 -28 of Section 5 .14 in the Draft EIS. Caltrans evaluates development projects of local and regional significance to determine if they will impact the State transportation system and works with lead agencies to develop potential mitigation measures.

District 8 of Caltrans reviewed the Draft EIS and prepared comments in a letter dated January 15, 2015 (Comment Letter No. 3). Caltrans did not require a freeway segment analysis, a weaving section analysis, or a ramp analysis to be performed.

Caltrans typically requires an operational analysis of the intersections where interchange ramps terminate at arterials that provide access to I-10. Section 5.14 of the Draft EIS included an operational analysis of the Project -related traffic impacts on the I -10 interchange at Bob Hope Drive and Ramon Road, identified as Intersections 1, 2, and 7. These three intersections represent the constraining component of the closest ramps that provide access to and from I -10 in both directions. All three ramps in the Existing with development of the Active Adult Community are projected to operate at LOS C or better during the AM and PM peak hours, as identified in Table 5.14-6 in Section 5.14. All three ramps in the Existing with Full Project Development are projected to operate at LOS C or better du ring both peak hours, as identified in Table 5.14 -8. Intersection 1 during the AM peak hour and Intersections 2 and 7 during both peak hours in the Year 2035 with Full Project Development are projected to operate at LOS B or better, as identified in Table 5.14-12 in Section 5.14. Intersection 1 during the PM peak hour in the Year 2035 with Full Project Development is projected to operate at LOS D, as identified in Table 5.14-12.

The eastbound ramps are projected to operate at LOS A during the peak hours, as shown in Table 5-5 on page 5-12 of the Traffic Study (Appendix G of the Draft EIS).

The I-10 Route Concept Fact Sheet is currently in the process of being updated by Caltrans and will identify the future right -of-way requirements and a design concept to accommodate buildout of the local general plans with a target of maintaining LOS E during the peak periods in the urbanizing areas and LOS C in the rural areas. If the design concept achieves the goal of accommodating buildout of the local general plans, it will accommodate the P roject and all project alternatives at acceptable levels of service. The Project would generate less traffic than buildout per the adopted land use designations for the Project Site in the Riverside County General Plan and the Wester n Coachella Valley Area Plan.

Maintaining these levels of service will achieve a reasonable balance between desired levels of mobility and forecasted traffic with consideration of development abutting rights of way and constrained financial transportation resources. Accordingly, the Project would operate within the LOS identified by 12-3046

2.0 Responses to Comments
Meridian Consultants 2.0-270 Section 24 Specific Plan Project 044-001-13 March 2015
Caltrans for ramps along the I -10 during peak hours. No supplemental analysis would be required as no new significant impacts or substantially increased impacts were identified.

Response to Comment 7-19
LIUNA contracted an environmental firm, SWAPE, to evaluate the air quality analyses prepared for the Draft EIS. The SWAPE comments are attached to the LIUNA letter as Exhibit A . A portion of SWAPE’s review was focused on the valu es used to characterize emissions associated with construction and operation of the Project in the California Emission Estimator Model (“CalEEMod”). The comment provides an overview of the variables that SWAPE identified as being incorrect or requiring rev ision. The CalEEMod input files were revisited and updates were made as appropriate to maintain consistency with the air quality assessment in the text of Section 5.2, Air Quality of the Draft EIS. Specific responses to SWAPE’s comments and modifications t o the CalEEMod input sheets are discussed in Response to Comment 7-41.

The comments provided by SWAPE relied upon analyses that suffered from several methodological errors and misrepresented air quality impacts from implementation of the Project. This Final EIS contains a discussion of supplemental modeling performed to address the assertions made by SWAPE.

Upon incorporating the accurate and relevant comments into the updated analyses, no additional air quality impacts were identified associated with const ruction and operation of the Project. Appendix 3.0 attached to this Final EIS provides technical documentation of the calculations utilized to arrive at this conclusion. A detailed discussion of the methodologies employed to respond to the SWAPE comments is provided in Response to Comment 7-47, Response to Comment 7-48, and Response to Comment 7-49.

Response to Comment 7-20
This comment claims that emissions of criteria air pollutants generated during construction and operation of the Project were not accurately quantified, and suggests that these emissions were not adequately abated using the Mitigation Measures identified in the Draft EIS. Extensive supplemental analyses were conducted to evaluate the SWAPE comments pertaining to emissions quantification.

Updated CalEEMod development scenarios for the Active Adult Community, Tribal Planning Areas, and the Combined Scenario were processed. Results of the supplemental assessment for the Final EIS determined that the SWAPE comments lacked validity regarding determination of significance for air quality impacts. Findings and conclusions of the Final EIS air quality assessment are presented in Response to Comment 7-49.

The Draft EIS provides an extensive array of Project Design Features and Mitigation Measures to reduce emissions of criteria air pollutants and greenhouse gases. The comment does not make any effort to determine whether or not the recommended Mitigation Measures are feasibly applicable to the Project. 12-3047

2.0 Responses to Comments
Meridian Consultants 2.0-271 Section 24 Specific Plan Project 044-001-13 March 2015
In fact, several of the mitigation measures su ggested in the comment have already been incorporated into the Project, such as improved bicycle lanes (Draft EIS pp. 5.9 -12, 5.9-14, 5.9-17, 5.9-19, 5.9-23) and low VOC paints (Draft EIS pages 3.0-30, 5.2-25). Additional Mitigation Measures presented in S ection

3.0, Project Description of the Draft EIS include, but are not limited to:
• Energy Star appliances;
• Electric car charging stations;
• Solar roofing;
• Solar water heating; and
• Passive solar configuration.

It appears that the reviewer did not account for many of the Mitigation Measures that are already incorporated into the Project. The Mitigation Measures discussed in the Draft EIS are reiterated several times throughout this Final EIS. The Mitigation Measures remain adequate and reduce Project emissions of criteria air pollutants and GHGs to the maximum extent feasible.

Response to Comment 7-21
This comment erroneously claims that the Draft EIS did not calculate emissions of Toxic Air Contaminants (TACs) that will be generated during Project construction. Diesel particulate matter (DPM) is the primary TAC released in the exhaust of construction equipment. The CalEEMod – developed by the California Air Resources Board and the California Air Pollution Control Officer’s Association – produces estimates of CAP and GHG emissions for land use development projects. One of the chemicals that are quantified is DPM from construction equipment. Emissions of DPM for the Active Adult Community, Tribal Planning Areas, and the Combined Scenario were presented in Appendix B to the Draft EIS. This comment is incorrect in asserting that TAC emissions were not calculated in the Draft EIS.

Updated emissions estimates for the Active Adult Community, Tribal Planning Areas, and Comb ined Scenario were processed in CalEEMod for this Final EIS, and are attached as Appendix 3.0. Estimates of DPM emissions were used to prepare a screening health risk assessment (HRA) for nearby residential receptors during Project construction in accordance with SCAQMD and California Air Pollution Control Officers Association (CAPCOA) guidance. The United States Environmental Protection Agency (USEPA) promulgates the AERSCREEN software as the preferred screening air dispersion model; AERSCREEN was used to simulate maximum reasonable concentrations of DPM at off- site receptor locations during Project construction. The modeled concentrations were used to calculate cancer risks to adults, children, and infants living in the vicinity of the Project. The cancer risks to adults, children, and infants calculated in this supplemental screening HRA were 0.69 in one million, 3.85 in one million, and 6.53 in one million, 12-3048

2.0 Responses to Comments
Meridian Consultants 2.0-272 Section 24 Specific Plan Project 044-001-13 March 2015
respectively. The SCAQMD threshold of significance for cancer risk to an individual is 10.0 in one million, therefore the Project will not pose significant cancer risks to nearby residents. A thorough discussion of the Final EIS HRA formulation is presented in Response to Comment 7 -47, Response to Comment 7-48, and Response to Comment 7-49.

SWAPE’s calculations were reviewed and it was determined that the methodology suffered from several flaws, as discussed in Response to Comment 7 -47, rendering the results unreliable. The comment is unfounded in its assertions and does not accurately reflect cancer risks posed by implementation of the Project.

Response to Comment 7-22
The potential impacts to sensitive plant and animal species was analyzed in Section 5.3, Biological Resources of the Draft EIS. As discussed on page 5.3 -11 in Section 5.3 of the Draft EIS, two habitat conservation plans (HCPs) have been prepared in the Coachella Valley. The Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP) addresses approximately 1.2 million acres in the Coachella Vall ey and the surrounding mountains . Be cause approximately 69,000 acres of Indian reservation lands are not included in the CVMSHCP area the acreage covered by the plan is about 1 .1 million acres. The Agua Caliente Tribal Habitat Conservation Plan (THCP) addresses approximately 31,500 acres of land within the Reservation.

The THCP establishes conservation areas to be dedicated as habitat preserves which would be managed in perpetuity for the conservation of covered species. The habitat preserve would be assembled through land dedications, restrictions, or conditions on covered projects through the adoption of development standards, assessment of fees, and other mitigation measures to ensure the covered projects are approved consistent with the THCP. The Tribe is currently collecting mitigation fees to be used to purchase conservation lands to implement the THCP.

As identified in Section 5.3, Mitigation Measure MM 5.3-1 will require payment of the THCP that will be collected to purchase conservation lands to implement the THCP. Mitigation Measure MM 5.3-2 follows the US Fish and Wildlife Service (USFWS) protocols to ensure that an incidental take does not occur to a burrowing owl. Mitigation Measure MM 5.3 -3 requires breeding surveys to be conducted prior to construction to ensure that no impacts o r a take does not occur to a Loggerhead shrike. These Mitigation Measures are required to be implemented prior to construction activities to ensure that no significant impacts will occur to sensitive plant and wildlife species within the Project Site, and therefore, do not defer measures to a later date. Accordingly, the Project will result in less than significant impacts to biological resources. Please also see the responses to Comment L etter No. 8 regarding the analysis and mitigation of impacts to biological resources. 12-3049

2.0 Responses to Comments
Meridian Consultants 2.0-273 Section 24 Specific Plan Project 044-001-13 March 2015
Response to Comment 7-23
While this EIS follows the structure of CEQA, this EIS is prepared in accordance with TEPA with the Tribe serving as the appropriate lead agency. Pursuant to Section 15088.5 of the CEQA Guidelines, a lead agency is required to recirculate an EIR when significant new information is added to the EIR after public review and before certification. The lead agency must provide notice of the recirculation of the EIR pursuant to Section 21092 of the CEQA Guidelines. Potentially significant impacts related to air contaminants, criteria air pollutants, and greenhouse gases have been analyzed in compliance with CEQA within Section 5.2 and Section 5.6 in this Draft EIS. The Project’s potentially significant traffic impacts are analyzing in compliance with CEQA within Section 5.14 in this Draft EIS. Based on comments received on the Draft EIS, the Final EIS provides additional information to clarify the analysis presented in the Draft EIS. Any revisions or clarifications in the text of the Draft EIS can be found in Section 3.0 of the Final EIS. As presented in this Final EIS, no new significant environmental impact would result from the Project nor is a new mitigation measure proposed to be implemented as a result of the comments received. As clarified for air quality, greenhouse gas, biological resources, and traffic analysis, no substantial increase in the severity of an impact would occur nor was a feasible alternative or mitigation measure considerably different from others previously analyzed to lessen significant environmental air quality impacts identified for the Project. As discussed in the EIS, all analysis presented herein was based on facts provided by technical experts and on available research to support the identified environmental impacts. No new significant information has been added to this EIS nor has any new information become available that was previously unknown; therefore, the recirculation of a supplemental EIS is not required to further address these particular impacts.

Response to Comment 7-24
The comment is noted and will be reviewed by the Tribal Council in their consideration of the Record of Decision for the Project.

Response to Comment 7-25
This comment identifies a conclusion of the SWAPE reviewer that emissions of criteria air pollutants generated by construction and operation of the Project are not adequately mitigated. The comment is expanded upon within subsequent comments in the letter. Responses have been prepared to elaborate and clarify information regarding characterization and mitigation of criteria air pollutants from construction and operation of the Project in successive responses. As set forth in these responses, the Draft and Final EIS do adequately disclose, evaluate and mitigate construction and operational criteria air pollutants to the maximum extent feasible.

12-3050

2.0 Responses to Comments
Meridian Consultants 2.0-274 Section 24 Specific Plan Project 044-001-13 March 2015
Response to Comment 7-26
This comment suggests that the Draft EIS did not properly evaluate potential health risks to nearby sensitive receptors that may result from of using d iesel-fueled heavy equipment during Project construction. Estimates of diesel particulate matter (DPM) emissions are provided in the CalEEMod output files in Appendix B of the Draft EIS along with criteria air pollutants and GHG for construction and operat ion of the Project. To address comments received from LIUNA and SWAPE, certain parameters input to CalEEMod were updated to ensure consistency with the analyses discussed in the Draft EIS. Section 5.2 on page 5.2-42 provides a discussion of potential toxic air contaminant impacts on residents within the Project Site. The updated CalEEMod files are attached to this Final EIS as Appendix

3.0. Updates to Section 5.2 are provided in Section 3.0 of this Final EIS.

Emissions of DPM from construction equipment wou ld be spread out over the course of 18 years between construction of the Active Adult Community and the Tribal Planning Areas . Furthermore, the Draft EIS identifies that Tier 4 interim diesel equipment will be used to substantially reduce atmospheric releases of DPM during construction of the Project. To further elaborate on the analysis presented in the EIS, the CalEEMod output files were revised to clarify that estimates of exhaust DPM emissions during construction, and the revise d results confirm that the Project would not result in significant impacts to residents surrounding the Project Site. To clarify, the CalEEMod output files were utilized to prepare a screening HRA. Subsequent responses, and Response to Comment 7 -49, provide a more elaborate discussion of potential DPM impacts to nearby sensitive receptors.

Estimates of DPM emissions from construction equipment were extracted from the updated CalEEMod output files, attached to this Final EIS as Appendix 3.0 . As a conservative approach, and following SWAPE’s recommendation, equipment usage counts were doubled for the Tribal Planning Areas construction to account for the potential shortening of the construction schedule. An emission rate was calculated for each year of construction based on maximum daily emissions of DPM during that year.

Each emission rate was plugged in to AERSCREEN, the screening- level air dispersion model promulgated for regulatory purposes by the United States Environmental Protection Agency (USEPA).

The model produced maximum single -hour concentrations of DPM at downwind distances of sensitive receptors, which were converted to approximate maximum annual concentrations using a 10 percent scaling factor. Cancer risks were calculated for adult, child, and infantile exposures to the modeled concentrations. Over the consolidated 6.73 years of Combined Scenario construction, cancer risks to adult, child, and infant receptors were approximately 0.69 in one million, 3.85 in one million, and 6.53 in one million, re spectively. The SCAQMD threshold of significance for cancer risk is 10 in one million.

Results of the screening HRA concluded that no new significant air quality impacts will occur to sensitive receptors from Project construction. Accordingly, impacts will remain less than significant. 12-3051

2.0 Responses to Comments
Meridian Consultants 2.0-275 Section 24 Specific Plan Project 044-001-13 March 2015
Response to Comment 7-27
The Draft EIS provides an extensive discussion of Project Design Features and Mitigation Measures that will be implemented to reduce energy consumption and emissions of GHGs. Project Design Features are addressed in Section 5.2, on pages 5.2-25 to 5.2-26, and in Section 5.6 on pages 5.6 -21 to 5.6-22. These PDFs and Mitigation Measures substantially reduce the Project’s environmental impacts associated with GHG emissions. Please also see Responses to Comments 7-7 through 7-12, above, regarding the GHG emissions analysis in the Draft EIS.

The comment suggests that the BAU scenario defined for the Project in the Draft EIS was improperly characterized. The comment does not acknowledge or reference the appr oved and adopted 2012 Riverside County Climate Action Plan (CAP). The 2012 CAP provides a methodology for determining whether or not implementation of a project will result in significant air quality impacts. As originally discussed in Response to Comment 7-7, SCAQMD unofficially recommended a 3,000 MTCO2e screening threshold for individual projects. This screening criterion was incorporated into the 2012 CAP, but does not apply to large scale developments such as the Project. For those projects exceeding the 3,000 MTCO2e screening criterion, or those that are too large to evaluate against a simple metric, the 2012 CAP offers the following alternative for GHG emission quantification in unincorporated areas of the county to demonstrate compliance with AB 32:

Analysis of development projects not using the screening tables should use the latest version of the California Emission Estimator Model (CalEEMod). Two modeling runs should be completed. The first modeling run calculates GHG emissions at 2011 levels of efficiency using energy efficiency standards (Title 24) and the California Air Resources Board on road vehicle emissions factors (EMFAC2012) set at 2011. A second modeling run is required that calculates GHG emissions at Project buildout year levels of eff iciency and includes Project design features and/or mitigation measures to reduce GHG emissions such that the levels of efficiency result in a 25% reduction of GHG emissions compared to the model run using the 2011 levels of efficiency.

The 2012 CAP identifies 2011 as the BAU year that emission reduction strategies should be compared against. The baseline is defined by 2011 GHG emissions that are not reduced beyond Title 24 levels, as this was the regulatory framework for GHG emissions mitigation when the 2012 CAP was prepared.

Updated CalEEMod runs were processed for the 2011 Combined Scenario without mitigation beyond Title 24. The Draft EIS BAU scenario was conducted using a 2022 operational baseline as a conservative approach. Incorporating the 2011 base line, as recommended by the 2012 CAP, actually increases the unmitigated BAU annual estimate from 82,065.58 MTCO2e per year – as stated on page 5.6 -29 of the Draft EIS – to 96,236.10 MTCO2e per year based on the less recent CARB emission factors. The comment 12-3052

2.0 Responses to Comments
Meridian Consultants 2.0-276 Section 24 Specific Plan Project 044-001-13 March 2015
is erroneous in its interpretation of the Project BAU scenario, and the Draft EIS was overly conservative in using 2022 as the operational baseline.

The updated CalEEMod runs completed to supplement the Final EIS calculated that annual emissions of GHGs from the Combined Scenario after mitigation would be 46,481.27 MTCO2e. The 2012 CAP requires that a 25 percent reduction compared to the 2011 emissions be achieved through implementation of mitigation measures. The total annual 2011 Combined Scenario emis sions are 96,236.10 MTCO2e per year. Comparing the updated Final EIS operational GHG annual emissions (46,481.27 MTCO2e/year) to the 2011 scenario as recommended per the 2012 CAP guidance, mitigation measures for the Project will achieve a reduction of app roximately 52 percent in GHG emissions. This value is more than double the required 25 percent stated in the 2012 CAP, and no further consideration of mitigation measures is required.

Response to Comment 7-28
This Final EIS was prepared to address comments received on the Draft EIS, in accordance with TEPA.

Clarifications and updates presented in the Final EIS do not represent significant new information regarding environmental impacts of the Project. Because the EIS has been prepared in accordance with both TEPA and CEQA, CEQA Guidelines 15088.5 states when a Draft EIS must be recirculated and only if significant new information is added, such as:

1. A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented;

2. A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance;

3. A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the environmental impacts of the project, but the project’s proponents decline to adopt it;

4. The Draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.

None of these conditions apply to the Project with regards to air quality and greenhouse gases.

Information in the Final EIS has been updated to clarify information provided in the Draft EIS.

Accordingly, the Draft EIS does not need to be required to be recirculated prior to Project approval. As discussed in the Responses to Comment 7-5 above, if and when a lead agency under CEQA proposes to take any action on the Project, that agency will need to independently determine the adequacy of the 12-3053

2.0 Responses to Comments
Meridian Consultants 2.0-277 Section 24 Specific Plan Project 044-001-13 March 2015
existing environmental review under CEQA, including whether the Final EIS needs further revisions and/or recirculation.

Response to Comment 7-29
This comment refers to the air pollutants that will exceed applicable South Coast Air Quality Management District (SCAQMD) emissions thresholds of significance during construction and operation of the Project, and suggests that additional mitigation measures available that should be incorporated into the Project. All feasible mitigation m easures have been identified and, as determined in San Diego Citizenry Group v. County of San Diego (Aug. 26, 2013) 219 Cal.App.4 th 1, not every infeasible mitigation
measure is required to be discussed. Furthermore, Section 21002 of the CEQA Guidelines states a project should not be approved if there are feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects. The Project identified feasible mitigation to reduce air quality impacts during construction and operation. Implementation of the suggested measures identified in Comment 7 -31 would not substantially reduce these significant air quality impacts.

The definition of feasible, per Section 21061.1 of the CEQA Guidelines, means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors.

Response to Comment 7-30
The comment correctly identifies the mitigation measures to reduce si gnificant construction and operational VOC impacts. The Draft EIS did identify significant VOC impacts during construction of the Tribal Planning Area and Combined Project (Active Adult Community and Tribal Planning Area) scenarios. The VOC emissions durin g construction of the Tribal Planning Areas would be 126.21 pounds per day, 51.21 pounds per day over the SCAQMD construction threshold of 75 pounds per day for VOC.

The VOC emissions during construction of the Combined Project would be 278.94 pounds per d ay, 203.94 pounds per day over the SCAQMD construction threshold. The reported construction emissions in Section 5.2 included reductions from Project Design Features, SCAQMD regulations, and the identified Mitigation Measures to reduce the significant impacts to the extent feasible.

Response to Comment 7-31
As discussed in Response to Comment 7 -29 and 7-30, the identified VOC emissions during the construction phases for the Tribal Planning Area and the Combined Scenarios included incorporation of Project D esign Features, compliance with SCAQMD regulations, and reductions from the identified 12-3054

2.0 Responses to Comments
Meridian Consultants 2.0-278 Section 24 Specific Plan Project 044-001-13 March 2015
Mitigation Measures. VOC emissions during operation for all three scenarios included all Project Design Features, compliance with regulations, and reductions from Mitigation Measures.

The commenter identified three other mitigation measures to reduce VOC emissions. The use of zero VOC paint, construct buildings that do not require paint, and require the use of spray equipment with greater transfer efficiencies.

Project Design Feature PDF 5.2 -5 indicates that the Project construction contractor will be required to use low and zero VOC paints, finishes, adhesives, caulks, and other substances to improve indoor air quality and reduce the harmful health effects of off- gassing. Mitigation Measure MM 5.2-1 requires the use of paint with VOC emissions below the required 50 grams per Liter SCAQMD requirement; a minimum transfer efficiency of at least 50 percent for high -pressure, low-volume paint applicators by construction contractors; utilize construction and building materials that do not require painting; and prepainted materials. As discussed in Response to Comment 7 -30, implementation of mitigation still resulted in exceedance of SCAQMD thresholds by a minimum of 51.21 pounds per day under the Tribal Planning Area construction scenario and a minimum of 203.94 pounds per day under the combined construction scenario. As discussed in Section 5.2 on page 5.2 -46, the precise quantification of VOC emission reductions cannot b e determined accurately as it cannot be determined precisely how much prepainted construction materials and materials that require no painting will be used in the development of the Project. Under the assumption that the identified mitigation measures redu ce construction VOC emissions by a maximum of 30 pounds per day, the Tribal Planning Areas would still exceed the 75 pound per day VOC standard during construction by 20 pounds per day. The Project would continue to result in significant VOC impacts during construction for the Tribal Planning Area and Combined Project scenarios, with the incorporation of Project Design Features PDF 5.2 -5 and implementation of Mitigation Measures MM 5.2-2 and MM 5.6-10.

Response to Comment 7-32
The commenter incorrectly quotes information in the Draft EIS. The commenter indicates that the Draft EIS “claims no feasible Mitigation Measures are available to reduce…operational…NOx…emissions below SCAQMD regional thresholds (p. 5.3 -2)”. First, Section 5. 2, Air Quality, of the Draft EIS included the discussion on the environmental setting, applicable regulations, potential impacts, and mitigation to reduce impacts on air quality to less than significant. Second, M itigation Measures have been identified to reduce NOx, specifically M itigation Measures MM 5.2-2 that will require construction equipment to utilize Tier 4 engines or better during construction and Mitigation Measures MM 5.6-10 that will require the use of employment based trip and vehicle miles traveled policies for the use of alternative transportation to reduce operational NOx emissions.
12-3055

2.0 Responses to Comments
Meridian Consultants 2.0-279 Section 24 Specific Plan Project 044-001-13 March 2015
The commenter indicates that the Draft EIS states that the Project “implements all feasible mitigation measures and complies with all applicable SCAQMD Rules directed toward reduction of NOx emissions,” and that “no feasible mitigation measures exist that would further substantively reduce these emissions” (p. 4.3 -32). First, Section 4.0, Environmental Setting is 22 pages in length, so page 4.3 -32 does not exist. Second, Section 5.2 does not contain the quoted sentence identified above or in this comment. The Draft EIS does acknowledge that operational NOx emissions would exceed SCAQMD thresholds. Mitigation Measures were identified to reduce NOx emissions during all construction scenarios to below the SCAQMD threshold of 100 pounds per day. Mitigation Measures were also identified to reduce operation related NOx emissions to the extent feasible. However, the operational emissions for the Tribal Planning Area and Combined Project scenarios continued to exceed SCAQMD thresholds by 119.8 pounds per day and 206.2 pounds per day, respectively.

Response to Comment 7-33
The recommended measures identified by the commenter have been included in the Draft EIS. As identified in Section 3.0, Project Description in Figure 3.0- 9, Existing and Conceptual Public Transportation System Plan, there are 4 identified SunLine bus stops located adjacent to the Project Site near the intersection of Bob Hope Drive and Ramon Road and Bob Hope Drive and Dinah Shore Drive. As part of the Project, two new bus stops will be proposed near the Ramon Road and Los Alamos Road intersection to provide residents and employees increased access to public transportation. Three future neighborhood circulator stops will also be incorporated within the Project Site to provide residents and employees to public transportation. Additionally, Mitigation Measures MM 5.6 -10 requires project proponents to offer services to encourage the use of alternative transportation.

Greenhouse gas emis sions were found to be less than significant with incorporation of Project Design Features and implementation of Mitigation Measures, as discussed in Section 5.6.

As identified in Section 3.0, in Figure 3.0-5, Conceptual Open Space Plan, the interior of t he Project Site will include a pedestrian trail connection between the Active Adult Community (Planning Area 8) and the Tribal Planning Areas (Planning Areas 1 through 7). Furthermore, Figure 3.0 -8, Conceptual Pedestrian and Alternative Vehicle Circulation Plan, identifies numerous pedestrian, bicycle paths, and golf cart paths within the interior of the Project Site. As shown in Figure 3.0-8 , on-street neighborhood electric vehicle (NEV) paths have been identified bisecting the Active Adult Community, as w ell as providing connections to all Planning Areas within the Tribal Planning Area along the internal roadways. Sidewalks and bicycle paths have also been identified along major roadways within the Project Site. A pedestrian trail is also proposed to provide access by residents to the Tribal Planning Areas along the boundary of the Active Adult Community. Greenhouse gas emissions were found to be less than significant with 12-3056

2.0 Responses to Comments
Meridian Consultants 2.0-280 Section 24 Specific Plan Project 044-001-13 March 2015
incorporation of Project Design Features and implementation of Mitigation Measures, as discussed in Section 5.6.

Response to Comment 7-34
The CEQA and Federal Conformity Guidelines referenced in this comment were prepared in August 2011 by the Antelope Valley Air Quality Management District (AVAQMD), whose jurisdiction is limited to a northern desert portion of Los Angeles County. The Projec t Site, comprised of the Active Adult Community (identified as Planning Area 8 in Section 3.0 ) and the Tribal Planning Areas (identified as Planning Areas 1 through 7 in Section 3.0 ), is located in the Coachella Valley, which falls under the jurisdiction o f the SCAQMD. Please note that the Tribe is not subject to the rules and regulations of SCAQMD, but for purposes of analysis, has utilized the SCAQMD guidance for the Draft EIS. While consideration of guidelines formulated by other air districts can aid in the preparation of air quality assessments, conformance with those air quality guidelines is not required and could potentially create a risk of inconsistencies with the applicable guidance. The air quality and greenhouse gas analyses presented in the Dra ft EIS were prepared in accordance with the SCAQMD Air Quality Handbook, the SCAQMD Rule Book, and applicable regulations for mitigating emissions.

The comment suggests that the Draft EIS did not adequately address the data values that were used to estimate emissions from construction and operation of the Project. The CalEEMod is the preferred regulatory model promulgated by the California Air Resources Board (CARB) and the California Air Pollution Control Officers Association (CAPCOA) for estimating emissi ons from land use development projects. The model is designed to accept user -input data describing project-specific characteristics, and relies upon default data derived through a survey of facilities in California to generate estimated emissions of CAPs, ozone precursors (oxides of nitrogen and volatile organic compounds), and GHGs associated with construction and operational phases of implementing a proposed project. When project-specific data is not available, CalEEMod utilizes default values to characte rize emissions from phases of construction, associated vehicle trips, and operational emissions from mobile, area, and stationary sources.

The CalEEMod run that was prepared for the Draft EIS (in Appendix B) did not rely upon unsubstantiated assumptions, as the comment suggests. Each user -input value was selected based on correspondence with the Applicant and Project -specific parameters determined through the air quality analyses. The CalEEMod program automatically fills in data corresponding to user- input information for land uses within the project. Modification of the default values filled in by the model are shown on pages five to eight of Appendix B of the Draft EIS. Each of the values that was changed was discussed in Section 5.2 starting on page 5.2 -21 of the Draft EIS. There were no instances where a value was modified from the 12-3057

2.0 Responses to Comments
Meridian Consultants 2.0-281 Section 24 Specific Plan Project 044-001-13 March 2015
default provided by the model unless specified in the text of the Draft EIS or denoted in the CalEEMod remarks. Specific parameters are discussed in the following responses.

Response to Comment 7-35
The focus of this comment refers to the acreage of the site that will be graded during construction of the Project Site. The total acreage of the site upon which the Project will be developed is approximately 577 acres, and the entirety of the site will be graded during the construction phase of the Project. The text of the Draft EIS is consistent in its designation of the area to be graded (see page 5.2 -23 and 5.2- 24 in Section 5.2). However, based on the user-defined land use inputs, CalEEMod assigned a default value of 450 acres for grading. This value remained unchanged as it did not appear within the list of value modifications in Appendix B to the Draft EIS. An updated CalEEMod run was prepared to address the total site acreage t o be graded, and the default value of 450 acres was updated to 577 acres to comply with the description of the Project in the Draft EIS. A thorough discussion of the updated modeling results is presented in subsequent responses. As discussed in Response to Comment 7-37 refinement of the model to include 577 acres of grading area did not substantially increase on -site fugitive dust emissions. No additional air quality impacts were identified with the updated value input into the CalEEMod model.

Response to Comment 7-36
This comment refers to the number of construction worker trips that will be required during the utilities trenching phase of constructing the Project. The comment identifies a discrepancy between the value given in the text of the Draft EIS (p age 5.2 - 23 in Section 5.2 ) and the default number of worker trips generated by CalEEMod (Appendix B to the Draft EIS, page 15). The value was updated and an updated CalEEMod run was prepared, as discussed in Response to Comment 7 -35. The amendment resulted in a total addition of approximately 600 worker trips over five and a half months of trenching activities. The change in the input value did not generate a substantial increase to estimated emissions from trenching activities or significant impacts related to air quality. The results of the updated analysis are more extensively discussed in ensuing responses, and no additional consideration of mitigation measures is warranted.

Response to Comment 7-37
User-defined equipment lists were prepared for the Active Adult Community, and for the Tribal Planning Areas, and Combined CalEEMod scenarios in the Draft EIS. The comment has been considered and updated CalEEMod runs, as mentioned above, were prepared for the Active Adult Community, Tribal Planning Areas, and Combined scenarios. Results of the revised modeling scenarios are more comprehensively discussed in Response to Comment 7 -41, and the output files are provided in 12-3058

2.0 Responses to Comments
Meridian Consultants 2.0-282 Section 24 Specific Plan Project 044-001-13 March 2015
Appendix 3.0 to this Final EIS. As a conservative approach, the two equipment lists for th e Active Adult Community Trenching and Combined Scenario Trenching were merged and duplicate pieces of equipment were removed. Table 1, Updated Trenching Equipment List and Usage Rates , identifies the equipment and usage rates that were incorporated into the updated CalEEMod runs, as well as the estimates of total daily emissions for the two scenarios. Ultimately, a Signal Board and a Trencher were added to the Combined Scenario list from the Draft EIS CalEEMod runs (Appendix B to the Draft EIS).

Table 1
Updated Trenching Equipment List and Usage Rates
Equipment Type
Draft EIS
Active
Adult
Count
Draft EIS
Active
Adult
Usage
Hours
Draft EIS
Combined
Count
Draft EIS
Combined
Usage
Hours
Final EIS
Trenching
Count
Final EIS
Trenching
Usage
Hours*
Air Compressor 0 N/A 1 6.0 1 6.0
Forklift 1 4.0 4 4.0 1 8.0
Generator Set 0 N/A 1 8.0 1 8.0
Off-Highway Trucks 2 8.0 2 8.0 2 8.0
Signal Board 1 8.0 0 N/A 1 8.0
Tractors/Loaders/Backhoes 0 N/A 3 7.0 3 7.0
Trencher 1 6.0 0 N/A 1 6.0
Welder 1 4.0 1 4.0 1 4.0

*Usage hours for Combined FEIS CalEEMod emissions modeling were all set to 8 for maximum emissions scenario.

Trenching emissions were included in both the Active Adult Community and Combined Scenarios for the updated Final EIS CalEEMod runs. As noted in the Table 1, for the Combined Scenario, all equipment was assumed to be operating for eight hours per day to maximize emissions estimates during this phase of construction. The emissions estimates during the 2016 Trenching and Grading phase for the Draft EIS Active Adult Community and Combined Scenarios, Final EIS Active Adult Community and Combined Scenarios, and the incremental increases based on updated inventory data are presented in Table 2 , Comparison of Maximum Daily Air Pollutant Emissions during 2016 Trenching/Grading.

12-3059

2.0 Responses to Comments
Meridian Consultants 2.0-283 Section 24 Specific Plan Project 044-001-13 March 2015
Table 2
Comparison of Maximum Daily Air Pollutant Emissions during 2016 Trenching/Grading Pollutant (pounds/day)
Scenario VOC NOx CO SOx PM10 PM2.5
DEIS Active Adult Comm. 1.64 29.72 57.03 0.10 3.48 1.53 FEIS Active Adult Comm. 2.04 37.544 70.08 0.12 3.82 1.62 Incremental Increase 0.40 7.82 13.05 0.02 0.34 0.09
SCAQMD Threshold 75 100 550 150 150 55
FEIS Exceeds? No No No No No No
DEIS Combined 2.00 37.03 68.28 0.11 3.79 1.65
FEIS Combined 2.66 42.84 73.30 0.12 4.21 1.98
Incremental Increase 0.66 5.81 5.02 0.01 0.42 0.33
SCQMD Threshold 75 100 550 150 150 55
FEIS Exceeds? No No No No No No

The updated CalEEMod emissions were incorporated into the remainder of the analysis for the Final EIS air quality assessment. Results of the updated Final EIS analysis for the Trenching emissions demonstrate that no significant incremental increases occurred through the merging of construction equipment inventories for the previously defined Draft EIS Active Adult Community and Combined Scenarios. The updated emissions estimates do not exceed the SCAQMD construction thresholds of significance for any of the criteria pollutants, and therefore the conclusions of the analysis have not changed. Therefore, the identified significant VOC air quality impacts during construction would remain significant and the incremental increase in construction emissions for NOx, CO, SOx, PM10, and PM2.5 would remain less than significant.

Response to Comment 7-38
As stated throughout the Draft EIS and in Table 2-1 of the Traffic Study (Appendix G to the Draft EIS), the total maximum population that the completed Project will accommodate is 4,331 individuals. This is based on the assumption that the overall Project population density would not exceed 1.8 persons/household with 2,406 total dwelling units, and was the population used in deriving traffic study circulation projections. The traffic study circulation projections were manually input to CalEEMod for operational vehicle trips to reflect the most accurate representation of future traffic conditions.

Therefore, the population values presented in the land use table in the CalEEMod output files are not directly tied to the estimates for vehicle trips, which are based on the traffic study.

The reviewer suggests that population values in CalEEMod were underestimated and references a Remark in the CalEEMod output files. The CalEEMod files were prepared in July 2014, prior to receipt of the final Traffic Study for the Project. The population estimates in the Draft EIS CalEEMod files included 2,340 for the Active Adult Community and 2,028 for the Tribal Planning Areas, as shown in Appendix B 12-3060

2.0 Responses to Comments
Meridian Consultants 2.0-284 Section 24 Specific Plan Project 044-001-13 March 2015
to the Draft EIS, for a total population of 4,368. This value is greater than the maximum anticipated population of 4,331, and therefore the CalEEMod population was overstated relative to the actual Project specifications derived from the Traffic Study (Appendix G to the Draft EIS).

The comment recommends that the CalEEMod population estimates be updated to reflect the Remark that population for each housing type was calculated by multiplying the number of dwelling units by a factor of 1.95. The Rem ark was denoted prior to receipt of the final Traffic Study, wherein it was denoted that the total Project population density would not exceed 1.8. As discussed in Section 5.11.B.2 of the Draft EIS, the Active Adult Community would accommodate up to 2,160 new residents, and the Tribal Planning Areas would house up to 2,171 inhabitants, for a total of 4,331. These numbers have replaced the previous population values of 2,352 and 2,028, respectively, in the updated CalEEMod runs attached to the Final EIS as Appendix 3.0 . The vehicle trips and energy use calculations relied upon these population values, and therefore the updated information has no effect on the emission estimation for operational sources in CalEEMod.

Response to Comment 7-39
This comment addresses the characterization of construction equipment usage for the Combined Scenario in the Draft EIS. The reviewer asserts that because the duration of the Tribal Planning Areas construction period was shortened by approximately half to be concurrent with the Active Adult Community development, the number of equipment should have been doubled, citing a Sacramento Metropolitan Air Quality Management District (SMAQMD) document. As discussed previously, the Project is located in the Coachella Valley and falls under the jurisdiction of the SCAQMD. Guidelines and regulations set forth by other air districts are not directly applicable to the Project under CEQA.

However, the assertion is conceptually sound and has been incorporated into the updated CalEEMod emissions estimates provided with the Final EIS as Appendix 3.0 . To be overly conservative, it was assumed that all construction equipment would be operating for eight hours each day under the Combined Scenario. The equipment inventory for the Building Constructi on and Architectural Coating phases were doubled, and the schedule of construction phases was preserved from the original Active Adult Community and Combined Scenarios. A thorough discussion of the parameters that were updated for the Final EIS supplemental CalEEMod scenarios is presented in Response to Comment 7-41.

Response to Comment 7-40
As mentioned on pages 5.2 -23 and 5.2-24 of the Draft EIS, it is anticipated that all off- site travel during construction will take place on paved roads. The Project is bounded by paved roads on all sides: Ramon Road to the north, Bob Hope Drive to the east, Dinah Shore Drive to the south, and Los Alamos Road to the west. All construction worker, vendor, and hauling trips are expected to access the site via one of 12-3061

2.0 Responses to Comments
Meridian Consultants 2.0-285 Section 24 Specific Plan Project 044-001-13 March 2015
these existing roadways. On- site fugitive dust emissions are automatically incorporated into the CalEEMod estimates; changing the percentage of travel on paved roads only affects off- site fugitive emissions calculations. The comment suggests that assuming 100 pe rcent travel on paved roads was unrealistic. Appendix D to the CalEEMod user guide provides default values for paved road travel. Within SCAQMD, paved road travel is assumed to be 100 percent. Additionally, at the county level, paved road travel is assumed to be 100 percent by default for all of Riverside County. There is no legitimate reason to assume that off -site construction traffic would be traversing unpaved roads, and this default value remained unchanged in the updated CalEEMod runs prepared for the Final EIS.

Response to Comment 7-41
Updated CalEEMod runs were prepared to address the assertions within this comment regarding grading acreage, construction equipment usage, and population data. Table 3, Parameters Updated for Final EIs CalEEMod Runs , pr ovides an overview of the parameters that were updated based on comments and review of the Draft EIS text. Each value selected for the updated CalEEMod runs is justified with a description in the final column of the table, citing either text in the Draft EIS or an alternative reference value.

Table 3
Parameters Updated for Final EIS CalEEMod Runs
Parameter DEIS Value
LIUNA
Value
FEIS
Value Citation/Justification
Grading Acreage 450 577 577 Entire Project Site will be graded; Default CalEEMod value replaced.

Active Adult Community
Population
2,340 N/A 2,160 Updated CalEEMod input value to
match text of DEIS (p. 5.11-5).

Tribal Planning Areas Population 2,028 2,352 2,171 Updated CalEEMod input value to match text of DEIS (p. 5.11-5).

Trenching Worker Trips 15 20 20 Updated CalEEMod input value to match text of DEIS (pp. 5.2-23, 5.2-
24).

Combined Scenario Tribal Planning
Areas Equipment Counts
Single Double Double Tribal Planning Area equipment
counts were doubled for the
Combined Scenario and all usage
rates were set to 8 hours to maximize
emissions.

Incorporating the updates mentioned above, CalEEMod runs were processed and model outputs were evaluated against SCAQMD thresholds for the Active Adult Community, Tribal Planning Areas, and Combined Scenarios. As discussed in Response to Comment 7 -40, the percentage of paved roads upon 12-3062

2.0 Responses to Comments
Meridian Consultants 2.0-286 Section 24 Specific Plan Project 044-001-13 March 2015
which workers would be traveling to the site remained unchanged at 100%. This value is consistent with the default data tables provided in Appendix D to the CalEEMod User’s Guide and with existing surface street conditions surrounding the Project Site. There is no evidence to suggest that off -site construction worker travel would occur on unpaved roads, as the commenter suggests.

The updated CalEEMod runs are attached to this Final EIS as Appendix 3.0 . When comparing the updated emissions estimates to those presented in Section 5.2 of the Draft EIS (Tables 5.2 -6 to 5.2- 11, pages 5.2-30 to 5.2- 37), no additional instances of exceeding SCAQMD thresholds of significance were incurred by revising the input values. The estimates calculated by the reviewer are not representative of anticipated construction emissions for particulate matter due to the assumption regarding percentage of paved roads. The tables in Section 3.0 of this Final EIS display the updated CalEEMod emissions estimates for the Active Adult Community, Tribal Planning Areas, and Combined Scenarios.

As evidenced by the emissions estimates in the tables on pages 3.0-3 through 3.0 -6, the updated parameters for Project construction and operation did not result in any additional significant air quality impacts. No new Mitigation Measures are required based on the updated emissions estimates. The estimates prepared by the reviewer are not as accurately representative of Project conditions, as they overestimate fugitive dust g eneration from construction activities. As described in the Draft EIS, implementation of Mitigation Measures MM 5.2-1 and MM 5.2-2 will reduce emissions to the maximum extent feasible, but significant and unavoidable air quality impacts previously disclose d in the Draft EIS will remain.

Response to Comment 7-42
This comment relies on inaccurately calculated emissions estimates to assert that implementation of the Project will result in additional cumulatively considerable air quality impacts relative to tho se disclosed in the Draft EIS (page 5.2-38). The CEQA Environmental Checklist (Appendix G to the CEQA Guidelines) specifies that cumulatively considerable impacts should be evaluated for criteria air pollutants, “for which the project region is in non- attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors).” The Project is situated in Coachella Valley, which is in nonattainment for ozone. Therefore , only emissions of ozone precursors exceeding applicable thresholds may be characterized as cumulatively considerable.

The SCAQMD prepared a white paper in 2003 to address cumulatively considerable impacts. The document states that a CEQA document,
may determine that a project’s contribution to a significant cumulative impact will be rendered less than cumulatively considerable and thus is not significant. A project’s 12-3063

2.0 Responses to Comments
Meridian Consultants 2.0-287 Section 24 Specific Plan Project 044-001-13 March 2015
contribution is less than cumulatively considerable if the project is required to implement or fund its fair share of a mitigation measure or measures designed to alleviate the cumulative impact.6
Ample Mitigation Measures have been prepared and presented in the Draft EIS, as referenced in Response to Comment 7 -31, for emissions of VOCs that will exceed SCAQMD thresholds. As such, compliance with the requirements for cumulatively considerable impacts is achieved, and no additional mitigation measures are required.

Furthermore, the commenter does not identify the source of this information. The SCAQMD CEQA Air Quality Handbook does not specifically mention that an exceedance of the air quality pollutant threshold would result in a cumulatively considerable net increase of these pollutants.

Project Design Features, Mitigation Measures, and a reasonable range of Alternatives have been identified and analyzed in the Draft EIS to reduce the identified significant air quality impacts during construction and operation, to the maximum extent feasible.

Response to Comment 7-43
This comment is related to previous comments regarding updated Project parameters in the CalEEMod model and has already been addressed in prior responses. An updated CalEEMod model was prepared for the Active Adult Community, Tribal Planning Areas, and the Combined Scenario to est ablish consistency with the text of the Draft EIS; no additional significant air quality impacts were identified based on the clarified information. Mitigation Measures MM 5.2 -1 and MM 5.2 -2 were previously incorporated into the analyses and will remain applicable to the updated Project emissions. This Final EIS presents an updated discussion of potential air quality impacts from implementation of the Project, but no significant changes resulted from including the recommended revisions to the construction a nd operational emissions. The updated analysis presented in this Final EIS is sufficient to demonstrate conformance with the CEQA environmental checklist requirements pertaining to air quality.

Response to Comment 7-44
This comment addresses emissions of Toxic Air Contaminants (TACs), specifically diesel particulate matter ( DPM), associated with construction of the Project that were not previously evaluated in the Draft EIS. Long -term operation of the residential land uses subsequent to Project completion will not

6 SCAQMD Cumulative Impacts White Paper – Appendix A. 2003. http://www.aqmd.gov/docs/default- source/Agendas/Environmental-Justice/cumulative-impacts-working-group/cumulative-impacts-white-paper- appendix.pdf?sfvrsn=4
12-3064

2.0 Responses to Comments
Meridian Consultants 2.0-288 Section 24 Specific Plan Project 044-001-13 March 2015
generate substantial quantities of DPM as stated in the Draft EIS (page 5.2 -42). Emissions of DPM during construction will be temporary and considerably variable, as each phase of construction requires a different inventory of equipment operating for different daily durations. To address this comment, a supplemental assessment of air quality impacts from construction of the Combined Scenario, which represents a worst -case emissions projection, was prepared and maximum off -site concentrations of DPM were analyzed against the SCAQMD carcinogenic risk threshold. The results of the screening HRA prepared for the Final EIS are discussed in Response to Comment 7 -49, and show that the Project will not have a significant impact.

Response to Comment 7-45
This comment references a 2012 document published by the Office of Environmental Health Hazard Assessment (OEHHA) and suggests that the Project’s air quality impacts analyzed in the Draft EIS do not satisfy the CEQA environmental checklist criterion regarding exposure of sensitive receptors to substantial pollutant concentrations. The recommendations set forth in the 2012 OEHHA Technical Support Document (TSD) for Exposure Assessment and Stochastic Analysis have not yet been adopted or incorporated by any regulatory authority responsible for oversight of land use development projects and air quality. Until recently, there was no published literature with a framework for assessing potential health risks attributed to short-term construction projects.

The CAPCOA organization is responsible for providing guidance on health risk assessments under CEQA, and it has not updated its Health Risk Assessments for Proposed Land Use Projects document to reflect the recent OEHHA recommendations. The CAPCOA document states that, “[t]his guidance does not include how risk assessments for construction projects should be addressed in CEQA” (p. 2).

Furthermore, the SCAQMD is in the process of updating its Air Quality Analysis Handbook which was originally published in 1993, and therefore would not account for recent OEHHA recommendations.

Despite the fact that there is no current regulatory guidance on assessing air quality impacts from short- term construction projects, a supplemental HRA has been prepared to address DPM emissions associated with Project construction. Results of this assessment are presented in Response to Comment 7-49, and show that the Project will not have a significant impact.

Response to Comment 7-46
This comment identifies AERSCREEN as the appropriate regulatory model for conducting screening -level health risk assessments based on USEPA recommendations, citing guidance from both OEHHA and CAPCOA. AERSCREEN was selected as the appropriate screening air dispersion model for the supplemental HRA prepared as part of this Final EIS. The model generates estimates of maximum downwind ground -level concentrations of an air pollutant released to the atmosphere from a 12-3065

2.0 Responses to Comments
Meridian Consultants 2.0-289 Section 24 Specific Plan Project 044-001-13 March 2015
continuous emission source. A more thorough discussion of the modeling exercise and results of the screening HRA are presented in Response to Comment 49 , and show that the Project will not have a significant impact.

Response to Comment 7-47
The reviewer prepared a CalEEMod run using modified input parameters and relied upo n the estimated emissions to conduct a screening- level health risk assessment. The CalEEMod data was attached as Appendix A to Exhibit A to Comment Letter No. 7. This comment describes the selection of DPM emission estimates from the CalEEMod output files that were subsequently incorporated into the AERSCREEN model. It should be noted that Appendix A did not contain the annual emissions estimates, so the Tribe was unable to compare the annual estimates to the maximum daily emissions.

The comment identifies that the Combined Scenario emissions were selected based on a recommendation from the SCAQMD CEQA Air Quality Handbook. Upon reviewing the CalEEMod output files, it was determined that the selected quantity of DPM emissions during Project construction (purportedly 6,248 pounds) was derived using a flawed calculation methodology. It appears that the reviewer misinterpreted the CalEEMod output files, and the miscalculation resulted in a severe overestimation of DPM emissions from Project construction.

The comment claims that the estimated 6,248 pounds (3.124 tons) of DPM was derived from the “highest daily emission” during the Combined Scenario construction. However, dividing the DPM emissions by the total number of construction work days presented in the CalE EMod table (1,755), the daily emission rate is calculated to be approximately 3.56 pounds per day (lb/day). This value does not correspond to the maximum daily emission rate for any of the years evaluated in the SWAPE CalEEMod runs, but is the sum of the highest daily emission rates for all eight of the years during which construction is occurring in the Combined Scenario.

The maximum daily “Exhaust PM10” emission rate produced by the CalEEMod software was approximately 0.6779 lb/day in 2016 (Table 2.1, Combined Scenario p. 8 of 55, Appendix A to Exhibit A, Comment Letter No. 7 ). This value represents the maximum daily emission rate of DPM during Project construction under the Combined Scenario. Based on the model output provided by the reviewer, none of the daily emissions of DPM during each year of Project construction would exceed 1 lb/day, much less

3.5 lb/day. The misinterpretation of the model output resulted in the average emission rate being exceeded by at least 5.25 times. Using an emission rate that is 5.25 times the appropriate value resulted in an overestimation of the consequential exposure as calculated by the AERSCREEN dispersion model.

Therefore, supplemental screening -level HRA calculations were prepared for the Project’s Combined Scenario using the updated Final EIS CalEEMod runs and are discussed extensively in Response to 12-3066

2.0 Responses to Comments
Meridian Consultants 2.0-290 Section 24 Specific Plan Project 044-001-13 March 2015
Comment 7-49. As determined below, the Project would not result in any significant DPM impacts to on- site or off-site residents. Accordingly, impacts would be less than significant.

Response to Comment 7-48
This comment provides a brief description of the parameters that were used to characterize the DPM emissions and maximum downwind concentrations from construction of the Combined Scenario Project.

As previously discussed, the values used in the emission rate calculation on page 14 of Exhibit A to Comment Letter No. 7 are incorrect. To supplement the Final EIS, additional CalEEMod runs were processed for the Active Adult Community, Tribal Planning Areas, and Combined Scenar io emissions based on the comments received in the LIUNA letter. As shown in the table within Response to Comment 7-41, certain input parameters were updated to establish consistency between the text in the Draft EIS and the data in the model. Using the updated Project information, maximum daily and annual emissions were estimated for the three construction scenarios. As identified by the reviewer, the Combined Scenario generated the highest daily emission rate due to the compounding of construction activity, and was selected as the basis for the screening-level HRA.

In reviewing the updated Final EIS CalEEMod output files, the Winter season emission rates were marginally higher than those calculated for the Summer season, and were used for estimating the annual average emission rate during construction activities. Average DPM emission rates were calculated for each of the eight years that construction is anticipated to take place (2015 -2022) by dividing the maximum daily “Exhaust PM10” emissions by 24 hours and then converting the rate to grams per second. The generic equation is the same as was presented on page 14 of Exhibit A to the LIUNA letter:

𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑅𝑅𝑅𝑅 �
𝑔𝑔𝑔𝑔𝑔
𝑔𝑠
𝑠𝑠𝑠𝑠� = 𝐷𝐷𝐷 𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 �
𝑙𝑙𝑔
𝑠
𝑔
𝑑� ×
453.6 𝑔𝑔𝑔𝑔𝑔
𝑙𝑙 ×
1 𝑠𝑔𝑑
2 4 ℎ𝑠
𝑜𝑔𝑔 ×
1 ℎ𝑠 𝑜𝑔
3,6
00 𝑔𝑠
𝑠𝑠𝑠𝑠
𝑔
Once the average emission rate for each of the eight years of construction was calculated, AERSCREEN models were conducted to determine the maximum average single- hour concentration of DPM at an off-site receptor location. AERSCREEN relies on a continuous emission rate to simulate atmospheric releases; the average emission rate for each year was used and eight different models were prepared.

For screening purposes the Project Site was evaluated as a rectangular area source of approximate dimensions 1600 meters by 1450 meters to characterize the Project boundary closest to residential receptors (1,600 meters along Dinah Shore Drive and 1,450 meters along Los Alamos Road). The release height was set to three meters to simulate exhaust stacks on construction equipment, with an initial vertical dimension of 1.5 meters to represent instantaneous plume dispersion. As stated in Comment 7 - 48, meteorological inputs assumed an urban setting and program defaults for wind speed and direction distribution.
12-3067

2.0 Responses to Comments
Meridian Consultants 2.0-291 Section 24 Specific Plan Project 044-001-13 March 2015
The Project Site is bordered to the south and west by residential communities, with sensitive receptors located within approximately 40 meters to the west and extending to far greater distances radially. The size o f the Project Site is so large that cumulatively maximum concentrations from all construction equipment operating simultaneously may be generated at distances from the boundary greater than the most proximal receptors. This means that a receptor located ap proximately 1,000 meters from the Project Site may be exposed to a higher concentration of DPM at a given moment than a receptor located approximately 100 meters from the Project Site based on atmospheric dispersion patterns. For the purposes of the screening model and health risk assessment, the maximum one- hour concentration of DPM was extracted from the AERSCREEN output data tables for each year that construction emissions were modeled.

Table 4, Daily Emission Rates from CalEEMod and Maximum 1 -hour Conce ntrations, presents the maximum daily DPM emission rate in grams per second and the corresponding maximum one -hour concentration that was produced by the AERSCREEN model for the eight years evaluated. The maximum concentrations vary based on the constructi on activities that were assigned start and end dates in CalEEMod.

Table 4
Daily Emission Rates from CalEEMod and Maximum 1-hour Concentrations Year
Exposure
Start Date
Exposure
End Date
Year
Fraction
DPM Emission
Rate (lb/day)
DPM Emission
Rate (g/s)
Max One-
Hour
Concentration
(µg/m3)
2015 11/1/2015 12/31/2015 0.17 0.102 0.00054 0.032
2016 1/1/2016 12/31/2016 1 0.928 0.00487 0.285
2017 1/1/2017 12/31/2017 1 0.961 0.00505 0.295
2018 1/1/2018 12/31/2018 1 0.926 0.00486 0.284
2019 1/1/2019 12/31/2019 1 0.892 0.00469 0.274
2020 1/1/2020 12/31/2020 1 0.848 0.00445 0.260
2021 1/1/2021 12/31/2021 1 0.146 0.00076 0.044
2022 1/1/2022 7/22/2022 0.56 0.109 0.00057 0.033
Total Duration
(years) 6.73
Weighted Average
Concentration
(µg/m
3)

0.218

It should be noted that these values represent the highest maximum daily DPM emissions and resulting single-hour concentrations. Within each year, daily emissions will not remain at the maximum for the entire duration of the year. Therefore, these emission s quantities and concentrations represent 12-3068

2.0 Responses to Comments
Meridian Consultants 2.0-292 Section 24 Specific Plan Project 044-001-13 March 2015
conservative approximations for a screening -level exposure assessment. As stated in Comment 7-48, the USEPA recommends that the maximum reasonable estimate of an annualized average concentration can be defined as 10 percent of the single-hour maximum concentration in screening model output. This methodology for estimating the annual average concentration was utilized for the exposure assessment in this Final EIS. The weighted average concentration for the 6.73 years of construction was calculated and multiplied by 10 percent, resulting in an annualized average concentration for the duration of the exposure assessment of 0.0218 µg/m

3. Using this annualized average concentration during construction, maximum cancer risks to off- site receptors were calculated following guidance from CAPCOA and OEHHA for adult, child, and infant exposures. The methodology and results of the health risk assessment are presented in Response to Comment 7 -49. None of the three exposure scenarios exceeded the ten in one million cancer risk threshold established by the SCAQMD. Emissions of DPM during construction will not present any significant air quality impacts to nearby sensitive receptors from a health risk assessment perspective.

Response to Comment 7-49
This comment presents the results of the screening -level HRA prepared by the reviewer. The described methodology in the comment, however, is not consistent with the calculations that were executed to estimate the cancer risk to sensitive receptors. The 2012 OEHHA TSD promulgates the use of Age Sensitivity Factors (ASFs) in quantifying carcinogenic risks to susceptible populations, such as young children, as t he comment states. The ASF for the first two years of life (“Infant”) is ten, for the subsequent fourteen years of life (“Child”) is three, and for the remaining years (“Adult”) is one. These scaling factors were designed to account for the increased sensitivity to air pollution – and specifically carcinogens – that young children with developing biological systems possess.

It appears that calculation of the “Infant” exposure in Comment 7-49 applied the scaling factor of ten to all 6.73 years of exposure. This error exaggerates the calculated cancer risk by approximately two times, as the average scaling factor over the first 6.73 years should have been calculated as 5.08 instead of ten.

This miscalculation, in combination with the misinterpreted CalEEMod output for maximum daily emissions, resulted in the cancer risks to off -site residential receptors to be drastically overestimated. A screening-level HRA was prepared to supplement the Final EIS and address the comments within the LIUNA letter. Results of th e HRA for the 6.73 years of exposure are identified in Table 5, Combined Scenario Cancer Risks to Off-site Sensitive Receptors.

12-3069

2.0 Responses to Comments
Meridian Consultants 2.0-293 Section 24 Specific Plan Project 044-001-13 March 2015
Table 5
Combined Scenario Cancer Risks to Off-site Sensitive Receptors Parameter Description Units Adult Exposure Child Exposure Infant Exposure Cair Concentration µg/m3 0.0218 0.0218 0.0218
DBR Daily Breathing Rate L/(kg-day) 302 581 581
EF Exposure Frequency days/year 350 350 350
ED Exposure Duration years 6.73 6.73 6.73
AT Averaging Time days 25,550 25,550 25,550

Doseinh Inhaled Dose mg/(kg-day) 6.1 E-07 1.2 E-06 1.2 E-06 CPF Cancer Potency Factor 1/(mg/kg-day) 1.1 1.1 1.1
ASF Age Sensitivity Factor - 1 3 5.08*
Cancer Risk 6.68 E-07 3.85 E-06 6.53 E-06
SCAQMD
Threshold 1.0 E-05 1.0 E-05 1.0 E-05
Exceeds? No No No

*5.08 is weighted average ASF from 2 years of exposure with ASF = 10 and 4.73 years of exposure with ASF = 3.

To simplify the process, weighted average calculations were performed to estimate the annual average concentration during the 6.73 years of construction. The ASF values of 1, 3, and 5.08 were applied to the Adult, Child, and Infant exposure scenarios, respectively, for the 6.73 -year exposure duration. The total cancer risks to the maximally exposed off- site receptor were calculated t o be 6.52 in one million for Infant exposure, 3.85 in one million for Child exposure, and 0.67 in one million for Adult exposure.

Contrary to the assertion made by Response to Comment 7-49, the calculated exposures do not exceed the SCAQMD threshold for cancer risk of ten in one million, and a refined air dispersion modeling exercise is not warranted. Construction of the Project will not result in cancer risks to nearby residential receptors exceeding the SCAQMD threshold of significance. No significant air quality impacts are associated with DPM emissions generated by construction of the Project.

Response to Comment 7-50
This comment claims that actual excess cancer risks may be higher than those calculated for the exposure assessment presented in Exhibit A to Comment Letter No. 7. Based on the misinterpretation of the CalEEMod output data and the incorrect application of the ASF value for the Infant exposure, it is factually impossible for the exposures to be higher than those presented in Exhibit A . Having corrected for the erroneous calculations upon which the commenter relied, the estimated cancer risks presented in Response to Comment 7-49 represent the maximum reasonable estimates for cancer risks to off-site residential receptors during Project construction. As such, conclusions expressed in Section 5.2 of the 12-3070

2.0 Responses to Comments
Meridian Consultants 2.0-294 Section 24 Specific Plan Project 044-001-13 March 2015
Draft EIS remain valid, and it is confirmed that implementation of the Project will not expose sensitive receptors to substantial pollutant concentrations, nor emit toxic air contaminants resulting in exposures exceeding the ten in one million individual cancer risk threshold. Air quality impacts from TACs remain less than significant with selected DPM mitigation strategies.

Response to Comment 7-51
The comment suggests that the BAU scenar io defined for the Project in the Draft EIS was improperly characterized. The comment does not acknowledge or reference the approved and adopted 2012 Riverside County Climate Action Plan (CAP). The 2012 CAP provides a methodology for determining whether or not implementation of a project will result in significant GHG emissions and air quality impacts. As originally discussed in Response to Comment 7 -7, SCAQMD unofficially recommended a 3,000 MTCO2e initial screening threshold for individual projects. This screening criterion was incorporated into the 2012 CAP, but does not apply to large scale developments such as the Project. For those projects exceeding the 3,000 MTCO2e screening criterion, or those that are too large to evaluate against a simple metric, the 2012 CAP offers the following alternative for GHG emission quantification in unincorporated areas of the county to demonstrate compliance with AB 32:

Analysis of development projects not using the screening tables should use the latest version of the California Emission Estimator Model (CalEEMod). Two modeling runs should be completed. The first modeling run calculates GHG emissions at 2011 levels of efficiency using energy efficiency standards (Title 24) and the California Air Resources Board on road vehicle emissions factors (EMFAC2012) set at 2011. A second modeling run is required that calculates GHG emissions at Project buildout year levels of efficiency and includes Project design features and/or mitigation measures to reduce GHG emissions such th at the levels of efficiency result in a 25% reduction of GHG emissions compared to the model run using the 2011 levels of efficiency.

The 2012 CAP identifies 2011 as the BAU year that emission reduction strategies should be compared against. The baseline is defined by 2011 GHG emissions that are not reduced beyond Title 24 levels, as this was the regulatory framework for GHG emissions mitigation when the 2012 CAP was prepared.

Updated CalEEMod runs were processed for the 2011 Combined Scenario without mitigation beyond Title 24. The Draft EIS BAU scenario was conducted using a 2022 operational baseline as a conservative approach. Incorporating the 2011 baseline, as recommended by the 2012 CAP, actually increases the unmitigated BAU annual estimate from 82,06 5.58 MTCO2e per year – as stated on page 5.6 -29 of the Draft EIS – to 96,236.10 MTCO2e per year based on the less recent CARB emission factors. The comment is erroneous in its interpretation of the Project BAU scenario, and the Draft EIS was overly conserv ative in using 2022 as the operational baseline.
12-3071

2.0 Responses to Comments
Meridian Consultants 2.0-295 Section 24 Specific Plan Project 044-001-13 March 2015
The updated CalEEMod runs completed to supplement the Final EIS calculated that annual emissions of GHGs from the Combined Scenario after mitigation would be 46,481.27 MTCO2e. The 2012 CAP requires that a 25 percent reduction compared to the 2011 emissions be achieved through implementation of mitigation measures. The total annual 2011 Combined Scenario emissions are 96,236.10 MTCO2e per year. Comparing the updated Final EIS operational GHG annual emissions ( 46,481.27 MTCO2e/year) to the 2011 scenario as recommended per the 2012 CAP guidance, Mitigation Measures for the Project will achieve approximately a 52 percent reduction in GHG emissions. This value is more than double the required 25 percent stated in t he 2012 CAP, and no further consideration of mitigation measures is required.

Response to Comment 7-52
Response to Comment 7 -51 provided a discussion of the 2012 Riverside County CAP and how the document evaluates a BAU scenario. All analyses prepared for the Draft EIS and Final EIS are consistent with the methodologies outlined in the 2012 CAP for unincorporated areas of Riverside County. The Project is a specific plan and is not subject to the same GHG thresholds as an individual project. This comment ref lects the reviewer’s lack of familiarity with the Riverside County approach to reducing regional GHG emissions and achieving compliance with state -wide efforts. Also see Responses to Comments 7-7 through 7-12 regarding the adequacy of the GHG emissions analysis for the Project.

Response to Comment 7-53
This comment misinterprets the analysis presented in Section 5.6 of the Draft EIS regarding the definition of a baseline scenario. There is not a single iteration of the word “baseline” included in Section 5 .6 of the Draft EIS. The Draft EIS does not suggest that “business as usual” constitutes a baseline for GHG emissions. A baseline, in terms of GHG analysis, refers to a level of emissions that is established as a metric to which future emission inventories and projections may be compared. A baseline can apply to state level, regional level, and local level GHG emission inventories. From a set baseline, forecasters generate projections of future GHG emissions using assumptions to accommodate for anticipated growth and development. The Draft EIS does not suggest that “business as usual” constitutes a baseline for analyzing potential GHG impacts.

The Riverside County Greenhouse Gas Technical Report states that, “business as usual refers to continued operations and development of the County according to 2008 policies, without the inclusion of proposed reduction or sustainability initiatives as part of the forthcoming Climate Action Plan.” Characterization of “business as usual” for the Project in the Draft EIS provided a conceptual framework for evaluating the effectiveness of identified mitigation measures relative to what they would have been in 2008. The “business as usual” operating condition does not reflect a “worst case scenario” as the 12-3072

2.0 Responses to Comments
Meridian Consultants 2.0-296 Section 24 Specific Plan Project 044-001-13 March 2015
comment suggests, but rather, a realistic assessment of the Project’s GHG emissions without the emissions reducing Project Design Features , Mitigation Measures, and regulatory effects. In the referenced Friends of San Jacinto case, the “business as usual” scenario was reject ed because it ignored local planning and zoning laws, stripped all vegetation from the project, and contemplated infeasible development. Therefore, the business as usual assumptions in that case were rejected as unrealistic.

None of these conditions apply to the “business as usual” scenario as described in the Draft EIS, which does provide a realistic business as usual scenario.

Response to Comment 7-54
The comment addresses the methodology for determining whether a project’s greenhouse gas emissions are significant under Section 15064.4 of the CEQA Guidelines.

The comment cites excerpts from two unpublished trial court decisions in CEQA cases, Friends of Northern San Jacinto Valley v. County of Riverside and Center for Biological Diversity v. Department of Fish and Wildlife , related to the characterization of a GHG baseline and proper definition of BAU emissions scenario. The subject of defining a GHG baseline and “BAU” emissions is a controversial one.

The Center for Biological Diversity v. Department of Fish and Wildlife litigation is currently being considered by the Supreme Court of California. The Supreme Court has not yet reached a final decision on the ruling, and therefore speculation about the validity of the GHG baseline assessment is unfounded at this time. The evaluation of GHG emissions from Project implementation is consistent with the current regulatory framework . As such, the discussion of GHG emissions significance presented in Section 5.6 of the Draft EIS remains valid.

The comment goes on to suggest that comparing emissions of GHGs from Project implementation to a realistic BAU scenario would result in non -compliance with the GHG emission reduction goals of AB 32.

This claim is not supported by calculations to demonstrate that the Project would in fact violate AB 32 objectives. The comment does not make reference to any local or regional Climate Action Plan to verify that Project emissions exceed local GHG emission inventory projections for achieving compliance with statewide policies. The assertion that the Project is in violation of AB 32 is unsubstantiated.

Furthermore, as addressed previously in these responses to comments, the Project (with Project Design Features and Mitigation Measures) is consistent with the climate action plans of R iverside County and the City, and is consistent with AB 32.

As mentioned previously, master, general, and specific plans were excluded from the consideration of the SCAQMD GHG Working Group in evaluating the tiered approach to determining significance.

Comparing GHG emissions from the Project to those of a retail center is worse than comparing apples to oranges; the two projects are of drastically different sizes and scope. The Project will consist of 577 12-3073

2.0 Responses to Comments
Meridian Consultants 2.0-297 Section 24 Specific Plan Project 044-001-13 March 2015
acres of residential, recreational, and retail spac e, developed in stages over eighteen years. As expressed by the SCAQMD, it is inappropriate to compare GHG emissions from a specific plan to those of a retail center, and the same regulatory thresholds would not apply when they are officially adopted.

As stated in the SWAPE letter, the tiered threshold approach for GHG analysis is only a draft and has not been officially adopted, and therefore does not qualify as a definitive regulatory metric. The comment repeatedly refers to the 3,000 MTCO2e threshold, but that initial screening threshold would not apply to the Project because it is a specific plan. GHG Mitigation Measures are provided in the Draft EIS as MM

5.6-1 through MM 5.6 -10, discussed in Section 2.0 and Section 5.6 of the document. No additional mitigation measures are required and no significant changes to the GHG analysis are warranted.

Response to Comment 7-55
As discussed previously, the Tier 3 threshold is a draft screening threshold that has not been adopted, and even upon adoption would not apply to a specific plan such as the Project. Furthermore, this proposed screening threshold identifies which projects would need further evaluation under Tier 4, it does not determine when carbon offsets would be required or appropriate. The Project has incorporated extensive mitigation measures to reduce GHG emissions associated with construction and operational phases. The purchase of carbon offsets is not required as GHG emissions from the Project are less than significant after mitigation.

Response to Comment 7-56
This comment suggests that additional GHG mitigation measures are available that should be incorporated into the Project. All feasible mitigation measures have been identified and, as determined in San Diego Citizenry Group v. County of San D iego (Aug. 26, 2013) 219 Cal.App.4 th 1, not every
infeasible mitigation measure is required to be discussed. Here, the Project identified feasible mitigation to substantially reduce impacts from GHG emissions during construction and operation. Implementation of the suggested measures identified in this comment are not needed to substantially reduce any significant impacts from GHG emissions.

The definition of feasible, per Section 21061.1 of the CEQA Guidelines, means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors.

The comment lists several mitigation measures that were identified for GHG emissions in the Draft EIS, in Table 2.0-1 and on pages 5.6 -32 to 5.6-35. The reiteration of mitigation measures demonstrates that minimal attention was paid to the details of the GHG reduction strategies presented in the Draft EIS.

Furthermore, as discussed in Response to Comment 7 -51, the Project does not have any remaining 12-3074

2.0 Responses to Comments
Meridian Consultants 2.0-298 Section 24 Specific Plan Project 044-001-13 March 2015
significant GHG impacts. The 3,000 MTCO2e screening criterion does not apply to the Project, as evidenced in the 2012 Riverside County CAP and the SCAQMD GHG Working Group meeting minutes.

The comment relies on inaccurate and unfounded assumptions in suggesting that further mitigation of GHG emissions is required.

Response to Comment 7-57
This comment presents a concluso ry statement summarizing the topics evaluated in the SWAPE comments. Previous responses have addressed the comments regarding mitigation of criteria air pollutant emissions, potential health risks to nearby sensitive receptors from exposure to DPM, and determination of significance for the Project’s GHG emissions.

Response to Comment 7-58
The comment incorrectly states that the Project Site is located within the City limits. The Project Site is located within the City’s Sphere of Influence, which is not re cognized by the Tribe. The comment is noted and will be reviewed by the Tribal Council in their consideration of approval of the Project.

Response to Comment 7-59
The comment indicates that the traffic analysis is based on key assumptions that are both u nreasonably favorable to the Project and not reasonably supportable. Four key assumptions presented in the letter are discussed and responded to in further detail below, none of which change the accuracy of validity of the analysis and conclusions in the Draft EIS.

Response to Comment 7-60
Please refer to Response to Comment 7 -14 with a more detailed response on the trip generation rates used to analyze the Project’s potential traffic impacts on the surrounding roadway network. As stated in the Traffic Study ( Appendix G of the Draft EIS) as well as thoroughly discussed in Section 5.14 , the RivTAM was used to develop total traffic volume projections for the future horizon year 2035. RivTAM was used to ensure consistency with regional transportation modeling and to avoid the need for subjective assumptions regarding which trip -generation rates are appropriate and what percentage of the future site traffic would be pass-by trips and internal trips.

RivTAM has been calibrated and validated for the entire six -county southern California region. Thus, trip generation forecast that was utilized to evaluate the Project -related traffic impacts was based upon the numerous socio -economic parameters for each of the traffic analysis zones within the Project Site.

Additionally, Endo Engineering did not make direct manipulations to RivTAM model runs nor were there 12-3075

2.0 Responses to Comments
Meridian Consultants 2.0-299 Section 24 Specific Plan Project 044-001-13 March 2015
any assumption changes in RivTAM to make them more favorable to the Project. Accordingly, the non - residential trips generated by the Project would not result in higher traffic numbers.

Response to Comment 7-61
Please refer to Response to Comment 7 -14 and 7 -15 for a discussion on the use of internal trips. The traffic impact analysis discussed in Section 5 .14 in the EIS addressed all of the future year 2035 project - related external trips projected by RivTAM. As discussed on page 5.14-19 in Section 5.14 and page 4-5 in the Traffic Study, the internal capture rate between the proposed residential and non -residential uses on-site would be limited by the total number of residential trips. The residential trips for the Project represent approximately 14 percent of the total amount of trips generated by all the proposed uses, therefore, the conservative internal capture rate of 15 percent of residential trips was assumed f or purposes of analysis. Accordingly, the traffic impact analysis, specifically the use of the internal capture rate of 15 percent, presented in Section 5.14 and in the Traffic Study ( Appendix G of the Draft EIS) addressed all of the future year 2035 Project-related external trips.

Response to Comment 7-62
Please refer to Response to Comment 7 -14 and 7-16 for a discussion on the use of pass -by trips. As discussed on page 5.14 -20 in Section 5.14 and page 4 -6 in the Traffic Study, p ass-by trips will be attracted to the commercial uses in the Project Site from traffic passing the site on adjacent streets. As noted above, RivTAM was used to avoid the need for subjective assumptions regarding what percentage of the future Project traffic would be pass -by trips. The analysis presented in Section 5.14 of the Draft EIS and the Traffic Study addressed all of the future year 2035 project-related external trips projected by RivTaM. Since the commercial uses anticipated on -site have not been established, a conservative pass - by rate of 15 percent was assumed. Accordingly, the traffic impact analysis, specifically the use of the pass-by rate of 15 percent, presented in Section 5.14 and in the Traffic Study ( Appendix G of the Draft EIS) addressed all of the future year 2035 Project-related external trips.

Response to Comment 7-63
Please refer to Response to Comment 7 -14 and 7-17 about the peak hour factor. As discussed on page

5.14-18 in Section 5.14 , t he peak hour factors determined from the peak hour traffic counts at the existing key intersection were assumed for the existing and year 2022 operational analyses. The traffic analysis used a peak hour factor of 1.0 for full development of the Project consistent with the input parameters specified by the Riverside Country Transportation Department. The higher peak hour factor reflects future conditions with heavier traffic volumes distributed more evenly during the peak hours.

12-3076

2.0 Responses to Comments
Meridian Consultants 2.0-300 Section 24 Specific Plan Project 044-001-13 March 2015
Response to Comment 7-64
The Riverside County Traffic Analysis Model (RivTAM), completed in May 2009, was developed with the cooperative efforts of the Riverside County Transportation Department ( RCTD), Western Riverside Council of Governments (WRCOG), Coachella Valley Association of Governments (CVAG), Riverside County Transportation Commission (RCTC), Southern California Association of Governments (SCAG), and California Department of Transportation (Caltrans).

The RivTAM incorporates a detailed description of Riverside County, while maintaining consistency with the SCAG Regional Model. RivTAM is intended for use for transportation planning purposes throughout Riverside County by all levels of governmental jurisdiction and by private entities and as a tool to determine the potential impacts of large development proposals, General Plan land use changes, and forecasting for Transportation projects.

As discussed in Section 5.14 pages 5.14- 21 through 5. 14-26 and thoroughly discussed in the Traffic Study prepared for the Project, the methodology used for the traffic study was agreed upon with the City. The scope and methodology for preparation of the Section 24 Traffic Impact Study was discussed and coordinated with City Staff at a meeting held in January 9, 2014, prior to preparation of the study.

The number and locations of the intersections to be studied were reviewed, as well as the use of the RivTAM to assess project and cumulative impacts. The number of intersections proposed for study was increased at the request of the City. In addition, it was agreed that the RivTAM was the most appropriate traffic demand model available for use. All potential traffic impacts to intersections and roadways within th e study area were identified as less than significant or were determined to be less than significant with feasible mitigation. Accordingly, the Traffic Study prepared for the Project would not need to be re-modeled based on the four assumptions identified in the letter.

Response to Comment 7-65
No improvements would be required at the intersection of Da Vall Drive with Ramon Road to accommodate existing plus Project buildout traffic volumes at acceptable levels of service. The traffic generated by the Initial Phase of the Section 24 Specific Plan in the year 2022 would represent only 6 percent of the total Project-related traffic and would not have a significant impact at this intersection.

The mitigation required at this intersection in the horizon year 20 35 would be needed with or without Project traffic. The primary increase in traffic that will occur on Da Vall Drive at this intersection will be the result of the future I -10 interchange at Da Vall Drive. For that reason, Riverside County has included improvements to DaVall Drive in the Transportation Project Prioritization Study (TPPS). The additional southbound left-turn lane on Da Vall Drive at Ramon Road will need to be in place before the Da Vall 12-3077

2.0 Responses to Comments
Meridian Consultants 2.0-301 Section 24 Specific Plan Project 044-001-13 March 2015
Drive interchange is constructed and opened, and is the refore expected to be part of the interchange improvement project.

Response to Comment 7-66
Please refer to Response to Comment 7 -18 for a more detailed discussion on potential impacts on freeways and freeway ramps. Section 5.14 of the Draft EIS included an operational analysis of the Project-related traffic impacts on the I-10 interchange at Bob Hope Drive and Ramon Road, identified as Intersections 1, 2, and 7. These three intersections represent the constraining component of the closest ramps that provide access to and from I- 10 in both directions. All three ramps in the Existing with development of the Active Adult Community are projected to operate at LOS C or better during the AM and PM peak hours, as identified in Table 5.14 -6 in Section 5.14. All three ramps in the Existing with Full Project Development are projected to operate at LOS C or better during both peak hours, as identified in Table 5.14-8. Intersection 1 during the AM peak hour and Intersections 2 and 7 during both peak hours in the Year 2035 with Full Project Development are projected to operate at LOS B or better, as identified in Table 5.14- 12 in Section 5.14. Intersection 1 during the PM peak hour in the Year 2035 with Full Project Development is projected to operate at LOS D, a s identified in Table 5.14- 12. Accordingly, the Project would operate within the LOS identified by Caltrans for ramps along the I -10 during peak hours.

No supplemental analysis would be required as no new significant impacts or substantially increased impacts were identified.

Response to Comment 7-67
Please refer to Response to Comment 7 -66. Without the I- 10 Route Concept Fact Sheet, which is currently being updated by Caltrans, it is not possible to accurately identify the future right -of-way requirements and design concept to accommodate buildout of the local general plans with a target of maintaining LOS E during the peak periods in the urbanizing areas and LOS C in the rural areas. If the design concept achieves the goal of accommodating buildout of the local general plans, it will accommodate the Project and all Project alternatives at acceptable levels of service.

Response to Comment 7-68
Please refer to Response to Comment 7 -64 in which the Traffic Study utilized the local traffic model (RivTAM) adopted by jurisdictions within the CVAG boundary. The analysis presented in Section 5.14 determined that, with the incorporation of Project Design Features PDF 5.14 -1 through PDF 5.14 -9 and Mitigation Measures MM 5.14 -1 through MM 5.14-6, transportation and traffic impacts would be less than significant.

12-3078

January 20, 2015

Via Electronic Mail and Overnight Mail

Margaret Park, AICP
Director of Planning and Natural Resources
Agua Caliente Band of Cahuilla Indians
5401 Dinah Shore Drive
Palm Springs, CA 92264
Email: mpark@aguacaliente‐nsn.gov
Fax: (760) 699‐6822

City of Rancho Mirage
Mayor Iris Smotrich ([email protected])
And Honorable Member of the Rancho Mirage City Council
Cindy Scott, City Clerk ([email protected])
Steven B. Quintanilla, City Attorney ([email protected]) Bud Kopp, Planning Manager ([email protected])
Rancho Mirage City Hall
69-825 Highway 111
Rancho Mirage, CA 92270
Phone: (760) 324-4511
Fax: (760) 324-8830

Riverside Local Agency Formation Commission
3850 Vine St, Suite 240
Riverside, CA. 92507-4277
(951) 369-0631
([email protected])

Re: Comment re: Draft Environmental Impact Statement for the Proposed Section 24 Specific Plan Agua Caliente Band of Cahuilla Indians (SCH No. 2014011035)

Dear Ms. Park, Mayor Smotrich and Riverside Local Agency Formation Commission:

This letter is submitted on behalf of Laborers International Union of North America, Local Union 1184 and its thousands of members in Riverside County(collectively "LIUNA" or "Commenters") regarding the proposed Section 24 Specific Plan project proposed by the Agua Caliente Band of Cahuilla Indians (SCH No. 2014011035). (“Project”). This letter supplements our letter submitted 1 2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-302
12-3079
Comment on Section 24 Specific Plan DEIS
January 20, 2015

on January 16, 2015, and focuses on the biological impacts of the Project. This letter is supported by the comments of expert wildlife biologist, Dr. Shawn Smallwood, Ph.D. Dr. Smallwood’s comments are attached hereto and should be responded to separately. We incorporate by reference herein our letter dated January 16, 2015.

As discussed herein, after reviewi ng the Draft Environmental Impact Statement (“DEIS”) for the Project together with our expert consultants, it is evident that the document fails to comply with the California Environmental Quality Act, Public Resources Code § 21000 et seq. (“CEQA”), and contains numerous errors and omissions that continue to preclude accurate analysis of the Project.

As a result of these inadequacies, the DEIS fails as an informational document, fails to analyze all significant impacts of the Project, fails to identify and impose feasible mitigation measures to reduce the Project’s impacts, and fails to properly analyze Project alternatives and cumulative impacts. 1 As a
result, the Project will result in significant environmental impacts that have not been adequately addressed or mitigated as required by CEQA. LIUNA Local 1184 therefore requests that the Tribe and the City of Rancho Mirage (“City”) or the Riverside Local Agency Formation Commission (“LAFCO”) prepare and circulate a Supplemental Draft Environmental Impact Report (“SEIR”) to address the issues raised in this and other comments, and to require implementation of feasible mitigations and alternatives required by law.

1. The FEIR Fails to Adequately Analyze Impacts to Biological Resources.

It is the policy of the State of California to

Prevent the elimination of fish or wildlife species due to man’s activities, insure that fish and wildlife populations do not drop below self- perpetuating levels, and preserve for future generations representations of all plant and animal communities.

(Pub. Res. Code § 21001(c).) An EIR may not avoid studying impacts to biological resources by proposing future study or mitigation based on future studies unless the mitigation measures and performance standards are explicit in the DEIR. (San Joaquin Raptor Rescue Center v. County of Merced (2007) 149 Cal.App.4th 645, 671)

1 We reserve the right to supplement these comments at any later hearings and proceedings related to this Project. See Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109.
1 2
3 2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-303
12-3080
Comment on Section 24 Specific Plan DEIS
January 20, 2015

As discussed by Dr. Smallwood, the DEIS fails to assess impacts to wildlife, especially sensitive species and plants. Where impacts are identified, the DEIS impermissibly relies on vague, unenforceable and deferred mitigation measures, most of which lack a foundation in science and performance standards. Consequently, the DEIS must be revised to reassess impacts to biological resources and, where appropriate, propose adequate mitigation measures with definite terms and verifiable performance standards.

a. The DEIS Fails to Describe Existing Conditions That are Necessary for a Reasonable Analysis of the Project’s
Potentially Significant Biological Impacts.

Dr. Smallwood concludes that the truncated wildlife surveys for the site ignore applicable protocols and fail to provide a proper baseline or describe the true environmental setting at the proposed Project site.

A CEQA document “must include a description of the environment in the vicinity of the project, as it exists before the commencement of the project, from both a local and a regional perspective.” (CEQA Guidelines § 15125; see Environmental Planning and Info. Council v. County of El Dorado (1982) 131 Cal.App.3d 350, 354.) This environmental setting will normally constitute the baseline physical conditions by which a Lead Agency determines whether an impact is significant.” (CEQA Guidelines § 15125.) Thus, the CEQA “baseline” is the set of environmental conditions against which to compare a project’s anticipated impacts. (Communities for a Better Environment v. So Coast Air Qual. Mgmnt. Dist. (2010) 48 Cal. 4th 310, 321.) Where a Project’s baseline is skewed by omissions or misrepresentations in the MND, it “mislead(s) the public” and “draws a red herring across the path of public input.” (San Joaquin Raptor Rescue Center v. County of Merced (2007) 149 Cal.App.4th 645, 656; Woodward Park Homeowners v. City of Fresno (2007) 150 Cal.App.4th 683, 708-711. See Save Our Peninsula Committee v. County of Monterey (2001) 87 Cal.App.4th 99, 121-23 (“the impacts of the project must be measured against the ‘real conditions on the ground,’” as opposed to hypothetical conditions).)

The failure of the DEIS and DEIS consultant to conduct wildlife surveys capable of accurately detecting burrowing owls, clapper rails, other birds of concern, or reptiles and amphibians provides no baseline in the DEIS or its attachments from which the public can evaluate potential impacts to wildlife.

Dr. Smallwood points out that a fundamental shortcoming of the DEIS is that it concludes that Section 24 is an “ecological island.” Dr. Smallwood points out this is a biased perspective to ignores the fact that “many animals can fly, walk, or crawl” on an off of the Project site. Furthermore, plant species exist on the site and successfully spread their seeds. The “ecological island” theory is 3 4
5 2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-304
12-3081
Comment on Section 24 Specific Plan DEIS
January 20, 2015

contradicted by the plain fact that several special status species have been found on the site, including the Coachella Valley fringe-toed lizard, flat-tail horned lizard, burrowing owl, and Palm Springs ground squirrel.

Dr. Smallwood concludes that the bi ological surveys performed for the DEIS were inadequate and failed to conform with applicable guidance and protocols. For example, Dr. Smallwood points out that site surveys were conducted in February and March 2014, but this is a time when it is least likely to find special status species. Burrowing owls do not begin nesting until April. (Smallwood, p.3). Dr. Smallwood points out that the consultant smoothed surfaces of Section 24 and then concluded that there are no wildlife movement corridors on the site. Dr. Smallwood concludes that the soil smoothing changes animal behavior by eliminating markings that animals use to mark their paths. “Smoothing obliterates the markings of wildlife, and so disrupt the use of ‘corridors.’” (Smallwood, p.4). Thus, “The EIS had no foundation for concludes ‘no discrenable and routinely used corridors could be found.’” (Id.). Dr.

Smallwood points out that the DEIS used no accurate method for detecting bats.

Dr. Smallwood points out that desert tortoise surveys were conducted in February and March, but US Fish and Wildlife Service protocols require that surveys be conducted in April and May or September and October. Thus, the DEIS’ conclusion that desert tortoise was not found on the site lacks foundation.

The DEIS fails entirely to analyze t he Project site’s importance as stop- over habitat for migratory birds.

As a result of these and other deficiencies identified by Dr. Smallwood, the DEIS fails to describe the existing environment of Section 24. A supplemental Draft EIS is necessary to accurately describe the Project site and the Project’s impacts on the existing environment.

b. The Project Has Adverse Environmental Impacts Not
Addressed in the DEIS.

Dr. Cashen concludes that the Pr oject will have adverse impacts on wildlife movement corridors. Dr. Cashen states:

Section 24 represents a chokepoint to wildlife movement, so losing it to another residential project will block movement of wildlife along the northwest-southeast band of open spaces south of I-10. Converting Section 24 to urban housing will not only remove 577 acres of habitat of many wildlife species, but will also effectively remove the habitat capacity of at least 2,500 acres of acres of additional habitat southeast of Section

24. The additional impacts are readily apparent in Figure 1, and should not be ignored in the EIS.
5 6
7 8
9 10
11 2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-305
12-3082
Comment on Section 24 Specific Plan DEIS
January 20, 2015

Figure 1. Google Earth imagery from 2012 shows the linkages of open space south of I-10, and how converting Section 24 (red boundary) to houses will eliminate the ability of terrestrial wildlife to move (orange arrows) into and out of >2,500 acres of open space.

This impact must be analyzed and mitigated in a supplemental DEIS.

c. The Project Has Signifi cant Cumulative Impacts.

Dr. Smallwood points out t hat the DEIS contains essentially no cumulative impacts analysis – devoting a mere 19 lines of text to the subject. Dr. Smallwood concludes that the Project will have significant cumulative impacts related to habitat fragmentation together with other ongoing, proposed or likely future projects in the area. For example, Dr. Smallwood points out that according to the Desert Renewable Energy Conservation Plan (“DRECP”), 330,000 acres are likely to be converted to solar, wind, geothermal, distributed energy and transmission projects with the Mojave Desert in the near future. Dr. Smallwood concludes that the Project, together with these cumulative projects, “would eliminate most of the remaining population of burrowing owls in California, as well as large proportions of the remaining populations of desert tortoise, Coachella Valley fringe-toed lizard, flat-tail horned lizard, and Palm Springs ground squirrel, among many other special-status species.” (Smallwood, p. 6).

An EIR must discuss significant cumulative impacts. CEQA Guidelines section 15130(a). This requirement flows from CEQA section 21083, which requires a finding that a project may have a significant effect on the environment 11 12
13 2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-306
12-3083
Comment on Section 24 Specific Plan DEIS
January 20, 2015

if “the possible effects of a project are individually limited but cumulatively considerable. . . . ‘Cumulatively considerable’ means that the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” “Cumulative impacts” are defined as “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts.” CEQA Guidelines section 15355(a). “[I]ndividual effects may be changes resulting from a single project or a number of separate projects.” CEQA Guidelines section 15355(a).

“The cumulative impact from several projects is the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time.” Communities for a Better Environment v. Cal. Resources Agency (“CBE v. CRA”), (2002) 103 Cal.App.4
th 98, 117. A legally adequate cumulative impacts analysis views a particular project over time and in conjunction with other related past, present, and reasonably foreseeable probable future projects whose impacts might compound or interrelate with those of the project at hand. “Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time.” CEQA Guidelines § 15355(b).

As the court stated in CBE v. CRA, 103 Cal. App. 4th at 114:

Cumulative impact analysis is necessary because the full environmental impact of a proposed project cannot be gauged in a vacuum. One of the most important environmental lessons that has been learned is that environmental damage often occurs
incrementally from a variety of small sources. These sources appear insignificant when considered individually, but assume threatening dimensions when considered collectively with other sources with which they interact.

(Citations omitted).

In Kings County Farm Bureau v. City of Hanford, 221 Cal.App.3d at 718, the court concluded that an EIR inadequately considered an air pollution (ozone) cumulative impact. The court said: “The [ ] EIR concludes the project’s contributions to ozone levels in the area would be immeasurable and, therefore, insignificant because the [cogeneration] plant would emit relatively minor amounts of [ozone] precursors compared to the total volume of [ozone] precursors emitted in Kings County. The EIR’s analysis uses the magnitude of the current ozone problem in the air basin in order to trivialize the project’s impact.” The court concluded: “The relevant question to be addressed in the EIR 13 2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-307
12-3084
Comment on Section 24 Specific Plan DEIS
January 20, 2015

is not the relative amount of precursors emitted by the project when compared with preexisting emissions, but whether any additional amount of precursor emissions should be considered significant in light of the serious nature of the ozone problems in this air basin.”2 The Kings County case was recently reaffirmed in CBE v. CRA, 103 Cal.App.4th at 116, where the court rejected cases with a narrower construction of “cumulative impacts.”

Similarly, in Friends of Eel River v. Sonoma County Water Agency, (2003) 108 Cal. App. 4th 859, the court recently held that the EIR for a project that would divert water from the Eel River had to consider the cumulative impacts of the project together with other past, present and reasonably foreseeable future projects that also divert water from the same river system. The court held that the EIR even had to disclose and analyze projects that were merely proposed, but not yet approved. The court stated, CEQA requires “the Agency to consider ‘past, present, and probable future projects producing related or cumulative impacts . . . .’ (Guidelines, § 15130, subd. (b)(1)(A).) The Agency must interpret this requirement in such a way as to ‘afford the fullest possible protection of the environment.’” Id., at 867, 869. The court held that the failure of the EIR to analyze the impacts of the project together with other proposed projects rendered the document invalid. “The absence of this analysis makes the EIR an inadequate informational document.” Id., at 872.

The court in Citizens to Preserve the Ojai v. Bd. of Supervisors, 176 Cal.App.3d 421 (1985), held that an EIR prepared to consider the expansion and modification of an oil refinery was inadequate because it failed to consider the cumulative air quality impacts of other oil refining and extraction activities combined with the project. The court held that the EIR’s use of an Air District Air Emissions Inventory did not constitute an adequate cumulative impacts analysis.

The court ordered the agency to prepare a new EIR analyzing the combined impacts of the proposed refinery expansion together with the other oil extraction projects.

The DEIS contains no list of cu mulative past, present and reasonably foreseeable future projects, and contains no legally sufficient cumulative impact analysis. A supplemental DEIS is required to analyze the Project’s cumulative impacts and to propose feasible mitigation.

2 Los Angeles Unified v. City of Los Angeles, 58 Cal.App.4th at 1024-1026 found an EIR inadequate for concluding that a project's additional increase in noise level of another 2.8 to

3.3 dBA was insignificant given that the existing noise level of 72 dBA already exceeded the regulatory recommended maximum of 70 dBA. The court concluded that this "ratio theory" trivialized the project's noise impact by focusing on individual inputs rather than their collective significance. The relevant issue was not the relative amount of traffic noise resulting from the project when compared to existing traffic noise, but whether any additional amount of traffic noise should be considered significant given the nature of the existing traffic noise problem. 13 2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-308
12-3085
Comment on Section 24 Specific Plan DEIS
January 20, 2015

d. The DEIS Relies on Legally Inadequate Mitigation
Measures.

Dr. Smallwood points out that the DEIS relies on legally and factually inadequate mitigation measures for the Project’s biological impacts. The primary mitigation measure is a payment to the Tribal Habitat Conservation Plan (THCP) in the amount of $2371 per disturbed acre. This mitigation measure is inadequate as a matter of law.

First, the US Fish and Wildlife Service has not yet approved the THCP. (DEIS p.2.0-23). Therefore, there can be no assurance that the THCP is adequate to mitigate Project impacts, and no calculation of the appropriate fee that would be required for mitigation. The DEIS may not rely on an unapproved TCHP as mitigation.

Second, mitigation fees are generally not adequate mitigation, unless specific measures are identified that will be paid for and implemented by the fee.

The DEIS fails to identify any specific measures. Measures may include such things as conservation easements, creation of off-site habitat, or other measures, but the DEIS fails to identify any specific measures. This renders the mitigation legally inadequate. Mitigation fees are not adequate mitigation unless the lead agency can show that the fees will fund a specific mitigation plan that will actually be implemented in its entirety. Napa Citizens for Honest Gov. v. Bd. Of Supervisors (2001) 91 CallApp.4th 342 (no evidence that impacts will be mitigated simply by paying a fee); Anderson First Coal. v. City of Anderson (2005) 130 Ca.App.4th 1173 (traffic mitigation fee is inadequate because it does not ensure that mitigation measure will actually be implemented); Kings Co. Farm Bureau v. Hanford (1990) 221 Cal.App.3d 692. But see, Save Our Peninsula Comm v. Monterey Co. (2001) 87 Cal.App.4th 99 (mitigation fee allowed when evidence in the record demonstrates that the fee will fund a specific mitigation plan that will actually be implemented in its entirety). In California Native Plant Society v. County of El Dorado et al. (2009) 170 Cal. App. 4th 1026, the court held that the fee program had to have gone through CEQA review for an agency to say that the payment of the fee alone is adequate CEQA mitigation.

Third, the mitigation fee constitu tes a prohibited deferred mitigation measure. CEQA requires the specific mitigation measures to be set forth in the DEIR, so that the public may review and comment on the measures. The DEIS fails to identify any specific measures to mitigate the Project’s biological impacts.

While a payment amount is identified, the DEIS fails to identify any specific measures that will be implemented with this fee. Any specific measures will be developed at a later time. This constitutes improper deferred mitigation. Deferral of mitigation measures is prohibited under CEQA:

14 2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-309
12-3086
Comment on Section 24 Soecific Plan DEIS
January 20, 2015
Page I of I
By adopting the condition that applicant would comply with environmental standards for sludge disposal, the County effectively removed this aspect of the project from environmental review, trusting that the Regional Water Quality Control Board and the applicant would work out some solution in the future..... Having no "relevant data" pointing to a solution of the sludge disposal problem, the County evaded its duty to engage in a comprehensive environmental review by approving the use permit subject to a condition requiring future regulatory compliance. Sundstrom,202 Cal.App.3d at 309.
[R]eliance on tentative plans for future mitigation after completion of the CEQA process significantly undermines CEQA's goals of full disclosure and informed decisionmaking; and[,] consequently, these mitigation plans have been overturned on judicial review as constituting improper deferral of environmental assessment. Communities for a Better Environment v.

City of Richmond (2010) 184 Cal.App.4th at 92.

Fourth, the burrowing owl mitigation measure fails to comply with applicable guidance. MM 5.3-2 requires pre-construction surveys for burrowing owls 30 days prior t construction. However, the California Department of Fish and Game (2012) requires burrowing owl surveys 15 days prior to construction. CDFG also recommends 500 meler buffer zones between owl burrows and construction areas. The DEIS fails to incorporate these measures. The DEIS therefore fails to impose all feasible mitigation measures.

CONCLUSION
LIUNA Local Union No. 1184 believes the DEIS is legally inadequate and requires significant revision, recirculation and review. Thank you for your attention to these comments. Please include this letter and all attachments hereto in the record of proceedings for this project.

Richard T. Drury
Lozeau Drury LLP
Attorneys for Laborers'
North America (LIUNA),
lnternational Union of
Local Union No. 11 84
14 15

2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-310
12-3087
K. Shawn Smallwood, Ph.D.
3108 Finch Street
Davis, CA 95616

Margaret Park, AICP
Director of Planning and Natural Resources
Agua Caliente Band of Cahuilla Indians
5401 Dinah Shore Drive
Palm Springs, CA 92264

City of Rancho Mirage
Mayor Iris Smotrich
And Honorable Member of the Rancho Mirage City Council Cindy Scott, City Clerk Steven B. Quintanilla, City Attorney Bud Kopp, Planning Manager, Rancho Mirage City Hall
69-825 Highway 111
Rancho Mirage, CA 92270

Riverside Local Agency Formation Commission
3850 Vine St, Suite 240
R i v e r s i d e , C A . 9 2 5 0 7 - 4 2 7 7 1 9 J a n u a r y 2 0 1 5

RE: Draft Environmental Impact Statement for the Proposed Section 24 Specific Plan Agua Caliente Band of Cahuilla Indians (SCH No. 2014011035)

Dear Ms. Park, Mayor Smotrich and Riverside Local Agency Formation Commission,

I write to comment on the Draft Environmental Impact Statement for the Proposed Section 24 Specific Plan Agua Caliente Band of Cahuilla Indians (“EIS”) (Meridian Consultants 2014). I have reviewed the biological resources section of the EIS and the supporting report on biological resources (Cornett 2014).

My education and experience are as follows. I earned a Ph.D. degree in Ecology from the University of California at Davis in 1990. Subsequently I worked at U.C. Davis for four years as a post-graduate researcher in the Department of Agronomy and Range Sciences. My research has been focused on animal density and distribution, habitat selection, habitat restoration, interactions between wildlife and human infrastructure and activities, conservation of rare and endangered species, and the ecology of invading species. I have authored numerous papers on special-status species issues, including “Using The Best Scientific Data For Endangered Species Conservation,” published in Environmental Management (Smallwood et al. 1998), and “Suggested Standards For Science Applied To Conservation Issues” published in the Transactions of the Western Section of The Wildlife Society (Smallwood et al. 2001). I served as Chair of the Conservation Affairs Committee for The Wildlife Society – Western Section. I am a member of The Wildlife Society and the Raptor Research Foundation, and I was a part- time lecturer at California State University, Sacramento. I was also Associate Editor of 16 2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-311
12-3088
wildlife biology’s premier scientific journal, The Journal of Wildlife Management, as well as of Biological Conservation, and I was on the Editorial Board of Environmental Management.

I have performed numerous surveys for special-status species over the last 25 years, including 11 years of surveys for California red-legged frog and California tiger salamander, and 14 years for Fresno kangaroo rat, several years for salt marsh harvest mouse and California clapper rail, 16 years for burrowing owl, and 25 years for Swainson’s hawk and white-tailed kite. Based on my education and field experience, I am familiar with the ecology and habitat of wildlife species likely to occur on the project site. My CV is attached.

IMPACTS ASSESSMENT

The EIS addressed the potential impacts of converting 577 acres of plant and wildlife habitat to residential use. This 577-acre area is one of the last open spaces south of Interstate 10 in the Coachella Valley, in a region known for high species richness.

Therefore, it is important that the EIS carefully and comprehensively considers the potential project impacts and mitigation. However, this EIS inadequately described the current environmental setting, and its impact assessments and mitigation measures fell far short of what was needed.

Under CEQA,
1 “[A] paramount consideration is the right of the public to be informed in such a way that it can intelligently weigh the environmental consequences of any contemplated action and have an appropriate voice in the formulation of any decision.” The public needs information that is thorough, relevant, unbiased, and honest; the public needs full disclosure of the environmental setting and possible cumulative impacts. Documents presenting information from a biased perspective will tend to include omissions, logical fallacies, internal contradictions, and unfounded responses to substantial issues. Therefore, my assessment of the EIS and of Cornett (2014) also considers omissions and bias, which bear on the sufficiency of the EIS.

As an example of bias, Cornett (2014:10) described the project site as “…nearly an ecological island bounded on all four sides by paved roadways (three of them carrying high volumes of traffic) and on two sides by residential developments.” This characterization might apply to some unnamed species that cannot cross a road, but for most animal and plant species the roadways probably do not isolate the habitat on the project site; many animals can fly, walk, or crawl across, alth0ugh many undoubtedly die in the attempt, but they also carry and disperse plant seeds and life does continue on Section 24 despite the roads. The implication of Cornett’s unfortunate site characterization is that the site is a throw-away site in terms of the local ecological resources, and so biological surveys need not consist of anything more than the cursory

1 Environmental Planning and Information Council vs. County of El Dorado (1982) 131 Cal. App. 3d 350, 354.

16 17
18 2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-312
12-3089
surveys that were performed and satisfactory mitigation can be achieved mostly by paying a fee into a habitat conservation plan that has yet to be approved.

In fact, Section 24 is not an ecological island. If it was an ecological island, then special- status species, such as Coachella Valley fringe-toed lizard, flat-tail horned lizard, burrowing owl, and Palm Springs ground squirrel, would not have been found on site.

These species, and probably other special-status species as well, persist on the site, despite the near complete conversion of habitat to residential and commercial uses within the Coachella Valley south of Interstate 10. Had adequate surveys been performed, additional special-status species probably would have been found.

The biological surveys performed on the proposed project site were inadequate. Site visits were made by Cornett and Walter Millin for unreported periods of time on 19 days during February and March 2014, and during two nights in February (presumably involving the mammal live-traps). Cornett and Millin walked along east-west transects at 10-yard intervals during a small portion of a single season of a single year, and this time of year was, in my experience, the least likely to detect special-status species.

Burrowing owls behave cryptically during this time of year, and so are difficult to detect.

Burrowing owls do not begin nesting until April. Other special-status species are typically aestivating during this time of year. And during this time of year, migrating birds are generally not on the move.

Besides these pedestrian transects, Cornett and Millin also set 25 mammal live-traps on two nights for a mere 50 trap-nights, although the number of effective trap nights was not reported, nor were the locations of the traps or any report of trapping methods, capture success or trap mortality. The trap coverage averaged 23 acres per trap (577 acres ÷25 traps) and 0.5% of a year, and so grossly under-sampled Section 24.

Cornett (2014) monitored roadkill on roads bordering Section 24 to assess whether the site is used as a movement corridor. However, Cornett provided no details on how the roadkill surveys were performed or what was found. Without methods and results, these alleged surveys were meaningless. Furthermore, February and March is not when roadkill should be used to inform about mammalian or reptilian travel patterns. I have performed thousands of miles of roadkill surveys since 1989, so I can testify with ample confidence that most of the mammals killed by cars are killed during fall, which is the peak of dispersal and migration. There should also be lower reptile activity during February and March.

Finally, Cornett (2014) smoothed soil surfaces on portions of Section 24 to record animal tracks as a means of determining whether the site includes wildlife movement corridors. Cornett (2014) provided no details of how much area was smoothed, or in what orientation or shape the soil was smoothed. No results were reported, either.

Having developed tracking techniques since 1985, and having performed many research studies and surveys involving track counts, I can testify with ample confidence that soil smoothing changes the behaviors of the animals under survey. Wildlife that use trails or that develop routine travel routes also mark their travel paths with scent glands associated with scrapes, scats, and urine. Smoothing obliterates the markings of 18 19
20 2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-313
12-3090
wildlife, and so disrupt the use of “corridors.” Smoothing is the last thing I would do if I was interested in detecting travel paths or corridors. The EIS (page 5.3-9) had no foundation for concluding “…no discernable and routinel y used corridors could be found.”

Despite the extremely cursory nature of the surveys, Cornett (2014) detected multiple special-status species. More special-status species likely would have been detected had surveys been performed during other times of year, or had surveys been performed off site (No off-site surveys due to private property restrictions), or had surveys involved methods appropriate for the species. For example, pedestrian surveys and mammal live-trapping are unsuited for detecting bats. Bat surveys need to be performed using acoustic detectors or thermal cameras. Until appropriate surveys are performed, it is indefensible to conclude that only two species of bat potentially use Section 24. I have yet to encounter any place in California that hosts only two species of bat.

As another example, bird species will remain underrepresented until point counts are performed, and until they are performed over each season of the year. Point counts have been the standard method for detecting birds for about a century. Walking back and forth across a site is not the standard method for detecting most birds. Therefore, there was no foundation for Cornett’s (2014:13) conclusion, “In spite of severe long- term drought, it was concluded that this phenomenon did not impact the findings in this report because of evidence of sensitive species that was discovered and historical information regarding the biota of the project site.” Other than the species detections that were made despite the extremely cursory nature of the surveys, there was no support for determining that undetected species are absent from the site, and absolutely no support for making any determination about the impacts of the drought on Cornett’s findings.

According to Cornett 2014:17, “… the California Natural Diversity Database (March, 2014) has no records of the tortoise on or within one mile of the project site.” If this is the sort of historical information that Cornett referred to, as summarized in the previous paragraph, then it was unreliable. The California Natural Diversity Database (“CNDDB”) is not a scientific sampling or monitoring program; it is strictly voluntary in the reporting of special-status species by consulting and research biologists. It is inappropriate to use lack of records in CNDDB to support a conclusion that a species is absent from a site. To help get this message across, the California Department of Fish and Wildlife posts a disclaimer on its CNDDB web site: “We work very hard to keep the CNDDB and the Spotted Owl Database as current and up-to-date as possible given our capabilities and resources. However, we cannot and do not portray the CNDDB as an exhaustive and comprehensive inventory of all rare species and natural communities statewide. Field verification for the presence or absence of sensitive species will always be an important obligation of our customers.”
2 Protocol-level surveys would be needed
to conclude that special-status species do not occur at the project site.

2 http://www.dfg.ca.gov/biogeodata/cnddb/cnddb_info.asp 20 21

2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-314
12-3091
Cornett (2014) and the EIS reported that desert tortoise was not found on site.

However, the surveys performed on site were inconsistent with the US Fish and Wildlife Service protocol on desert tortoise surveys. The surveys were performed in February and March, whereas the protocol is for surveys to be performed in April and May or September and October. Also, transects should have been surveyed in a random order, but there was no indication that they were surveyed this way on Section 24. In summary, protocol-level surveys were not performed for desert tortoise. For that matter, protocol-level surveys were not performed for any special-status species potentially occurring on Section 24.

Stop-over Habitat

The EIS made no mention of the project impacts on migratory birds. The creosote scrub on Section 24 is undoubtedly used as stop-over habitat by migratory birds during migration seasons. No surveys were performed during migration seasons, and no discussion was provided of the critical importance of stop-over habitat to migratory birds. Essentially, a critical biological value of the site – its role as stop-over habitat -- was never addressed in any way.

Wildlife Movement Corridors

According to Cornett (2014:5.3-17), “The Project Site does not serve as a wildlife movement corridor. The Project Site does not connect any otherwise isolated areas of habitat; it serves more as a wildlife habitat than a wildlife corridor or linkage.

Accordingly, no significant impacts to the movement of wildlife species would result from the development of the Project.” However, these conclusions lack foundation.

Cornett did not perform surveys that would inform of whether or to what degree that Section 24 or any portion of Section 24 serves as a wildlife movement corridor. Not only were the surveys performed on site inconsistent with the types of surveys that would be needed to identify movement corridors, but methodological details and results were unreported by Cornett (2014).

Cornett (2014) and the EIS concluded that Section 24 does not serve as a wildlife movement corridor, but this conclusion represented a red herring argument. CEQA does not identify corridors as central to the environmental impact on wildlife movement. The real issue is whether the proposed project will interfere with the movement of wildlife, thereby disrupting a fundamental ecological requirement of wildlife species. The EIS did not address the real question of whether the project will interfere with the movement of any species of wildlife in the area.

That the project will interfere with wildlife movement should be obvious, given the extent of land conversions in the region and the position that Section 24 occupies on this landscape (Figure 1). Any remaining potential for terrestrial wildlife movement across the valley portion of the landscape south of I-10 has been constrained by past residential and commercial development (Figure 1). Section 24 represents a chokepoint to wildlife movement, so losing it to another residential project will block movement of wildlife along the northwest-southeast band of open spaces south of I-10. Converting 22 23
24 2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-315
12-3092
Section 24 to urban housing will not only remove 577 acres of habitat of many wildlife species, but will also effectively remove the habitat capacity of at least 2,500 acres of acres of additional habitat southeast of Section 24. The additional impacts are readily apparent in Figure 1, and should not be ignored in the EIS.

Figure 1. Google Earth imagery from 2012 shows the linkages of open space south of I-10, and how converting Section 24 (red boundary) to houses will eliminate the ability of terrestrial wildlife to move (orange arrows) into and out of >2,500 acres of open space.

Cumulative Impacts

The EIS devoted 18 lines of text to cumulative impacts. Given such a cursory treatment of cumulative impacts, one would think that the EIS would err on the side of caution when making conclusions about cumulative impacts. After all, erring on the side of caution is the standard when making conclusions of potential impacts to sensitive resources in the face of high uncertainty (National Research Council 1986, Shrader- Frechette and McCoy 1992, O’Brien 2000). But that was not what the EIS did.

According to the EIS (page 5.3-19), “No significant unavoidable project or cumulative impacts to biological resources would result from the Project.” This conclusion was inconsistent with scientific standards, it was inconsistent with the evidence, and it was incorrect.

According to the EIS (page 2.0-24), “The Project Site does not serve as a wildlife movement corridor. The Project Site does not connect any otherwise isolated areas of habitat. Accordingly, no significant impacts to the movement of wildlife species would result from the development of the Project.” Figure 1 clearly shows that the project site does, in fact, connect otherwise isolated areas of habitat. At least 2,500 acres will be cut off from terrestrial wildlife movement should the 577 acre project area be converted to 24 25

2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-316
12-3093
houses. This type of impact is what is referred to as habitat fragmentation, which is recognized as one of the most serious threats to the continued existence of terrestrial wildlife (Wilcox and Murphy 1985). Dismissing this process in the EIS was a substantial error.

Even the most simple cumulative impacts assessment was not provided in the EIS. The EIS could have tallied the number of acres of likely or potential land conversions in the Coachella Valley due to ongoing, proposed, or likely future residential, commercial and industrial projects in the foreseeable future. The EIS could have tallied the acres of proposed or anticipated land conversions to renewable energy projects within Riverside County and the larger Mojave Desert. According to the Desert Renewable Energy Conservation Plan (“DRECP”), 330,000 acres are likely to be converted to solar, wind, geothermal, distributed energy, and transmission projects within the Mojave Desert in the near future (California Energy Commission et al. 2014). These land conversions would eliminate most of the remaining population of burrowing owls in California, as well as large proportions of the remaining populations of desert tortoise, Coachella Valley fringe-toed lizard, flat-tail horned lizard, and Palm Springs ground squirrel, among many other special-status species.

MITIGATION

The core element of the mitigation plans is payment of a mitigation fee into a Habitat Conservation Plan (HCP), at the rate of $2,371 per disturbed acre. According to the EIS (page 2.0-23), “The Project would pay the development mitigation fees identified by the Tribal Habitat Conservation Plan (THCP). …In addition, the City of Rancho Mirage is a participant and permittee in the Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP) and is coordinating with the Tribe regarding the THCP. … While the Un ited States Fish and Wildlife Service (USFWS) has not yet approved the THCP or issued a 10(a) Permit, the Tribe has independent authority to implement the THCP to mitigate impacts to sensitive resources on Reservation lands.” However, there are two problems with this mitigation plan, as summarized in the EIS.

First, there is no approved HCP to pay into, so this portion of the mitigation amounts to deferring the formulation of the mitigation plan to an unspecified later date when one or both of the referenced HCPs might include mitigation that is acceptable to the US Fish and Wildlife Service and results in approval(s), and after any litigation over the approval has resulted in an outcome. Paying into one or both HCPs prior to approval(s) effectively prevents me and other members of the public from participating with this critical part of the environmental review, because Section 24 would have been developed prior to the circulation of the environmental review documents for one or both HCPs.

The second problem is that portion of the proposed measure that alleges the Tribe has the authority to independently implement mitigation on Reservation lands. Even if the Tribe possesses this authority (I do not know whether it does or does not), the EIS still needs to identify where habitat will be protected or where habitat restoration would occur, and it needs to prove that the promised levels of protection and restoration will be feasible. Does the Reservation have sufficient acreage of habitat to protect at 25 26

2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-317
12-3094
whatever mitigation ratio is adequate? What is the mitigation ratio? Where is the like- kind habitat located? The EIS included no details on whether the Reservation has the capacity to conserve sufficient habitat to adequate mitigate the project’s impacts.

According to the EIS (page 5.3-18),“By establishing dedicated conservation areas with stringent development restrictions, the intent of the HCPs is to allow needed development to proceed elsewhere in the valley while preserving sufficient habitat for plant and wildlife species to survive. In this manner, compliance with the HCPs ensure that cumulative impacts to biological resources are mitigated to a level considered less than significant.” But again, there are no approved HCPs available. Even if there were, the EIS should identify where in the Valley conservation areas could be located. The imagery in Figure 1 indicates that there is little opportunity remaining to mitigate for the loss of 577 acres of special-status species habitat within Coachella Valley, and certainly there remains insufficient acreage to offset the loss of both the 577 acre project area and the effective loss of >2,500 acres due to habitat fragmentation.

The EIS stated that MM 5.3-2 would consist of preconstruction surveys for burrowing owls within 30 days of construction. However, this measure made no mention of passive or active relocation if owls are found; the EIS only says that grading can be halted to protect burrowing owls. More detail would be needed on mitigating impacts to burrowing owl. The same detail needs to be added for MM 5.3-3, which is the measure that is supposed to mitigate project impacts to loggerhead shrike.

Also, the California Department of Fish and Game (“CDFG”) (2012) staff recommendations on burrowing owl surveys listed minimum qualifications of survey personnel. The EIS provided no evidence that Cornett met the minimum qualifications of (1) Being familiar with burrowing owl ecology; (2) Experience conducting habitat assessments and non-breeding and breeding season surveys, or experience with these surveys conducted under the direction of an experienced surveyor; (3) Familiarity with the appropriate state and federal statutes related to burrowing owls, scientific research, and conservation; and, (4) Experience with analyzing impacts of development on burrowing owls and their habitat. Given the way the survey were performed, and the conclusions that were made about project impacts to burrowing owl and how to mitigate them, I would suggest that the survey protocol on qualifications was not met.

The CDFG staff report also identified 500 m buffer areas be maintained between burrowing owl burrows and high disturbance activities, but this buffer was not identified in the EIS. The EIS did not include a burrowing owl exclusion plan, but if it was to be revised to include such a plan, then this plan should meet the approval of CDFG. Furthermore, the EIS failed to meet any of the compensatory mitigation options listed in the CDFG staff report.

______________________
Shawn Smallwood, Ph.D.

27 28
29 2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-318
12-3095

REFERENCES CITED

CDFG (California Department of Fish and Game). 2012. Staff Report on Burrowing Owl Mitigation. Sacramento, California.

California Energy Commission, California Department of Fish and Wildlife, U.S. Bureau of Land Management, U.S. Fish and Wildlife Service. 2014. Draft Desert Renewable Energy Conservation Plan (DRECP) and Environmental Impact Report/Environmental Impact Statement, SCH No. 2011071092 , BLM/CA/PL- 2014/025+1793, FWS–R8–ES–2014–N165. http://www.drecp.org/

Cornett, J. W. 2014. General biological resources assessment: Rancho Mirage Section 24 Specific Plan Site, Located Within SECTION 24, RANGE 5 EAST, TOWNSHIP 4 SOUTH Parcels 673-120-021, 673-120-022, 673-120-023, 673-120-024 and 673- 120-025, Riverside County, California. Report to Meridian Consultants, Westlake Village, California.

Meridian Consultants LLC. 2014. Draft Environmental Impact Statement, Section 24 Specific Plan, Agua Caliente Band of Cahuilla Indians (SCH No. 2014011035).

Prepared for Agua Caliente Band of Cahuilla Indians, Palm Springs, California.

National Research Council. 1986. Ecological knowledge and environmental problem- solving: concepts and case studies. National Academy Press, Washington, D.C.

O’Brien, M. 2000. Making better environmental decisions: an alternative to risk management. The MIT Press, Cambridge, Massachusetts.

Shrader-Frechette, K. S., and E. D. McCoy. 1992. Statistics, costs and rationality in ecological inference. Tree 7: 96-99.

Smallwood, K.S., J. Beyea and M. Morrison. 1999. Using the best scientific data for endangered species conservation. Environmental Management 24:421-435.

Smallwood, K.S., A. Gonzales, T. Smith, E. West, C. Hawkins, E. Stitt, C. Keckler, C.

Bailey, and K. Brown. 2001. Suggested standards for science applied to conservation issues. Transactions of the Western Section of the Wildlife Society 36:40-49.

Wilcox, B. A., and D. D. Murphy. 1985. Conservation strategy: the effects of fragmentation on extinction. American Naturalist 125:879-887.

2.0 Responses to Comments
Letter No. 8
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-319
12-3096

2.0 Responses to Comments
Meridian Consultants 2.0-320 Section 24 Specific Plan Project 044-001-13 March 2015
Comment Letter No. 8
Laborers’ International Union of North America (LIUNA), Local Union No. 1184 Richard T. Drury
Attorney, Lozeau Drury LLP
410 12th Street, Suite 250
Oakland, CA 94607
Response to Comment 8-1
The comment identifying the submittal of a comment letter on the behalf of the LIUNA, Local Union No. 1184 in regards to the Project is noted.

Response to Comment 8-2
The Draft EIS has been prep ared in accordance with TEPA and CEQA, with the Tribe serving as the Lead Agency under TEPA. The Draft EIS is intended to serve as an informational document to enable the Tribe, other potential lead and/or responsible agencies under CEQA, and other interes ted parties to evaluate the environment impacts of the Project. Preparation of the environmental document was prepared in compliance with Section 15000 et seq. of the CEQA Guidelines, even though CEQA does not apply to any Project approvals by the Tribe. All mitigation measures, alternatives, and cumulative impacts are identified for the Project as would be required by CEQA. Significant impacts identified for the Project include construction and operation air quality impacts and construction related noise i mpacts. Five alternatives were analyzed to avoid or substantially reduce identified significant impacts and one alternative was chosen as the environmentally superior alternative.

Response to Comment 8-3
The comment suggests that the Draft EIS fails to p roperly assess the Project’s impacts to sensitive species and plants based on the opinion of Dr. Smallwood. As noted in Response to Comment 8 -18, the EIS contains factual, objective and accurate information regarding the biological resources present on the Project Site and in the Coachella Valley that supports the conclusions presented on the significance of the impacts of the Project on biological resources. The Draft EIS appropriately assesses the Project’s potential biological impacts and identifies feas ible mitigation measures to reduce these impacts to a level of less than significance in accordance with CEQA. As discussed in Response to Comment 8-16, Mr.

Smallwood’s experience is limited to Northern California. James W. Cornett, the ecological consultant who conducted the Biological Survey for the Project has over 40 years of expertise within the Coachella Valley and is very knowledgeable regarding the environmental and ecological conditions that are present within the Project Area.
12-3097

2.0 Responses to Comments
Meridian Consultants 2.0-321 Section 24 Specific Plan Project 044-001-13 March 2015
Response to Comment 8-4
As further discussed in detail in Response to Comment 8 -20, biological surveys conducted for the Project Site were based upon the unique existing environmental conditions of the Coachella Valley. The survey pattern used has been approved by the USFWS for detecting the presence of officially listed or federally protected species. The three potential Coachella Valley sensitive species identified through these biological surveys to be found on the Project Site include the Coachella Valley milkvetch, the Coachella Valley fringe -toed lizard, and the burrowing owl. The Palm Springs Ground Squirrel was also detected on the Project Site, which is considered a S pecies of Special Concern by the State of California.

The identification of these sensitive species serves as the baseline within the Draft EIS of the Project’s potentially significant impacts to biological resources.

Response to Comment 8-5
As discussed in Response to Comment 8-4, several special status species have been found on the Project Site through biological surveys. The Project Site is bounded on all four sides by existing roadways and residential developments, thus acting as an isolating mechanism that presents physical barriers to plant and animal dispersal to surrounding areas. The Project Site offers no water, no shelter and no food for migratory bird species while the existing country clubs that lie along the entire western and southern boundaries of the Project Site offer more favorable conditions. Due to the lack of water, shelter and food on the Project Site, the Project Site does not serve as a potentially significant stop-over location for migratory birds. Contrary to what is suggested by the comment, the presence of these special status species on the Project Site does not diminish its existence as an ecological island. Please refer to Response to Comments 8-18 and 8-19 for further discussion.

Response to Comment 8-6
The comment suggests that the biological surveys conducted for the Project Site were inadequate.

Burrowing owls are easily detected on the valley floor because of unobstructed views, their conspicuous burrows and habitat of calling at the approach of threats. The surveys conduc ted were not cursory as the following maximum intensity protocols were followed: parallel transects were conducted at 10 meters apart as described for both burrowing owl and desert tortoise. 7,8 Therefore, the site surveys
that were conducted in February an d March 2014 were adequate to record the presence of burrowing owls on the Project. As discussed in Response to Comment 8 -16, Mr. Smallwood’s experience is limited

7 California Department of Fish & Game. 2012. Staff Report on Burrowing Owl Mitigation. Natural Resources Agency, State of California.
8 Preparing For Any Action That May Occur Within The Range Of The Mojave Desert Tortoise ( Gopherus agassizii). United States Fish & Wildlife Service, 2010 Field Season.
12-3098

2.0 Responses to Comments
Meridian Consultants 2.0-322 Section 24 Specific Plan Project 044-001-13 March 2015
to Northern California and does not demonstrate knowledge of the unique environmental and ecological conditions present in the Coachella Valley.

Response to Comment 8-7
As discussed in further detail in Response to Comment 8 -24, the Project Site does not serve part of a corridor between open space areas. The Project Site is bounded by existing ro adways and residential development, thus not linking it to any vacant land that would serve as a corridor for wildlife.

Additionally, as discussed in Response to Comment 8 -20, soil smoothing was conducted on the Project Site as the site contains dune sand habitat to determine if large animal corridors existed on the Project Site. In addition, sand sifting and smoothing was done in several areas, specifically within the Project Site along Ramon Road and Bob Hope Drive, so that tracks would be more prominent and identifiable.

This is a commonly conducted and accepted survey practice in sand dune habitat in the Coachella Valley.

Response to Comment 8-8
The comment is correct to note that USFWS survey protocol prefers that desert tortoise surveys be conducted between April and May or September and October. As stated in the Biological Resources Assessment (Appendix C of the Draft EIS) prepared for the Project, the CNDDB (March, 2014) has no records of the presence of the desert tortoise on or within one mile of the Project Site. The protocol also notes that surveys outside these periods may be appropriate when only presence/absence needs to be determined. No evidence of any kind (e.g. shells, bones, scutes, limbs, burrows, palle ts, scats, egg shell fragments, tracks, courtship rings, drinking sites, mineral licks, etc.) was found during intensive surveys and no direct observations were made. The surveys conducted for the desert tortoise were adequate and support the conclusions reached on the presence or absence of sensitive species on the Project Site.

Therefore, the likelihood of detecting the desert tortoise on the Project Site is considered low. Please refer to Response to Comment 8-22 for further discussion. In addition, it should be noted that the Draft EIS was provided to both the USFWS and the CDFW for review and neither agency submitted comments recommending additional surveys.

Response to Comment 8-9
The Project Site consists of approximately 577 acres of vacant land with minimal existing vegetation. As also discussed in Response to Comment 8 -23, the Project Site does not offer water, shelter, or food for migratory bird species. For this reason, the Project Site does not serve as a stop -over location for migratory birds.
12-3099

2.0 Responses to Comments
Meridian Consultants 2.0-323 Section 24 Specific Plan Project 044-001-13 March 2015
Response to Comment 8-10
As demonstrated by the responses to the comments in this letter, the Draft EIS properly assessed the Project’s potential impacts to biological resources. Pursuant to CEQA Guidelines Section 21166, a supplemental Draft EIS would not be required as there are no substantial new circumstances with respect to the Project, nor is there any new information that was not known upon preparation of the Draft EIS.

Response to Comment 8-11
The comment suggests that the 577 acres that comprise the Project Site serve as habitat for wildlife movement, as concluded by Dr. Cashen. As discussed in further detail within Response to Comment 8 - 24, development of the Project Site would not remove the link of 2,500 acres of natural habitat located south of the Project Site due to the nature of the Project Site and the developed areas immediately adjacent to the site. Existing arterial roads and development located between the Project Site and the I - 10 t o the east makes any wildlife movement traveling west across the Project Site unlikely. The biological surveys conducted in the Draft EIS conclude that the Project Site does not serve as an existing wildlife corridor within the Coachella Valley. These surveys constitute substantial evidence in support of the conclusions in the Draft EIS; whereas, this comment is based upon sheer speculation regarding wildlife movement.

Response to Comment 8-12
Pursuant to CEQA Guidelines Section 15130, the Draft EIS properl y evaluated the Project’s cumulative impacts to biological resources. Any potentially significant impacts to special- status species, such as the burrowing owls, desert tortoise, Coachella Valley fringe -toed lizard, flat-tail horned lizard, and the Palm Springs ground squirrel are addressed and mitigated under the CVMSHCP and THCP, which adequately protect the critical habitat for these species. Therefore, development of the proposed Project in conjunction with other related projects would not eliminate the remaining populations of these special- status species or their habitat.

Response to Comment 8-13

Project along with related projects within the Coachella Valley are permitted by General Plans of other jurisdictions. All anticipated growth and cumulative impacts to biological resources have been analyzed by each of these jurisdictions. The CVMSHCP and THCP are intended to address the cumulative impacts on sensitive biological species posed by development throughout the Coachella Valley through the provision of mitigation for regional cumulative biological effects resulting from development within the HCP areas. The Project and all cumulative development would be subject to payment of the CVMSHCP 12-3100

2.0 Responses to Comments
Meridian Consultants 2.0-324 Section 24 Specific Plan Project 044-001-13 March 2015
Conservation Plan Fee or Tribal HCP Conservation Fee, as applicable, in order to reduce impacts to a level of less than significance. Additionally, the Project Site is located within an area of the Coachella Valley that already contains various fragmented habitat, which is why the Project site is not designated for habitat preservation under either HCP. Please refer to Response to Comment 8 -25 for further discussion.

Response to Comment 8-14
As discussed in further detail in Response to Comment 8-28, the CVMSHCP and THCP are fully approved habitat conservation plans that contain provisions for mitigation to address project-level and cumulative impacts to biological species. Mitigation Measures identified for the Project can be found on page 5.3-18 and 5.3 -19 of the Draft EIS and were made available during the 60 -day public comment and review period between November 20, 2014, and January 20, 2015.

Response to Comment 8-15
The comment will be reviewed by the Tribal Council in their consideration of the Record of D ecision for the Project. The submitted letter will be included within this Final EIS.

Response to Comment 8-16
The comment identifying Mr. Smallwood’s professional qualification is noted, however, it is also noted that Mr. Smallwood’s experience is limited to Northern California and does not demonstrate knowledge of the unique environmental and ecological conditions present in the Coachella Valley.

Response to Comment 8-17
The comment states the Project Site represents one of the last open spaces located south of I- 10 in the Coachella Valley. This characterization is not correct and demonstrates a lack of familiarity with both existing land use and environmental conditions in the Coachella Valley. Figure 1 as attached to Mr.

Smallwood’s own letter shows nearly 10,000 acres of undeveloped valley floor land south of I-10 and, in fact, there is much more than 10,000 acres. A large percentage of the open space south of the freeway is protected under the Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP) 9 a fact
ignored by Smallwoo d. The United States Fish & Wildlife Service (USFWS) has approved the CVMSHCP (which was reviewed by dozens of professional biologists) indicating adequate valley floor habitat is protected to preserve populations of not only officially listed species but also species of concern.

9 Coachella Valley Multiple Species Habitat Conservation Plan, available online at http://www.cvmshcp.org/. 12-3101

2.0 Responses to Comments
Meridian Consultants 2.0-325 Section 24 Specific Plan Project 044-001-13 March 2015
This comment also states that the Coachella Valley is a region known for high species richness. It should be noted that while the greater Coachella Valley region is well known for species richness because of its extremely varied topography, the Project Site and other sand field habitats on the valley floor are not. 10 Their uniformity of substrate, lack of plant form diversity and lack of topographical relief on any scale results in relatively small numbers of vascular plant, inverte brate and vertebrate species compared with most other habitat types in the region.
11 While two listed species are known to occur in the Project Site (and were discussed in the Section 5.3, Biological Resources of the Draft EIS), the presence of these two species does not indicate a high level of diversity that could be characterized as high species richness.

Response to Comment 8-18
As demonstrated by the responses to the comments in this letter, the Draft EIS contains factual, objective and accurate information regarding the biological resources present on the Project Site and in the Coachella Valley that supports the conclusions presented on the significance of the impacts of the Project on biological resources.

This comment challenges the characterization of the Project Site as being nearly an ecological island bounded on all four sides by paved roadways (three of them carrying high volumes of traffic) and on two sides by residential developments. This statement accurately describes the fact that the site is bordered by existing roadways.

An isolating mechanism, whether a mountain range, river or roadway, functions to reduce or eliminate the movement of plants and animals from one parcel of land to another. This contributes to ecological isolation. This is a widely recognized biological principle that is applicable to the Project Site due to the presence of major roadways on all four edges of the site, which are physical barriers to plant and animal dispersal that surround it.

This comment also does not ac curately represent the surveys conducted . For example, surveys were conducted by walking east/west transects at 10 -yard intervals through the P roject Site. Th is survey pattern used has been approved by the USFWS for determining the presence or absence of t he burrowing owl and desert tortoise and represents an intensive survey effort that resulted in no officially listed or federally protected species being overlooked.

10 Zabriskie, J. 1987. Plants of Deep Canyon. University of California, Riverside. 11 Cornett, J. W. 1980. Factors affecting reptile species diversity in the Deep Canyon Transect, Colorado Desert, California.

Master’s Thesis, California State University, San Bernardino. 12-3102

2.0 Responses to Comments
Meridian Consultants 2.0-326 Section 24 Specific Plan Project 044-001-13 March 2015
Response to Comment 8-19
The presence of threatened or endangered species in no way dimini shes the existence of an ecological island. Populations of threatened or endangered species are often found trapped within isolated, island- like environments. Typically, this is why they are threatened or endangered in the first place. This concept is described in papers written by Swartz
12 and MacArthur.13
Response to Comment 8-20
This comment indicates the biological surveys performed on the Project Site were inadequate because the time of year the surveys were conducted, in Mr. Smallwood’s opinion, at a time of year least likely to result in the detection of special -status species. This opinion does not recognize the unique existing environmental conditions in the Coachella Valley.

For example, the endangered Coachella Valley milkvetch is growing and even blooming by the end of January, reaches its peak bloom in February and begins to decline in March providing there has been adequate rainfall. Young individuals of the officially threatened Coachella Valley fringe -toed lizard are active even in January on c lear, calm winter days and all individuals of this species are active by early March. Burrowing owls are easily detected on the valley floor because of unobstructed views, their conspicuous burrows and habit of calling at the approach of threats. It should be noted that all three of these sensitive species were identified on the Project Site, which further demonstrates that the biological surveys were conducted at an appropriate time of year for the detection of sensitive species in the Coachella Valley.

The mammal live -trapping conducted was adequate given the habitat present on the Project Site.

Because two sensitive species might possibly be present on site, live trapping was conducted which confirmed the presence of the Palm Springs Ground Squirrel and did not confirm the presence of the Palm Springs Pocket Mouse. Neither of these two species has any federal status. Both are considered Species of Special Concern by the State of California.
14 Even if it is assumed the pocket mouse is present
on the site, i t is a species addressed by the CVMSHCP, which will result in the preservation of sufficient land to preserve this unlisted subspecies even without inclusion of any Agua Caliente Band of Cah uilla Indians Reservation lands.15

12 Schwartz, M. W., L. R. Iverson, A. M. Prasad, S. N. Matthews, and R. J. O'Connor. 2006. Predicting extinctions as a result of climate change. Ecology 87:1611–1615.
13 MacArthur, Robert H.; Wilson, E. O. The Theory of Island Biogeography, (Princeton, New Jersey: Princeton University Press), 1967.
14 Status available at https://www.dfg.ca.gov/biogeodata/cnddb/pdfs/spanimals.pdf. 15 Coachella Valley Multiple Species Habitat Conservation Plan, available online at http://www.cvmshcp.org/. 12-3103

2.0 Responses to Comments
Meridian Consultants 2.0-327 Section 24 Specific Plan Project 044-001-13 March 2015
This comment offers an opinion on the effect of soil smoothing on animal movement that is not relevant to the sand habitat present in the Coachella Valley. In fact, soil smoothing is typically completed on sites that contain dune sand habitat, rather than the type of habitat found in northern California that Mr.

Smallwood is familiar with. As described in the Biological Resources Assessment (see Appendix C in the Draft EIS), in an effort to determine if large animal corridors existed on the Project S ite special attention was given to observing and identifying animal tracks. In addition, sand sifting and smoothing was done in several areas so that tracks would be more prominent and identifiable. Specifically, a 100 meter long by 1 meter wide sand smoothing tr ansect along the northwest Project Site, along Ramon Road, and a second identical transect along Bob Hope Drive near Dinah Shore Drive was conducted. No indication of wildlife departing or arriving through either transect occurred after inspection. This is a commonly conducted and accepted survey practice in sand dune habitat in the Coachella Valley.

While road kill surveys are not routinely conducted as part of a biological survey program, such surveys were conducted for the Draft EIS. Again, Mr. Smallwoo d’s opinion on when these surveys should have been conducted reflects his experience in Northern California, which is not applicable to the unique ecological conditions in the desert environment of the Coachella Valley.

Response to Comment 8-21
Contrary to the assertion made in this comment, the surveys conducted were not cursory as the following maximum intensity protocols were followed: parallel transects were conducted at 10 meters apart as described for both burrowing owl and desert tortoise. 16,17
The point count surveys recommended in this comment are applicable for very large project sites or sites that have obstructed views. These conditions do not, however, apply to the Project Site. It should be noted that this comment does not identify a single sensitive species that was not addressed in the biological resource evaluation. Conducting surveys with acoustic detectors or thermal cameras to detect bats was not necessary because no sensitive bat species roost and hunt over the Project Site due to lack of suitable habitat for roosting or for prey species. Not one bat roost occurred within the Project Site because of the complete absence of topographical relief or large native trees or shrubs. The biological surveys recorded the bat species that were identified flying over the site.

16 California Department of Fish & Game. 2012. Staff Report on Burrowing Owl Mitigation. Natural Resources Agency, State of California.
17 Preparing For Any Action That May Occur Within The Range Of The Mojave Desert Tortoise ( Gopherus agassizii). United States Fish & Wildlife Service, 2010 Field Season.
12-3104

2.0 Responses to Comments
Meridian Consultants 2.0-328 Section 24 Specific Plan Project 044-001-13 March 2015
The biological surveys conducted did not rely on the California Natural Diversity Database (CNDDB), as incorrectly stated in this comment, but instead appropriately used this database to develop the exhaustive site survey program that was conducted.

It should also be noted that r oad kills on surrounding paved roadways were also monitored on all site visits.

Response to Comment 8-22
This comment does not present the full guidance from the USFWS on conducting surveys to determine the presence or absence of desert tortoise. Specifically while the USFWS survey protocol states that it is preferable to conduct surveys during the tortoise’s most active periods, which are identified as April through May and September through October, if the survey area is large (over 40 acres) and if the project could affect more than 2 or 3 tortoises. The protocol also notes that surveys outside these periods may be appropriate when only presence/absence needs to be determined.

Specifically, the USFWS guidance states that surveys outside the active period may be appropriate when only a presence/absence determination is necessary and that USFWS staff bases determination of whether the results are valid on a whole suite of factors, including but not limit ed to the type and condition of habitat, the general location of the survey area, the experience of the surveyors, the time and weather when the survey was conducted, the nature of the year in which the survey occurred (i.e., if it rained a lot, desert tortoises are likely to have been active and are more likely to have left evidence of their presence), how much time surveyors spent at the site, and whether they were conducting a focused survey for tortoises or looking for a suite of biological and/or cultural resources. T hese factors are considered together to determine whether the surveyors were likely to have found whatever evidence might exist that desert tortoises were present.

As stated in the Biological Resources Assessment (Appendix C of the Draft EIS) prepared for the Project, the CNDDB (March, 2014) has no records of the tortoise on or within one mile of the Project Site. Based on this information indicating the lack of observance of the de sert tortoise in the general vicinity of the site, and the location of the site and the type and condition of the habitat available, the likelihood of the desert tortoise being present on the site was considered low. Nonetheless, as reported in the Biologi cal Resources Assessment, surveys were conducted by walking east/west transects at 10-yard intervals through the Project Site. This survey pattern used has been approved by the USFWS for determining the presence or absence of the burrowing owl and desert t ortoise in the Coachella Valley and represents an intensive survey effort that resulted in no officially listed or federally protected species being overlooked. However, no evidence of any kind (e.g. shells, bones, scutes, limbs, burrows, palle ts, scats, egg shell fragments, tracks, courtship rings, drinking sites, mineral licks, etc.) was found and no direct 12-3105

2.0 Responses to Comments
Meridian Consultants 2.0-329 Section 24 Specific Plan Project 044-001-13 March 2015
observations were made. In addition, it should be noted that the Draft EIS was provided to both the USFWS and the CDFW for review and neither agency submitted comments recommending additional surveys. The surveys conducted for the desert tortoise were adequate and support the conclusions reached on the presence or absence of sensitive species on the Project Site.

Response to Comment 8-23
The Project Si te offers no water, no shelter and no food for migratory bird species while the existing country clubs that lie along the entire western and southern boundaries of the Project Site offer more favorable conditions. Due to the lack of water, shelter and food on the Project Site, the Project Site does not serve as a potentially significant stop-over location for migratory birds.

Response to Comment 8-24
This comment is based on the unsupported premise that there is a band of open space located south of the I -10 that facilitates wildlife movement and also links approximately 2,500 acres of habitat area located south of the Project Site with other open space areas. Based on the existing pattern of development this is clearly not the case. As clearly shown on the aerial photograph included in Mr.

Smallwood’s letter, there are major arterial streets and a dense connected pattern of development south of the I- 10. There is not 2,500 acres of natural habitat located south of the Project Site. South of Dinah Shore Drive, which is the southern boundary of Section 24 and west of Bob Hope Drive the area is completely developed. The section of land located between Gerald Ford Drive, Monterey Avenue, Frank Sinatra Drive and Bob Hope Drive is vacant but is surrounded by devel opment and not linked to the Project Site or any other nearby undeveloped areas. The Project Site is located at the extreme southern end of the band of undeveloped land referenced in this comment and existing major arterial roads and development are located between the site and the I -10 to the east, precluding any wildlife movement from the south or east that would use the site to travel west. The intent of the HCPs is to allow development, such as the Section 24 Specific Plan Project, to proceed elsewhere in the valley while preserving sufficient habitat to assure the survival of both sensitive and common plant and wildlife species. For these reasons, as presented in the Biological Resources Assessment and in Section 5.3 of Draft EIS, the Project Site does not serve as part of a corridor between open space areas. In addition, due to the existing habitat conditions, including the lack of water, shelter or food for wildlife species, wildlife movement through the site has determined to be minimal, as documented by the biological surveys conducted.

Response to Comment 8-25
This comment offers an opinion regarding the analysis of potential cumulative impacts to biological resources provided in the Draft EIS, but does not offer any information or analysis to support this 12-3106

2.0 Responses to Comments
Meridian Consultants 2.0-330 Section 24 Specific Plan Project 044-001-13 March 2015
opinion. This comment implies that the conclusion on cumulative impacts is the only information provided, when this is not the case. This conclusion is based on the information discussed on page 5.3 - 18 in Section 5.3 of the Draft EIS. First, it should be noted that this discussion begins with the statement that the Project, in conjunction with other related projects in the area, as well as the additional growth permitted by the City of Rancho Mirage General Plan and the General Plans of the oth er jurisdictions in the Coachella Valley will result in cumulative impacts to biological resources. This discussion then addresses the comprehensive analysis and natural resource planning included in the CVMSHCP and the Agua Caliente Tribal Habitat Conserv ation Plan (THCP). The plans provide for mitigation of regional cumulative biological effects resulting from development within the HCP areas by establishing dedicated conservation areas with stringent development restrictions. The intent of the HCPs is to allow development, such as the Section 24 Specific Plan Project, to proceed elsewhere in the valley while preserving sufficient habitat to assure the survival of both sensitive and common plant and wildlife species. In this manner, compliance with the HCP s ensure that cumulative impacts to biological resources are mitigated to a level considered less than significant.

As discussed in the Response to Comment 8 -24, the Project Site is located in a portion of the Coachella Valley where the existing pattern of development has already resulted in the type of fragmentation of habitat discussed in this comment. This is the primary reason why the CVMSHCP and THCP identify large areas of natural habitat elsewhere in the Coachella Valley that has not been fragmented by development for preservation.

Response to Comment 8-26
As stated in the Draft EIS, the THCP has been approved by the Agua Caliente Tribal Council and is being implemented by the Tribe. The THCP identifies conservation areas within the Reservation suffi cient in size and habitat quality to mitigate the impact of development on other land within the Reservation.

Response to Comment 8-27
This comment is incorrect in stating the CVMSHCP and THCP are not approved. The CVMSHCP is fully approved and, as stated above, the THCP has been approved by the Agua Caliente Tribal Council.

Response to Comment 8-28
The biologist who conducted the surveys and prepared the Biological Resources Assessment has been conducting burrowing owl surveys since 1973, longer than an y other actively working biological consultant in California. Furthermore, his credentials have been accepted by both the USFWS and CDFW. A curriculum vitae detailing Mr. Cornett’s credentials and expertise is attached to Appendix 4.0 of this Final EIS.
12-3107

2.0 Responses to Comments
Meridian Consultants 2.0-331 Section 24 Specific Plan Project 044-001-13 March 2015
This comment suggests that the mitigation for the burrowing owl is inadequate because does not specify relocation details in the event that burrowing owls are found during pre-construction surveys. To the contrary,the Biological Resources Study goes into detail regarding this issue on pages 20 and 21 (see Appendix C in the Draft EIS). It is up to the USFWS and the CDFW as to the disposition of any burrowing owls found during preconstruction surveys.

Response to Comment 8-29
A buffer area cannot be established until the preconstruction survey has been completed and burrowing owls are found to be present on the site. Burrowing owls, migrate, relocate and abandon burrows.

Where they are today is not necessarily an indication where they will be in t he future. This is the reason the preconstruction surveys will be conducted. If burrowing owls are present, as required in Mitigation Measure MM 5.3-2, all appropriate mitigation recommended in the California Department of Fish and Game (CDFG) 2012 Staff R eport on Burrowing Owl Mitigation will be applied as appropriate and necessary to avoid impacts to burrowing owls.

12-3108
1 2

2.0 Responses to Comments
Letter No. 9
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-332
12-3109
3 4
5 6

2.0 Responses to Comments
Letter No. 9
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-333
12-3110

2.0 Responses to Comments
Letter No. 9
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-334
12-3111

2.0 Responses to Comments
Meridian Consultants 2.0-335 Section 24 Specific Plan Project 044-001-13 March 2015
Comment Letter No. 9
Union Pacific Railroad Company
Patrick R. McGill
Senior Counsel
1400 Douglas Street, Stop 1580
Omaha, Nebraska 68179
Response to Comment 9-1

located approximately 725 feet (or 0.14 miles ) north/northeast of the Project Site, north of Ramon Road. The Project Site is not, therefore, adjacent to the rail line as indicated in this comment. Due to the distance of the Project Site from the UPRR transportation corridor, any increases in train volumes would not directly impact the residents/employees within the Project Site, as presented in the analysis in Section 5.9, Land Use and Planning, and Section 5.10, Noise.

Response to Comment 9-2
While the Project Site is not directly adjacent to the I-10/UPRR corridor, design of the Project considered its close proximity to the I- 10/UPRR transportation corridor. The Project’s retail and resort land uses would be located along Dinah Shore Drive, Ramon Road, and Bob Hope Drive . As discussed in Section

5.9, Land Use and Planning and Section 5.10, Noise, the land uses and projected noise levels within the Project Site would be compatible with those uses along the I -10/UPRR corridor. Therefore, the combination of the Project Site’s 725 foot distance to the railroad and the proposed layout of land uses would result in compatibility with the I-10/UPRR transportation corridor.

Response to Comment 9-3
Based on the location and characteristics of the rail line in relation to the Project Site, the Project will not result in the need for train operations to reduce speed. The UPRR transportation corridor is located approximately 725 feet (or 0.14 miles) north/northeast of the Project Site. Access across the UPRR transportation corridor within the vicinity of the Project occurs via above grade, or overhead, street and sidewalk crossings. P edestrians and vehicles associated with the Project would cross the UPPR transportation corridor via Bob Hope D rive, Ramon Road, Date Palm Drive, and Monterey Avenue and would not impact the daily operations of the Union Pacific Railroad . No at-grade crossings are in the immediate vicinity of the Project Site. No significant traffic impacts related to railroad operations were identified, and as such, no additional mitigation would be required. 12-3112

2.0 Responses to Comments
Meridian Consultants 2.0-336 Section 24 Specific Plan Project 044-001-13 March 2015
Response to Comment 9-4
As previously noted, the Project Site is not directly adjacent to the UPRR transportation corridor and is approximately 725 feet south/southwest from the closest point to the railroad tracks . Any pedestrians associated with the Project would have to cross over the four above-grade crossings along Bob Hope Drive, Ramon Road, Date Palm Drive, and Monterey Avenue to gain access to other side of UPRR corridor. As pedestrian traffic would be directed above -grade, trespassing along the railroad tracks would be less likely. Cumulative projects located adjacent to the UPRR, such as the Section 19 Specific Plan Project, would implement similar design features such as barrier walls or block fences, to minimize the likelihood of trespassing onto the railroad right -of-way. Due to the distance of the Project from the railroad right-of-way and the adequate number of above grade crossings for pedestrians, no signi ficant impacts would occur and no mitigation would be required.

Response to Comment 9-5
The UPRR anticipates an increase in rail operations which would result in the likely increase in noise and vibration levels along the railroad corridor. Pages 5.10-9 through 5.10 -12 of Section 5 .10, Noise of the Draft EIS identify that predominant ambient noise levels are attributed to roadway noise surrounding the Project Site and traffic associated with the I -10. Page 5.10-12 of Section 5.10, Noise identifies that the existing ground vibration environment within the Project vicinity would be below perceptible levels.

Noise generated by the event of a single train passing is dominated primarily by the train horn and secondarily by the train engines and cars. Train horns are required by the Federal Railroad Administration (FRA) to produce a minimum sound level of 96 dBA as measured from 100 feet from the train.
18 The frequency of the trains on the UPRR tracks is estimated to be one train every 15 minutes with trains taking approximately three to five minutes to pass. The typical average noise attenuation for rail noise, a line source, is 3 dB per doubling of distance. Instantaneous noise levels at the closest edge of the Project Si te would likely be 87 dBA and 84 dBA at the Active Adult Community. As discussed in Section 5.10, the sound levels from vehicle traffic along Ramon Road and Bob Hope Drive would result in a 24 hour average of 72.1 to 77.6 dBA and 74.6 to 76.3 dBA, respecti vely. The instantaneous noise levels from rail operations would not result in a substantial increase in the average 24 hour noise levels that would exceed the acceptable interior and exterior noise levels for the land uses proposed on the Project Site.

18 Code of Federal Regulations, Title 49, Part 229.129(a) – Railroad Locomotive Safety Standards. 12-3113

2.0 Responses to Comments
Meridian Consultants 2.0-337 Section 24 Specific Plan Project 044-001-13 March 2015
The proposed land use plan would ensure that compatible land uses would be located adjacent to one another and that noise sensitive land uses such as residential would be protected from noise impacts by locating them away from high noise sources such as the I-10/UPRR corridor and traffic along the adjacent major arterials (Dinah Shore Drive and Bob Hope Drive). For example, retail and resort land uses have been located along Dinah Shore Drive, Ramon Road, and Bob Hope Drive for maximum exposure, but also beca use these uses would be more compatible with the vehicular noise levels along these roadways. Placing the retail and resort land uses along the major roadway frontages would also provide a noise buffer for the residential uses that would be developed in th e Mixed Use Core and Residential Planning Areas.

The FTA criteria for frequent vibration events from transit is 72 VdB. 19 Freight trains traveling at 50
miles per hour can generate vibration levels of 90 VdB at 25 feet. Vibration levels only attributed to train operations would not be noticeable as a result of the distance from the Project Site to the railroad right - of-way. Therefore, no vibration impacts would occur and no mitigation would be necessary.

Refer to Section 5.10, Noise , for a detailed noise analysis and the Project’s Design Features and Mitigation Measures that would reduce noise level impacts at the Project Site.

Response to Comment 9-6
The Tribe will provide notice to the Union Pacific Railroad Company of public meetings to consider this Project as requested.

19 U.S. Department of Transportation, Federal Railroad Administration, High -Speed Ground Transportation Noise and Vibration Impact Assessment, https://www.fra.dot.gov/Elib/Document/2680, (September 2012). 12-3114
1 2
3 4
5 2.0 Responses to Comments
Letter No. 10
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-338
12-3115

2.0 Responses to Comments
Meridian Consultants 2.0-339 Section 24 Specific Plan Project 044-001-13 March 2015
Comment Letter No. 10

Mira Vista Homeowners
Carol Trentacosta
Board Member
98 Via Bella
Rancho Mirage, CA 92270
Response to Comment 10-1
As discussed in Section 3.0, Project Description , the Project is anticipated to be developed in two phases. The Active Adult Community is estimated to start construction in late fourth quarter of 2015 and would require six to eigh t years to complete, with a n estimated completion date for 2022. The second phase of construction involves the development of the Tribal Planning Areas. While there is currently no established timeframe, buildout of the Tribal Planning Areas is projected for 2035.

Response to Comment 10-2
The construction entrance would initially be from Los Alamos Road. Dinah Shore is heavily travelled and access is not currently available from Ramon Road or Bob Hope Drive. As discussed in Section 5.14, Traffic and Transportation of the Draft EIS Mitigation Measure MM 5.14-1 requires that each individual project proponent prepare and submit a detailed construction traffic management plan to the Tribe, City, and/or County for review and approval, as applicable. The construction traffic management plan would be required to identify construction entrances and measures to maximize traffic flow conditions around the Project Site. As discussed throughout the Draft EIS, construction hours would conform to the appropriate jurisdiction’s Municipal Code, either the City (7:00 AM to 7:00 PM except on Sundays) or the County of Riverside Municipal Code (7:00 AM to 7:00 PM weekdays and 8:00 AM to 5:00 PM on Saturdays). As the Project is built out, the project proponent would explore other feasible opportunities for construction access to the Project Site.

Response to Comment 10-3
The scope and timing of the ultimate buildout of Los Alamos Road would be outlined within the conditions of approval for the Project tentative map. These conditions of approval would be prepared by the governing agency, either the Tribe, the City, and/or the County, as part of the map approval process.

Response to Comment 10-4
Access to the Project Site was addressed in the Draft EIS in Section 5.14, on page 5.14-21. The Project’s access point from Los Alamos Road at Via Bella (Intersection 8) would not serve as the primary access 12-3116

2.0 Responses to Comments
Meridian Consultants 2.0-340 Section 24 Specific Plan Project 044-001-13 March 2015
point to the Project Site and would account for approximately 43 percent of the traffic generated by the Active Adult Co mmunity. The primary access point would be from Dinah Shore Drive, opposite the existing signalized access to the Westin Mission Hills Golf Resort, with secondary access to Bob Hope Drive via Casino Drive. As discussed in Section 5.14 of the Draft EIS, the intersection at Los Alamos Road at Via Bella would operate at a Level of Service (LOS) A during both peak hours for the major street left turn and LOS B during both peak hours for the minor street approach under Full Project Development conditions. A traffic signal warrant analysis was performed for all proposed intersections, and due to the projected LOS at this intersection, signalization of the intersection is not warranted (see Appendix 4 of the Traffic Study [Appendix G of the Draft EIS]).

Response to Comment 10-5
Please refer to Response 10 -4 above regarding the access point to the Project Site at Los Alamos Road.

As it has been determined that the intersection of Los Alamos Road at Via Bella would operate at acceptable conditions for both the maj or street left turn and minor street approach (LOS A and B, respectively) with full development of the Project, a traffic control signal would not be necessary.

C. PUBLIC MEETING COMMENTS AND RESPONSES
The following subsection contains the comments, ident ified in Table 2.0 -1, collected from the public meeting that was held by the Indian Planning Commission on December 17, 2014, at the Agua Caliente Casino Resort Spa Cahuilla Room B, located at 32 -250 Hope Drive in Rancho Mirage . The individual comments have been bracketed and numbered for ease of reference. The comments are followed by written responses to the comments numbered to correspond to the numbered comment.

12-3117
1 2
3 4
5 6

2.0 Responses to Comments
Public Comment No. 1
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-341
12-3118

2.0 Responses to Comments
Meridian Consultants 2.0-342 Section 24 Specific Plan Project 044-001-13 March 2015
Public Comment No. 1
Mira Vista Homeowners
Carol Trentacosta
Board Member
98 Via Bella
Rancho Mirage, CA 92270
Response to Public Comment 1
The comment identifying the representation of Carol Trentacosta on behalf of the Mira Vista Homeowners Association (HOA) in regards to the Project is noted. The information in the EIS, including this comment in support of the Project as proposed, will be reviewed and considered by the Tribal Council.

Response to Public Comment 2
The comment suggests that a signalized intersection at Los Alamos Road at Via Bella (Intersection 8) would be necessary upon buildout of the Active Adult Community. Access to the Project Site was addressed in the Draft EIS in Section 5.14, on page 5.14 -21. This intersection is located across directly across the street from the main entrance to the Mira Vista HOA and currently features a stop sign for traffic control. As discussed in detail in Response to Comment 10 -4, the traffic signal warrant analysis performed for this intersection identified that a traffic signal is not warranted (see Appendix 4 of the Traffic Study [Appendix G of the Draft EIS]).

Response to Public Comment 3
As stated in Response to Comment 10 -3, the scope and timing of the ultimate bu ildout of Los Alamos Road would be outlined within the conditions of approval for the Project tentative map. These conditions of approval would be prepared by the governing agency, the Tribe, the City, and/or the County, as part of the map approval process.

Response to Public Comment 4
As discussed in detail in Response to Comment 10 -2, the construction entrance for the Project would initially be from Los Alamos Road. Individual project proponent s would prepare and submit a detailed construction traffic management plan to the Tribe, City, and/or County for review and approval, as applicable. The construction traffic management plan would be required to identify construction entrances and measures t o maximize traffic flow conditions around the Project Site. The Project’s potential access impacts to the adjacent residential uses were identified as less than significant. 12-3119

2.0 Responses to Comments
Meridian Consultants 2.0-343 Section 24 Specific Plan Project 044-001-13 March 2015
Response to Public Comment 5
As discussed in Section 3.0, Project Description , the Project is anticipated to be developed in two phases. The Active Adult Community is estimated to start construction in late fourth quarter of 2015 and would require six to eight years to complete, with an estimated completion date for 2022. The second phase of construction involves the development of the Tribal Planning Areas. While there is currently no established timeframe, buildout of the Tribal Planning Areas is projected for 2035.

Response to Public Comment 6
The Tribe acknowledges the concerns of the Mira Vista HOA in regards to implementation of the Project.

These concerns are addressed by the responses to the comments from the public meeting , as well as Comment Letter No. 10, and will be reviewed and considered by the Tribal Council.

12-3120
7 8
9 10

2.0 Responses to Comments
Public Comment No. 2
Meridian Consultants
044-001-13
Section 24 Specific Plan Project
March 2015

2.0-344
12-3121

2.0 Responses to Comments
Meridian Consultants 2.0-345 Section 24 Specific Plan Project 044-001-13 March 2015
Public Comment No. 2
Rod Pennycook
31 Via Bella
Rancho Mirage, CA 92270
Response to Public Comment 7
The Tribe acknowledges the concerns Rod Pennycook has regarding t he Project. These concerns are similar to those presented by Carol Trentacosta on behalf of the Mira Vista Homeowners Association (HOA) within Public Comment No. 1 . Please refer to Responses to Public Comment No. 1 above for additional information.

Response to Public Comment 8
The comment suggests concern over the Project’s construction schedule and specifically the noise impacts that would result. As stated in Response to Comment 10 -1, the Project is anticipated to be developed in two phases. The Ac tive Adult Community is estimated to start construction in late fourth quarter of 2015 and would require six to eight years to complete, with an estimated completion date for 2022. The second phase of construction involves the development of the Tribal Planning Areas. While there is currently no established timeframe, buildout of the Tribal Planning Areas is projected for 2035.

With respect to construction access to the site, Section 5.14, Traffic and Transportation of the Draft EIS identifies Mitigation Measure MM 5.14 -1, which requires that each individual project proponent prepare and submit a detailed construction traffic management plan to the Tribe, City, and/or County for review and approval, as applicable. The refore, construction activities would comply with the appropriate jurisdiction’s regulations and requirements, as appropriate, to ensure construction access impacts are less than significant. As the Project is built out, the project proponent would explore other feasible opportunities for construction access to the Project Site.

As the Project would be developed in various phases through 2035, noise impacts related to construction activities would vary in location, intensity, duration. As discussed througho ut the Draft EIS, construction hours would conform to the appropriate jurisdiction’s Municipal Code, either the City (7:00 AM to 7:00 PM except on Sundays) or the County of Riverside Municipal Code (7:00 AM to 7:00 PM weekdays and 8:00 AM to 5:00 PM on Saturdays), as appropriate..

Response to Public Comment 9
As discussed in Response to Public Comment 8 and Response to Comment 10-2 above, the construction entrance would initially be from Los Alamos Road. A construction traffic management plan, which was 12-3122

2.0 Responses to Comments
Meridian Consultants 2.0-346 Section 24 Specific Plan Project 044-001-13 March 2015
previously described above , would be required from each individual project proponent to identify construction entrances and measures to maximize traffic flow conditions around the Project Site. Haul trucks traveling to and from the site would operate under those conditions identified within the construction traffic management plan, as approved by the appropriate jurisdiction. As the Project is built out, the project proponent would explore other feasible opportunities for construction access to the Project Site. Impacts to the adjacent residential communities would be less than significant.

Response to Public Comment 10
The responses to these comments are demonstrated above. This Final EIS for the Project will be made available to those potentially impacted or interested parties prior to the Record of Decision made by the Tribal Council. The comments presented by Mr. Pennycook are noted by the Tribe. 12-3123
Meridian Consultants 3.0-1 Section 24 Specific Plan Project 044-001-13 March 2015

3.0 REVISIONS TO THE DRAFT EIS
The Tribe, acting as the Lead Agency for the planning and environmental review of this Project, under Agua Caliente Tribal Environmental Policy Act (TEPA) (Tribal Ordinance No. 28) , has also decided to prepare this Environmental Impact Statement ( EIS) in compliance with the California Environmental Quality Act (CEQA ). In accordance with the CEQA Guidelines § 15132 (a), this S ection of the Final EIS provides changes to the Draft EIS that have been made to clarify, correct or supplement the environmental impact analysis for the Project. Such changes are a result of recognition of inadvertent errors or omissions as well as public and agency comments received in response to the Draft EIS . The changes described in this section do not result in any new or increased significant environmental impacts that would result from the Project.

Provided below are correction s and additions to the Draft EIS, including whe re appropriate, the associated technical appendices. Changes are identified below by the corresponding Draft EIS section and subsection, if applicable, and the page number. Additions are underlined and deletions are shown in strikethrough (strikethrough) format.

Section 1.0.B.1 Introduction
The following revision has been made to clarify language and proper characterization.

Page Revision

1.0-3 The NOI also provided notice of the public scoping meetings the Tribe held on February 1412, 2014, at 4:00 PM and 7:00 PM, at the Agua Caliente Casino Resort Spa, located at 32-250 Bob Hope Drive in Rancho Mirage.

Section 2.0.F Summary
The following revision has been made to clarify language and proper characterization.

Page Revision

2.0-26 MM 5.4-1 Prior to the start of any ground disturbing activities within the Project Site the Agua Caliente Band of Cahuilla Indians (Tribe) Tribal Historic Preservation Officer (THPO) shall be notified of the pending activities. A qualified archaeologist shall coordin ate with the THPO during the drafting for the archaeological monitoring plan and the plan shall allow for the archaeologist in consultation with the THPO to determine the 12-3124

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-2 Section 24 Specific Plan Project 044-001-13 March 2015
timing of when monitoring is no longer necessary. During earth moving disturbances that involve excavation activities, if there is any evidence of Native American resources (significant or otherwise), the THPO will be notified and construction activities modified in accordance with the archaeological monitoring plan.

The following revision has been made to reflect the changes made in Section 5.6, Greenhouse Gases.

Page Revision

2.0-33 Project operational GHG emissions for the Active Adult Community, Tribal Planning Areas, and Combined Development would be 8,879.398,882.84, 39,326.09, and 45,899.9446,480.7 metric tons of carbon dioxide equivalents (MTCO2e) per year, respectively.

The following revision has been made to address a minor and necessary text edit within the Section subtitle within Table 2.0-1.

Page Revision

2.0-64 Project Design Feature 5.15.1-4 will ensure that all future wells developed on-site would be constructed consistent with the CVWD Development Design Manual , and if groundwater te sting for total chromium prior to installation indicates that the groundwater exceeds US Environmental Protection Agency (US EPA) Maximum Contaminant Level (MCL), the water wells would provide treatment to reduce the level of chromium below the USEPA MCL.

Section 3.C.6 Project Description
The following revision has been made to clarify the Project Site’s proposed water wells.

Page Revision

3.0-20 The seven proposed wells would be constructed consistent with the CVWD Development Design Manual . Groundwater testing for total chromium will be undertaken prior to construction to determine if the groundwater exceeds USEPA MCL, and if the US EPA MCL is exceeded, the wells will provide treatment t o reduce the level of chromium below the EPA MCL.
12-3125

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-3 Section 24 Specific Plan Project 044-001-13 March 2015
Section 3.D Project Description
The following revision has been made to clarify language and proper characterization.

Page Revision

3.0-35
Table 3.0-2
Intended Uses of the EIS
Potential Lead and/or Lead Agency under TEPA Potential Action Agua Caliente Band of Cahuilla Indians • Record of Decision of EIS • Approval of the Section 24 Specific Plan
• Adoption of the Section 24 Specific Plan
• Parcel Map to Reconfigure Allottee Parcels
• Consent to Annexation
• Approval of Tentative Tract Maps and permits for
future project development in the Tribal Planning
Areas (Planning Areas 1 through 7)
Potential Lead and/or Responsible Agencies Potential Action City of Rancho Mirage • Certification of EIS
• Adoption of the Section 24 Specific Plan
• Approve Request for Annexation
• Approval of Tentative Tract Maps and permits for
future project development in the Active Adult
Community (Planning Area 8)
Local Agency Formation of Riverside County • Approve Annexation of the Project Site into the City of Rancho Mirage
Coachella Valley Water District • Approve Construction and Specifications Plans for CVWD service infrastructure

12-3126

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-4 Section 24 Specific Plan Project 044-001-13 March 2015
Section 5.2.B.4 Air Quality
The following revision has been made to update the calculations for construction emissions related to implementation of the Active Adult Community.

Page Revision

5.2-30
Table 5.2-6
Active Adult Community Construction Emissions
Pollutant (pounds/day)
Source VOC NOx CO SOx PM10 PM2.5
Year 2015
Maximum 1.091.07 20.4120.43 39.3739.13 0.060.06 6.806.80 3.76 SCAQMD threshold 75 100 550 150 150 55
Threshold
Exceeded? No No No No No No
Year 2016
Maximum 3.644.06 29.7237.54 59.2670.08 0.100.12 3.483.82 1.531.62 SCAQMD threshold 75 100 550 150 150 55
Threshold
Exceeded? No No No No No No
Year 2017
Maximum 72.9673.07 1.571.57 7.056.13 0.010.01 0.240.24 0.08 SCAQMD threshold 75 100 550 150 150 55
Threshold
Exceeded? No No No No No No
Year 2018
Maximum 73.0372.93 1.52 6.575.73 0.01 0.24 0.08
SCAQMD threshold 75 100 550 150 150 55
Threshold
Exceeded? No No No No No No
Year 2019
Maximum 73.0072.90 1.49 6.215.43 0.01 0.24 0.08
SCAQMD threshold 75 100 550 150 150 55
Threshold
Exceeded? No No No No No No
Year 2020
Maximum 73.9873.89 11.35 22.68 0.040.03 0.32 0.13
SCAQMD threshold 75 100 550 150 150 55
Threshold
Exceeded? No No No No No No
Year 2021
Maximum 73.9673.87 11.33 23.3022.49 0.040.03 0.32 0.13
SCAQMD threshold 75 100 550 150 150 55
Threshold
Exceeded? No No No No No No
12-3127

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-5 Section 24 Specific Plan Project 044-001-13 March 2015
Pollutant (pounds/day)
Source VOC NOx CO SOx PM10 PM2.5
Year 2022
Maximum 72.9472.86 1.42 5.544.87 0.01 0.24 0.08
SCAQMD threshold 75 100 550 150 150 55
Threshold
Exceeded? No No No No No No

Source: Refer to the data sheets in Appendix 3.0XXB, Air Quality Air Quality – Supplemental Emission Modeling Information and Greenhouse Gas Emissions ModelingXXXX.

Abbreviations: CO = carbon monoxide; NO x = nitrogen oxide; PM10 = particulate matter less than 10 microns; PM2.5 = particulate matter less than 2.5 microns; VOC = volatile organic compound; SCAQMD = South Coast Air Quality Management District; SOX = sulfur oxide.

The following revision has been made to update the calculations for operational emissions related to implementation of the Active Adult Community.

Page Revision

5.2-32
Table 5.2-7
Active Adult Community Operational Emissions
Pollutant (pounds/day)
Source VOC NOx CO SOx PM10 PM2.5
Maximum 106.84 102.78 49.98 309.80 0.430.41 26.19 8.74 SCAQMD threshold 75 100 550 150 150 55
Threshold exceeded? Yes No No No No No

Source: Refer to the data sheets in Appendix B3.0, Air Quality – Supplemental Emission Modeling Informationand Greenhouse Gas Emissions Modeling.

The following revision has been made to update the calculations for construction emissions related to implementation of both the Active Adult Community and Tribal Planning Areas.

Page Revision

5.2-35
Table 5.2-10
Combined Construction Emissions
Pollutant (pounds/day)
Source VOC NOx CO SOx PM10 PM2.5
Year 2015
Maximum 1.099 20.43 39.3737 0.06 6.916.80 3.783.76
SCAQMD 75 100 550 150 150 55
12-3128

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-6 Section 24 Specific Plan Project 044-001-13 March 2015
Pollutant (pounds/day)
Source VOC NOx CO SOx PM10 PM2.5
threshold
Threshold
Exceeded? No No No No No No
Year 2016
Maximum 9.9516.83 36.6372.18 131.31236.37 0.190.34 12.667.23 3.732.85 SCAQMD
threshold 75 100 550 150 150 55
Threshold
Exceeded? No No No No No No
Year 2017
Maximum 259.64278.94 6.2282.06 54.84326.90 0.090.53 7.7111.70 2.084.26 SCAQMD
threshold 75 100 550 150 150 55
Threshold
Exceeded? Yes No No No No No
Year 2018
Maximum 259.23276.77 5.7877.86 50.00302.85 0.090.53 7.7111.66 2.084.22 SCAQMD
threshold 75 100 550 150 150 55
Threshold
Exceeded? Yes No No No No No
Year 2019
Maximum 258.91275.13 5.4274.31 46.37284.92 0.090.52 7.7111.62 2.084.19 SCAQMD
threshold 75 100 550 150 150 55
Threshold
Exceeded? Yes No No No No No
Year 2020
Maximum 260.21273.64 15.0369.95 61.06268.62 0.120.52 7.8711.57 2.154.15 SCAQMD
threshold 75 100 550 150 150 55
Threshold
Exceeded? Yes No No No No No
Year 2021
Maximum 260.02263.03 14.8221.49 59.01100.22 0.120.21 7.874.62 2.151.53 SCAQMD
threshold 75 100 550 150 150 55
Threshold
Exceeded? Yes No No No No No
Year 2022
Maximum 258.31261.18 4.7711.30 39.5279.01 0.090.18 7.714.54 2.081.48 SCAQMD
threshold 75 100 550 150 150 55
Threshold
Exceeded? Yes No No No No No

Note: Refer to the data sheets in Appendix 3.0B, Air Quality – Supplemental Emission Modeling Informationand Greenhouse Gas Emissions Modeling.

Abbreviations: CO = carbon monoxide; NO x = nitrogen oxide; PM10 = particulate matter less than 10 microns; PM2.5 = particulate matter less than 2.5 microns; VOC = volatile organic compounds; SCAQMD = South Coast Air Quality Management District; SOX = sulfur oxide.

12-3129

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-7 Section 24 Specific Plan Project 044-001-13 March 2015
Section 5.4.C Cultural Resources
The following revision has been made to clarify language and proper characterization of MM 5.4-1.

Page Revision

5.4-18 MM 5.4-1 Prior to the start of any ground disturbing activities within the Project Site, the Agua Caliente Band of Cahuilla Indians (Tribe) Tribal Historic Preservation Officer (THPO) shall be notified of the pending activities. A qualified archaeologist shall c oordinate with the THPO during the drafting for the archaeological monitoring plan and the plan shall allow for the archaeologist in consultation with the THPO to determine the timing of when monitoring is no longer necessary. During earth moving disturbances that involve excavation activities, if there is any evidence of Native American resources (significant or otherwise), the THPO will be notified and construction activities modified in accordance with the archaeological monitoring plan.

Section 5.5.C Geology and Soils
The following revisions has been made to clarify language and proper characterization.

Page Revision

5.5-18 MM 5.5-1 As part of final design development, a detailed geotechnical and soils investigation shall be conducted by a registered engineering geologist for review and approval by the City of Rancho Mirage Building and Safety Division, if annexed into the City, the Tribe Tribal Engineer, or the County Engineer as applicable, prior to the issuance of grading and building permits.

The following revisions has been made to clarify language and proper characterization.

Page Revision

5.5-19 MM 5.5-2 All grading and earthwork recommendations from the Project geotechnical and soils reports , including any updates, must be incorporated into the final Project design, including the final grading, drainage and erosion control plans, or other plans deemed necessary by the City of Rancho Mirage Building and Safety Division , if annexed into 12-3130

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-8 Section 24 Specific Plan Project 044-001-13 March 2015
the City, the Tribal Engineer, or the County Engineer as applicable , and must ensure they meet the City’s Building Code requirements set forth in the City Municipal Code , the Tribe Tribal Land Use Ordinance, or the County Municipal Code as applicable . All grading activities must be supervised by a certified engineering geologist: Final grading, drainage, and erosion control plans must be reviewed and approved by the City of Rancho Mirage Building and Safety Division before the City issues a grading permit , by the Tribal Engineer, or the County Engineer, as applicable.

Section 5.6.B.4 Greenhouse Gases
The following revision has been made to update the CalEEMod calculations for construction GHG emissions related to the Active Adult Community.

Page Revision

5.6-23 As presented in Table 5.6 -3, Active Adult Community Construction GHG Emissions, construction activities associated with the Active Adult Community would generate 4,770.86 1,559.45 MTCO2e GHG emissions.

The following revision has been made t o update the CalEEMod calculations for construction GHG emissions related to the Active Adult Community.

Page Revision

5.6-23
Table 5.6-3
Active Adult Community Construction GHG Emissions
Year
CO2e Emissions
(Metric Tons per Year)
2015 111.68
2016 654.88 758.55
2017 84.43
2018 109.92
2019 107.04
2020 134.37
2021 196.81
2022 56.65
12-3131

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-9 Section 24 Specific Plan Project 044-001-13 March 2015
Year
CO2e Emissions
(Metric Tons per Year)
Total Construction GHG Emissions* 1,455.78 1,559.45
Annualized over Project Lifetime 48.53 51.98

Source: CalEEMod Emissions calculations are provided in Appendix 3.0B, Air Quality and Greenhouse Gas Emissions Modeling – Supplemental Emission Modeling Information.

Note: Totals in table may not appear to add exactly due to rounding in the computer model calculations.

Abbreviations: MTCO2e = metric tons of carbon dioxide emissions. *N2O emissions account for 0.06 MTCO2e/year.

The following revision has been made to update the CalEEMod calculations for operational GHG emissions related to the Active Adult Community.

Page Revision

5.6-24
Table 5.6-4
Active Adult Community Operational GHG Emissions
GHG Emissions Source
Emissions
(MTCO2e/year)
Construction (amortized) 48.5351.98
Operational (mobile) sources* 3,223.21
Area sources 329.60
Energy 4,054.66
Waste 109.18
Water 1,114.21
Annual Total 8,879.398,882.84

Source: CalEEMod Emissions calculations are provided in Appendix 3.0B, Air Quality – Supplemental Emission Modeling Information and Greenhouse Gas Emissions Modeling.

Notes: Totals in table may not appear to add exactly due to rounding in the computer model calculations.

Abbreviations: MTCO2e = metric tons of carbon dioxide emissions. *N2O emissions account for 0.1317 MTCO2e/year.

The following revision has been made to revise the Active Adult Community’s operational GHG emissions based upon the updated CalEEMod calculations.

Page Revision

5.6-24 As shown in Table 5.6-4, the operational GHG emissions for the Active Adult Community with Project Design Features and Mitigation Measures would be 8,879.39 8,882.84 MTCO2e per year.
12-3132

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-10 Section 24 Specific Plan Project 044-001-13 March 2015
The following revision has been made to revise the GHG emissions for the Active Adult Community that would result from the business as usual scenario.

Page Revision

5.6-25 The business as usual scenario would result in GHG emissions (without Title 24 efficiencies, Project Design Features, or Mitigation Measures ) of 11,763.65 11,767.14 MTCO2e per year.25 As indicated in Table 5.6 -4, the Active Adult Community portion of the Project would result in 8,879.39 8,882.84 MTCO2e per year with Project Design Features and Mitigation Measures. The Project Design Features and Mitigation Measures would reduce GHG emissions by 2,884.26 MTCO2e per year , approximately

24.52 24.51percent, from the business as usual scenario.

25 11,714.99 MTCO2e per year BAU + 48.53 51.98 MTCO2e per year BAU Construction + 0.13 0.17 MTCO2e per year N2O = 11,763.65 11,767.14 MTCO2e per year BAU.

The following revision has been made to revise the combined construction GHG emissions.

Page Revision

5.6-28
Table 5.6-7
Combined Construction GHG Emissions
Year
CO2e Emissions
(Metric Tons per Year)a
2015 111.68
2016 746.381,171.62
2017 629.654,693.40
2018 811.484,974.29
2019
782.244,828.24
2020 784.644,366.22
2021 835.061,573.41
2022 406.01810.97
Total Construction GHG Emissions 5,107.1422,529.88
Annualized over Project Lifetime 170.24751.00

Source: CalEEMod Emissions calculations are provided in Appendix 3.0B, Air Quality – Supplemental Emission Modeling Informationand Greenhouse Gas Emissions Modeling. *N2O emissions account for 0.21 MTCO2e per year.
12-3133

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-11 Section 24 Specific Plan Project 044-001-13 March 2015
The following revision has been made to revise the combined operational GHG emissions.

Page Revision

5.6-29
Table 5.6-8
Combined Operational GHG Emissions
GHG Emissions Source
Emissions
(MTCO2e/year)
Construction (amortized) 170.24751.00
Operational (mobile) sources* 19,860.16
Area sources 661.06
Energy 21,432.25
Waste 547.13
Water 3,229.10
Annual Total 45,899.9446,480.7

Source: CalEEMod Emissions calculations are provided in Appendix 3.0B, Air Quality – Supplemental Emission Modeling Information and Greenhouse Gas Emissions Modeling.

Note: Totals in table may not appear to add exactly due to rounding in the computer model calculations.

Abbreviations: MTCO2e = metric tons of carbon dioxide emissions. * N2O emissions account for 0.81 MTCO2e per year.

The following revision has been made to revise the combined business as usual scenario.

Page Revision

5.6-29 The combined business as usual scenario GHG emissions (without Title 24 efficiencies, Project Design Features, or mMitigation mMeasures) would be 82,065.58 82,646.10 MTCO2e per year. 27 As indicated in Table 5.6 -8, the Project Design Features and Mitigation Measures would reduce GHG emissions for the entire Project by 36,165.4064 MTCO2e per year to 45,899.9446,480.70 MTCO2e per year, a reduction of approximately 44.07 43.76 percent.

27 81,894.53 MTCO2e per year BAU + 170.24751.00 MTCO2e per year Construction BAU + 0.81 0.57 MTCO2e per year N2O emissions = 82,065.58 MTCO2e per year BAU emissions.

12-3134

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-12 Section 24 Specific Plan Project 044-001-13 March 2015
Section 5.6.C Greenhouse Gases
The following revision has been made to clarify language and proper characterization.

Page Revision

5.6-34 MM 5.6-7 Prior to the issuance of each building permit, the applicant shall provide evidence to the appropriate Planning Department of the use of water efficient irrigation systems and devices, such as soil- based irrigation controls and use water -efficient irrigation methods consistent with measures recommended in the Voluntary Green Building Program, and any other green building standards adopted by the Tribe or City, and the Coachella Valley Water District water efficiency goals . In accordance with the appropriate program, the applicant shall provide evidence that building is consistent with the follow ing Specific Plan -wide water conservation measures and/or does not prevent or conflict with the Specific Plan’s ability to meet the following water conservation measures:
• 90 100 percent of all builder- installed plumbing devices in each residential buildings shall be low-flow and water-efficient. • 90 100 percent of all builder-installed plumbing devices in each non- residential buildings shall be low-flow and water-efficient. • Turf shall not exceed 20 percent of the total landscaped area of each lot, with the exception of parks and recreation centers. • 80 percent of public and common landscape areas shall use smart irrigation systems per project.
• 80 percent of public and common landscape areas shall use drought-tolerant, native, and/or water -efficient plant materials per project.

Section 5.6.D Greenhouse Gases
The following revision has been made to clarify language and proper characterization.

Page Revision

5.6-35 D. Level of Significance of After Mitigation
12-3135

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-13 Section 24 Specific Plan Project 044-001-13 March 2015
Section 5.8.A.1 Hydrology and Water Quality
The following revision has been made to clarify beneficial uses of the downstream receiving waters of Whitewater River, Coachella Valley Storm Water Channel, and Salton Sea.

Page Revision

5.8-7 The beneficial uses of the downstream receiving waters (Whitewater River, Coachella Valley Storm Water Channel, and Salton Sea) of the Project include but are not limited to agriculture supply, water-contact recreation, and warm fresh water habitat.

Section 5.8.A.2 Hydrology and Water Quality
The following revision has been made to incorporate County of Riverside regulatory information in regards to the design of flood hazard protection facilities.

Page Revision

5.8-14 Riverside County Ordinance No. 458
The County of Riverside adopted Ordinance No. 458 to specifically regulate development within FEMA -designated flood hazard areas , or also known as the 100- year flood hazard areas. This oOrdinance was adopted by the County as its participation in the National Flood Insurance Program (NFIP) of FEMA.34

34 Code of Federal Regulations, Title 44, Section 65.

The following revision has been made to incorporate Coachella Valley Water District (CVWD) regulatory information in regards to the design of flood hazard protection facilities.

Page Revision

5.8-16 Coachella Valley Water District Ordinance No. 1234.1 CVWD requires conditions of approval for development in flood hazard areas within the CVWD Stormwater Unit Boundary.36 The key provisions of this ordinance are as follows:
• Whitewater River/Coachella Valley Stormwater Channel : Designed and constructed utilizing the Standard Project Storm/Standard Project Flood (SPS/SPF) design standard. The SPS/SPF design standard will continue to be utilized for this facility, and for the analyses addressing impacts associated with lands adjacent to 12-3136

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-14 Section 24 Specific Plan Project 044-001-13 March 2015
this facility. The Whitewater River/Coachella Valley Stormwater Channel can be owned, operated, and maintained by CVWD or by a private entity that has an existing regional stormwater facilities agreement with CVWD. • Existing Tributary Reg ional Facilities: Designed and constructed utilizing the SPS/SPF design standard. The SPS/SPF design standard will continue to be utilized for these facilities and adjacent lands. These existing tributary regional facilities can be owned, operated, and mai ntained by CVWD or by a private entity that has an existing regional stormwater facilities agreement with CVWD. • Existing Tributary Regional Facilities (100- Year Storm/100 -Year Flood): Designed and constructed utilizing the 100 -Year Storm/100-Year Flood design standard. The 100-Year Storm/100 -Year Flood design standard shall continue to be utilized for these facilities and for analyses addressing impacts associated with land adjacent to these facilities. These facilities will continue to be owned, operated, and maintained by an entity or party other than CVWD.
• Proposed Tributary Regional Stormwater Facilities: Design shall be based on the 100-Year Storm/100-Year Flood design standard. CVWD shall assume operation and maintenance of proposed 100 -year tributary regional stormwater facilities unless the developer specifically requests to assume the operation and maintenance responsibility.

36 Coachella Valley Water District, Ordinance 1234.1, Guideline K-7, March 25, 2013.

The following information is added after the first full paragraph on page 5.8 -29 to the discussion under the heading Otherwise substantially degrade water quality to address potential water quality impacts associated with the proposed water wells.

Page Revision

5.8-29 Furthermore, Project Design Feature 5.15.1-4 will ensure that all future wells developed on site would be constructed consistent with the CVWD Development Design Manual , and if groundwater testing for total chromium prior to installation indicates that the groundwater exceeds US EPA MCL, the water wells would provide treatment to reduce the level of chromium below US EPA MCL . Accordingly, water quality provided to 12-3137

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-15 Section 24 Specific Plan Project 044-001-13 March 2015
residents and employees in the Pr oject Site would meet USEPA MCL standards under the Safe Drinking Water Act and water quality impacts would be less than significant.

Section 5.15.1.A.1 Water Supply
The following revision has been made to clarify language and proper characterization.

Page Revision

5.15.1-2 CVWD has been recycling reclaimed wastewater since 1967 and operates six WRPs, three of which currently provide recycled water for reuse.

The following revision has been made to clarify language and proper characterization within Section

5.15.1, Water Service.

Page Revision

5.15.1-3 The primary source of water supply for the Coachella Valley is the Coachella Valley Groundwater Basin, which is recharged by other sources of water such as Colorado River water, reclaimed irrigation return water, SWP supplies and potentially desalinated agricultural drain water.

The following revision has been made to clarify language and proper characterization.

Page Revision

5.15.1-6 Since 2010, groundwater levels in the eastern portion of the Coachella V alley have risenrose due to groundwater management activities, which include recharge of Colorado River water at the Thomas E. Levy Recharge Facility , and changes in private landowner water use practices.

The following revision has been made to modify the title for Table 5.15.1-9.

Page Revision

5.15.1-29 Table 5.15.1-9, Summary of Historical and Projected Average Water Suppliesy, shows the actual water supplies in 2010 as well as the projected water supplies from 1995 2010 through 2035.
12-3138

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-16 Section 24 Specific Plan Project 044-001-13 March 2015
The following revision has been made to reflect Table 4 -1, Projected Water Supplies in the CVWD 2010 Urban Water Management Plan within Table 5.15.1-9.

Page Revision

5.15.1-30
Table 5.15.1-9
Summary of Historical and Projected Average Water Suppliesy Year
Groundwater
Supply1
Treated Colorado
River Water
Supply2
SWP Exchange
WaterUntreated
Colorado River Water3
Recycled
Water
Desalinated
Drain Water Total Supply
1995 66,600 285,929 45,214 11,100 -- 408,843
1996 50,700 289,726 100,376 11,520 -- 452,322
1997 52,400 281,179 83,407 12,550 -- 429,536
1998 71,100 281,714 99,729 13,657 -- 466,200
1999 53,800 282,021 70,446 13,397 -- 419,664
2000 71,000 282,781 56,161 13,289 -- 423,231
2001 73,000 272,741 3,242 12,923 -- 361,906
2002 76,500 280,845 26,912 13,289 -- 397,546
2003 78,600 245,069 3,177 13,903 -- 340,749
2004 73,400 238,456 16,167 14,831 -- 342,854
2005 85,100 282,000 46,000 15,300 -- 428,400
2010 106,700109,488 318,0000 62,0000 23,100 4,0000 513,800109,488 2015 123,100118,700 342,0005,700 70,6001,300 25,100 8,0000 568,800125,800 2020 123,700125,600 379,00019,300 70,10011,100 26,500 8,0000 607,300156,100 2025 124,200129,900 404,00031,400 68,10026,300 27,600 11,0000 634,900187,700 2030 123,200133,500 429,00039,500 66,50039,000 28,300 11,0000 658,000212,000 2035 128,700 49,100 54,800 10,000 242,700

Source: CVWD, 2010 Urban Water Management Plan (July 2011) Table 4-1. 1 CVWD Share of net groundwater inflow to Whitewater and Mission Creek Subbasins, shared with DWA Service Area and private pumpers. 2 Net water deliveries to Coachella Valley, excluding conveyance losses.

Anticipated average availability assuming MWD calls-back 50 percent of the time in dry years.

Modified version of CVWD UWMP 2010 Update to account for advanced deliveries, DWR SWP 2013 Draft Reliability Report, and reductions to associate with Longfin Smelt and other issues

12-3139

3.0 Revisions to the Draft EIS
Meridian Consultants 3.0-17 Section 24 Specific Plan Project 044-001-13 March 2015
Section 5.15.1.A.2 Water Supply
The following revision has been made to clarify language and proper characterization.

Page Revision

5.15.1-38 Safe DrinkingClean Water Act
The following revision has been made to clarify the Project Site’s proposed water wells.

Page Revision

5.15.1-52 PDF 5.15.1-4 All proposed water wells to be constructed within the Project Site shall be consistent with the CVWD Development Design Manual , and if groundwater testing for total chromium prior to installation indicates that the groundwater exceed s USEPA MCL, the water wells shall provide treatment to reduce the level of chromium below the USEPA MCL . The USEPA MCL is different from the California EPA MCL, in that the California EPA MCL only tests for one isotope of chromium, not total chromium.

The following revision has been made to clarify the Project Site’s proposed water wells.

Page Revision

5.15.1-54 Project Design Feature 5.15.1-4 will ensure that all future wells developed on site would be constructed consistent with the CVWD Development Desi gn Manual , and if groundwater testing for total chromium prior to installation indicates that the groundwater exceeds US EPA MCL, the water wells would provide treatment to r educe the level of chromium below the USEPA MCL.

12-3140
APPENDIX 1.0
Mitigation Monitoring and Reporting Program
12-3141

Mitigation Monitoring and Enforcement Program

Section 24 Specific Plan
Agua Caliente Band of Cahuilla Indians

Adopted by:

Agua Caliente Band of Cahuilla Indians
5401 Dinah Shore Drive
Palm Springs, California 92264

February 2015
12-3142
Agua Caliente Band of Cahuilla Indians i Section 24 Specific Plan Project MMEP February 2015

TABLE OF CONTENTS
Section Page

1.0 Introduction ..................................................................................................................................... 1

1.1 Monitoring Authority ....................................................................................................................... 1

1.2 Enforcement Responsibility ............................................................................................................. 1

1.3 Monitoring Compliance Responsibility ............................................................................................ 2

1.4 General Monitoring Procedures ...................................................................................................... 2

1.5 Mitigation Monitoring Table ............................................................................................................ 3 12-3143
Agua Caliente Band of Cahuilla Indians 1 Section 24 Specific Plan Project MMEP February 2015

MITIGATION MONITORING PROGRAM

1.0 INTRODUCTION
As the Lead Agency under the Agua Caliente Tribal Environmental Policy Act (TEPA) (Tribal Ordinance No. 28), the Agua Caliente Band of Cahuilla Indians (“Tribe” ) has decided to prepare the Environmental Impact Statement (EIS) for the Section 24 Specific Plan (“Project”) in accordance with TEPA, as well as to prepare this EIS in compliance with the substantive and procedural requirements of the California Environmental Quality Act (CEQA). The Tribe will adopt a program for reporting , enforcing, and monitoring the implementation of mitigation measures adopted for the Project, to ensure that the adopted mitigation measures are implemented as defined in the Final EIS and/or Record of Decision for the Project.

As set forth in TEPA, the Tribal Council of the Agua Caliente Band of Cahuilla Indians ( “Tribal Council”) will make a final decision, in the form of a Record of Decision, with respect to the Project’s requested actions after review and consideration of this EIS. As part of the Record of Decision , the Tribe has adopted a monitoring and enforcement program and summarized all applicable mitigation in this Section, as defined under the Code of Federal Regulations (CFR ), Title 40, Chapter 5, Part 1505.2(c) (Record of decision in cases requiring EIS).

While compliance with CEQA is not required at this time, the Lead Agency responsibility to adopt such a program originates in Public Resources Code section 21081.6(a) (Find ings), and the State CEQA Guidelines sections 15091(d) (Findings), and 15097 (Mitigation Monitoring or Reporting).

Projects, activities, and decisions implemented under the Project would be overseen by the agencies having jurisdiction over affected lands and resources. Lead, Responsible, and Cooperating Agencies having approval or oversight responsibilities for some aspect of the Project would consider each applicable measure identified in the EIS at a project level, making any necessary adjustments in the measures to account for the specific nature and location of the project proponent and its impacts. The agencies would ensure that issues identified in the EIS are adequately considered and addressed as part of the Project implementation. This responsibility would apply to all actions within the scope of this EIS that are subject to further TEPA or CEQA review.

1.1 MONITORING AUTHORITY
The purpose of a Mitigation Monitoring and Enforcement Program (MMEP) is to ensure that measures adopted to mitigate or avoid significant impacts are implemented. A MMEP can be a working guide to facilitate not only the implementation of mitigation measures by individual project proponents, but also the monitoring, compliance/enforcement and reporting activities of the appropriate jurisdiction, in this 12-3144
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 2 Section 24 Specific Plan Project MMEP February 2015
case either the Tribe, the County of Riverside (County), the City of Rancho Mirage (City) , the Riverside Local Agency Formation Commission (LAFCo), or the Coachella Valley Water District (CVWD).

The appropriate jurisdictio n may delegate duties and responsibilities for monitoring to other environmental monitors or consultants as deemed necessary, and some monitoring responsibilities may be assumed by responsible agencies, such as affected jurisdictions and cities, and state agencies. The number of monitors assigned to the P roject will depend on the number of concurrent operation activities and their locations. The Tribe’s Chief Planning and Development Officer (or equivalent position or appropriate agency representative ) or h is/her designee(s), however, will ensure that each person delegated duties or responsibilities are qualified to monitor compliance and enforcement. It is the responsibility of the environmental monitor assigned to each measure to ensure that appropriate agency reviews and approvals are obtained.

1.2 ENFORCEMENT RESPONSIBILITY
The project proponent is responsible for successfully implementing all of the adopted mitigation measures in the MMEP. The MMEP guides implementation of mitigation measures and specifi es the type of compliance, monitoring, and reporting required with regard to those measures.

Any assigned environmental monitor shall note problems with monitoring, notify appropriate agencies or individuals about any problems, and report the problems to the Tribes’ Chief Planning and Development Officer (or equivalent position for the applicable agency representative) or his/her designee. The Tribes’ Chief Planning and Development Officer (or equivalent position for the applicable agency representative) o r his/her designee will also ensure that any deviation from the procedures identified under the monitoring program is approved by the Tribes’ Chief Planning and Development Officer (or equivalent position for the applicable agency representative).

1.3 MITIGATION COMPLIANCE RESPONSIBILITY
The Tribe, County, City, or CVWD, as appropriate for the applicable jurisdiction, will be responsible for enforcing the procedures adopted for monitoring the implementation of each mitigation measure.

Standards for successful mitigation are included in some of the adopted mitigation measures. Additional mitigation success thresholds may be established by applicable agencies with jurisdiction through the permit process and through the review and approval of specific plans for the implementation of mitigation measures.

1.4 CHANGES TO MITIGATION MEASURES
Any substantive change in the monitoring and reporting plan made by the applicable jurisdiction shall be reported in writing to the Tribe’s Chief Planning and Development Officer (or equivalent position for the 12-3145
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 3 Section 24 Specific Plan Project MMEP February 2015
applicable agency representative) or his/her designee(s). Reference to such changes shall be made in the monthly/yearly Environmental Mitigation Monitoring and Enforcement Report prepar ed by the appropriate jurisdiction . Modifications to the mitigation measures may be made by the appropriate jurisdiction subject to one of the following findings, documented by evidence included in the record:
(a) The mitigation m easure included in the Final EIS and/or Record of Decision and the MMEP is no longer required because the significant environmental impact identified in the Final EIS has been found not to exist, or to occur at a level which makes the impact less than significant as a result of changes in the project, changes in conditions of the environment, or other factors.

OR
(b) The modified or substitute mitigation measure to be included in the MMEP provides a level of environmental protection equal to or greater than that afforded by the mitigation measure included in the Final EIS and/or Record of Decision and the MMEP.

The modified or substitute mitigation measure does not have significant adverse effects on the environment in addition to or greater than that which was considered by the responsible hearing bodies in their decisions on the Final EIS and the proposed project.

The modified or substitute mitigation measure is feasible, and the appropriate jurisdiction , through measures included in the MMEP or other agency procedures, can assure its implementation.

1.5 MITIGATION MONITORING TABLE
Table 1, Mitigation Monitoring and Enforcement Program – Section 24 Specific Plan , presents the mitigation monitoring requirements for each adopted mitigation measure.

12-3146
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 4 Section 24 Specific Plan Project MMEP February 2015
Table 1
Mitigation Monitoring and Enforcement Program – Section 24 Specific Plan Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
Air Quality
Construction emissions would exceed the
South Coast Air Quality Management
District (SCAQMD) threshold for volatile
organic compounds (VOCs), and
operation emissions would exceed
SCAQMD threshold for VOCs, nitrous
oxides (NOx), and carbon monoxide (CO).

The primarily source of operational
emissions would be generated from
mobile sources as a result of normal day-
to-day activities on the Project Site.

Mobile emissions would be generated by
the motor vehicles travelling to and from
the Project Site.

Active Adult Community and Tribal Planning Areas

5.2-1 The contractor shall incorporate the
following into construction plans and
specifications, which shall be implemented
to reduce VOC emissions resulting from
application of architectural coatings:
• Contractors sh all use high -pressure,
low-volume (HPLV) paint applicators
with a minimum transfer efficiency of at
least 50 percent.
• Coatings and solvents with a VOC
content lower than required under Rule
1113 shall be used.
• Construction and building materials that
do not require painting shall be used to
the extent feasible.
• Prepainted construction materials shall
be used to the extent feasible.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Works and/or
Building & Safety
Departments
Prior to issuance
of Building Permits

During
Construction

Short-term emissions associated with
construction of the Project would exceed
the SCAQMD VOC thresholds for regional
emissions for the Tribal Planning Area
only and Combined Project Buildout
scenarios.

Active Adult Community and Tribal Planning Areas

5.2-2 Construction equipment engines shall utilize
Tier 4 engines or better.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Prior to issuance
of Building Permits

12-3147
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 5 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
Works and/or
Building & Safety
Departments
Biological Resources
Development of the Project Site would
be subject to the Tribal Habitat
Conservation Plan ( THCP), which is
intended to address development and
other activities taking place within the
Tribe’s jurisdiction and provide the
means to protect and conserve federa lly
listed species and others deemed by the
Tribe and the United States Fish and
Wildlife Service ( USFWS) to be sensitive
and potentially in need of listing in the
future. The Project Site is not located
within the Target Acquisition Areas
identified in th e THCP and with payment
of the conservation fee, development
would be consistent with the THCP. In
addition, the City of Rancho Mirage
(“City”) is a participant and permittee in
the Coachella Valley Multiple Species
Habitat Conservation Plan ( CVMSHCP)
and is coordinating with the Tribe
regarding the THCP. The Active Adult
Community portion of the Project would
also pay the development mitigation fees
identified by the THCP. T he Tribe will use
mitigation fees collected to acquire
conservation lands to implem ent the
THCP. While the USFWS has not yet
approved the THCP or issued a 10(a)
Permit, the Tribe has independent
Active Adult Community and Tribal Planning Areas

5.3-1 Tribal Habitat Conservation Plan. Prior to
the issuance of any grading permits, the
THCP Conservation Fee shall be paid.

Tribal Planning
and Development
Department
Prior to issuance
of Grading Permits

12-3148
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 6 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
authority to implement the THCP to
mitigate impacts to sensitive resources
on Reservation lands.

The burrowing owl is a covered species
under the THCP and was detected on -
site. Development of the Project Site
would result in the loss of native
vegetation and habitats that support
sensitive species , such as the identified
burrowing owl. Impacts to the burrowing
owl could occur directly from habitat
modification and roadway construction.

Active Adult Community and Tribal Planning Areas

5.3-2 Burrowing Owl. To avoid impacts to
burrowing owls during construction, the
following actions, which are consistent with
the Staff Report on Burrowing Owl
Mitigation prepared by the California
Department of Fish and Wildlife on March 7,
2012 and approved and accepted by the U.S.

Fish and Wildlife Service, shall be taken:

1. A preconstruction survey should take
place not more than 30 days prior to any
construction activities planned between
February 15 and June 15, the breeding
season for burrowing owls, project
grading to determine the location of any
active burrows on and within 550 yards
of an approved project site. If no active
burrows are found in the survey area,
site disturbance may commence
providing a biological monitor is onsite.

2. A biological monitor, with the authority
to halt or redirect grading, shall be
present whenever grading or
construction vehicles are present and
operating on the project site. The
function of the monitor is to protect
burrowing owls that arrive on or near the
project site after the clearance survey
and during the construction period.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Planning
Division
Less than 30 days
prior to planned
construction
activities between
February 15 and
June 15

During
Construction

12-3149
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 7 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
Development of the Project Site would
result in the loss of native vegetation and
habitats that support sensitive species.

While no old or new nests were found,
the Loggerhead Shrike was observed on -
site. The Loggerhead Shrike is considered
a Species of Special Concern by the State
of California; however it is not addressed
in the THCP. Impacts to this species could
occur directly from habitat modification
and roadway construction.

Active Adult Community and Tribal Planning Areas

5.3-3 Loggerhead Shrike. To avoid impacts to
Loggerhead Shrikes during construction,
breeding surveys shall be conducted
simultaneously with burrowing owls surveys,
30 days prior to any construction activities
planned between February 15 and June 15,
which is the breeding season
for both
species. If a shrike nest is found, a buffer
shall be established in which construction
activities are prohibited until all young have
fledged. The width of the buffer shall be
determined by a qualified biologist.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Planning
Division
Less than 30 days
prior to planned
construction
activities between
February 15 and
June 15;
concurrent with
Burrowing owl
surveys

During
Construction

Cultural Resources
No known ethnographic villages
associated with the Project Site were
identified. However, because of the
presence of the large sand dune,
previously identified archaeological
artifacts on the Project Site, SRI -1
identified during field surveys, and
nearby prehistoric sites, the area is
deemed sensitive for buried
archaeological sites. The Tribe has
specifically identified the Project as an
area of concern for sensitive cultural
resources.

Active Adult Community and Tribal Planning Areas

5.4-1 Prior to the start of any ground disturbing
activities within the Project Site the Agua
Caliente Band of Cahuilla Indians (Tribe)
Tribal Historic Preservation Officer (THPO)
shall be notified of the pending activities. A
qualified archaeologist shall coord inate with
the THPO during the drafting for the
archaeological monitoring plan and the plan
shall allow for the archaeologist in
consultation with the THPO to determine
when monitoring is no longer necessary.

During earth moving disturbances that
involve excavation activities, if there is any
evidence of Native American resources
(significant or otherwise), the THPO will be
notified and construction activities modified
in accordance with the archaeological
monitoring plan.

Tribal Historic
Preservation
Office
Prior to issuance
of Grading Permits

12-3150
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 8 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
The Project Site does not contain
religious or sacred uses as identified in
the cultural resources study.

Development of the Project would
therefore not restrict existing religious or
sacred uses. However, there is potential
to discover religious or sacred materials
beneath the surface. As a result,
construction impacts should be mitigated
to be less than significant.

Active Adult Community and Tribal Planning Areas

5.4-2 If prehistoric or historical -period artifacts or features are found during the course of
construction and no archaeological or Tribe
approved Native American cultural resource
monitor is present, work within 300 feet of
the discovery shall cease, and a qualified
archaeologist and a Tribe approved Native
American cultural resource monitor shall be
brought in to examine the find to determine
if it contains any historical or unique
archaeological resources that require further
mitigation. Additional fieldwork may be
required to evaluate the site s for their
eligibility for listing in the California Register
of Historic Resources. If the archaeologist
determines, in consultation with the THPO,
that the resources are unique, the project
applicant shall cease any disturbance of the
soil within 300 fe et of the find to allow
sufficient time for mitigation by avoidance
measures and/or other mitigation options as
specified in Public Resources Code (PRC),
Section 211083.2.

Tribal Historic
Preservation
Office
During
Construction

No human remains were found in the
Project Site during the surveys. Based on
the cultural sensitivity of the area , there
is the potential to find human remains
during subsurface grading activities.

P
roject construction would require
ground-disturbing activ ities, including
grading and excavation, which could
result in the discovery of previously
unrecorded human remains, including
Active Adult Community and Tribal Planning Areas

5.4-3 If human remains are identified during
construction, all construction near the find
must cease immediately and the area must
be secured. The Riverside County Coroner’s
office must be contacted immediately, in
accordance with the State Health and Safety
Code
(HSC) Section 7050.5(b). If the
determination i s made by the coroner that
the remains are those of a Native American,
Tribal Historic
Preservation
Office
During
Construction

12-3151
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 9 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
Native American burials. HSC section 7050.5(c) requires that the coroner contact the NAHC by telephone
within 24 hours. The NAHC will select the
Most Likely Descendant and will coordinate
the treatment and fina l disposition
(repatriation) of human remains with that
individual, according to the provisions of PRC
section 5097.98 and any other legal
requirements.

Geology and Soils
The relatively flat topography of the
Project Site and surrounding off -site
areas precludes both stability and the
potential for lurching. Additionally,
ground surface water and groundwater
are not found to be present within the
Project Site. However, the re is the
potential for hazards such as lateral
spreading, subsidence, liquefaction, or
collapse.

Active Adult Community

5.5-1 As part of final design development, a
detailed geotechnical and soils investigation
shall be conducted by a registered
engineering geologist for review and
approval by the City of Rancho Mirage
Building and Safety Division, if annexed into
the City, the T ribal Engineer, or the County
Engineer as applicable, prior to the issuance
of grading and building permits.

As applicable to
the appropriate
agency:

Tribe Planning and
Development
Department /

City of Rancho
Mirage Public
Works and/or
Building & Safety
Departments
Prior to issuance
of Grading and
Building Permits

The relatively flat topography of the
Project Site and surrounding off -site
areas precludes both stability and the
potential for lurching. Additionally,
ground surface water and groundwater
are not found to be present within the
Project Site. However, there is the
potential for hazards such as lateral
spreading, subsidence, liquefaction, or
collapse.

Active Adult Community

5.5-2 All grading and earthwork recommendations
from the Project geotechnical and soils
reports, including any updates, must be
incorporated into the final Project design,
including the final grading, drainage and
erosion control plans, or other plans deemed
necessary by the City of Rancho Mirage
Building and Safety Division, if annexed into
the City, the Tribal Engineer, or the County
As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department /

City of Rancho
Prior to issuance
of Grading Permits

During
Construction

12-3152
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 10 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
Engineer as applicable, and must ensure they
meet the City’s Building Code requirements
set forth in the City Municipal Code, the
Tribal Land Use Ordinance, or the County
Municipal Code as applicable. All grading
activities must be supervised by a certified
engineering geologist: Final grading,
drainage, and erosion control plans must be
reviewed and approved by the City of
Rancho Mirage Building and Safety Division
before the City issues a grading permit, by
the Tribal Engineer, or the County Engineer,
as applicable.

Mirage Public
Works and/or
Building & Safety
Departments
The relatively flat topography of the
Project Site and surrounding off -site
areas precludes both stability and the
potential for lurching. Additionally,
ground surface water and groundwater
are not found to be present within the
Project Site. However, ther e is the
potential for hazards such as lateral
spreading, subsidence, liquefaction, or
collapse.

Tribal Planning Areas

5.5-3 As part of final design development, a
detailed geotechnical and soils investigation
shall be conducted by a registered
engineering geologist for review and
approval by the Agua Caliente Band of
Cahuilla Indians Tribal Engineer prior to the
issuance of grading and building permits.

Tribal Planning
and Development
Department
Prior to issuance
of Grading and
Building Permits

The relat ively flat topography of the
Project Site and surrounding off -site
areas precludes both stability and the
potential for lurching. Additionally,
ground surface water and groundwater
are not found to be present within the
Project Site. However, there is the
potential for hazards such as lateral
spreading, subsidence, liquefaction, or
collapse.

Tribal Planning Areas

5.5-4 All grading and earthwork recommendations
from the Project geotechnical and soils
reports, including any updates, must be
incorporated into the final Project design,
including the final grading, drainage and
erosion control plans, or other plans deemed
necessary by the Agua Caliente Band of
Cahuilla Indians Tribal Engineer, and must
ensure they meet the Tribe’s Building Code
requirements set f orth in the Tribal Building
Tribal Planning
and Development
Department
Prior to issuance
of Grading Permits

12-3153
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 11 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
and Safety Code. All grading activities must
be supervised by a certified engineering
geologist: Final grading, drainage, and
erosion control plans must be reviewed and
approved by the Agua Caliente Band of
Cahuilla Indians Trib al Engineer before the
Tribe issues a grading permit.

Greenhouse Gas Emissions
The Project would result in short -term
emissions of greenhouse gases (GHGs)
during construction. Project operational
GHG emissions for the Active Adult
Community, Tribal Planning Areas, and
Combined Development would be
8,882.84, 39,326.09, and 46,480.7 me tric
tons of carbon dioxide equivalents
(MTCO2e) per year, respectively.

Active Adult Community and Tribal Planning Areas

5.6-1 Prior to issuance of each building permit, the
applicant shall provide a list to the Planning
Department of the green building practices
and design elements used in building that
reduce GHG emissions. The green building
practices and design elements shall be
consistent with the current standards in the
Voluntary Green Building Program and any
other green building standards subsequently
adopted either by the Agua Caliente Band of
Cahuilla Indians (Tribe) or by the City of
Rancho Mirage (City).

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Planning
Division
Prior to issuance
of Building Permits

The Project would result in short -term
emissions of GHGs during construction.

Project operational GHG emissions for
the Active Adult Community, Tribal
Planning Areas, and Combined
Development would be 8,882.84,
39,326.09, and 46,480.7 M TCO2e per
year, respectively.

Active Adult Community and Tribal Planning Areas

5.6-2 Prior to the issuance of each building permit,
the applicant shall provide evidence of its
use of energy -
efficient designs meeting
and/or consist ent with the standards in the
current Voluntary Green Building Program
and any other green building standards
adopted by either the Tribe or City. In
accordance with the Voluntary Green
Building Program, all residential buildings
shall, at a minimum, exceed Title 24 (2008)
by 15 percent and all non- residential
As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Planning
Division and/or
Building & Safety
Prior to issuance
of Building Permits

12-3154
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 12 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
buildings shall, at a minimum, exceed Title
24 (2008) by 15 percent. This measure does
not exempt buildings from meeting future
energy efficiency obligations that may result
from future revisions to t he Title 24
standards. Furthermore, the Project shall
commit to exceeding future Title 24
standards as close to the 15 percent target
for residential and commercial buildings as
possible, to the extent that it is feasible to do
so based on technological an
d financial
feasibility factors at the time of permit
application.

Department

The Project would result in short -term
emissions of GHGs during construction.

Project operational GHG emissions for
the Active Adult Community, Tribal
Planning Areas, and Combined
Development would be 8,882.84,
39,326.09, and 46,480.7 MT CO2e per
year, respectively.

Active Adult Community and Tribal Planning Areas

5.6-3 Prior to the issuance of each building permit,
the applicant shall provide evidence to the
appropriate Planning Department of its use
of energy efficient lighting, heating and
cooling systems, appliances, equipment, and
control systems, including the installation of
ENERGY STAR -certified products, consistent
with the standards in the Voluntary Green
Building Program and any other energy
efficiency standards adopted by eithe r the
Tribe or City.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Planning
Division
Prior to issuance
of Building Permits

The Project would result in short -term
emissions of GHGs during construction.

Project operational GHG emissions for
the Active Adult Community, Tribal
Planning Areas, and Combined
Development would be 8,882.84,
39,326.09, and 46,480.7 MTCO2e per
year, respectively.

Active Adult Community and Tribal Planning Areas

5.6-4 Prior to the issuance of each building permit,
the applicant shall provide evidence to the
appropriate Planning Department of the use
of “cool” roofs or “green” roofs, and cool
pavements for all roofs and pavements to
the extent that such products are
commercially available for the implementing
As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

Prior to issuance
of Building Permits

12-3155
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 13 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
Project. City of Rancho
Mirage Planning
Division
The Project would result in short -term
emissions of GHGs during construction.

Project operational GHG emissions for
the Active Adult Community, Tribal
Planning Areas, and Combined
Development would be 8,882.84,
39,326.09, and 46,480.7 MTCO2e per
year, respectively.

Active Adult Community and Tribal Planning Areas

5.6-5 Prior to the issuance of each building permit,
the applicant shall provide evidence to the
appropriate Planning Department of the use
of automatic covers, efficient pumps and
motors, and solar heating for all pools and
spas to the extent that such products are
commercially available for the implementing
Project.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Planning
Division
Prior to issuance
of Building Permits

The Project would result in sh ort-term
emissions of GHGs during construction.

Project operational GHG emissions for
the Active Adult Community, Tribal
Planning Areas, and Combined
Development would be 8,882.84,
39,326.09, and 46,480.7 MTCO2e per
year, respectively.

Active Adult Community and Tribal Planning Areas

5.6-6 Prior to the issuance of each building permit,
the applicant shall provide evidence to the
appropriate Planning Department of the use
of water efficient irrigation systems and
devices, such as soil -based irrigation contr ols
and use water -efficient irrigation methods
consistent with measures recommended in
the Voluntary Green Building Program, and
any other green building standards adopted
by the Tribe or City, and the Coachella Valley
Water District water efficiency goals . In
accordance with the appropriate program,
the applicant shall provide evidence that
building is consistent with the following
Specific Plan -wide water conservation
measures and/or does not prevent or
conflict with the Specific Plan’s ability to
meet th e followi ng water conservation
As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Planning
Division
Prior to issuance
of Building Permits

12-3156
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 14 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
measures:
• 100 percent of all builder -installed
plumbing devices in each residential
buildings shall be low -flow and water -
efficient.
• 100 percent of all builder -installed
plumbing devices in each non- residential
buildings shall be low -flow and water -
efficient.
• Turf shall not exceed 20 percent of the
total landscaped area of each lot, with
the exception of parks and recreation
centers.
• 80 pe rcent of public and common
landscape areas shall use smart irrigation
systems per project.
• 80 percent of public and common
landscape areas shall use drought -
tolerant, native, and/or water -efficient
plant materials per project.

The Project would result in short -term
emissions of GHGs during construction.

Project operational GHG emissions for
the Active Adult Community, Tribal
Planning Areas, and Combined
Development would be 8,882.84,
39,326.09, and 46,480.7 MTCO2e per
year, respectively.

Active Adult Community and Tribal Planning Areas

5.6-7 Prior to grading for the Project, the applicant
or their contractor shall submit to the
appropriate Public Works Department for
review and approval of a site construction
management plan for the reuse and recycle
construction and demolition waste (including
soil, vegetation, concrete, lumber, metal,
and cardboard).

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Works and/or
Building & Safety
Prior to issuance
of Grading Permits

12-3157
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 15 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
Departments
The Project would result in short -term
emissions of GHGs during construction.

Project operational GHG emissions for
the Active Adult Community, Tribal
Planning Areas, and Combined
Development would be 8,882.84,
39,326.09, and 46,480.7 MTCO2e per
year, respectively.

Active Adult Community and Tribal Planning Areas

5.6-8 Prior to the issuance of each building permit,
the applicant shall provide evidence to the
appropriate Planning Department of reuse
and recycling measures in residential,
industrial, and commercial projects
consistent with measures recommended in
the Voluntary Green Building Program or any
other green building standards adopted by
the Tribe or City. In accordance with the
adopted green building program, the
applicant shall provide evidence that the
building is consistent with the following
Specific Plan -wide recycling and waste
reduction measures and/or does not prevent
or conflict with the Specific Plan’s ability to
meet the following recycling and waste
reduction measures:
• Provide recycli ng containers within all
multi-family residential communities
• Provide recycling containers within all
commercial, office, and light industrial
buildings.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Works
Department
Prior to issuance
of Building Permits

The Project would result in short -term
emissions of GHGs during construction.

Project operational GHG emissions for
the Active Adult Community, Tribal
Planning Areas, and Combined
Development would be 8,882.84,
39,326.09, and 46,480.7 MTCO2e per
year, respectively.

Active Adult Community and Tribal Planning Areas

5.6-19 Prior to the issuance of each building permit,
the applicant shall provide evidence to the
appropriate Planning Depar tment the use of
employment based trip and vehicle miles
traveled (VMT) policies that encourage the
use of alternative transportation.

Comprehensive employment based trip and
VMT reduction policy measures shall be in
As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Prior to issuance
of Building Permits

12-3158
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 16 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
compliance with City or Tribe mass tran sit
programs and include but are not limited to
the measures listed below:
• Seek approval from the appropriate
Planning Department(s) to waive
minimum parking requirements and
reduce parking from the minimum
standards by as much as 20 percent for
projects within a quarter mile of a transit
station.
• Use shared and/or centralized parking
facilities consistent with a “park once”
approach.
• Require that employers provide
information on public transportation
options to employees.
• Require that large employers (250 or
more employees at a single work -site
location) and encourage small employers
(less than 250 employees at a single
work-site location) to provide bicycle
parking facilities, employee break rooms
with refrigerators and microwaves, and
automated teller machines (ATMs).
• Require that large employers (250 or
more employees at a single work -site
location) provide a transportation
demand management program, such as
vanpools/carpools, ride -sharing/ride-
matching, and/or “guaranteed ride
home” services that allow employees
who use public transit to get a free ride
home if they need to stay at work late.

Mirage Planning
Division
12-3159
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 17 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
• Require that 1 electric vehicle charging
station be provided for every application
for 100,000 or more square feet of non -
residential development.

Hazards and Hazardous Materials
The Project Site does not contain any
unidentified soil contamination or
disturbance, nor is the Site identified as a
hazardous site or contain any hazardous
materials. However, caution should be
taken during construction in regards to
the unidentified PVC riser located within
the Tribal Planning Areas portion of the
Project Site.

Tribal Planning Areas

5.7-1 The unidentified PVC riser on the
southeastern portion of the Project Site shall
be further assessed. If an underground
storage tank or other buried features are
identified, they shall be removed in
accordance with S tate and federal
regulations. The Rivers ide County Fire
Department must be notified if any
underground storage tanks and/or other
materials are found, and consulted during
removal of such materials.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Works and/or
Building & Safety
Departments/

Riverside County
Fire Department
Prior to issuance
of Grading Permits
Hydrology and Water Quality
Development of the Project would
increase the amount of impervious
surfaces on the Project Site, which would
potentially increase runoff within the
Project Area.

Active Adult Community and Tribal Planning Areas

5.8-1 Prior to grading final for each individual
project proponent, a project -specific water
quality management plan (WQMP) shall be
submitted to the appropriate jurisdiction for
review and approval.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Prior to issuance
of Grading Permits

12-3160
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 18 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
Works and/or
Building & Safety
Departments
Development of the Project would
increase the amount of impervious
surfaces on the Project Site, which would
potentially increase runoff within the
Project Area. The Project would include
15 retention basins in the Active Adult
Community and up to 11 retention basins
in the Tribal Planning Areas to ensure on-
site flows do not exceed pre- project
conditions. Storm drain improvements
would convey runoff to t he proposed on-
site retention basins.

Active Adult Community and Tribal Planning Areas

5.8-3 Prior to final grading, individual project
proponents shall submit a detailed operation
and maintenance plan to the appropriate
jurisdiction and CVWD for review and
approval of the as-built project conditions.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Works
Department /

Coachella Valley
Water
Conservation
District
Prior to issuance
of Building Permits

The Project would include 15 retention
basins in the Active Adult Community
and up to 11 retention basins in the
Tribal Planning Areas to ensure on -site
flows do not exceed pre- project
conditions. Storm drain improvements
would convey runoff to the proposed on -
site retention basins.

Active Adult Community and Tribal Planning Areas

5.8-4 Periodic inspection of the conditions of the
open channels, retention basins, and storm
drains will need to be performed year round
and after significant precipitation events will
be required to be performed by each
homeowner association (HOA). Annual
inspection reports shall be prepared by each
HOA, and submitted to and filed with the
Tribe, City if property is annexed, and/or
CVWD by June 30th each year calendar year.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Works
Department /
Annually by June
30th each calendar
year upon
operation of the
Active Adult
Community and/or
the Tribal Planning
Areas

12-3161
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 19 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)

Coachella Valley
Water
Conservation
District
CVWD has developed more localized
flood models which indicate that the
northeast portion of the Project Site is
located within a 100- year flood hazard
area. T he Project includes a drainage
master pl an designed to convey flows
without substantial modification to
existing off - and on -site drainage
conditions. Off -site flows would be
collected at natural concentration points
along the northeastern boundary of the
Project Site and within the southern
portion of the site and conveyed via
engineered channels that follow existing
drainage patterns and CVWD facilities.

Tribal Planning Areas

5.8-2 Prior to the issuance of a grading permits for
development within Tribal Planning Area 3; a
detailed hydrology stu
dy shall be prepared
and submitted to the Tribal Engineer and/or
CVWD for review and approval. This study
shall evaluate the potential flows from the
Morongo Watershed and will identify
facilities to be constructed to collect, route
and discharge flows in a manner compatible
with pre project/existing conditions across
the Project Site. At the completion of
construction of the flood control facilities,
submit “as -built” topography, construction
drawings and engineering analysis for CVWD
review to verify that the design capacity is
adequate.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

Coachella Valley
Water
Conservation
District
Prior to issuance
of Grading Permits

Noise
Construction-related activities would
occur over a period of up to six years for
the Active Adult Community. Project-
related construction activities would
occur within the least noise -sensitive
portion of the day between 7:00 AM and
7:00 PM.

However, no construction
timeline has been proposed for the Tribal
Planning Areas, and as such, construction
activities could occur up to 20 years near
Active Adult Community and Tribal Planning Areas

5.10-1 The project a pplicant shall require that the
following construction best management
practices (BMPs) be implemented by
contractors to reduce construction noise
levels:
• Two weeks prior to construction
activities, the applicant must notify all
surrounding land uses withi n 200 feet of
a project site, of the construction
As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Notice residences
within 200 feet
two weeks prior to
construction
activities

Review approve
Haul Route prior
to issuance of
Grading Permits

12-3162
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 20 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
the sensitive uses to the west and south
of the Project Site.
schedule, including the various types of
activities that will be occurring
throughout the duration of the
construction period.
• Before any site activity, the contractor
shall be required to submit a material
haul route plan to the Agua Caliente Band
of Cahuilla Indians (Tribe) Traffic Engineer
and to the City of Rancho Mirage for
review and approval. The contractor
must ensure that the approved haul
routes are used for all materials hauling,
to minimize expos ure of sensitive
receivers to potential adverse noise
levels from hauling operations.
• Ensure that construction equipment is
properly muffled according to industry
standards and in good working condition.
• Place noise -generating construction
equipment and lo cate construction
staging areas away from sensitive uses,
where feasible.
• Stationary construction equipment, such
as pumps, generators, or compressors,
must be placed as far from noise
sensitive uses as feasible during all
phases of project construction.
• Implement noise attenuation measures
to the extent feasible, which may include,
but are not limited to, temporary noise
barriers or noise blankets around
stationary construction noise sources.
• Use electric air compressors and similar
Works and/or
Building & Safety
Departments
12-3163
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 21 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
power tools rather than diesel
equipment, where feasible.
• Construction-related equipment,
including heavy -duty equipment, motor
vehicles, and portable equipment, must
be turned off when not in use for more
than 30 minutes.
• Construction hours, allowable workdays,
and the phone nu
mber of the job
superintendent must be clearly posted at
all construction entrances to allow for
surrounding owners and residents to
contact the job superintendent. If the
Tribe, the City, or the job superintendent
receives a complaint, the superintendent
must investigate, take appropriate
corrective action, and report the action
taken to the reporting party. Contract
specifications must be included in the
proposed Project construction
documents, which must be reviewed by
the Tribe prior to issuance of grad ing
permits.

The exterior noise levels along the
Project’s internal roadways from vehicle
traffic would exceed the exterior State
and local threshold of 65 dB(A) within the
Planning Areas proposed for res idential
uses.

Active Adult Community and Tribal Planning Areas

5.10-2 Prior to implementing project approval for
each implementing project, for on -site
residential lots located within the 65 dB(A)
CNEL or greater noise contour for internal
roadways
(including Street “C” between
Planning Area 1 and 2, Street “D” between
Planning Areas 2, 3, 4, 5, and 6, and Street
“E” between Planning Areas 6 and 7), an
acoustic analysis shall be required to address
requirements for determining and mitigating
As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Prior to issuance
of Building Permits

12-3164
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 22 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
traffic noise impacts to residential structures.

The acoustical analysis must be received,
reviewed, and approved by the appropriate
agency (such as the Agua Caliente Band of
Cahuilla Indians or City of Rancho Mirage).

Methods that may be implemented to meet
the standards include, but are not limited to,
providing noise walls of sufficient size to
break the line of sight between roadways
and residential areas, providing open- space
buffers, providing natural barriers such as
hills, berms, boulders, and dense vegetat ion,
or a combination of these methods.

Works and/or
Building & Safety
Departments
Single noise even ts from parking lots
could be an annoyance to on- site and
surrounding residents during certain time
periods such as evening and morning
hours and may exceed local standards at
receptor locations.

Tribal Planning Areas

5.10-3 Sound attenuation measures shall be
incorporated into the design of individual
projects to minimize noise from parking lots.

These measures could include, but are not
limited to, a noise barrier of sufficient size to
break the line of sight, an open- space
buffer, a setback, or a combination of
methods shall be developed along locations
between parking lot noise and exterior
usable areas within on -site and adjacent
residential uses where these uses interface.

Acoustical analysis shall be performed to
demonstrate that the parking lot does not
result in noise levels on sensitive uses within
the City of Rancho Mirage that exceed the
City Municipal Code L50 standard of 60
dB(A) between 7:00 AM and 6:00 PM, 55
dB(A) between 6:00 PM and 10:00 PM, and
50 dB(A) betwe en 10:00 PM and 7:00 AM.

These components shall be incorporated
Tribal Planning
and Development
Department

Prior to issuance
of Building Permits

12-3165
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 23 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
into the plans submitted by the applicant to
the Tribe, prior to th e issuance of building
permits.

External truck loading and unloading
docks associated with the Project would
introduce potential stationary noise
sources. The specific location of potential
loading docks has not been determined.

The operations at loading docks typically
result in noise levels of 64 to 66 dB(A) at
75 feet. The noise from loading docks
would not cause an increase in long -term
average noise of more than 5 dB(A) on
the time-weighted CNEL scale, and would
not be significant from that perspective.

However, single noise events could be a n
annoyance during certain time periods
such as evening and morning hours to
existing on -site and off -
site residential
land uses along Los Alamos Road, Dinah
Shore Drive , and internal roadways.

Noise levels may exceed local standards.

Tribal Planning Areas

5.10-4 Sound attenuation measures must be
incorporated into the design of individual
projects to minimize noise from loading
docks. These measures may include, but are
not limited to, designing loading docks to
have either a depressed (i.e., below grade)
loading
area, an internal bay, or a wall to
break the line of sight between on -site and
adjacent residential land uses and loading
operations. Acoustical analysis shall be
performed to demonstrate that the loading
dock does not result in noise levels on
sensitive uses within the City that exceed the
City’s L50 standard of 60 dB(A) between 7:00
AM and 6:00 PM, 55 dB(A) between 6:00 PM
and 10:00 PM, and 50 dB(A) between 10:00
PM and 7:00 AM. These components must
be incorporated into the plans submitted by
the applic ant to the Tribe for review and
approval, prior to issuance of building
permits.

Tribal Planning
and Development
Department
Prior to issuance
of Building Permits

Public Services
Fire Protection and Emergency Medical Services
The Project would generate a total of
4,331 new residents to the Project Site.

This increase in residents would increase
the demand on the Riverside County Fire
Department ( RCFD)
for services and
facilities.

Active Adult Community and Tribal Planning Areas

5.12.1-1 Prior to the iss uance of building permits,
individual project proponents shall pay
development impact fees for fire protection
facilities, or their equivalent, to the City if
annexed into City jurisdiction, or County as
As applicable to
the appropriate
agency:

Tribal Planning
and Development
Prior to issuance
of Building Permits

12-3166
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 24 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
applicable. Department

City of Rancho
Mirage Planning
Division/

Riverside County
Planning
Department
Law Enforcement
The Project would generate a total of
4,331 new residents to the Project Site.

The Riverside County Sheriff’s
Department has indicated that in order
to accommodate the increased requests
for law enforcement services that would
be associated with the Project, the
service area would require an additi onal
patrol deputies.

Active Adult Community and Tribal Planning Areas

5.12.2-1 Prior to the issuance of building permits,
individual P
roject proponents shall pay
applicable development impact fees, or
provide equivalent funding, to offset the cost
of addi tional law enforcement services for
the Project.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Planning
Division/

Riverside County
Planning
Department
Prior to issuance
of Building Permits

Schools
Due to the nature of the Active Adult
Community being an age -restricted
community, it is assumed it would not
generate any additional students into the
Palm Springs Unified School District. The
Tribal Planning Areas would add 98
Active Adult Community and Tribal Planning Areas

5.12.3-1 Prior to the issuance of building permits,
individual project proponents shall pay
applicable development fees to PSUSD.

Palm Springs
Unified School
District
Prior to issuance
of Building Permits

12-3167
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 25 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
students to Sunny Sands Elementary , 42
students to Nellie N Coffman School , and
add 49 students to Rancho Mirage High
School. All schools serving the Project
Site are currently operating under
capacity and would not require the
provision of new or physically alter
existing school facilities. However,
individual project proponents will be
required to pay applicable development
fees to Palm Springs Unified School
District to ensure that school facilities are
not adversely impacted.

Libraries
The Project would create additional
demand on the Rancho Mirage Public
Library for services and facilities. It is
currently operating below capacity and
has plenty of room for growth. However,
the Project would increase demand on
the Rancho Mirage Public Library.

Active Adult Community and Tribal Planning Areas

5.12.4-1 Prior to the issuance of building permits,
individual project proponents shall pay
applicable development impact fees, or
provide equivalent funding, to the City if
annexed and under City jurisdiction or
County as applicable.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Planning
Division/

Riverside County
Planning
Department
Prior to issuance
of Building Permits

12-3168
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 26 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
Recreation
The Project would generate a total of up
to 4, 331 new residents and would
provide for a minimum of 13 acres of
parkland. This would increase demand on
existing City and County recreation
facilities.

Active Adult Community and Tribal Planning Areas

5.13-1 Prior to the issuance of building permits,
individual project proponents shall pay
applicable in -lieu parkland fees, or
equivalent, to ensure adequate funding for
parks and recreation improvements.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Planning
Division/

Riverside County
Planning
Department
Prior to issuance
of Building Permits

Traffic and Transportation
Temporary traffic impacts would occur
during the construction of infrastructure
improvements serving the Project,
including the widening of Bob Hope
Drive, and other offsite roadway and
infrastructure improvements.

Construction of these infrastructure
improvements would cause short -term
impacts related to noise, dust, and traffic
flows as a result of temporar y lane
closures.

Active Adult Community and Tribal Planning Areas

5.14-1 Prior to obtaining a grading permit, the
individual project proponent shall prepare
and submit to the Agua Caliente Band of
Cahuilla Indians, City of Rancho Mirage
and/or Riverside Co unty for review and
approval detailed construction traffic
management plans, including street closure
information, detour plans, haul routes, and
staging plans as necessary for any off -site
work that would encroach on public right -of-
way. The construction traffic management
plans shall include the following elements, as
appropriate:
• Provisions for temporary traffic control
As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Works
Department /

County of
Prior to issuance
of Grading Permits

12-3169
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 27 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
during all construction activities adjacent
to public right -of-way to improve traffic
flow on public roadways (e.g., flag
person);
• Construction-related vehicles shall not
park on surrounding public streets;
• Provision of safety precautions for
pedestrians and bicyclists through such
measures as alternate routing and
protection barriers;
• Schedule construction -related deliveries
to reduce tra vel during peak travel
periods;
• Obtain the required permits for truck
haul routes from the Tribe, City of
Rancho Mirage and/or Riverside County
prior to the issuance of any permit for
the project;
• Obtain a Caltrans transportation permit
for use of oversized transport vehicles on
Caltrans facilities;
• Outline adequate measures to ensure
emergency vehicle access during all
aspects of the project’s construction,
including, but not limited to, the use of
flagmen during partial closures to streets
surrounding the Project Site to facilitate
the traffic flow until construction is
complete; and
• Include the implementation of security
measures during construction in areas
that are accessible to the general public
to help reduce any increased demand on
Riverside
Transportation
Department

California
Department of
Transportation,
District 8
12-3170
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 28 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
law enfor cement services, including
fencing construction areas, providing
security lighting, and providing security
personnel to patrol construction sites.

Adequate inbound and outbound
capacity shall be provided to
accommodate the site traffic volumes.

Active Adult Community and Tribal Planning Areas

5.14-2 Appropriate right -of-way shall be provided
by individual development projects to
accommodate the ultimate improvement of
the abutting public roadways, and these
roadways sections shall be ful ly improved in
conjunction with the adjacent development
project.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Works
Department /

County of
Riverside
Transportation
Department
At Design Review
and Plan Check

Adequate inbound and outbound
capacity shall be provided to
accommodate the site traffic volumes.

The proposed site access plan
incorporates joint access (the sharing of a
driveway access point by two or more
Planning Areas), which is a desirable and
effective means of minimizing the
adverse impacts of site access
connections on adjacent streets.

Active Adult Community and Tribal Planning Areas

5.14-3 To ensure compliance with applicable
roadway and access design standards when
individual development projects are
processed, their final layout and site access
design shall be subject to review and
approval by the Tribe and, as appropriate,
the City of Rancho Mirage and/or Riverside
County. The need for street widening to
accommodate entry drives, the internal
circulation design, and other features shall
be accommodated on a project by project
As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Works
At Design Review
and Plan Check

12-3171
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 29 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
basis. A traffic signing and striping plan may
also be required for review and approval in
conjunction with detailed construction plans
for a
ny individual development project
within the Project Site.

Department /

County of
Riverside
Transportation
Department
Future sidewalk/bikeway/golf cart paths
are planned on the perimeter of the
Project Site (along Ramon Road, Bob
Hope Drive, and Los Alamos Road) in the
Rancho Mirage General Plan that would
link with the integrated system being
developed throughout the study area.

Active Adult Community and Tribal Planning Areas

5.14-4 All individual development projects shall
comply with applicable requirements in the
Section 24 Specific Plan and construct the
future combination sidewalk / bikeway / golf
cart paths along Ramon Road, Bob Hope
Drive, Dinah Shore Drive and Los Alamos
Road.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Works
Department /

County of
Riverside
Transportation
Department
At Design Review
and Plan Check

All intersection studies along the
intersections and roadway segments
within the Congestion Management
Program (CMP) System of Highways and
Roadways would operate at an
acceptable LOS (LOS D or better) under
existing and future (Year 2022)
conditions.

Active Adult Community and Tribal Planning Areas

5.14-5 The developers of individual development
projects within the Project Site shall make a
fair-share contribution to the cost for
planned future roadway improve ments by
paying an in- lieu fee equal in amount to
what the CVAG Traffic Uniform Mitigation
Fee (TUMF) would be for that project at the
time building permits are issued.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Prior to issuance
of Building Permits

12-3172
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 30 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
Mirage Public
Works and/or
Building & Safety
Departments
The Project will pay the CVAG
Transportation Uniform Mitigation Fee
(TUMF), or an in -lieu fee equal to TUMF,
which is the major source of regi onal
roadway improvement fees in the
Coachella Valley.

Active Adult Community and Tribal Planning Areas

5.14-6 The project proponent shall pay applicable
fees to the appropriate jurisdictions to
ensure that a fair -share contribution is made
to Cathedral City for improvements to the
intersection of Da Vall Drive and Ramon
Road, such as the TUMF program.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Public
Works and/or
Building & Safety
Departments
Prior to issuance
of Building Permits

Utilities and Service Systems
Sewer
The onsite wastewater collection system
for the Active Adult Community would
connect proposed 8 -inch sewer lines to
the existing 15 -inch sewer line within Los
Alamos Road. The CVWD has indicated
that the sewer line beneath Varner Road
east of Cook Street which serves WRP -7
is currently at capacity. As such, the
Project would potentially result in
significant impacts on CVWD’s existing
sewer system.

Active Adult Community and Tribal Planning Areas

5.15.2-1 Prior to the issuance of the first occupancy
permit, individual project proponents shall
pay applicable fees, or provide equivalent
funding, to CVWD to update the sewer line
beneath Varner Road east of Cook Street, as
reques
ted by CVWD, and to cover the
Project’s fair share from the cumulative need
to expand WRP-7.

Coachella Valley
Water District

Prior to issuance
of 1st Occupancy
Permit

12-3173
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 31 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
Solid Waste
Although adequate capacity exists for the
near term, the P roject would generate
solid waste that would require disposal,
thus decreasing the capacity of existing
permitted landfills. E ach individual
development proponent would
implement a waste diversion program in
an effort to reduce solid waste impacts
on exist ing landfill capacities, similar to
the State’s waste diversion goal of 75
percent as identified by State law (SB
1016 and AB 939). The Project would be
required to divert up to 75 percent of its
operational solid waste by 2020.

Active Adult Community and Tribal Planning Areas

5.15.3-1 Prior to implementing individual project
approval, a Waste Recycling Plan (WRP) shall
be submitted and approved by the
appropriate Planning Department and
provided to the appropriate Department of
Building and Safety prior t o the issuance of
building permits. At a minimum the WRP
shall identify the materials (e.g., concrete,
asphalt, wood, etc.) that would be generated
by construction and development, the
project amounts, measures/methods that
would be implemented to recycle, reuse,
and/or reduce the amount of materials, the
facilities and haulers that would be utilized,
and the targeted recycling or reduction rates
to be achieved.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/

City of Rancho
Mirage Planning
Division and/or
Building & Safety
Department/

Riverside County
Waste
Management
Department
Prior to issuance
of Building Permits

Each individual development proponent
would implement a waste diversion
program in an effort to reduce solid
waste impacts on existing landfill
capacities, similar to the State’s waste
diversion goal of 75 percent as identified
by State law (SB 1016 and AB 939). The
Project would be required to dive rt up to
75 percent of its operational solid waste
by 2020.

5.15.3-2 Each individual project proponent shall
recycle, reuse, and/or reduce, to the
maximum extent feasible, the amount of
construction and demolition materials (i.e.,
concrete, asphalt, wood, etc.) generated by
development of the Project that would
otherwise be taken to a landfill. This
diversion of waste must exceed a 50 percent
reduction by weight. The Project shall
complete a Construction and Demolition
Waste form as evidence to ensure
compliance. The reporting form must be
approved by the appropriate Planning
Department and submitted to the
As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/
City of Rancho
Mirage Planning
Division and/or
Building & Safety
Department/
During
Construction

Prior to Issuance
of Certificate of
Occupancy

12-3174
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 32 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
Department of Building and Safety prior to
the issuance of certificat e of occupancy/final
inspection.

Riverside County
Waste
Management
Department
Each individual development proponent
would implement a waste diversion
program in an effort to reduce solid
waste impacts on existing landfill
capacities, similar to the State’s waste
diversion goal of 75 percent as identified
by State law (SB 1016 and AB 939). The
Project would be required to divert up to
75 percent of its operational solid waste
by 2020.

5.15.3-3 All commercial and residential refuse
generated from the Project shall be delivered
to regional transfer stations; any residual
waste that these transfer stations could not
accept shall be disposed of at the Lamb
Canyon Landfill or El Sobrante Landfill or
other locations as determined by the
Riverside Coun ty Waste Management
Department.

Riverside County
Waste
Management
Department
During Operation
Each individual development proponent
would implement a waste diversion
program in an effort to reduce solid
waste impacts on existing landfill
capacities, similar to the State’s waste
diversion goal of 75 percent as identified
by State law (SB 1016 and AB 939). The
Project would be required to divert up to
75 percent of its operational solid waste
by 2020.

5.15.3-4 The Homeowners Association established for
the proposed development shall establish
green waste recycling through its yard
maintenance or waste hauling contracts.

Green waste recycling includes such things as
grass recycling (where lawn clippings from a
mulching-type mower are left on the lawn)
and on- or off-site composting. This measure
shall be implemented to reduce green waste
going to landfills. If such services are not
available through the yard maintenance or
waste haulers in the area, the HOA shall
provide individual homeowners with
information about ways to recycle green
waste individually and collectively.

Homeowners shall be notified of such in the
CC&Rs.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/
City of Rancho
Mirage Planning
Division and/or
Building & Safety
Department
During Operation Each individual development proponent would implement a waste diversion
program in an effort to reduce solid

5.15.3-5 Prior to issuance of building permits for any
multi-unit residential or commercial
facilities, the project proponent shall obtain
As applicable to
the appropriate
Prior to Issuance
of Building Permits

12-3175
Mitigation Monitoring and Enforcement Program
Agua Caliente Band of Cahuilla Indians 33 Section 24 Specific Plan Project MMEP February 2015
Impact Mitigation Measure
Responsible
Agency Timing
Verification
(Date and
Initials)
waste impacts on existing landfill
capacities, similar to the State’s waste
diversion goal of 75 percent as identified
by State law (SB 1016 and AB 939). The
Project would be required to dive rt up to
75 percent of its operational solid waste
by 2020.
clearance from the applicable Waste
Management Department to verify
compliance with local jurisdiction
requirements, including providing adequate
areas for collecting and loading recyclable
materials.
agency:

Tribal Planning
and Development
Department/
City of Rancho
Mirage Planning
Division and/or
Building & Safety
Department
Each individual development proponent
would implement a waste diversion
program in an effort to reduce solid
waste impacts on existing landfill
capacities, similar to the State’s waste
diversion goal of 75 percent as identified
by State law (SB 1016 and AB 939). The
Project would be required to divert up to
75 percent of its operational solid waste
by 2020.

5.15.3-6 Prior to implementing project approval,
individual pr oject proponents shall submit
for review and approval to the appropriate
Planning Department landscape plans that
provide for the use of xeriscape landscaping
and the use of drought tolerant low
maintenance vegetation in all landscaped
areas of the Project.

As applicable to
the appropriate
agency:

Tribal Planning
and Development
Department/
City of Rancho
Mirage Planning
Division and/or
Building & Safety
Department
At Design Review
and Plan Check

12-3176
APPENDIX 2.0
Traffic Report—Highway Capacity Software Calculation Worksheets 12-3177
/uni0053/uni0048/uni004F/uni0052/uni0054/uni0020/uni0052/uni0045/uni0050/uni004F/uni0052/uni0054/uni0020 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni0053/uni0069/uni0074/uni0065/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0074/uni0047/uni0072/uni0065/uni0067/uni0020 /uni0020/uni0041/uni0067/uni0065/uni006E/uni0063/uni0079/uni0020/uni006F/uni0072/uni0020/uni0043/uni006F/uni002E/uni0045/uni006E/uni0064/uni006F/uni0020/uni0045/uni006E/uni0067/uni0069/uni006E/uni0065/uni0065/uni0072/uni0069/uni006E/uni0067/uni0020 /uni0020/uni0044/uni0061/uni0074/uni0065/uni0020/uni0050/uni0065/uni0072/uni0066/uni006F/uni0072/uni006D/uni0065/uni0064/uni0032/uni002F/uni0031/uni0037/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0065/uni0020/uni0050/uni0065/uni0072/uni0069/uni006F/uni0064/uni0041/uni004D/uni0020/uni0050/uni0065/uni0061/uni006B/uni0020/uni0048/uni006F/uni0075/uni0072/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0042/uni006F/uni0062/uni0020/uni0048/uni006F/uni0070/uni0065/uni0020/uni0044/uni0072/uni0069/uni0076/uni0065/uni0020/uni0040/uni0020/uni0049/uni002D/uni0031/uni0030/uni0020/uni0057/uni0042/uni0020 /uni0052/uni0061/uni006D/uni0070/uni0073/uni0020
/uni0020/uni0041/uni0072/uni0065/uni0061/uni0020/uni0054/uni0079/uni0070/uni0065/uni0041/uni006C/uni006C/uni0020/uni006F/uni0074/uni0068/uni0065/uni0072/uni0020/uni0061/uni0072/uni0065/uni0061/uni0073/uni0020 /uni0020/uni004A/uni0075/uni0072/uni0069/uni0073/uni0064/uni0069/uni0063/uni0074/uni0069/uni006F/uni006E/uni0052/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0064/uni0065/uni0020/uni0043/uni006F/uni0075/uni006E/uni0074/uni0079/uni0020 /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0059/uni0065/uni0061/uni0072/uni0059/uni0065/uni0061/uni0072/uni0020/uni0032/uni0030/uni0033/uni0035/uni0020/uni002D/uni0020/uni004E/uni006F/uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0061/uni006E/uni0064/uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0049/uni006E/uni0070/uni0075/uni0074 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004E/uni0075/uni006D/uni0062/uni0065/uni0072/uni0020/uni006F/uni0066/uni0020/uni004C/uni0061/uni006E/uni0065/uni0073/uni0031/uni0020/uni0031/uni0020/uni0031/uni0020/uni0032/uni0020/uni0032/uni0020/uni0033/uni0020/uni0031/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni004C/uni0054/uni0020/uni0052/uni0020/uni004C/uni0020/uni0054/uni0020/uni0054/uni0020/uni0052/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0028/uni0076/uni0070/uni0068/uni0029/uni0036/uni0039/uni0033/uni0020/uni0031/uni0031/uni0020/uni0033/uni0030/uni0031/uni0020/uni0031/uni0033/uni0035/uni0020/uni0037/uni0030/uni0039/uni0020/uni0034/uni0034/uni0030/uni0020/uni0032/uni0031/uni0034/uni0020 /uni0020/uni0025/uni0020/uni0048/uni0065/uni0061/uni0076/uni0079/uni0020/uni0056/uni0065/uni0068/uni0069/uni0063/uni006C/uni0065/uni0073/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020 /uni0020/uni0050/uni0048/uni0046 /uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020 /uni0020/uni0050/uni0072/uni0065/uni0074/uni0069/uni006D/uni0065/uni0064/uni002F/uni0041/uni0063/uni0074/uni0075/uni0061/uni0074/uni0065/uni0064/uni0020/uni0028/uni0050/uni002F/uni0041/uni0029/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020 /uni0020/uni0053/uni0074/uni0061/uni0072/uni0074/uni0075/uni0070/uni0020/uni004C/uni006F/uni0073/uni0074/uni0020/uni0054/uni0069/uni006D/uni0065/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0045/uni0066/uni0066/uni0065/uni0063/uni0074/uni0069/uni0076/uni0065/uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0074/uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0065/uni0064/uni002F/uni0042/uni0069/uni006B/uni0065/uni002F/uni0052/uni0054/uni004F/uni0052/uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0057/uni0069/uni0064/uni0074/uni0068/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0047/uni0072/uni0061/uni0064/uni0065/uni002F/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0048/uni006F/uni0075/uni0072 /uni0020/uni0042/uni0075/uni0073/uni0020/uni0053/uni0074/uni006F/uni0070/uni0073/uni002F/uni0048/uni006F/uni0075/uni0072/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004D/uni0069/uni006E/uni0069/uni006D/uni0075/uni006D/uni0020/uni0050/uni0065/uni0064/uni0065/uni0073/uni0074/uni0072/uni0069/uni0061/uni006E/uni0020/uni0054/uni0069/uni006D/uni0065/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020 /uni0020/uni0050/uni0068/uni0061/uni0073/uni0069/uni006E/uni0067/uni0020/uni0057/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0030/uni0032/uni0020/uni0030/uni0033/uni0020/uni0030/uni0034/uni0020/uni004E/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0054/uni0068/uni0072/uni0075/uni0020/uni0026/uni0020/uni0052/uni0054/uni0020/uni0030/uni0037/uni0020/uni0030/uni0038/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0033/uni0036/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0037/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0033/uni0035/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0044/uni0075/uni0072/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0028/uni0068/uni0072/uni0073/uni0029/uni0020/uni003D/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0043/uni0079/uni0063/uni006C/uni0065/uni0020/uni004C/uni0065/uni006E/uni0067/uni0074/uni0068/uni0020/uni0043/uni0020/uni003D/uni0020/uni0020/uni0020/uni0039/uni0030/uni002E/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002C/uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni002C/uni0020/uni0061/uni006E/uni0064/uni0020/uni004C/uni004F/uni0053/uni0020/uni0044/uni0065/uni0074/uni0065/uni0072/uni006D/uni0069/uni006E/uni0061/uni0074/uni0069/uni006F/uni006E /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni0020/uni0041/uni0064/uni006A/uni0075/uni0073/uni0074/uni0065/uni0064/uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni0033/uni0034/uni0037/uni0020/uni0033/uni0035/uni0037/uni0020/uni0033/uni0030/uni0031/uni0020/uni0031/uni0033/uni0035/uni0020/uni0037/uni0030/uni0039/uni0020/uni0034/uni0034/uni0030/uni0020/uni0032/uni0031/uni0034/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni0036/uni0038/uni0038/uni0020/uni0036/uni0039/uni0030/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0032/uni0036/uni0030/uni0020/uni0031/uni0037/uni0036/uni0031/uni0020/uni0031/uni0039/uni0031/uni0037/uni0020/uni0031/uni0032/uni0038/uni0032/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0035/uni0030/uni0020/uni0030/uni002E/uni0035/uni0032/uni0020/uni0030/uni002E/uni0032/uni0030/uni0020/uni0030/uni002E/uni0035/uni0032/uni0020/uni0030/uni002E/uni0034/uni0030/uni0020/uni0030/uni002E/uni0032/uni0033/uni0020/uni0030/uni002E/uni0031/uni0037/uni0020 /uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0034/uni0030/uni0020/uni0030/uni002E/uni0034/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0030/uni002E/uni0030/uni0038/uni0020/uni0030/uni002E/uni0035/uni0031/uni0020/uni0030/uni002E/uni0033/uni0039/uni0020/uni0030/uni002E/uni0038/uni0033/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0066/uni006F/uni0072/uni006D/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0031 /uni0032/uni0030/uni002E/uni0033/uni0020/uni0032/uni0030/uni002E/uni0034/uni0020/uni0030/uni002E/uni0030/uni0020/uni0033/uni0039/uni002E/uni0039/uni0020/uni0031/uni0033/uni002E/uni0035/uni0020/uni0031/uni0038/uni002E/uni0035/uni0020/uni0031/uni002E/uni0035/uni0020 /uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0020/uni006B/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0032/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0033/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020 /uni0020/uni0049/uni006E/uni0063/uni0072/uni0065/uni006D/uni0065/uni006E/uni0074/uni0061/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0032 /uni0030/uni002E/uni0036/uni0020/uni0030/uni002E/uni0037/uni0020/uni0030/uni002E/uni0031/uni0020/uni0031/uni002E/uni0039/uni0020/uni0030/uni002E/uni0032/uni0020/uni0030/uni002E/uni0031/uni0020/uni0030/uni002E/uni0031/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0030/uni002E/uni0039/uni0035/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0032/uni0030/uni002E/uni0039/uni0020/uni0032/uni0031/uni002E/uni0031/uni0020/uni0030/uni002E/uni0031/uni0020/uni0034/uni0031/uni002E/uni0037/uni0020/uni0031/uni0033/uni002E/uni0037/uni0020/uni0031/uni0038/uni002E/uni0035/uni0020/uni0031/uni002E/uni0035/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni004C/uni004F/uni0053/uni0043/uni0020/uni0043/uni0020/uni0041/uni0020/uni0044/uni0020/uni0042/uni0020/uni0042/uni0020/uni0041/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0031/uni0034/uni002E/uni0037/uni0020/uni0020/uni0031/uni0038/uni002E/uni0032/uni0020/uni0020/uni0031/uni0033/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni004C/uni004F/uni0053/uni0042/uni0020/uni0020/uni0042/uni0020/uni0020/uni0042/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0031/uni0035/uni002E/uni0034/uni0020/uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni004C/uni004F/uni0053/uni0042/uni0020/uni0020 /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0032/uni002F/uni0032/uni0030/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020/uni0020/uni0020/uni0020/uni0034/uni003A/uni0033/uni0038/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0053/uni0068/uni006F/uni0072/uni0074/uni0020/uni0052/uni0065/uni0070/uni006F/uni0072/uni0074 /uni0032/uni002F/uni0032/uni0030/uni002F/uni0032/uni0030/uni0031/uni0034/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0033/uni0041/uni0032/uni0041/uni002E/uni0074/uni006D/uni0070 12-3178
/uni0042/uni0041/uni0043/uni004B/uni002D/uni004F/uni0046/uni002D/uni0051/uni0055/uni0045/uni0055/uni0045/uni0020/uni0057/uni004F/uni0052/uni004B/uni0053/uni0048/uni0045/uni0045/uni0054 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020/uni0044/uni0065/uni0073/uni0063/uni0072/uni0069/uni0070/uni0074/uni0069/uni006F/uni006E/uni0020/uni0020/uni0020/uni0020/uni0053/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0032/uni0034/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni0020/uni004C/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020/uni004C/uni0020/uni0020/uni0054/uni0020/uni0020/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0069/uni0074/uni0069/uni0061/uni006C/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0033/uni0034/uni0037/uni0020/uni0020/uni0033/uni0035/uni0037/uni0020/uni0020/uni0033/uni0030/uni0031/uni0020/uni0020/uni0031/uni0033/uni0035/uni0020/uni0020/uni0037/uni0030/uni0039/uni0020/uni0020/uni0034/uni0034/uni0030/uni0020/uni0020/uni0032/uni0031/uni0034/uni0020/uni0020 /uni0020/uni0053/uni0061/uni0074/uni0066/uni006C/uni006F/uni0077/uni002F/uni004C/uni0061/uni006E/uni0065/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0037/uni0032/uni0036/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020 /uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0036/uni0038/uni0038/uni0020/uni0020/uni0036/uni0039/uni0030/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0032/uni0036/uni0030/uni0020/uni0020/uni0031/uni0037/uni0036/uni0031/uni0020/uni0020/uni0031/uni0039/uni0031/uni0037/uni0020/uni0020/uni0031/uni0032/uni0038/uni0032/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0035/uni0030/uni0020/uni0020/uni0030/uni002E/uni0035/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0030/uni0020/uni0020/uni0030/uni002E/uni0035/uni0032/uni0020/uni0020/uni0030/uni002E/uni0034/uni0030/uni0020/uni0020/uni0030/uni002E/uni0032/uni0033/uni0020/uni0020/uni0030/uni002E/uni0031/uni0037/uni0020/uni0020 /uni0020/uni0049/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020 /uni0020/uni0050/uni006C/uni0061/uni0074/uni006F/uni006F/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0031 /uni0036/uni002E/uni0035/uni0020/uni0020/uni0036/uni002E/uni0038/uni0020/uni0020/uni0031/uni002E/uni0037/uni0020/uni0020/uni0035/uni002E/uni0037/uni0020/uni0020/uni0032/uni002E/uni0037/uni0020/uni0020/uni0031/uni002E/uni0030/uni0020/uni0020 /uni0020/uni006B/uni0042 /uni0030/uni002E/uni0036/uni0020/uni0020/uni0030/uni002E/uni0036/uni0020/uni0020/uni0030/uni002E/uni0039/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0037/uni0020/uni0020/uni0030/uni002E/uni0036/uni0020/uni0020/uni0030/uni002E/uni0038/uni0020/uni0020 /uni0020/uni0051/uni0032 /uni0030/uni002E/uni0036/uni0020/uni0020/uni0030/uni002E/uni0036/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020 /uni0020/uni0051/uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0037/uni002E/uni0031/uni0020/uni0020/uni0037/uni002E/uni0033/uni0020/uni0020/uni0031/uni002E/uni0039/uni0020/uni0020/uni0036/uni002E/uni0032/uni0020/uni0020/uni0032/uni002E/uni0039/uni0020/uni0020/uni0031/uni002E/uni0032/uni0020/uni0020 /uni0020/uni0050/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0028/uni0039/uni0035/uni0074/uni0068/uni0020/uni0070/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0029 /uni0020/uni0066/uni0042/uni0025 /uni0031/uni002E/uni0039/uni0020/uni0020/uni0031/uni002E/uni0039/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0031/uni002E/uni0039/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0031/uni0020/uni0020 /uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0031/uni0033/uni002E/uni0035/uni0020/uni0020/uni0031/uni0033/uni002E/uni0039/uni0020/uni0020/uni0033/uni002E/uni0038/uni0020/uni0020/uni0031/uni0031/uni002E/uni0039/uni0020/uni0020/uni0035/uni002E/uni0038/uni0020/uni0020/uni0032/uni002E/uni0035/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0070/uni0061/uni0063/uni0069/uni006E/uni0067/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020 /uni0052/uni0061/uni0074/uni0069/uni006F
/uni0020/uni0039/uni0035/uni0025/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0020/uni0020/uni0020/uni0020/uni0033/uni003A/uni0032/uni0035/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0042/uni0061/uni0063/uni006B/uni002D/uni006F/uni0066/uni002D/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0057/uni006F/uni0072/uni006B/uni0073/uni0068/uni0065/uni0065/uni0074 /uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0036/uni0046/uni0033/uni0043/uni002E/uni0074/uni006D/uni0070 12-3179
/uni0053/uni0048/uni004F/uni0052/uni0054/uni0020/uni0052/uni0045/uni0050/uni004F/uni0052/uni0054/uni0020 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni0053/uni0069/uni0074/uni0065/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0074/uni0047/uni0072/uni0065/uni0067/uni0020 /uni0020/uni0041/uni0067/uni0065/uni006E/uni0063/uni0079/uni0020/uni006F/uni0072/uni0020/uni0043/uni006F/uni002E/uni0045/uni006E/uni0064/uni006F/uni0020/uni0045/uni006E/uni0067/uni0069/uni006E/uni0065/uni0065/uni0072/uni0069/uni006E/uni0067/uni0020 /uni0020/uni0044/uni0061/uni0074/uni0065/uni0020/uni0050/uni0065/uni0072/uni0066/uni006F/uni0072/uni006D/uni0065/uni0064/uni0032/uni002F/uni0031/uni0037/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0065/uni0020/uni0050/uni0065/uni0072/uni0069/uni006F/uni0064/uni0050/uni004D/uni0020/uni0050/uni0065/uni0061/uni006B/uni0020/uni0048/uni006F/uni0075/uni0072/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0042/uni006F/uni0062/uni0020/uni0048/uni006F/uni0070/uni0065/uni0020/uni0044/uni0072/uni0069/uni0076/uni0065/uni0020/uni0040/uni0020/uni0049/uni002D/uni0031/uni0030/uni0020/uni0057/uni0042/uni0020 /uni0052/uni0061/uni006D/uni0070/uni0073/uni0020
/uni0020/uni0041/uni0072/uni0065/uni0061/uni0020/uni0054/uni0079/uni0070/uni0065/uni0041/uni006C/uni006C/uni0020/uni006F/uni0074/uni0068/uni0065/uni0072/uni0020/uni0061/uni0072/uni0065/uni0061/uni0073/uni0020 /uni0020/uni004A/uni0075/uni0072/uni0069/uni0073/uni0064/uni0069/uni0063/uni0074/uni0069/uni006F/uni006E/uni0052/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0064/uni0065/uni0020/uni0043/uni006F/uni0075/uni006E/uni0074/uni0079/uni0020 /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0059/uni0065/uni0061/uni0072/uni0059/uni0065/uni0061/uni0072/uni0020/uni0032/uni0030/uni0033/uni0035/uni0020/uni002D/uni0020/uni004E/uni006F/uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0061/uni006E/uni0064/uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0049/uni006E/uni0070/uni0075/uni0074 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004E/uni0075/uni006D/uni0062/uni0065/uni0072/uni0020/uni006F/uni0066/uni0020/uni004C/uni0061/uni006E/uni0065/uni0073/uni0031/uni0020/uni0031/uni0020/uni0031/uni0020/uni0032/uni0020/uni0032/uni0020/uni0033/uni0020/uni0031/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni004C/uni0054/uni0020/uni0052/uni0020/uni004C/uni0020/uni0054/uni0020/uni0054/uni0020/uni0052/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0028/uni0076/uni0070/uni0068/uni0029/uni0037/uni0032/uni0037/uni0020/uni0035/uni0020/uni0032/uni0033/uni0032/uni0020/uni0034/uni0039/uni0034/uni0020/uni0035/uni0034/uni0037/uni0020/uni0036/uni0032/uni0031/uni0020/uni0033/uni0035/uni0032/uni0020 /uni0020/uni0025/uni0020/uni0048/uni0065/uni0061/uni0076/uni0079/uni0020/uni0056/uni0065/uni0068/uni0069/uni0063/uni006C/uni0065/uni0073/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020 /uni0020/uni0050/uni0048/uni0046 /uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020 /uni0020/uni0050/uni0072/uni0065/uni0074/uni0069/uni006D/uni0065/uni0064/uni002F/uni0041/uni0063/uni0074/uni0075/uni0061/uni0074/uni0065/uni0064/uni0020/uni0028/uni0050/uni002F/uni0041/uni0029/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020 /uni0020/uni0053/uni0074/uni0061/uni0072/uni0074/uni0075/uni0070/uni0020/uni004C/uni006F/uni0073/uni0074/uni0020/uni0054/uni0069/uni006D/uni0065/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0045/uni0066/uni0066/uni0065/uni0063/uni0074/uni0069/uni0076/uni0065/uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0074/uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0065/uni0064/uni002F/uni0042/uni0069/uni006B/uni0065/uni002F/uni0052/uni0054/uni004F/uni0052/uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0057/uni0069/uni0064/uni0074/uni0068/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0047/uni0072/uni0061/uni0064/uni0065/uni002F/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0048/uni006F/uni0075/uni0072 /uni0020/uni0042/uni0075/uni0073/uni0020/uni0053/uni0074/uni006F/uni0070/uni0073/uni002F/uni0048/uni006F/uni0075/uni0072/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004D/uni0069/uni006E/uni0069/uni006D/uni0075/uni006D/uni0020/uni0050/uni0065/uni0064/uni0065/uni0073/uni0074/uni0072/uni0069/uni0061/uni006E/uni0020/uni0054/uni0069/uni006D/uni0065/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020 /uni0020/uni0050/uni0068/uni0061/uni0073/uni0069/uni006E/uni0067/uni0020/uni0057/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0030/uni0032/uni0020/uni0030/uni0033/uni0020/uni0030/uni0034/uni0020/uni004E/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0054/uni0068/uni0072/uni0075/uni0020/uni0026/uni0020/uni0052/uni0054/uni0020/uni0030/uni0037/uni0020/uni0030/uni0038/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0033/uni0032/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0032/uni0032/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0032/uni0034/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0044/uni0075/uni0072/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0028/uni0068/uni0072/uni0073/uni0029/uni0020/uni003D/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0043/uni0079/uni0063/uni006C/uni0065/uni0020/uni004C/uni0065/uni006E/uni0067/uni0074/uni0068/uni0020/uni0043/uni0020/uni003D/uni0020/uni0020/uni0020/uni0039/uni0030/uni002E/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002C/uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni002C/uni0020/uni0061/uni006E/uni0064/uni0020/uni004C/uni004F/uni0053/uni0020/uni0044/uni0065/uni0074/uni0065/uni0072/uni006D/uni0069/uni006E/uni0061/uni0074/uni0069/uni006F/uni006E /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni0020/uni0041/uni0064/uni006A/uni0075/uni0073/uni0074/uni0065/uni0064/uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni0033/uni0036/uni0034/uni0020/uni0033/uni0036/uni0038/uni0020/uni0032/uni0033/uni0032/uni0020/uni0034/uni0039/uni0034/uni0020/uni0035/uni0034/uni0037/uni0020/uni0036/uni0032/uni0031/uni0020/uni0033/uni0035/uni0032/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni0036/uni0031/uni0031/uni0020/uni0036/uni0031/uni0033/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0038/uni0031/uni0036/uni0020/uni0031/uni0039/uni0031/uni0034/uni0020/uni0031/uni0033/uni0031/uni0034/uni0020/uni0031/uni0030/uni0032/uni0035/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0036/uni0030/uni0020/uni0030/uni002E/uni0036/uni0030/uni0020/uni0030/uni002E/uni0031/uni0035/uni0020/uni0030/uni002E/uni0036/uni0031/uni0020/uni0030/uni002E/uni0032/uni0039/uni0020/uni0030/uni002E/uni0034/uni0037/uni0020/uni0030/uni002E/uni0033/uni0034/uni0020 /uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0033/uni0036/uni0020/uni0030/uni002E/uni0033/uni0036/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0030/uni002E/uni0032/uni0034/uni0020/uni0030/uni002E/uni0035/uni0036/uni0020/uni0030/uni002E/uni0032/uni0037/uni0020/uni0030/uni002E/uni0036/uni0037/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0066/uni006F/uni0072/uni006D/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0031 /uni0032/uni0033/uni002E/uni0037/uni0020/uni0032/uni0033/uni002E/uni0038/uni0020/uni0030/uni002E/uni0030/uni0020/uni0033/uni0030/uni002E/uni0032/uni0020/uni0031/uni0030/uni002E/uni0036/uni0020/uni0032/uni0037/uni002E/uni0037/uni0020/uni0036/uni002E/uni0035/uni0020 /uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0020/uni006B/uni0030/uni002E/uni0031/uni0038/uni0020/uni0030/uni002E/uni0031/uni0039/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0039/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020 /uni0020/uni0049/uni006E/uni0063/uni0072/uni0065/uni006D/uni0065/uni006E/uni0074/uni0061/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0032 /uni0031/uni002E/uni0036/uni0020/uni0031/uni002E/uni0037/uni0020/uni0030/uni002E/uni0030/uni0020/uni0031/uni002E/uni0033/uni0020/uni0030/uni002E/uni0031/uni0020/uni0030/uni002E/uni0033/uni0020/uni0030/uni002E/uni0032/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0030/uni002E/uni0039/uni0035/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0032/uni0035/uni002E/uni0033/uni0020/uni0032/uni0035/uni002E/uni0034/uni0020/uni0030/uni002E/uni0030/uni0020/uni0033/uni0031/uni002E/uni0034/uni0020/uni0031/uni0030/uni002E/uni0036/uni0020/uni0032/uni0038/uni002E/uni0030/uni0020/uni0036/uni002E/uni0037/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni004C/uni004F/uni0053/uni0043/uni0020/uni0043/uni0020/uni0041/uni0020/uni0043/uni0020/uni0042/uni0020/uni0043/uni0020/uni0041/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0031/uni0039/uni002E/uni0033/uni0020/uni0020/uni0032/uni0030/uni002E/uni0035/uni0020/uni0020/uni0032/uni0030/uni002E/uni0033/uni0020/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni004C/uni004F/uni0053/uni0042/uni0020/uni0020/uni0043/uni0020/uni0020/uni0043/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0032/uni0030/uni002E/uni0030/uni0020/uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni004C/uni004F/uni0053/uni0043/uni0020/uni0020 /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0032/uni002F/uni0032/uni0030/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020/uni0020/uni0020/uni0020/uni0034/uni003A/uni0034/uni0030/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0053/uni0068/uni006F/uni0072/uni0074/uni0020/uni0052/uni0065/uni0070/uni006F/uni0072/uni0074 /uni0032/uni002F/uni0032/uni0030/uni002F/uni0032/uni0030/uni0031/uni0034/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0033/uni0044/uni0044/uni0031/uni002E/uni0074/uni006D/uni0070 12-3180
/uni0042/uni0041/uni0043/uni004B/uni002D/uni004F/uni0046/uni002D/uni0051/uni0055/uni0045/uni0055/uni0045/uni0020/uni0057/uni004F/uni0052/uni004B/uni0053/uni0048/uni0045/uni0045/uni0054 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020/uni0044/uni0065/uni0073/uni0063/uni0072/uni0069/uni0070/uni0074/uni0069/uni006F/uni006E/uni0020/uni0020/uni0020/uni0020/uni0053/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0032/uni0034/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni0020/uni004C/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020/uni004C/uni0020/uni0020/uni0054/uni0020/uni0020/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0069/uni0074/uni0069/uni0061/uni006C/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0033/uni0036/uni0034/uni0020/uni0020/uni0033/uni0036/uni0038/uni0020/uni0020/uni0032/uni0033/uni0032/uni0020/uni0020/uni0034/uni0039/uni0034/uni0020/uni0020/uni0035/uni0034/uni0037/uni0020/uni0020/uni0036/uni0032/uni0031/uni0020/uni0020/uni0033/uni0035/uni0032/uni0020/uni0020 /uni0020/uni0053/uni0061/uni0074/uni0066/uni006C/uni006F/uni0077/uni002F/uni004C/uni0061/uni006E/uni0065/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0037/uni0032/uni0034/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020 /uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0036/uni0031/uni0031/uni0020/uni0020/uni0036/uni0031/uni0033/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0038/uni0031/uni0036/uni0020/uni0020/uni0031/uni0039/uni0031/uni0034/uni0020/uni0020/uni0031/uni0033/uni0031/uni0034/uni0020/uni0020/uni0031/uni0030/uni0032/uni0035/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0036/uni0030/uni0020/uni0020/uni0030/uni002E/uni0036/uni0030/uni0020/uni0020/uni0030/uni002E/uni0031/uni0035/uni0020/uni0020/uni0030/uni002E/uni0036/uni0031/uni0020/uni0020/uni0030/uni002E/uni0032/uni0039/uni0020/uni0020/uni0030/uni002E/uni0034/uni0037/uni0020/uni0020/uni0030/uni002E/uni0033/uni0034/uni0020/uni0020 /uni0020/uni0049/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020 /uni0020/uni0050/uni006C/uni0061/uni0074/uni006F/uni006F/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0031 /uni0037/uni002E/uni0034/uni0020/uni0020/uni0037/uni002E/uni0035/uni0020/uni0020/uni0035/uni002E/uni0036/uni0020/uni0020/uni0033/uni002E/uni0038/uni0020/uni0020/uni0034/uni002E/uni0038/uni0020/uni0020/uni0033/uni002E/uni0038/uni0020/uni0020 /uni0020/uni006B/uni0042 /uni0030/uni002E/uni0035/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020/uni0030/uni002E/uni0039/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0037/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0037/uni0020/uni0020 /uni0020/uni0051/uni0032 /uni0030/uni002E/uni0038/uni0020/uni0020/uni0030/uni002E/uni0038/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0036/uni0020/uni0020/uni0030/uni002E/uni0033/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020 /uni0020/uni0051/uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0038/uni002E/uni0032/uni0020/uni0020/uni0038/uni002E/uni0033/uni0020/uni0020/uni0036/uni002E/uni0033/uni0020/uni0020/uni0034/uni002E/uni0031/uni0020/uni0020/uni0035/uni002E/uni0032/uni0020/uni0020/uni0034/uni002E/uni0032/uni0020/uni0020 /uni0020/uni0050/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0028/uni0039/uni0035/uni0074/uni0068/uni0020/uni0070/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0029 /uni0020/uni0066/uni0042/uni0025 /uni0031/uni002E/uni0039/uni0020/uni0020/uni0031/uni002E/uni0039/uni0020/uni0020/uni0031/uni002E/uni0039/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0031/uni0035/uni002E/uni0034/uni0020/uni0020/uni0031/uni0035/uni002E/uni0036/uni0020/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0020/uni0038/uni002E/uni0030/uni0020/uni0020/uni0031/uni0030/uni002E/uni0031/uni0020/uni0020/uni0038/uni002E/uni0032/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0070/uni0061/uni0063/uni0069/uni006E/uni0067/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020 /uni0052/uni0061/uni0074/uni0069/uni006F
/uni0020/uni0039/uni0035/uni0025/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0020/uni0020/uni0020/uni0020/uni0033/uni003A/uni0030/uni0034/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0042/uni0061/uni0063/uni006B/uni002D/uni006F/uni0066/uni002D/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0057/uni006F/uni0072/uni006B/uni0073/uni0068/uni0065/uni0065/uni0074 /uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0034/uni0042/uni0041/uni0031/uni002E/uni0074/uni006D/uni0070 12-3181
/uni0053/uni0048/uni004F/uni0052/uni0054/uni0020/uni0052/uni0045/uni0050/uni004F/uni0052/uni0054/uni0020 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni0053/uni0069/uni0074/uni0065/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0074/uni0047/uni0072/uni0065/uni0067/uni0020 /uni0020/uni0041/uni0067/uni0065/uni006E/uni0063/uni0079/uni0020/uni006F/uni0072/uni0020/uni0043/uni006F/uni002E/uni0045/uni006E/uni0064/uni006F/uni0020/uni0045/uni006E/uni0067/uni0069/uni006E/uni0065/uni0065/uni0072/uni0069/uni006E/uni0067/uni0020 /uni0020/uni0044/uni0061/uni0074/uni0065/uni0020/uni0050/uni0065/uni0072/uni0066/uni006F/uni0072/uni006D/uni0065/uni0064/uni0032/uni002F/uni0031/uni0037/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0065/uni0020/uni0050/uni0065/uni0072/uni0069/uni006F/uni0064/uni0041/uni004D/uni0020/uni0050/uni0065/uni0061/uni006B/uni0020/uni0048/uni006F/uni0075/uni0072/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0042/uni006F/uni0062/uni0020/uni0048/uni006F/uni0070/uni0065/uni0020/uni0044/uni0072/uni0069/uni0076/uni0065/uni0020/uni0040/uni0020/uni0049/uni002D/uni0031/uni0030/uni0020/uni0057/uni0042/uni0020 /uni0052/uni0061/uni006D/uni0070/uni0073/uni0020
/uni0020/uni0041/uni0072/uni0065/uni0061/uni0020/uni0054/uni0079/uni0070/uni0065/uni0041/uni006C/uni006C/uni0020/uni006F/uni0074/uni0068/uni0065/uni0072/uni0020/uni0061/uni0072/uni0065/uni0061/uni0073/uni0020 /uni0020/uni004A/uni0075/uni0072/uni0069/uni0073/uni0064/uni0069/uni0063/uni0074/uni0069/uni006F/uni006E/uni0052/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0064/uni0065/uni0020/uni0043/uni006F/uni0075/uni006E/uni0074/uni0079/uni0020 /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0059/uni0065/uni0061/uni0072/uni0059/uni0065/uni0061/uni0072/uni0020/uni0032/uni0030/uni0033/uni0035/uni0020/uni002D/uni0020/uni0057/uni002F/uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0061/uni006E/uni0064/uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0049/uni006E/uni0070/uni0075/uni0074 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004E/uni0075/uni006D/uni0062/uni0065/uni0072/uni0020/uni006F/uni0066/uni0020/uni004C/uni0061/uni006E/uni0065/uni0073/uni0031/uni0020/uni0031/uni0020/uni0031/uni0020/uni0032/uni0020/uni0032/uni0020/uni0033/uni0020/uni0031/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni004C/uni0054/uni0020/uni0052/uni0020/uni004C/uni0020/uni0054/uni0020/uni0054/uni0020/uni0052/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0028/uni0076/uni0070/uni0068/uni0029/uni0038/uni0031/uni0039/uni0020/uni0031/uni0031/uni0020/uni0033/uni0030/uni0031/uni0020/uni0032/uni0033/uni0038/uni0020/uni0037/uni0032/uni0033/uni0020/uni0034/uni0035/uni0033/uni0020/uni0032/uni0031/uni0034/uni0020 /uni0020/uni0025/uni0020/uni0048/uni0065/uni0061/uni0076/uni0079/uni0020/uni0056/uni0065/uni0068/uni0069/uni0063/uni006C/uni0065/uni0073/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020 /uni0020/uni0050/uni0048/uni0046 /uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020 /uni0020/uni0050/uni0072/uni0065/uni0074/uni0069/uni006D/uni0065/uni0064/uni002F/uni0041/uni0063/uni0074/uni0075/uni0061/uni0074/uni0065/uni0064/uni0020/uni0028/uni0050/uni002F/uni0041/uni0029/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020 /uni0020/uni0053/uni0074/uni0061/uni0072/uni0074/uni0075/uni0070/uni0020/uni004C/uni006F/uni0073/uni0074/uni0020/uni0054/uni0069/uni006D/uni0065/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0045/uni0066/uni0066/uni0065/uni0063/uni0074/uni0069/uni0076/uni0065/uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0074/uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0065/uni0064/uni002F/uni0042/uni0069/uni006B/uni0065/uni002F/uni0052/uni0054/uni004F/uni0052/uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0057/uni0069/uni0064/uni0074/uni0068/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0047/uni0072/uni0061/uni0064/uni0065/uni002F/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0048/uni006F/uni0075/uni0072 /uni0020/uni0042/uni0075/uni0073/uni0020/uni0053/uni0074/uni006F/uni0070/uni0073/uni002F/uni0048/uni006F/uni0075/uni0072/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004D/uni0069/uni006E/uni0069/uni006D/uni0075/uni006D/uni0020/uni0050/uni0065/uni0064/uni0065/uni0073/uni0074/uni0072/uni0069/uni0061/uni006E/uni0020/uni0054/uni0069/uni006D/uni0065/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020 /uni0020/uni0050/uni0068/uni0061/uni0073/uni0069/uni006E/uni0067/uni0020/uni0057/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0030/uni0032/uni0020/uni0030/uni0033/uni0020/uni0030/uni0034/uni0020/uni004E/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0054/uni0068/uni0072/uni0075/uni0020/uni0026/uni0020/uni0052/uni0054/uni0020/uni0030/uni0037/uni0020/uni0030/uni0038/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0033/uni0035/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0031/uni0031/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0033/uni0032/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0044/uni0075/uni0072/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0028/uni0068/uni0072/uni0073/uni0029/uni0020/uni003D/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0043/uni0079/uni0063/uni006C/uni0065/uni0020/uni004C/uni0065/uni006E/uni0067/uni0074/uni0068/uni0020/uni0043/uni0020/uni003D/uni0020/uni0020/uni0020/uni0039/uni0030/uni002E/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002C/uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni002C/uni0020/uni0061/uni006E/uni0064/uni0020/uni004C/uni004F/uni0053/uni0020/uni0044/uni0065/uni0074/uni0065/uni0072/uni006D/uni0069/uni006E/uni0061/uni0074/uni0069/uni006F/uni006E /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni0020/uni0041/uni0064/uni006A/uni0075/uni0073/uni0074/uni0065/uni0064/uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni0034/uni0031/uni0030/uni0020/uni0034/uni0032/uni0030/uni0020/uni0033/uni0030/uni0031/uni0020/uni0032/uni0033/uni0038/uni0020/uni0037/uni0032/uni0033/uni0020/uni0034/uni0035/uni0033/uni0020/uni0032/uni0031/uni0034/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni0036/uni0036/uni0039/uni0020/uni0036/uni0037/uni0031/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0034/uni0030/uni0038/uni0020/uni0031/uni0037/uni0039/uni0039/uni0020/uni0031/uni0037/uni0035/uni0033/uni0020/uni0031/uni0032/uni0031/uni0033/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0036/uni0031/uni0020/uni0030/uni002E/uni0036/uni0033/uni0020/uni0030/uni002E/uni0032/uni0030/uni0020/uni0030/uni002E/uni0035/uni0038/uni0020/uni0030/uni002E/uni0034/uni0030/uni0020/uni0030/uni002E/uni0032/uni0036/uni0020/uni0030/uni002E/uni0031/uni0038/uni0020 /uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0033/uni0039/uni0020/uni0030/uni002E/uni0033/uni0039/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0030/uni002E/uni0031/uni0032/uni0020/uni0030/uni002E/uni0035/uni0032/uni0020/uni0030/uni002E/uni0033/uni0036/uni0020/uni0030/uni002E/uni0037/uni0039/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0066/uni006F/uni0072/uni006D/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0031 /uni0032/uni0032/uni002E/uni0031/uni0020/uni0032/uni0032/uni002E/uni0032/uni0020/uni0030/uni002E/uni0030/uni0020/uni0033/uni0037/uni002E/uni0033/uni0020/uni0031/uni0033/uni002E/uni0030/uni0020/uni0032/uni0030/uni002E/uni0036/uni0020/uni0032/uni002E/uni0033/uni0020 /uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0020/uni006B/uni0030/uni002E/uni0032/uni0030/uni0020/uni0030/uni002E/uni0032/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0037/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020 /uni0020/uni0049/uni006E/uni0063/uni0072/uni0065/uni006D/uni0065/uni006E/uni0074/uni0061/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0032 /uni0031/uni002E/uni0037/uni0020/uni0031/uni002E/uni0039/uni0020/uni0030/uni002E/uni0031/uni0020/uni0032/uni002E/uni0032/uni0020/uni0030/uni002E/uni0031/uni0020/uni0030/uni002E/uni0031/uni0020/uni0030/uni002E/uni0031/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0030/uni002E/uni0039/uni0035/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0032/uni0033/uni002E/uni0037/uni0020/uni0032/uni0034/uni002E/uni0031/uni0020/uni0030/uni002E/uni0031/uni0020/uni0033/uni0039/uni002E/uni0035/uni0020/uni0031/uni0033/uni002E/uni0031/uni0020/uni0032/uni0030/uni002E/uni0037/uni0020/uni0032/uni002E/uni0034/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni004C/uni004F/uni0053/uni0043/uni0020/uni0043/uni0020/uni0041/uni0020/uni0044/uni0020/uni0042/uni0020 /uni0043/uni0020/uni0041/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0031/uni0037/uni002E/uni0036/uni0020/uni0020/uni0031/uni0039/uni002E/uni0037/uni0020/uni0020/uni0031/uni0034/uni002E/uni0038/uni0020/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni004C/uni004F/uni0053/uni0042/uni0020/uni0020/uni0042/uni0020/uni0020/uni0042/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0031/uni0037/uni002E/uni0036/uni0020/uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni004C/uni004F/uni0053/uni0042/uni0020/uni0020 /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0032/uni002F/uni0032/uni0030/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020/uni0020/uni0020/uni0020/uni0034/uni003A/uni0033/uni0032/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0053/uni0068/uni006F/uni0072/uni0074/uni0020/uni0052/uni0065/uni0070/uni006F/uni0072/uni0074 /uni0032/uni002F/uni0032/uni0030/uni002F/uni0032/uni0030/uni0031/uni0034/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0033/uni0042/uni0039/uni0044/uni002E/uni0074/uni006D/uni0070 12-3182
/uni0042/uni0041/uni0043/uni004B/uni002D/uni004F/uni0046/uni002D/uni0051/uni0055/uni0045/uni0055/uni0045/uni0020/uni0057/uni004F/uni0052/uni004B/uni0053/uni0048/uni0045/uni0045/uni0054 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020/uni0044/uni0065/uni0073/uni0063/uni0072/uni0069/uni0070/uni0074/uni0069/uni006F/uni006E/uni0020/uni0020/uni0020/uni0020/uni0053/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0032/uni0034/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni0020/uni004C/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020/uni004C/uni0020/uni0020/uni0054/uni0020/uni0020/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0069/uni0074/uni0069/uni0061/uni006C/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0034/uni0031/uni0030/uni0020/uni0020/uni0034/uni0032/uni0030/uni0020/uni0020/uni0033/uni0030/uni0031/uni0020/uni0020/uni0032/uni0033/uni0038/uni0020/uni0020/uni0037/uni0032/uni0033/uni0020/uni0020/uni0034/uni0035/uni0033/uni0020/uni0020/uni0032/uni0031/uni0034/uni0020/uni0020 /uni0020/uni0053/uni0061/uni0074/uni0066/uni006C/uni006F/uni0077/uni002F/uni004C/uni0061/uni006E/uni0065/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0037/uni0032/uni0035/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020 /uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0036/uni0036/uni0039/uni0020/uni0020/uni0036/uni0037/uni0031/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0034/uni0030/uni0038/uni0020/uni0020/uni0031/uni0037/uni0039/uni0039/uni0020/uni0020/uni0031/uni0037/uni0035/uni0033/uni0020/uni0020/uni0031/uni0032/uni0031/uni0033/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0036/uni0031/uni0020/uni0020/uni0030/uni002E/uni0036/uni0033/uni0020/uni0020/uni0030/uni002E/uni0032/uni0030/uni0020/uni0020/uni0030/uni002E/uni0035/uni0038/uni0020/uni0020/uni0030/uni002E/uni0034/uni0030/uni0020/uni0020/uni0030/uni002E/uni0032/uni0036/uni0020/uni0020/uni0030/uni002E/uni0031/uni0038/uni0020/uni0020 /uni0020/uni0049/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020 /uni0020/uni0050/uni006C/uni0061/uni0074/uni006F/uni006F/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0031 /uni0038/uni002E/uni0032/uni0020/uni0020/uni0038/uni002E/uni0035/uni0020/uni0020/uni0032/uni002E/uni0039/uni0020/uni0020/uni0035/uni002E/uni0037/uni0020/uni0020/uni0032/uni002E/uni0039/uni0020/uni0020/uni0031/uni002E/uni0033/uni0020/uni0020 /uni0020/uni006B/uni0042 /uni0030/uni002E/uni0035/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020/uni0030/uni002E/uni0039/uni0020/uni0020/uni0030/uni002E/uni0033/uni0020/uni0020/uni0030/uni002E/uni0037/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020/uni0030/uni002E/uni0038/uni0020/uni0020 /uni0020/uni0051/uni0032 /uni0030/uni002E/uni0039/uni0020/uni0020/uni0030/uni002E/uni0039/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020 /uni0020/uni0051/uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0039/uni002E/uni0031/uni0020/uni0020/uni0039/uni002E/uni0034/uni0020/uni0020/uni0033/uni002E/uni0033/uni0020/uni0020/uni0036/uni002E/uni0032/uni0020/uni0020/uni0033/uni002E/uni0031/uni0020/uni0020/uni0031/uni002E/uni0035/uni0020/uni0020 /uni0020/uni0050/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0028/uni0039/uni0035/uni0074/uni0068/uni0020/uni0070/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0029 /uni0020/uni0066/uni0042/uni0025 /uni0031/uni002E/uni0039/uni0020/uni0020/uni0031/uni002E/uni0039/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0031/uni002E/uni0039/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0031/uni0020/uni0020 /uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0031/uni0036/uni002E/uni0039/uni0020/uni0020/uni0031/uni0037/uni002E/uni0034/uni0020/uni0020/uni0036/uni002E/uni0035/uni0020/uni0020/uni0031/uni0031/uni002E/uni0039/uni0020/uni0020/uni0036/uni002E/uni0033/uni0020/uni0020/uni0033/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0070/uni0061/uni0063/uni0069/uni006E/uni0067/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020 /uni0052/uni0061/uni0074/uni0069/uni006F
/uni0020/uni0039/uni0035/uni0025/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0020/uni0020/uni0020/uni0020/uni0033/uni003A/uni0032/uni0034/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0042/uni0061/uni0063/uni006B/uni002D/uni006F/uni0066/uni002D/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0057/uni006F/uni0072/uni006B/uni0073/uni0068/uni0065/uni0065/uni0074 /uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0042/uni0044/uni0042/uni0032/uni002E/uni0074/uni006D/uni0070 12-3183
/uni0053/uni0048/uni004F/uni0052/uni0054/uni0020/uni0052/uni0045/uni0050/uni004F/uni0052/uni0054/uni0020 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni0053/uni0069/uni0074/uni0065/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0074/uni0047/uni0072/uni0065/uni0067/uni0020 /uni0020/uni0041/uni0067/uni0065/uni006E/uni0063/uni0079/uni0020/uni006F/uni0072/uni0020/uni0043/uni006F/uni002E/uni0045/uni006E/uni0064/uni006F/uni0020/uni0045/uni006E/uni0067/uni0069/uni006E/uni0065/uni0065/uni0072/uni0069/uni006E/uni0067/uni0020 /uni0020/uni0044/uni0061/uni0074/uni0065/uni0020/uni0050/uni0065/uni0072/uni0066/uni006F/uni0072/uni006D/uni0065/uni0064/uni0032/uni002F/uni0031/uni0037/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0065/uni0020/uni0050/uni0065/uni0072/uni0069/uni006F/uni0064/uni0050/uni004D/uni0020/uni0050/uni0065/uni0061/uni006B/uni0020/uni0048/uni006F/uni0075/uni0072/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0042/uni006F/uni0062/uni0020/uni0048/uni006F/uni0070/uni0065/uni0020/uni0044/uni0072/uni0069/uni0076/uni0065/uni0020/uni0040/uni0020/uni0049/uni002D/uni0031/uni0030/uni0020/uni0057/uni0042/uni0020 /uni0052/uni0061/uni006D/uni0070/uni0073/uni0020
/uni0020/uni0041/uni0072/uni0065/uni0061/uni0020/uni0054/uni0079/uni0070/uni0065/uni0041/uni006C/uni006C/uni0020/uni006F/uni0074/uni0068/uni0065/uni0072/uni0020/uni0061/uni0072/uni0065/uni0061/uni0073/uni0020 /uni0020/uni004A/uni0075/uni0072/uni0069/uni0073/uni0064/uni0069/uni0063/uni0074/uni0069/uni006F/uni006E/uni0052/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0064/uni0065/uni0020/uni0043/uni006F/uni0075/uni006E/uni0074/uni0079/uni0020 /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0059/uni0065/uni0061/uni0072/uni0059/uni0065/uni0061/uni0072/uni0020/uni0032/uni0030/uni0033/uni0035/uni0020/uni002D/uni0020/uni0057/uni002F/uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0061/uni006E/uni0064/uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0049/uni006E/uni0070/uni0075/uni0074 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004E/uni0075/uni006D/uni0062/uni0065/uni0072/uni0020/uni006F/uni0066/uni0020/uni004C/uni0061/uni006E/uni0065/uni0073/uni0031/uni0020/uni0031/uni0020/uni0031/uni0020/uni0032/uni0020/uni0032/uni0020/uni0033/uni0020/uni0031/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni004C/uni0054/uni0020/uni0052/uni0020/uni004C/uni0020/uni0054/uni0020/uni0054/uni0020/uni0052/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0028/uni0076/uni0070/uni0068/uni0029/uni0031/uni0032/uni0038/uni0030/uni0020/uni0035/uni0020/uni0032/uni0033/uni0032/uni0020/uni0039/uni0032/uni0030/uni0020/uni0036/uni0030/uni0034/uni0020/uni0036/uni0037/uni0039/uni0020/uni0033/uni0035/uni0032/uni0020 /uni0020/uni0025/uni0020/uni0048/uni0065/uni0061/uni0076/uni0079/uni0020/uni0056/uni0065/uni0068/uni0069/uni0063/uni006C/uni0065/uni0073/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020 /uni0020/uni0050/uni0048/uni0046 /uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020 /uni0020/uni0050/uni0072/uni0065/uni0074/uni0069/uni006D/uni0065/uni0064/uni002F/uni0041/uni0063/uni0074/uni0075/uni0061/uni0074/uni0065/uni0064/uni0020/uni0028/uni0050/uni002F/uni0041/uni0029/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020 /uni0020/uni0053/uni0074/uni0061/uni0072/uni0074/uni0075/uni0070/uni0020/uni004C/uni006F/uni0073/uni0074/uni0020/uni0054/uni0069/uni006D/uni0065/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0045/uni0066/uni0066/uni0065/uni0063/uni0074/uni0069/uni0076/uni0065/uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0074/uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0065/uni0064/uni002F/uni0042/uni0069/uni006B/uni0065/uni002F/uni0052/uni0054/uni004F/uni0052/uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0057/uni0069/uni0064/uni0074/uni0068/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0047/uni0072/uni0061/uni0064/uni0065/uni002F/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0048/uni006F/uni0075/uni0072 /uni0020/uni0042/uni0075/uni0073/uni0020/uni0053/uni0074/uni006F/uni0070/uni0073/uni002F/uni0048/uni006F/uni0075/uni0072/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004D/uni0069/uni006E/uni0069/uni006D/uni0075/uni006D/uni0020/uni0050/uni0065/uni0064/uni0065/uni0073/uni0074/uni0072/uni0069/uni0061/uni006E/uni0020/uni0054/uni0069/uni006D/uni0065/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020 /uni0020/uni0050/uni0068/uni0061/uni0073/uni0069/uni006E/uni0067/uni0020/uni0057/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0030/uni0032/uni0020/uni0030/uni0033/uni0020/uni0030/uni0034/uni0020/uni004E/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0054/uni0068/uni0072/uni0075/uni0020/uni0026/uni0020/uni0052/uni0054/uni0020/uni0030/uni0037/uni0020/uni0030/uni0038/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0033/uni0037/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0032/uni0037/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0031/uni0034/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0044/uni0075/uni0072/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0028/uni0068/uni0072/uni0073/uni0029/uni0020/uni003D/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0043/uni0079/uni0063/uni006C/uni0065/uni0020/uni004C/uni0065/uni006E/uni0067/uni0074/uni0068/uni0020/uni0043/uni0020/uni003D/uni0020/uni0020/uni0020/uni0039/uni0030/uni002E/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002C/uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni002C/uni0020/uni0061/uni006E/uni0064/uni0020/uni004C/uni004F/uni0053/uni0020/uni0044/uni0065/uni0074/uni0065/uni0072/uni006D/uni0069/uni006E/uni0061/uni0074/uni0069/uni006F/uni006E /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni0020/uni0041/uni0064/uni006A/uni0075/uni0073/uni0074/uni0065/uni0064/uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni0036/uni0034/uni0030/uni0020/uni0036/uni0034/uni0035/uni0020/uni0032/uni0033/uni0032/uni0020/uni0039/uni0032/uni0030/uni0020/uni0036/uni0030/uni0034/uni0020/uni0036/uni0037/uni0039/uni0020/uni0033/uni0035/uni0032/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni0037/uni0030/uni0037/uni0020/uni0037/uni0030/uni0039/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0031/uni0030/uni0030/uni0031/uni0020/uni0031/uni0037/uni0032/uni0033/uni0020/uni0037/uni0036/uni0037/uni0020/uni0039/uni0034/uni0030/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0039/uni0031/uni0020/uni0030/uni002E/uni0039/uni0031/uni0020/uni0030/uni002E/uni0031/uni0035/uni0020/uni0030/uni002E/uni0039/uni0032/uni0020/uni0030/uni002E/uni0033/uni0035/uni0020/uni0030/uni002E/uni0038/uni0039/uni0020/uni0030/uni002E/uni0033/uni0037/uni0020 /uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0034/uni0031/uni0020/uni0030/uni002E/uni0034/uni0031/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0030/uni002E/uni0033/uni0030/uni0020/uni0030/uni002E/uni0035/uni0030/uni0020/uni0030/uni002E/uni0031/uni0036/uni0020/uni0030/uni002E/uni0036/uni0031/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0066/uni006F/uni0072/uni006D/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0031 /uni0032/uni0034/uni002E/uni0039/uni0020/uni0032/uni0034/uni002E/uni0039/uni0020/uni0030/uni002E/uni0030/uni0020/uni0033/uni0030/uni002E/uni0034/uni0020/uni0031/uni0033/uni002E/uni0036/uni0020/uni0033/uni0037/uni002E/uni0032/uni0020/uni0038/uni002E/uni0038/uni0020 /uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0020/uni006B/uni0030/uni002E/uni0034/uni0033/uni0020/uni0030/uni002E/uni0034/uni0033/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0034/uni0034/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0034/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020 /uni0020/uni0049/uni006E/uni0063/uni0072/uni0065/uni006D/uni0065/uni006E/uni0074/uni0061/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0032 /uni0031/uni0038/uni002E/uni0037/uni0020/uni0031/uni0039/uni002E/uni0036/uni0020/uni0030/uni002E/uni0030/uni0020/uni0031/uni0036/uni002E/uni0031/uni0020/uni0030/uni002E/uni0031/uni0020/uni0031/uni0033/uni002E/uni0039/uni0020/uni0030/uni002E/uni0033/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0030/uni002E/uni0039/uni0035/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0034/uni0033/uni002E/uni0035/uni0020/uni0034/uni0034/uni002E/uni0035/uni0020/uni0030/uni002E/uni0030/uni0020/uni0034/uni0036/uni002E/uni0035/uni0020/uni0031/uni0033/uni002E/uni0038/uni0020/uni0035/uni0031/uni002E/uni0031/uni0020/uni0039/uni002E/uni0031/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni004C/uni004F/uni0053/uni0044/uni0020/uni0044/uni0020/uni0041/uni0020/uni0044/uni0020/uni0042/uni0020/uni0044/uni0020/uni0041/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0033/uni0037/uni002E/uni0033/uni0020/uni0020/uni0033/uni0033/uni002E/uni0035/uni0020/uni0020/uni0033/uni0036/uni002E/uni0038/uni0020/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni004C/uni004F/uni0053/uni0044/uni0020/uni0020/uni0043/uni0020/uni0020/uni0044/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0033/uni0035/uni002E/uni0038/uni0020/uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni004C/uni004F/uni0053/uni0044/uni0020/uni0020 /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0032/uni002F/uni0032/uni0035/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020/uni0020/uni0020/uni0020/uni0031/uni0032/uni003A/uni0033/uni0031/uni0020/uni0041/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0053/uni0068/uni006F/uni0072/uni0074/uni0020/uni0052/uni0065/uni0070/uni006F/uni0072/uni0074 /uni0032/uni002F/uni0032/uni0035/uni002F/uni0032/uni0030/uni0031/uni0034/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0035/uni0043/uni0037/uni0036/uni002E/uni0074/uni006D/uni0070 12-3184
/uni0042/uni0041/uni0043/uni004B/uni002D/uni004F/uni0046/uni002D/uni0051/uni0055/uni0045/uni0055/uni0045/uni0020/uni0057/uni004F/uni0052/uni004B/uni0053/uni0048/uni0045/uni0045/uni0054 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020/uni0044/uni0065/uni0073/uni0063/uni0072/uni0069/uni0070/uni0074/uni0069/uni006F/uni006E/uni0020/uni0020/uni0020/uni0020/uni0053/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0032/uni0034/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni0020/uni004C/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020/uni004C/uni0020/uni0020/uni0054/uni0020/uni0020/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0069/uni0074/uni0069/uni0061/uni006C/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0036/uni0034/uni0030/uni0020/uni0020/uni0036/uni0034/uni0035/uni0020/uni0020/uni0032/uni0033/uni0032/uni0020/uni0020/uni0039/uni0032/uni0030/uni0020/uni0020/uni0036/uni0030/uni0034/uni0020/uni0020/uni0036/uni0037/uni0039/uni0020/uni0020/uni0033/uni0035/uni0032/uni0020/uni0020 /uni0020/uni0053/uni0061/uni0074/uni0066/uni006C/uni006F/uni0077/uni002F/uni004C/uni0061/uni006E/uni0065/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0037/uni0032/uni0034/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020 /uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0037/uni0030/uni0037/uni0020/uni0020/uni0037/uni0030/uni0039/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0030/uni0030/uni0031/uni0020/uni0020/uni0031/uni0037/uni0032/uni0033/uni0020/uni0020/uni0037/uni0036/uni0037/uni0020/uni0020/uni0039/uni0034/uni0030/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0033/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0039/uni0031/uni0020/uni0020/uni0030/uni002E/uni0039/uni0031/uni0020/uni0020/uni0030/uni002E/uni0031/uni0035/uni0020/uni0020/uni0030/uni002E/uni0039/uni0032/uni0020/uni0020/uni0030/uni002E/uni0033/uni0035/uni0020/uni0020/uni0030/uni002E/uni0038/uni0039/uni0020/uni0020/uni0030/uni002E/uni0033/uni0037/uni0020/uni0020 /uni0020/uni0049/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020 /uni0020/uni0050/uni006C/uni0061/uni0074/uni006F/uni006F/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0031 /uni0031/uni0035/uni002E/uni0030/uni0020/uni0020/uni0031/uni0035/uni002E/uni0032/uni0020/uni0020/uni0031/uni0031/uni002E/uni0034/uni0020/uni0020/uni0034/uni002E/uni0038/uni0020/uni0020/uni0036/uni002E/uni0031/uni0020/uni0020/uni0034/uni002E/uni0034/uni0020/uni0020 /uni0020/uni006B/uni0042 /uni0030/uni002E/uni0036/uni0020/uni0020/uni0030/uni002E/uni0036/uni0020/uni0020/uni0030/uni002E/uni0039/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020/uni0030/uni002E/uni0036/uni0020/uni0020/uni0030/uni002E/uni0033/uni0020/uni0020/uni0030/uni002E/uni0037/uni0020/uni0020 /uni0020/uni0051/uni0032 /uni0034/uni002E/uni0037/uni0020/uni0020/uni0034/uni002E/uni0039/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0034/uni002E/uni0033/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0032/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020 /uni0020/uni0051/uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0031/uni0039/uni002E/uni0037/uni0020/uni0020/uni0032/uni0030/uni002E/uni0031/uni0020/uni0020/uni0031/uni0035/uni002E/uni0038/uni0020/uni0020/uni0035/uni002E/uni0032/uni0020/uni0020/uni0038/uni002E/uni0033/uni0020/uni0020/uni0034/uni002E/uni0038/uni0020/uni0020 /uni0020/uni0050/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0028/uni0039/uni0035/uni0074/uni0068/uni0020/uni0070/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0029 /uni0020/uni0066/uni0042/uni0025 /uni0031/uni002E/uni0037/uni0020/uni0020/uni0031/uni002E/uni0037/uni0020/uni0020/uni0031/uni002E/uni0038/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0031/uni002E/uni0039/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0033/uni0033/uni002E/uni0035/uni0020/uni0020/uni0033/uni0034/uni002E/uni0031/uni0020/uni0020/uni0032/uni0037/uni002E/uni0036/uni0020/uni0020/uni0031/uni0030/uni002E/uni0031/uni0020/uni0020/uni0031/uni0035/uni002E/uni0036/uni0020/uni0020/uni0039/uni002E/uni0035/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0070/uni0061/uni0063/uni0069/uni006E/uni0067/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020 /uni0052/uni0061/uni0074/uni0069/uni006F
/uni0020/uni0039/uni0035/uni0025/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0020/uni0020/uni0020/uni0020/uni0033/uni003A/uni0030/uni0036/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0042/uni0061/uni0063/uni006B/uni002D/uni006F/uni0066/uni002D/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0057/uni006F/uni0072/uni006B/uni0073/uni0068/uni0065/uni0065/uni0074 /uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0034/uni0039/uni0032/uni0041/uni002E/uni0074/uni006D/uni0070 12-3185
/uni0053/uni0048/uni004F/uni0052/uni0054/uni0020/uni0052/uni0045/uni0050/uni004F/uni0052/uni0054/uni0020 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni0053/uni0069/uni0074/uni0065/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0074/uni0047/uni0072/uni0065/uni0067/uni0020 /uni0020/uni0041/uni0067/uni0065/uni006E/uni0063/uni0079/uni0020/uni006F/uni0072/uni0020/uni0043/uni006F/uni002E/uni0045/uni006E/uni0064/uni006F/uni0020/uni0045/uni006E/uni0067/uni0069/uni006E/uni0065/uni0065/uni0072/uni0069/uni006E/uni0067/uni0020 /uni0020/uni0044/uni0061/uni0074/uni0065/uni0020/uni0050/uni0065/uni0072/uni0066/uni006F/uni0072/uni006D/uni0065/uni0064/uni0032/uni002F/uni0031/uni0037/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0065/uni0020/uni0050/uni0065/uni0072/uni0069/uni006F/uni0064/uni0041/uni004D/uni0020/uni0050/uni0065/uni0061/uni006B/uni0020/uni0048/uni006F/uni0075/uni0072/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0042/uni006F/uni0062/uni0020/uni0048/uni006F/uni0070/uni0065/uni0020/uni0044/uni0072/uni0069/uni0076/uni0065/uni0020/uni0040/uni0020/uni0049/uni002D/uni0031/uni0030/uni0020/uni0045/uni0042/uni0020 /uni0052/uni0061/uni006D/uni0070/uni0073/uni0020
/uni0020/uni0041/uni0072/uni0065/uni0061/uni0020/uni0054/uni0079/uni0070/uni0065/uni0041/uni006C/uni006C/uni0020/uni006F/uni0074/uni0068/uni0065/uni0072/uni0020/uni0061/uni0072/uni0065/uni0061/uni0073/uni0020 /uni0020/uni004A/uni0075/uni0072/uni0069/uni0073/uni0064/uni0069/uni0063/uni0074/uni0069/uni006F/uni006E/uni0052/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0064/uni0065/uni0020/uni0043/uni006F/uni0075/uni006E/uni0074/uni0079/uni0020 /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0059/uni0065/uni0061/uni0072/uni0059/uni0065/uni0061/uni0072/uni0020/uni0032/uni0030/uni0033/uni0035/uni0020/uni002D/uni0020/uni004E/uni006F/uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0061/uni006E/uni0064/uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0049/uni006E/uni0070/uni0075/uni0074 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004E/uni0075/uni006D/uni0062/uni0065/uni0072/uni0020/uni006F/uni0066/uni0020/uni004C/uni0061/uni006E/uni0065/uni0073/uni0031/uni0020/uni0031/uni0020/uni0031/uni0020 /uni0033/uni0020/uni0031/uni0020/uni0032/uni0020/uni0032/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni004C/uni0054/uni0020/uni0052/uni0020 /uni0054/uni0020/uni0052/uni0020/uni004C/uni0020/uni0054/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0028/uni0076/uni0070/uni0068/uni0029/uni0033/uni0033/uni0036/uni0020/uni0038/uni0020/uni0036/uni0030/uni0035/uni0020/uni0033/uni0032/uni0030/uni0020/uni0033/uni0034/uni0020/uni0031/uni0034/uni0031/uni0020/uni0039/uni0035/uni0032/uni0020 /uni0020/uni0025/uni0020/uni0048/uni0065/uni0061/uni0076/uni0079/uni0020/uni0056/uni0065/uni0068/uni0069/uni0063/uni006C/uni0065/uni0073/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020 /uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020 /uni0020/uni0050/uni0048/uni0046/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020 /uni0020/uni0050/uni0072/uni0065/uni0074/uni0069/uni006D/uni0065/uni0064/uni002F/uni0041/uni0063/uni0074/uni0075/uni0061/uni0074/uni0065/uni0064/uni0020/uni0028/uni0050/uni002F/uni0041/uni0029/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020 /uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020 /uni0020/uni0053/uni0074/uni0061/uni0072/uni0074/uni0075/uni0070/uni0020/uni004C/uni006F/uni0073/uni0074/uni0020/uni0054/uni0069/uni006D/uni0065/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0045/uni0066/uni0066/uni0065/uni0063/uni0074/uni0069/uni0076/uni0065/uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020 /uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0074/uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0065/uni0064/uni002F/uni0042/uni0069/uni006B/uni0065/uni002F/uni0052/uni0054/uni004F/uni0052/uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0057/uni0069/uni0064/uni0074/uni0068/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0047/uni0072/uni0061/uni0064/uni0065/uni002F/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0048/uni006F/uni0075/uni0072 /uni0020/uni0042/uni0075/uni0073/uni0020/uni0053/uni0074/uni006F/uni0070/uni0073/uni002F/uni0048/uni006F/uni0075/uni0072/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004D/uni0069/uni006E/uni0069/uni006D/uni0075/uni006D/uni0020/uni0050/uni0065/uni0064/uni0065/uni0073/uni0074/uni0072/uni0069/uni0061/uni006E/uni0020/uni0054/uni0069/uni006D/uni0065/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020 /uni0020/uni0050/uni0068/uni0061/uni0073/uni0069/uni006E/uni0067/uni0020/uni0045/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0030/uni0032/uni0020/uni0030/uni0033/uni0020/uni0030/uni0034/uni0020/uni0053/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0054/uni0068/uni0072/uni0075/uni0020/uni0026/uni0020/uni0052/uni0054/uni0020/uni0030/uni0037/uni0020/uni0030/uni0038/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0031/uni0037/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0032/uni0036/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0033/uni0035/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0044/uni0075/uni0072/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0028/uni0068/uni0072/uni0073/uni0029/uni0020/uni003D/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0043/uni0079/uni0063/uni006C/uni0065/uni0020/uni004C/uni0065/uni006E/uni0067/uni0074/uni0068/uni0020/uni0043/uni0020/uni003D/uni0020/uni0020/uni0020/uni0039/uni0030/uni002E/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002C/uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni002C/uni0020/uni0061/uni006E/uni0064/uni0020/uni004C/uni004F/uni0053/uni0020/uni0044/uni0065/uni0074/uni0065/uni0072/uni006D/uni0069/uni006E/uni0061/uni0074/uni0069/uni006F/uni006E /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni0020/uni0041/uni0064/uni006A/uni0075/uni0073/uni0074/uni0065/uni0064/uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni0031/uni0036/uni0038/uni0020/uni0031/uni0037/uni0036/uni0020/uni0036/uni0030/uni0035/uni0020/uni0033/uni0032/uni0030/uni0020/uni0033/uni0034/uni0020/uni0031/uni0034/uni0031/uni0020/uni0039/uni0035/uni0032/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni0033/uni0032/uni0035/uni0020/uni0033/uni0032/uni0036/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0031/uni0039/uni0031/uni0037/uni0020/uni0039/uni0035/uni0037/uni0020/uni0039/uni0036/uni0034/uni0020/uni0032/uni0034/uni0038/uni0038/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0035/uni0032/uni0020/uni0030/uni002E/uni0035/uni0034/uni0020/uni0030/uni002E/uni0033/uni0039/uni0020/uni0030/uni002E/uni0031/uni0037/uni0020/uni0030/uni002E/uni0030/uni0034/uni0020/uni0030/uni002E/uni0031/uni0035/uni0020/uni0030/uni002E/uni0033/uni0038/uni0020 /uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0031/uni0039/uni0020/uni0030/uni002E/uni0031/uni0039/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0030/uni002E/uni0033/uni0039/uni0020/uni0030/uni002E/uni0036/uni0032/uni0020/uni0030/uni002E/uni0032/uni0039/uni0020/uni0030/uni002E/uni0037/uni0032/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0066/uni006F/uni0072/uni006D/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0031 /uni0033/uni0032/uni002E/uni0038/uni0020/uni0033/uni0033/uni002E/uni0030/uni0020/uni0030/uni002E/uni0030/uni0020/uni0031/uni0038/uni002E/uni0030/uni0020/uni0036/uni002E/uni0036/uni0020/uni0032/uni0033/uni002E/uni0038/uni0020/uni0034/uni002E/uni0038/uni0020 /uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0020/uni006B/uni0030/uni002E/uni0031/uni0032/uni0020/uni0030/uni002E/uni0031/uni0034/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020 /uni0020/uni0049/uni006E/uni0063/uni0072/uni0065/uni006D/uni0065/uni006E/uni0074/uni0061/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0032 /uni0031/uni002E/uni0035/uni0020/uni0031/uni002E/uni0038/uni0020/uni0030/uni002E/uni0032/uni0020/uni0030/uni002E/uni0030/uni0020/uni0030/uni002E/uni0030/uni0020/uni0030/uni002E/uni0031/uni0020/uni0030/uni002E/uni0031/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0030/uni002E/uni0039/uni0035/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0033/uni0034/uni002E/uni0033/uni0020/uni0033/uni0034/uni002E/uni0038/uni0020/uni0030/uni002E/uni0032/uni0020/uni0031/uni0038/uni002E/uni0030/uni0020/uni0036/uni002E/uni0036/uni0020/uni0032/uni0033/uni002E/uni0038/uni0020/uni0034/uni002E/uni0039/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni004C/uni004F/uni0053/uni0043/uni0020/uni0043/uni0020/uni0041/uni0020 /uni0042/uni0020/uni0041/uni0020/uni0043/uni0020/uni0041/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0031/uni0032/uni002E/uni0036/uni0020/uni0020/uni0031/uni0036/uni002E/uni0039/uni0020/uni0020/uni0037/uni002E/uni0033/uni0020/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni004C/uni004F/uni0053/uni0042/uni0020/uni0020 /uni0042/uni0020/uni0020/uni0041/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0031/uni0030/uni002E/uni0038/uni0020/uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni004C/uni004F/uni0053/uni0042/uni0020/uni0020 /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0032/uni002F/uni0032/uni0030/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020/uni0020/uni0020/uni0020/uni0034/uni003A/uni0034/uni0036/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0053/uni0068/uni006F/uni0072/uni0074/uni0020/uni0052/uni0065/uni0070/uni006F/uni0072/uni0074 /uni0032/uni002F/uni0032/uni0030/uni002F/uni0032/uni0030/uni0031/uni0034/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0042/uni0031/uni0046/uni0038/uni002E/uni0074/uni006D/uni0070 12-3186
/uni0042/uni0041/uni0043/uni004B/uni002D/uni004F/uni0046/uni002D/uni0051/uni0055/uni0045/uni0055/uni0045/uni0020/uni0057/uni004F/uni0052/uni004B/uni0053/uni0048/uni0045/uni0045/uni0054 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020/uni0044/uni0065/uni0073/uni0063/uni0072/uni0069/uni0070/uni0074/uni0069/uni006F/uni006E/uni0020/uni0020/uni0020/uni0020/uni0053/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0032/uni0034/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni0020/uni004C/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020/uni004C/uni0020/uni0020/uni0054/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0069/uni0074/uni0069/uni0061/uni006C/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0031/uni0036/uni0038/uni0020/uni0020/uni0031/uni0037/uni0036/uni0020/uni0020/uni0036/uni0030/uni0035/uni0020/uni0020/uni0033/uni0032/uni0030/uni0020/uni0020/uni0033/uni0034/uni0020/uni0020/uni0031/uni0034/uni0031/uni0020/uni0020/uni0039/uni0035/uni0032/uni0020/uni0020 /uni0020/uni0053/uni0061/uni0074/uni0066/uni006C/uni006F/uni0077/uni002F/uni004C/uni0061/uni006E/uni0065/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0037/uni0032/uni0037/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020 /uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0033/uni0032/uni0035/uni0020/uni0020/uni0033/uni0032/uni0036/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0039/uni0031/uni0037/uni0020/uni0020/uni0039/uni0035/uni0037/uni0020/uni0020/uni0039/uni0036/uni0034/uni0020/uni0020/uni0032/uni0034/uni0038/uni0038/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0020/uni0030/uni002E/uni0033/uni0020/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0035/uni0032/uni0020/uni0020/uni0030/uni002E/uni0035/uni0034/uni0020/uni0020/uni0030/uni002E/uni0033/uni0039/uni0020/uni0020/uni0030/uni002E/uni0031/uni0037/uni0020/uni0020/uni0030/uni002E/uni0030/uni0034/uni0020/uni0020/uni0030/uni002E/uni0031/uni0035/uni0020/uni0020/uni0030/uni002E/uni0033/uni0038/uni0020/uni0020 /uni0020/uni0049/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020 /uni0020/uni0050/uni006C/uni0061/uni0074/uni006F/uni006F/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0031 /uni0033/uni002E/uni0038/uni0020/uni0020/uni0034/uni002E/uni0030/uni0020/uni0020/uni0031/uni002E/uni0039/uni0020/uni0020/uni0030/uni002E/uni0033/uni0020/uni0020/uni0031/uni002E/uni0033/uni0020/uni0020/uni0034/uni002E/uni0038/uni0020/uni0020 /uni0020/uni006B/uni0042 /uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0039/uni0020/uni0020/uni0030/uni002E/uni0036/uni0020/uni0020/uni0030/uni002E/uni0037/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020/uni0030/uni002E/uni0038/uni0020/uni0020 /uni0020/uni0051/uni0032 /uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0036/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020 /uni0020/uni0051/uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0034/uni002E/uni0031/uni0020/uni0020/uni0034/uni002E/uni0034/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0031/uni002E/uni0034/uni0020/uni0020/uni0035/uni002E/uni0033/uni0020/uni0020 /uni0020/uni0050/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0028/uni0039/uni0035/uni0074/uni0068/uni0020/uni0070/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0029 /uni0020/uni0066/uni0042/uni0025 /uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0031/uni0020/uni0020/uni0032/uni002E/uni0031/uni0020/uni0020/uni0031/uni002E/uni0039/uni0020/uni0020 /uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0038/uni002E/uni0032/uni0020/uni0020/uni0038/uni002E/uni0036/uni0020/uni0020/uni0034/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0037/uni0020/uni0020/uni0032/uni002E/uni0039/uni0020/uni0020/uni0031/uni0030/uni002E/uni0033/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0070/uni0061/uni0063/uni0069/uni006E/uni0067/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020 /uni0052/uni0061/uni0074/uni0069/uni006F
/uni0020/uni0039/uni0035/uni0025/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0020/uni0020/uni0020/uni0020/uni0033/uni003A/uni0032/uni0037/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0042/uni0061/uni0063/uni006B/uni002D/uni006F/uni0066/uni002D/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0057/uni006F/uni0072/uni006B/uni0073/uni0068/uni0065/uni0065/uni0074 /uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0033/uni0037/uni0038/uni0043/uni002E/uni0074/uni006D/uni0070 12-3187
/uni0053/uni0048/uni004F/uni0052/uni0054/uni0020/uni0052/uni0045/uni0050/uni004F/uni0052/uni0054/uni0020 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni0053/uni0069/uni0074/uni0065/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0074/uni0047/uni0072/uni0065/uni0067/uni0020 /uni0020/uni0041/uni0067/uni0065/uni006E/uni0063/uni0079/uni0020/uni006F/uni0072/uni0020/uni0043/uni006F/uni002E/uni0045/uni006E/uni0064/uni006F/uni0020/uni0045/uni006E/uni0067/uni0069/uni006E/uni0065/uni0065/uni0072/uni0069/uni006E/uni0067/uni0020 /uni0020/uni0044/uni0061/uni0074/uni0065/uni0020/uni0050/uni0065/uni0072/uni0066/uni006F/uni0072/uni006D/uni0065/uni0064/uni0032/uni002F/uni0031/uni0037/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0065/uni0020/uni0050/uni0065/uni0072/uni0069/uni006F/uni0064/uni0050/uni004D/uni0020/uni0050/uni0065/uni0061/uni006B/uni0020/uni0048/uni006F/uni0075/uni0072/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0042/uni006F/uni0062/uni0020/uni0048/uni006F/uni0070/uni0065/uni0020/uni0044/uni0072/uni0069/uni0076/uni0065/uni0020/uni0040/uni0020/uni0049/uni002D/uni0031/uni0030/uni0020/uni0045/uni0042/uni0020 /uni0052/uni0061/uni006D/uni0070/uni0073/uni0020
/uni0020/uni0041/uni0072/uni0065/uni0061/uni0020/uni0054/uni0079/uni0070/uni0065/uni0041/uni006C/uni006C/uni0020/uni006F/uni0074/uni0068/uni0065/uni0072/uni0020/uni0061/uni0072/uni0065/uni0061/uni0073/uni0020 /uni0020/uni004A/uni0075/uni0072/uni0069/uni0073/uni0064/uni0069/uni0063/uni0074/uni0069/uni006F/uni006E/uni0052/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0064/uni0065/uni0020/uni0043/uni006F/uni0075/uni006E/uni0074/uni0079/uni0020 /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0059/uni0065/uni0061/uni0072/uni0059/uni0065/uni0061/uni0072/uni0020/uni0032/uni0030/uni0033/uni0035/uni0020/uni002D/uni0020/uni004E/uni006F/uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0061/uni006E/uni0064/uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0049/uni006E/uni0070/uni0075/uni0074 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004E/uni0075/uni006D/uni0062/uni0065/uni0072/uni0020/uni006F/uni0066/uni0020/uni004C/uni0061/uni006E/uni0065/uni0073/uni0031/uni0020/uni0031/uni0020/uni0031/uni0020 /uni0033/uni0020/uni0031/uni0020/uni0032/uni0020/uni0032/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni004C/uni0054/uni0020/uni0052/uni0020 /uni0054/uni0020/uni0052/uni0020/uni004C/uni0020/uni0054/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0028/uni0076/uni0070/uni0068/uni0029/uni0031/uni0035/uni0038/uni0020/uni0036/uni0020/uni0032/uni0039/uni0031/uni0020/uni0037/uni0033/uni0038/uni0020/uni0035/uni0039/uni0020/uni0032/uni0030/uni0032/uni0020/uni0031/uni0030/uni0030/uni0033/uni0020 /uni0020/uni0025/uni0020/uni0048/uni0065/uni0061/uni0076/uni0079/uni0020/uni0056/uni0065/uni0068/uni0069/uni0063/uni006C/uni0065/uni0073/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020 /uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020 /uni0020/uni0050/uni0048/uni0046/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020 /uni0020/uni0050/uni0072/uni0065/uni0074/uni0069/uni006D/uni0065/uni0064/uni002F/uni0041/uni0063/uni0074/uni0075/uni0061/uni0074/uni0065/uni0064/uni0020/uni0028/uni0050/uni002F/uni0041/uni0029/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020 /uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020 /uni0020/uni0053/uni0074/uni0061/uni0072/uni0074/uni0075/uni0070/uni0020/uni004C/uni006F/uni0073/uni0074/uni0020/uni0054/uni0069/uni006D/uni0065/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0045/uni0066/uni0066/uni0065/uni0063/uni0074/uni0069/uni0076/uni0065/uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020 /uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0074/uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0065/uni0064/uni002F/uni0042/uni0069/uni006B/uni0065/uni002F/uni0052/uni0054/uni004F/uni0052/uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0057/uni0069/uni0064/uni0074/uni0068/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0047/uni0072/uni0061/uni0064/uni0065/uni002F/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0048/uni006F/uni0075/uni0072 /uni0020/uni0042/uni0075/uni0073/uni0020/uni0053/uni0074/uni006F/uni0070/uni0073/uni002F/uni0048/uni006F/uni0075/uni0072/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004D/uni0069/uni006E/uni0069/uni006D/uni0075/uni006D/uni0020/uni0050/uni0065/uni0064/uni0065/uni0073/uni0074/uni0072/uni0069/uni0061/uni006E/uni0020/uni0054/uni0069/uni006D/uni0065/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020 /uni0020/uni0050/uni0068/uni0061/uni0073/uni0069/uni006E/uni0067/uni0020/uni0045/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0030/uni0032/uni0020/uni0030/uni0033/uni0020/uni0030/uni0034/uni0020/uni0053/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0054/uni0068/uni0072/uni0075/uni0020/uni0026/uni0020/uni0052/uni0054/uni0020/uni0030/uni0037/uni0020/uni0030/uni0038/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0039/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0031/uni0033/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0035/uni0036/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0044/uni0075/uni0072/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0028/uni0068/uni0072/uni0073/uni0029/uni0020/uni003D/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0043/uni0079/uni0063/uni006C/uni0065/uni0020/uni004C/uni0065/uni006E/uni0067/uni0074/uni0068/uni0020/uni0043/uni0020/uni003D/uni0020/uni0020/uni0020/uni0039/uni0030/uni002E/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002C/uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni002C/uni0020/uni0061/uni006E/uni0064/uni0020/uni004C/uni004F/uni0053/uni0020/uni0044/uni0065/uni0074/uni0065/uni0072/uni006D/uni0069/uni006E/uni0061/uni0074/uni0069/uni006F/uni006E /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni0020/uni0041/uni0064/uni006A/uni0075/uni0073/uni0074/uni0065/uni0064/uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni0037/uni0039/uni0020/uni0038/uni0035/uni0020/uni0032/uni0039/uni0031/uni0020/uni0037/uni0033/uni0038/uni0020/uni0035/uni0039/uni0020/uni0032/uni0030/uni0032/uni0020/uni0031/uni0030/uni0030/uni0033/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni0031/uni0037/uni0032/uni0020/uni0031/uni0037/uni0033/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0033/uni0030/uni0036/uni0037/uni0020/uni0031/uni0031/uni0037/uni0039/uni0020/uni0034/uni0038/uni0032/uni0020/uni0032/uni0037/uni0039/uni0034/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0034/uni0036/uni0020/uni0030/uni002E/uni0034/uni0039/uni0020/uni0030/uni002E/uni0031/uni0039/uni0020/uni0030/uni002E/uni0032/uni0034/uni0020/uni0030/uni002E/uni0030/uni0035/uni0020/uni0030/uni002E/uni0034/uni0032/uni0020/uni0030/uni002E/uni0033/uni0036/uni0020 /uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0031/uni0030/uni0020/uni0030/uni002E/uni0031/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0030/uni002E/uni0036/uni0032/uni0020/uni0030/uni002E/uni0037/uni0037/uni0020/uni0030/uni002E/uni0031/uni0034/uni0020/uni0030/uni002E/uni0038/uni0031/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0066/uni006F/uni0072/uni006D/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0031 /uni0033/uni0038/uni002E/uni0032/uni0020/uni0033/uni0038/uni002E/uni0033/uni0020/uni0030/uni002E/uni0030/uni0020/uni0037/uni002E/uni0036/uni0020/uni0032/uni002E/uni0035/uni0020/uni0033/uni0035/uni002E/uni0031/uni0020/uni0032/uni002E/uni0033/uni0020 /uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0020/uni006B/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020 /uni0020/uni0049/uni006E/uni0063/uni0072/uni0065/uni006D/uni0065/uni006E/uni0074/uni0061/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0032 /uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0032/uni0020/uni0030/uni002E/uni0031/uni0020/uni0030/uni002E/uni0030/uni0020/uni0030/uni002E/uni0030/uni0020/uni0030/uni002E/uni0036/uni0020/uni0030/uni002E/uni0031/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0030/uni002E/uni0039/uni0035/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0034/uni0030/uni002E/uni0032/uni0020/uni0034/uni0030/uni002E/uni0035/uni0020/uni0030/uni002E/uni0031/uni0020/uni0037/uni002E/uni0036/uni0020/uni0032/uni002E/uni0036/uni0020/uni0033/uni0035/uni002E/uni0037/uni0020/uni0032/uni002E/uni0033/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni004C/uni004F/uni0053/uni0044/uni0020/uni0044/uni0020/uni0041/uni0020 /uni0041/uni0020/uni0041/uni0020/uni0044/uni0020/uni0041/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0031/uni0034/uni002E/uni0036/uni0020/uni0020/uni0037/uni002E/uni0032/uni0020/uni0020/uni0037/uni002E/uni0039/uni0020/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni004C/uni004F/uni0053/uni0042/uni0020/uni0020 /uni0041/uni0020/uni0020/uni0041/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0038/uni002E/uni0039/uni0020/uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni004C/uni004F/uni0053/uni0041/uni0020/uni0020 /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0032/uni002F/uni0032/uni0030/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020/uni0020/uni0020/uni0020/uni0034/uni003A/uni0034/uni0038/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0053/uni0068/uni006F/uni0072/uni0074/uni0020/uni0052/uni0065/uni0070/uni006F/uni0072/uni0074 /uni0032/uni002F/uni0032/uni0030/uni002F/uni0032/uni0030/uni0031/uni0034/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0032/uni0036/uni0037/uni0039/uni002E/uni0074/uni006D/uni0070 12-3188
/uni0042/uni0041/uni0043/uni004B/uni002D/uni004F/uni0046/uni002D/uni0051/uni0055/uni0045/uni0055/uni0045/uni0020/uni0057/uni004F/uni0052/uni004B/uni0053/uni0048/uni0045/uni0045/uni0054 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020/uni0044/uni0065/uni0073/uni0063/uni0072/uni0069/uni0070/uni0074/uni0069/uni006F/uni006E/uni0020/uni0020/uni0020/uni0020/uni0053/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0032/uni0034/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni0020/uni004C/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020/uni004C/uni0020/uni0020/uni0054/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0069/uni0074/uni0069/uni0061/uni006C/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0037/uni0039/uni0020/uni0020/uni0038/uni0035/uni0020/uni0020/uni0032/uni0039/uni0031/uni0020/uni0020/uni0037/uni0033/uni0038/uni0020/uni0020/uni0035/uni0039/uni0020/uni0020/uni0032/uni0030/uni0032/uni0020/uni0020/uni0031/uni0030/uni0030/uni0033/uni0020/uni0020 /uni0020/uni0053/uni0061/uni0074/uni0066/uni006C/uni006F/uni0077/uni002F/uni004C/uni0061/uni006E/uni0065/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0037/uni0032/uni0039/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020 /uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0031/uni0037/uni0032/uni0020/uni0020/uni0031/uni0037/uni0033/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0033/uni0030/uni0036/uni0037/uni0020/uni0020/uni0031/uni0031/uni0037/uni0039/uni0020/uni0020/uni0034/uni0038/uni0032/uni0020/uni0020/uni0032/uni0037/uni0039/uni0034/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0020/uni0030/uni002E/uni0033/uni0020/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0034/uni0036/uni0020/uni0020/uni0030/uni002E/uni0034/uni0039/uni0020/uni0020/uni0030/uni002E/uni0031/uni0039/uni0020/uni0020/uni0030/uni002E/uni0032/uni0034/uni0020/uni0020/uni0030/uni002E/uni0030/uni0035/uni0020/uni0020/uni0030/uni002E/uni0034/uni0032/uni0020/uni0020/uni0030/uni002E/uni0033/uni0036/uni0020/uni0020 /uni0020/uni0049/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020 /uni0020/uni0050/uni006C/uni0061/uni0074/uni006F/uni006F/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0031 /uni0031/uni002E/uni0039/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0033/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0032/uni002E/uni0034/uni0020/uni0020/uni0033/uni002E/uni0035/uni0020/uni0020 /uni0020/uni006B/uni0042 /uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0039/uni0020/uni0020/uni0030/uni002E/uni0037/uni0020/uni0020/uni0030/uni002E/uni0038/uni0020/uni0020/uni0030/uni002E/uni0033/uni0020/uni0020/uni0030/uni002E/uni0039/uni0020/uni0020 /uni0020/uni0051/uni0032 /uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020 /uni0020/uni0051/uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0032/uni002E/uni0031/uni0020/uni0020/uni0032/uni002E/uni0032/uni0020/uni0020/uni0033/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0032/uni002E/uni0036/uni0020/uni0020/uni0034/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0050/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0028/uni0039/uni0035/uni0074/uni0068/uni0020/uni0070/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0029 /uni0020/uni0066/uni0042/uni0025 /uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0031/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0034/uni002E/uni0032/uni0020/uni0020/uni0034/uni002E/uni0036/uni0020/uni0020/uni0036/uni002E/uni0035/uni0020/uni0020/uni0030/uni002E/uni0038/uni0020/uni0020/uni0035/uni002E/uni0032/uni0020/uni0020/uni0037/uni002E/uni0039/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0070/uni0061/uni0063/uni0069/uni006E/uni0067/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020 /uni0052/uni0061/uni0074/uni0069/uni006F
/uni0020/uni0039/uni0035/uni0025/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0020/uni0020/uni0020/uni0020/uni0033/uni003A/uni0032/uni0038/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0042/uni0061/uni0063/uni006B/uni002D/uni006F/uni0066/uni002D/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0057/uni006F/uni0072/uni006B/uni0073/uni0068/uni0065/uni0065/uni0074 /uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0041/uni0035/uni0036/uni0042/uni002E/uni0074/uni006D/uni0070 12-3189
/uni0053/uni0048/uni004F/uni0052/uni0054/uni0020/uni0052/uni0045/uni0050/uni004F/uni0052/uni0054/uni0020 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni0053/uni0069/uni0074/uni0065/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0074/uni0047/uni0072/uni0065/uni0067/uni0020 /uni0020/uni0041/uni0067/uni0065/uni006E/uni0063/uni0079/uni0020/uni006F/uni0072/uni0020/uni0043/uni006F/uni002E/uni0045/uni006E/uni0064/uni006F/uni0020/uni0045/uni006E/uni0067/uni0069/uni006E/uni0065/uni0065/uni0072/uni0069/uni006E/uni0067/uni0020 /uni0020/uni0044/uni0061/uni0074/uni0065/uni0020/uni0050/uni0065/uni0072/uni0066/uni006F/uni0072/uni006D/uni0065/uni0064/uni0032/uni002F/uni0031/uni0037/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0065/uni0020/uni0050/uni0065/uni0072/uni0069/uni006F/uni0064/uni0041/uni004D/uni0020/uni0050/uni0065/uni0061/uni006B/uni0020/uni0048/uni006F/uni0075/uni0072/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0042/uni006F/uni0062/uni0020/uni0048/uni006F/uni0070/uni0065/uni0020/uni0044/uni0072/uni0069/uni0076/uni0065/uni0020/uni0040/uni0020/uni0049/uni002D/uni0031/uni0030/uni0020/uni0045/uni0042/uni0020 /uni0052/uni0061/uni006D/uni0070/uni0073/uni0020
/uni0020/uni0041/uni0072/uni0065/uni0061/uni0020/uni0054/uni0079/uni0070/uni0065/uni0041/uni006C/uni006C/uni0020/uni006F/uni0074/uni0068/uni0065/uni0072/uni0020/uni0061/uni0072/uni0065/uni0061/uni0073/uni0020 /uni0020/uni004A/uni0075/uni0072/uni0069/uni0073/uni0064/uni0069/uni0063/uni0074/uni0069/uni006F/uni006E/uni0052/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0064/uni0065/uni0020/uni0043/uni006F/uni0075/uni006E/uni0074/uni0079/uni0020 /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0059/uni0065/uni0061/uni0072/uni0059/uni0065/uni0061/uni0072/uni0020/uni0032/uni0030/uni0033/uni0035/uni0020/uni002D/uni0020/uni0057/uni002F/uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0061/uni006E/uni0064/uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0049/uni006E/uni0070/uni0075/uni0074 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004E/uni0075/uni006D/uni0062/uni0065/uni0072/uni0020/uni006F/uni0066/uni0020/uni004C/uni0061/uni006E/uni0065/uni0073/uni0031/uni0020/uni0031/uni0020/uni0031/uni0020 /uni0033/uni0020/uni0031/uni0020/uni0032/uni0020/uni0032/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni004C/uni0054/uni0020/uni0052/uni0020 /uni0054/uni0020/uni0052/uni0020/uni004C/uni0020/uni0054/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0028/uni0076/uni0070/uni0068/uni0029/uni0033/uni0033/uni0036/uni0020/uni0038/uni0020/uni0037/uni0030/uni0034/uni0020/uni0034/uni0033/uni0037/uni0020/uni0034/uni0038/uni0020/uni0031/uni0034/uni0031/uni0020/uni0031/uni0030/uni0039/uni0031/uni0020 /uni0020/uni0025/uni0020/uni0048/uni0065/uni0061/uni0076/uni0079/uni0020/uni0056/uni0065/uni0068/uni0069/uni0063/uni006C/uni0065/uni0073/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020 /uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020 /uni0020/uni0050/uni0048/uni0046/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020 /uni0020/uni0050/uni0072/uni0065/uni0074/uni0069/uni006D/uni0065/uni0064/uni002F/uni0041/uni0063/uni0074/uni0075/uni0061/uni0074/uni0065/uni0064/uni0020/uni0028/uni0050/uni002F/uni0041/uni0029/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020 /uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020 /uni0020/uni0053/uni0074/uni0061/uni0072/uni0074/uni0075/uni0070/uni0020/uni004C/uni006F/uni0073/uni0074/uni0020/uni0054/uni0069/uni006D/uni0065/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0045/uni0066/uni0066/uni0065/uni0063/uni0074/uni0069/uni0076/uni0065/uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020 /uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0074/uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0065/uni0064/uni002F/uni0042/uni0069/uni006B/uni0065/uni002F/uni0052/uni0054/uni004F/uni0052/uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0057/uni0069/uni0064/uni0074/uni0068/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0047/uni0072/uni0061/uni0064/uni0065/uni002F/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0048/uni006F/uni0075/uni0072 /uni0020/uni0042/uni0075/uni0073/uni0020/uni0053/uni0074/uni006F/uni0070/uni0073/uni002F/uni0048/uni006F/uni0075/uni0072/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004D/uni0069/uni006E/uni0069/uni006D/uni0075/uni006D/uni0020/uni0050/uni0065/uni0064/uni0065/uni0073/uni0074/uni0072/uni0069/uni0061/uni006E/uni0020/uni0054/uni0069/uni006D/uni0065/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020 /uni0020/uni0050/uni0068/uni0061/uni0073/uni0069/uni006E/uni0067/uni0020/uni0045/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0030/uni0032/uni0020/uni0030/uni0033/uni0020/uni0030/uni0034/uni0020/uni0053/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0054/uni0068/uni0072/uni0075/uni0020/uni0026/uni0020/uni0052/uni0054/uni0020/uni0030/uni0037/uni0020/uni0030/uni0038/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0031/uni0036/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0032/uni0036/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0033/uni0036/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0044/uni0075/uni0072/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0028/uni0068/uni0072/uni0073/uni0029/uni0020/uni003D/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0043/uni0079/uni0063/uni006C/uni0065/uni0020/uni004C/uni0065/uni006E/uni0067/uni0074/uni0068/uni0020/uni0043/uni0020/uni003D/uni0020/uni0020/uni0020/uni0039/uni0030/uni002E/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002C/uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni002C/uni0020/uni0061/uni006E/uni0064/uni0020/uni004C/uni004F/uni0053/uni0020/uni0044/uni0065/uni0074/uni0065/uni0072/uni006D/uni0069/uni006E/uni0061/uni0074/uni0069/uni006F/uni006E /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni0020/uni0041/uni0064/uni006A/uni0075/uni0073/uni0074/uni0065/uni0064/uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni0031/uni0036/uni0038/uni0020/uni0031/uni0037/uni0036/uni0020/uni0037/uni0030/uni0034/uni0020/uni0034/uni0033/uni0037/uni0020/uni0034/uni0038/uni0020/uni0031/uni0034/uni0031/uni0020/uni0031/uni0030/uni0039/uni0031/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni0033/uni0030/uni0036/uni0020/uni0033/uni0030/uni0037/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0031/uni0039/uni0037/uni0032/uni0020/uni0039/uni0035/uni0037/uni0020/uni0039/uni0036/uni0034/uni0020/uni0032/uni0035/uni0032/uni0036/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0035/uni0035/uni0020/uni0030/uni002E/uni0035/uni0037/uni0020/uni0030/uni002E/uni0034/uni0036/uni0020/uni0030/uni002E/uni0032/uni0032/uni0020/uni0030/uni002E/uni0030/uni0035/uni0020/uni0030/uni002E/uni0031/uni0035/uni0020/uni0030/uni002E/uni0034/uni0033/uni0020 /uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0031/uni0038/uni0020/uni0030/uni002E/uni0031/uni0038/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0030/uni002E/uni0034/uni0030/uni0020/uni0030/uni002E/uni0036/uni0032/uni0020/uni0030/uni002E/uni0032/uni0039/uni0020/uni0030/uni002E/uni0037/uni0033/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0066/uni006F/uni0072/uni006D/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0031 /uni0033/uni0033/uni002E/uni0037/uni0020/uni0033/uni0033/uni002E/uni0039/uni0020/uni0030/uni002E/uni0030/uni0020/uni0031/uni0037/uni002E/uni0038/uni0020/uni0036/uni002E/uni0036/uni0020/uni0032/uni0033/uni002E/uni0038/uni0020/uni0034/uni002E/uni0037/uni0020 /uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0020/uni006B/uni0030/uni002E/uni0031/uni0035/uni0020/uni0030/uni002E/uni0031/uni0037/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020 /uni0020/uni0049/uni006E/uni0063/uni0072/uni0065/uni006D/uni0065/uni006E/uni0074/uni0061/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0032 /uni0032/uni002E/uni0031/uni0020/uni0032/uni002E/uni0036/uni0020/uni0030/uni002E/uni0032/uni0020/uni0030/uni002E/uni0031/uni0020/uni0030/uni002E/uni0030/uni0020/uni0030/uni002E/uni0031/uni0020/uni0030/uni002E/uni0031/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0030/uni002E/uni0039/uni0035/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0033/uni0035/uni002E/uni0038/uni0020/uni0033/uni0036/uni002E/uni0035/uni0020/uni0030/uni002E/uni0032/uni0020/uni0031/uni0037/uni002E/uni0038/uni0020/uni0036/uni002E/uni0037/uni0020/uni0032/uni0033/uni002E/uni0038/uni0020/uni0034/uni002E/uni0038/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni004C/uni004F/uni0053/uni0044/uni0020/uni0044/uni0020/uni0041/uni0020 /uni0042/uni0020/uni0041/uni0020/uni0043/uni0020/uni0041/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0031/uni0032/uni002E/uni0030/uni0020/uni0020/uni0031/uni0036/uni002E/uni0037/uni0020/uni0020/uni0037/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni004C/uni004F/uni0053/uni0042/uni0020/uni0020 /uni0042/uni0020/uni0020/uni0041/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0031/uni0030/uni002E/uni0036/uni0020/uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni004C/uni004F/uni0053/uni0042/uni0020/uni0020 /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0032/uni002F/uni0032/uni0030/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020/uni0020/uni0020/uni0020/uni0034/uni003A/uni0034/uni0032/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0053/uni0068/uni006F/uni0072/uni0074/uni0020/uni0052/uni0065/uni0070/uni006F/uni0072/uni0074 /uni0032/uni002F/uni0032/uni0030/uni002F/uni0032/uni0030/uni0031/uni0034/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0037/uni0031/uni0038/uni0030/uni002E/uni0074/uni006D/uni0070 12-3190
/uni0042/uni0041/uni0043/uni004B/uni002D/uni004F/uni0046/uni002D/uni0051/uni0055/uni0045/uni0055/uni0045/uni0020/uni0057/uni004F/uni0052/uni004B/uni0053/uni0048/uni0045/uni0045/uni0054 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020/uni0044/uni0065/uni0073/uni0063/uni0072/uni0069/uni0070/uni0074/uni0069/uni006F/uni006E/uni0020/uni0020/uni0020/uni0020/uni0053/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0032/uni0034/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni0020/uni004C/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020/uni004C/uni0020/uni0020/uni0054/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0069/uni0074/uni0069/uni0061/uni006C/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0031/uni0036/uni0038/uni0020/uni0020/uni0031/uni0037/uni0036/uni0020/uni0020/uni0037/uni0030/uni0034/uni0020/uni0020/uni0034/uni0033/uni0037/uni0020/uni0020/uni0034/uni0038/uni0020/uni0020/uni0031/uni0034/uni0031/uni0020/uni0020/uni0031/uni0030/uni0039/uni0031/uni0020/uni0020 /uni0020/uni0053/uni0061/uni0074/uni0066/uni006C/uni006F/uni0077/uni002F/uni004C/uni0061/uni006E/uni0065/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0037/uni0032/uni0037/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020 /uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0033/uni0030/uni0036/uni0020/uni0020/uni0033/uni0030/uni0037/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0039/uni0037/uni0032/uni0020/uni0020/uni0039/uni0035/uni0037/uni0020/uni0020/uni0039/uni0036/uni0034/uni0020/uni0020/uni0032/uni0035/uni0032/uni0036/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0020/uni0030/uni002E/uni0033/uni0020/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0035/uni0035/uni0020/uni0020/uni0030/uni002E/uni0035/uni0037/uni0020/uni0020/uni0030/uni002E/uni0034/uni0036/uni0020/uni0020/uni0030/uni002E/uni0032/uni0032/uni0020/uni0020/uni0030/uni002E/uni0030/uni0035/uni0020/uni0020/uni0030/uni002E/uni0031/uni0035/uni0020/uni0020/uni0030/uni002E/uni0034/uni0033/uni0020/uni0020 /uni0020/uni0049/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020 /uni0020/uni0050/uni006C/uni0061/uni0074/uni006F/uni006F/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0031 /uni0033/uni002E/uni0038/uni0020/uni0020/uni0034/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0036/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020/uni0031/uni002E/uni0033/uni0020/uni0020/uni0035/uni002E/uni0036/uni0020/uni0020 /uni0020/uni006B/uni0042 /uni0030/uni002E/uni0033/uni0020/uni0020/uni0030/uni002E/uni0033/uni0020/uni0020/uni0030/uni002E/uni0039/uni0020/uni0020/uni0030/uni002E/uni0036/uni0020/uni0020/uni0030/uni002E/uni0037/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020/uni0030/uni002E/uni0038/uni0020/uni0020 /uni0020/uni0051/uni0032 /uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020/uni0030/uni002E/uni0038/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0036/uni0020/uni0020 /uni0020/uni0051/uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0034/uni002E/uni0032/uni0020/uni0020/uni0034/uni002E/uni0035/uni0020/uni0020/uni0032/uni002E/uni0038/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020/uni0031/uni002E/uni0034/uni0020/uni0020/uni0036/uni002E/uni0032/uni0020/uni0020 /uni0020/uni0050/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0028/uni0039/uni0035/uni0074/uni0068/uni0020/uni0070/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0029 /uni0020/uni0066/uni0042/uni0025 /uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0031/uni0020/uni0020/uni0032/uni002E/uni0031/uni0020/uni0020/uni0031/uni002E/uni0039/uni0020/uni0020 /uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0038/uni002E/uni0034/uni0020/uni0020/uni0038/uni002E/uni0038/uni0020/uni0020/uni0035/uni002E/uni0036/uni0020/uni0020/uni0031/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0039/uni0020/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0070/uni0061/uni0063/uni0069/uni006E/uni0067/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020 /uni0052/uni0061/uni0074/uni0069/uni006F
/uni0020/uni0039/uni0035/uni0025/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0020/uni0020/uni0020/uni0020/uni0033/uni003A/uni0032/uni0036/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0042/uni0061/uni0063/uni006B/uni002D/uni006F/uni0066/uni002D/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0057/uni006F/uni0072/uni006B/uni0073/uni0068/uni0065/uni0065/uni0074 /uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0031/uni0042/uni0038/uni0042/uni002E/uni0074/uni006D/uni0070 12-3191
/uni0053/uni0048/uni004F/uni0052/uni0054/uni0020/uni0052/uni0045/uni0050/uni004F/uni0052/uni0054/uni0020 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni0053/uni0069/uni0074/uni0065/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0074/uni0047/uni0072/uni0065/uni0067/uni0020 /uni0020/uni0041/uni0067/uni0065/uni006E/uni0063/uni0079/uni0020/uni006F/uni0072/uni0020/uni0043/uni006F/uni002E/uni0045/uni006E/uni0064/uni006F/uni0020/uni0045/uni006E/uni0067/uni0069/uni006E/uni0065/uni0065/uni0072/uni0069/uni006E/uni0067/uni0020 /uni0020/uni0044/uni0061/uni0074/uni0065/uni0020/uni0050/uni0065/uni0072/uni0066/uni006F/uni0072/uni006D/uni0065/uni0064/uni0032/uni002F/uni0031/uni0037/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0065/uni0020/uni0050/uni0065/uni0072/uni0069/uni006F/uni0064/uni0050/uni004D/uni0020/uni0050/uni0065/uni0061/uni006B/uni0020/uni0048/uni006F/uni0075/uni0072/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0042/uni006F/uni0062/uni0020/uni0048/uni006F/uni0070/uni0065/uni0020/uni0044/uni0072/uni0069/uni0076/uni0065/uni0020/uni0040/uni0020/uni0049/uni002D/uni0031/uni0030/uni0020/uni0045/uni0042/uni0020 /uni0052/uni0061/uni006D/uni0070/uni0073/uni0020
/uni0020/uni0041/uni0072/uni0065/uni0061/uni0020/uni0054/uni0079/uni0070/uni0065/uni0041/uni006C/uni006C/uni0020/uni006F/uni0074/uni0068/uni0065/uni0072/uni0020/uni0061/uni0072/uni0065/uni0061/uni0073/uni0020 /uni0020/uni004A/uni0075/uni0072/uni0069/uni0073/uni0064/uni0069/uni0063/uni0074/uni0069/uni006F/uni006E/uni0052/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0064/uni0065/uni0020/uni0043/uni006F/uni0075/uni006E/uni0074/uni0079/uni0020 /uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0059/uni0065/uni0061/uni0072/uni0059/uni0065/uni0061/uni0072/uni0020/uni0032/uni0030/uni0033/uni0035/uni0020/uni002D/uni0020/uni0057/uni002F/uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0061/uni006E/uni0064/uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0049/uni006E/uni0070/uni0075/uni0074 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004E/uni0075/uni006D/uni0062/uni0065/uni0072/uni0020/uni006F/uni0066/uni0020/uni004C/uni0061/uni006E/uni0065/uni0073/uni0031/uni0020/uni0031/uni0020/uni0031/uni0020 /uni0033/uni0020/uni0031/uni0020/uni0032/uni0020/uni0032/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni004C/uni0054/uni0020/uni0052/uni0020 /uni0054/uni0020/uni0052/uni0020/uni004C/uni0020/uni0054/uni0020 /uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0020/uni0028/uni0076/uni0070/uni0068/uni0029/uni0031/uni0035/uni0038/uni0020/uni0036/uni0020/uni0037/uni0032/uni0037/uni0020/uni0031/uni0032/uni0032/uni0030/uni0020/uni0031/uni0031/uni0036/uni0020/uni0032/uni0030/uni0032/uni0020/uni0031/uni0036/uni0031/uni0034/uni0020 /uni0020/uni0025/uni0020/uni0048/uni0065/uni0061/uni0076/uni0079/uni0020/uni0056/uni0065/uni0068/uni0069/uni0063/uni006C/uni0065/uni0073/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020 /uni0035/uni0020/uni0035/uni0020/uni0035/uni0020/uni0035/uni0020 /uni0020/uni0050/uni0048/uni0046/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020 /uni0020/uni0050/uni0072/uni0065/uni0074/uni0069/uni006D/uni0065/uni0064/uni002F/uni0041/uni0063/uni0074/uni0075/uni0061/uni0074/uni0065/uni0064/uni0020/uni0028/uni0050/uni002F/uni0041/uni0029/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020 /uni0041/uni0020/uni0041/uni0020/uni0041/uni0020/uni0041/uni0020 /uni0020/uni0053/uni0074/uni0061/uni0072/uni0074/uni0075/uni0070/uni0020/uni004C/uni006F/uni0073/uni0074/uni0020/uni0054/uni0069/uni006D/uni0065/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0045/uni0066/uni0066/uni0065/uni0063/uni0074/uni0069/uni0076/uni0065/uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020 /uni0033/uni0020/uni0033/uni0020/uni0033/uni0020/uni0033/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0074/uni0020/uni0045/uni0078/uni0074/uni0065/uni006E/uni0073/uni0069/uni006F/uni006E/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020/uni0033/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0065/uni0064/uni002F/uni0042/uni0069/uni006B/uni0065/uni002F/uni0052/uni0054/uni004F/uni0052/uni0020/uni0056/uni006F/uni006C/uni0075/uni006D/uni0065/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0057/uni0069/uni0064/uni0074/uni0068/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020/uni0031/uni0032/uni002E/uni0030/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0047/uni0072/uni0061/uni0064/uni0065/uni002F/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020/uni004E/uni0020/uni0030/uni0020/uni004E/uni0020 /uni0020/uni0050/uni0061/uni0072/uni006B/uni0069/uni006E/uni0067/uni002F/uni0048/uni006F/uni0075/uni0072 /uni0020/uni0042/uni0075/uni0073/uni0020/uni0053/uni0074/uni006F/uni0070/uni0073/uni002F/uni0048/uni006F/uni0075/uni0072/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0030/uni0020/uni0030/uni0020/uni0030/uni0020/uni0030/uni0020 /uni0020/uni004D/uni0069/uni006E/uni0069/uni006D/uni0075/uni006D/uni0020/uni0050/uni0065/uni0064/uni0065/uni0073/uni0074/uni0072/uni0069/uni0061/uni006E/uni0020/uni0054/uni0069/uni006D/uni0065/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020/uni0033/uni002E/uni0032/uni0020 /uni0020/uni0050/uni0068/uni0061/uni0073/uni0069/uni006E/uni0067/uni0020/uni0045/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0030/uni0032/uni0020/uni0030/uni0033/uni0020/uni0030/uni0034/uni0020/uni0053/uni0042/uni0020/uni004F/uni006E/uni006C/uni0079/uni0020/uni0054/uni0068/uni0072/uni0075/uni0020/uni0026/uni0020/uni0052/uni0054/uni0020/uni0030/uni0037/uni0020/uni0030/uni0038/uni0020 /uni0020/uni0054/uni0069/uni006D/uni0069/uni006E/uni0067/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0037/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0031/uni0031/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0036/uni0030/uni002E/uni0030/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020/uni0020/uni0047/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0034/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020/uni0020/uni0059/uni0020/uni003D/uni0020/uni0020 /uni0020/uni0044/uni0075/uni0072/uni0061/uni0074/uni0069/uni006F/uni006E/uni0020/uni006F/uni0066/uni0020/uni0041/uni006E/uni0061/uni006C/uni0079/uni0073/uni0069/uni0073/uni0020/uni0028/uni0068/uni0072/uni0073/uni0029/uni0020/uni003D/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0043/uni0079/uni0063/uni006C/uni0065/uni0020/uni004C/uni0065/uni006E/uni0067/uni0074/uni0068/uni0020/uni0043/uni0020/uni003D/uni0020/uni0020/uni0020/uni0039/uni0030/uni002E/uni0030/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002C/uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni002C/uni0020/uni0061/uni006E/uni0064/uni0020/uni004C/uni004F/uni0053/uni0020/uni0044/uni0065/uni0074/uni0065/uni0072/uni006D/uni0069/uni006E/uni0061/uni0074/uni0069/uni006F/uni006E /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni0020/uni0041/uni0064/uni006A/uni0075/uni0073/uni0074/uni0065/uni0064/uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni0037/uni0039/uni0020/uni0038/uni0035/uni0020/uni0037/uni0032/uni0037/uni0020/uni0031/uni0032/uni0032/uni0030/uni0020/uni0031/uni0031/uni0036/uni0020/uni0032/uni0030/uni0032/uni0020/uni0031/uni0036/uni0031/uni0034/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni0031/uni0033/uni0034/uni0020/uni0031/uni0033/uni0034/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0033/uni0032/uni0038/uni0036/uni0020/uni0031/uni0032/uni0031/uni0033/uni0020/uni0034/uni0030/uni0038/uni0020/uni0032/uni0038/uni0037/uni0031/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0035/uni0039/uni0020/uni0030/uni002E/uni0036/uni0033/uni0020/uni0030/uni002E/uni0034/uni0037/uni0020/uni0030/uni002E/uni0033/uni0037/uni0020/uni0030/uni002E/uni0031/uni0030/uni0020/uni0030/uni002E/uni0035/uni0030/uni0020/uni0030/uni002E/uni0035/uni0036/uni0020 /uni0020/uni0047/uni0072/uni0065/uni0065/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0030/uni0038/uni0020/uni0030/uni002E/uni0030/uni0038/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0030/uni002E/uni0036/uni0037/uni0020/uni0030/uni002E/uni0037/uni0039/uni0020/uni0030/uni002E/uni0031/uni0032/uni0020/uni0030/uni002E/uni0038/uni0033/uni0020 /uni0020/uni0055/uni006E/uni0069/uni0066/uni006F/uni0072/uni006D/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0031 /uni0034/uni0030/uni002E/uni0031/uni0020/uni0034/uni0030/uni002E/uni0033/uni0020/uni0030/uni002E/uni0030/uni0020/uni0036/uni002E/uni0036/uni0020/uni0032/uni002E/uni0032/uni0020/uni0033/uni0036/uni002E/uni0039/uni0020/uni0032/uni002E/uni0034/uni0020 /uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0020/uni006B/uni0030/uni002E/uni0031/uni0038/uni0020/uni0030/uni002E/uni0032/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0031/uni0020/uni0030/uni002E/uni0031/uni0036/uni0020 /uni0020/uni0049/uni006E/uni0063/uni0072/uni0065/uni006D/uni0065/uni006E/uni0074/uni0061/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0020/uni0064/uni0032 /uni0036/uni002E/uni0039/uni0020/uni0039/uni002E/uni0039/uni0020/uni0030/uni002E/uni0032/uni0020/uni0030/uni002E/uni0031/uni0020/uni0030/uni002E/uni0030/uni0020/uni0031/uni002E/uni0030/uni0020/uni0030/uni002E/uni0033/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0030/uni002E/uni0039/uni0035/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0043/uni006F/uni006E/uni0074/uni0072/uni006F/uni006C/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0034/uni0037/uni002E/uni0030/uni0020/uni0035/uni0030/uni002E/uni0031/uni0020/uni0030/uni002E/uni0032/uni0020/uni0036/uni002E/uni0037/uni0020/uni0032/uni002E/uni0032/uni0020/uni0033/uni0037/uni002E/uni0039/uni0020/uni0032/uni002E/uni0036/uni0020 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0020/uni004C/uni004F/uni0053/uni0044/uni0020/uni0044/uni0020/uni0041/uni0020 /uni0041/uni0020/uni0041/uni0020/uni0044/uni0020/uni0041/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0039/uni002E/uni0031/uni0020/uni0020/uni0036/uni002E/uni0033/uni0020/uni0020/uni0036/uni002E/uni0035/uni0020/uni0020 /uni0020/uni0041/uni0070/uni0070/uni0072/uni006F/uni0061/uni0063/uni0068/uni0020/uni004C/uni004F/uni0053/uni0041/uni0020/uni0020 /uni0041/uni0020/uni0020/uni0041/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0044/uni0065/uni006C/uni0061/uni0079/uni0037/uni002E/uni0030/uni0020/uni0020/uni0049/uni006E/uni0074/uni0065/uni0072/uni0073/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni004C/uni004F/uni0053/uni0041/uni0020/uni0020 /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0032/uni002F/uni0032/uni0035/uni002F/uni0032/uni0030/uni0031/uni0034/uni0020/uni0020/uni0020/uni0020/uni0031/uni0032/uni003A/uni0034/uni0030/uni0020/uni0041/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0053/uni0068/uni006F/uni0072/uni0074/uni0020/uni0052/uni0065/uni0070/uni006F/uni0072/uni0074 /uni0032/uni002F/uni0032/uni0035/uni002F/uni0032/uni0030/uni0031/uni0034/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0045/uni0044/uni0045/uni0032/uni002E/uni0074/uni006D/uni0070 12-3192
/uni0042/uni0041/uni0043/uni004B/uni002D/uni004F/uni0046/uni002D/uni0051/uni0055/uni0045/uni0055/uni0045/uni0020/uni0057/uni004F/uni0052/uni004B/uni0053/uni0048/uni0045/uni0045/uni0054 /uni0020/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni006C/uni0020/uni0049/uni006E/uni0066/uni006F/uni0072/uni006D/uni0061/uni0074/uni0069/uni006F/uni006E /uni0020/uni0050/uni0072/uni006F/uni006A/uni0065/uni0063/uni0074/uni0020/uni0044/uni0065/uni0073/uni0063/uni0072/uni0069/uni0070/uni0074/uni0069/uni006F/uni006E/uni0020/uni0020/uni0020/uni0020/uni0053/uni0065/uni0063/uni0074/uni0069/uni006F/uni006E/uni0020/uni0032/uni0034/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065 /uni0045/uni0042/uni0057/uni0042/uni004E/uni0042/uni0053/uni0042 /uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054/uni004C/uni0054/uni0020/uni0054/uni0048/uni0052/uni0054 /uni0020/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni004C/uni0020/uni0020/uni004C/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020/uni0054/uni0020/uni0020/uni0052/uni0020/uni0020/uni004C/uni0020/uni0020/uni0054/uni0020/uni0020 /uni0020/uni0049/uni006E/uni0069/uni0074/uni0069/uni0061/uni006C/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0065/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0037/uni0039/uni0020/uni0020/uni0038/uni0035/uni0020/uni0020/uni0037/uni0032/uni0037/uni0020/uni0020/uni0031/uni0032/uni0032/uni0030/uni0020/uni0020/uni0031/uni0031/uni0036/uni0020/uni0020/uni0032/uni0030/uni0032/uni0020/uni0020/uni0031/uni0036/uni0031/uni0034/uni0020/uni0020 /uni0020/uni0053/uni0061/uni0074/uni0066/uni006C/uni006F/uni0077/uni002F/uni004C/uni0061/uni006E/uni0065/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0037/uni0032/uni0039/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0031/uni0037/uni0031/uni0039/uni0020/uni0020/uni0031/uni0038/uni0030/uni0039/uni0020/uni0020 /uni0020/uni0043/uni0061/uni0070/uni0061/uni0063/uni0069/uni0074/uni0079/uni002F/uni004C/uni0061/uni006E/uni0065/uni0020/uni0047/uni0072/uni006F/uni0075/uni0070/uni0031/uni0033/uni0034/uni0020/uni0020/uni0031/uni0033/uni0034/uni0020/uni0020/uni0031/uni0035/uni0033/uni0038/uni0020/uni0020/uni0033/uni0032/uni0038/uni0036/uni0020/uni0020/uni0031/uni0032/uni0031/uni0033/uni0020/uni0020/uni0034/uni0030/uni0038/uni0020/uni0020/uni0032/uni0038/uni0037/uni0031/uni0020/uni0020 /uni0020/uni0046/uni006C/uni006F/uni0077/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0030/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020 /uni0020/uni0076/uni002F/uni0063/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0030/uni002E/uni0035/uni0039/uni0020/uni0020/uni0030/uni002E/uni0036/uni0033/uni0020/uni0020/uni0030/uni002E/uni0034/uni0037/uni0020/uni0020/uni0030/uni002E/uni0033/uni0037/uni0020/uni0020/uni0030/uni002E/uni0031/uni0030/uni0020/uni0020/uni0030/uni002E/uni0035/uni0030/uni0020/uni0020/uni0030/uni002E/uni0035/uni0036/uni0020/uni0020 /uni0020/uni0049/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0072/uni0072/uni0069/uni0076/uni0061/uni006C/uni0020/uni0054/uni0079/uni0070/uni0065/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020/uni0033/uni0020/uni0020 /uni0020/uni0050/uni006C/uni0061/uni0074/uni006F/uni006F/uni006E/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0050/uni0046/uni0020/uni0046/uni0061/uni0063/uni0074/uni006F/uni0072/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020/uni0031/uni002E/uni0030/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0031 /uni0031/uni002E/uni0039/uni0020/uni0020/uni0032/uni002E/uni0031/uni0020/uni0020/uni0034/uni002E/uni0039/uni0020/uni0020/uni0030/uni002E/uni0037/uni0020/uni0020/uni0032/uni002E/uni0034/uni0020/uni0020/uni0036/uni002E/uni0036/uni0020/uni0020 /uni0020/uni006B/uni0042 /uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0032/uni0020/uni0020/uni0030/uni002E/uni0039/uni0020/uni0020/uni0030/uni002E/uni0038/uni0020/uni0020/uni0030/uni002E/uni0038/uni0020/uni0020/uni0030/uni002E/uni0033/uni0020/uni0020/uni0030/uni002E/uni0039/uni0020/uni0020 /uni0020/uni0051/uni0032 /uni0030/uni002E/uni0033/uni0020/uni0020/uni0030/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0038/uni0020/uni0020/uni0030/uni002E/uni0035/uni0020/uni0020/uni0030/uni002E/uni0031/uni0020/uni0020/uni0030/uni002E/uni0033/uni0020/uni0020/uni0031/uni002E/uni0031/uni0020/uni0020 /uni0020/uni0051/uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0032/uni002E/uni0032/uni0020/uni0020/uni0032/uni002E/uni0034/uni0020/uni0020/uni0035/uni002E/uni0034/uni0020/uni0020/uni0030/uni002E/uni0037/uni0020/uni0020/uni0032/uni002E/uni0037/uni0020/uni0020/uni0037/uni002E/uni0038/uni0020/uni0020 /uni0020/uni0050/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0028/uni0039/uni0035/uni0074/uni0068/uni0020/uni0070/uni0065/uni0072/uni0063/uni0065/uni006E/uni0074/uni0069/uni006C/uni0065/uni0029 /uni0020/uni0066/uni0042/uni0025 /uni0032/uni002E/uni0030/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0031/uni002E/uni0039/uni0020/uni0020/uni0032/uni002E/uni0031/uni0020/uni0020/uni0032/uni002E/uni0030/uni0020/uni0020/uni0031/uni002E/uni0039/uni0020/uni0020 /uni0020/uni0042/uni0061/uni0063/uni006B/uni0020/uni006F/uni0066/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0034/uni002E/uni0035/uni0020/uni0020/uni0034/uni002E/uni0039/uni0020/uni0020/uni0031/uni0030/uni002E/uni0035/uni0020/uni0020/uni0031/uni002E/uni0035/uni0020/uni0020/uni0035/uni002E/uni0034/uni0020/uni0020/uni0031/uni0034/uni002E/uni0037/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0070/uni0061/uni0063/uni0069/uni006E/uni0067/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020/uni0032/uni0035/uni002E/uni0030/uni0020/uni0020 /uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020/uni0030/uni0020/uni0020 /uni0020/uni0041/uni0076/uni0065/uni0072/uni0061/uni0067/uni0065/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020 /uni0052/uni0061/uni0074/uni0069/uni006F
/uni0020/uni0039/uni0035/uni0025/uni0020/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0053/uni0074/uni006F/uni0072/uni0061/uni0067/uni0065/uni0020/uni0052/uni0061/uni0074/uni0069/uni006F /uni0043/uni006F/uni0070/uni0079/uni0072/uni0069/uni0067/uni0068/uni0074/uni0020/uni00A9/uni0020/uni0032/uni0030/uni0030/uni0037/uni0020/uni0055/uni006E/uni0069/uni0076/uni0065/uni0072/uni0073/uni0069/uni0074/uni0079/uni0020/uni006F/uni0066/uni0020/uni0046/uni006C/uni006F/uni0072/uni0069/uni0064/uni0061/uni002C/uni0020/uni0041/uni006C/uni006C/uni0020/uni0052/uni0069/uni0067/uni0068/uni0074/uni0073/uni0020/uni0052/uni0065/uni0073/uni0065/uni0072/uni0076/uni0065/uni0064/uni0048/uni0043/uni0053/uni002B/uni0054/uni004D/uni0020/uni0020/uni0020/uni0056/uni0065/uni0072/uni0073/uni0069/uni006F/uni006E/uni0020/uni0035/uni002E/uni0033/uni0047/uni0065/uni006E/uni0065/uni0072/uni0061/uni0074/uni0065/uni0064/uni003A/uni0020/uni0020/uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0020/uni0020/uni0020/uni0020/uni0033/uni003A/uni0032/uni0037/uni0020/uni0050/uni004D /uni0050/uni0061/uni0067/uni0065/uni0020/uni0031/uni0020/uni006F/uni0066/uni0020/uni0031/uni0042/uni0061/uni0063/uni006B/uni002D/uni006F/uni0066/uni002D/uni0051/uni0075/uni0065/uni0075/uni0065/uni0020/uni0057/uni006F/uni0072/uni006B/uni0073/uni0068/uni0065/uni0065/uni0074 /uni0031/uni002F/uni0032/uni0038/uni002F/uni0032/uni0030/uni0031/uni0035/uni0066/uni0069/uni006C/uni0065/uni003A/uni002F/uni002F/uni002F/uni0043/uni003A/uni002F/uni0055/uni0073/uni0065/uni0072/uni0073/uni002F/uni0055/uni0073/uni0065/uni0072/uni002F/uni0041/uni0070/uni0070/uni0044/uni0061/uni0074/uni0061/uni002F/uni004C/uni006F/uni0063/uni0061/uni006C/uni002F/uni0054/uni0065/uni006D/uni0070/uni002F/uni0073/uni0032/uni006B/uni0042/uni0034/uni0038/uni0030/uni002E/uni0074/uni006D/uni0070 12-3193
APPENDIX 3.0
Air Quality—Supplemental Emission Modeling Information
12-3194
Appendix 3.0-a
Updated CalEEMod Files
12-3195
Project Characteristics -
Land Use - Population based on 1.95 factor
Private Park 7 acres
25 acres of road right of way
23,000 sf = clubhouse
Construction Phase - Construction Assumptions
Off-road Equipment -
Salton Sea Air Basin, Annual
Active Adult Community (Planning Area 8)