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HomeMy Public PortalAbout01 January 6, 2005 Transit Policy• • • REVISED To INCLUDE VIDEO CONFERENCE SITE RECORDS 7e6/0 RIVERSIDE COUNTY TRANSPORTATION COMMISSION TRANSIT POLICY COMMITTEE MEETING AGENDA TIME: 11:00 a.m. DATE: Thursday, January 6, 2005 LOCATION: CONFERENCE ROOM — FIFTH FLOOR** County of Riverside Administrative Center 4080 Lemon Street, 5th Floor, Riverside County of Riverside 4th District Office (Video Conference Site) 73-710 Fred Waring Drive, Suite 222, Palm Desert * * * COMMITTEE MEMBERS * * Ameal Moore / Steve Adams, City of Riverside, Chairman Percy L. Byrd / Robert A. Bernheimer / Mary Roche, City of Indian Wells, Vice -Chairman Roger Berg / Jeff Fox, City of Beaumont Jeff Miller, City of Corona Terry Henderson / Don Adolph, City of La Quinta Frank West / Charles White, City of Moreno Valley Frank Hall / Harvey Sullivan, City of Norco Dick Kelly / Robert Spiegel, City of Palm Desert John F. Tavaglione, County of Riverside Roy Wilson, County of Riverside *** STAFF *** Cathy Bechtel, Director of Transportation Planning and Policy Development Tanya Love, Program Manager * * * AREAS OF RESPONSIBILITY Review items and make recommendations to the Commission on the following: • Policy directions to prepare for transit vision and to bring regional perspective to transit • Monitor transit implementation • Performance of transit operators and its services The Committee welcomes comments. If you wish to provide comments to the Committee, please complete and submit a Testimony Card to the Clerk of the Board. 11. • • REVISED TO INCLUDE VIDEO CONFERENCE SITE RIVERSIDE COUNTY TRANSPORTA TION COMMISSION TRANSIT POLICY COMMITTEE www.rctc.org AGENDA* *Actions may be taken on any item listed on the agenda 11:00 a.m. Thursday, January 6, 2005 CONFERENCE ROOM - FIFTH FLOOR** County of Riverside Administrative Center 4080 Lemon Street, 5th Floor, Riverside * *County of Riverside 4th District Office (Video Conference Site) 73-710 Fred Waring Drive, Suite 222, Palm Desert The Public is welcome to attend the meeting at the meeting location and at the video conference site. In compliance with the Americans with Disabilities Act and Government Code Section 54954.2, if you need special assistance to participate in a Committee meeting, please contact the Clerk of the Commission at (951) 787-7141. Notification of at least 48 hours prior to meeting time will assist staff in assuring that reasonable arrangements can be made to provide accessibility at the meeting. 1. CALL TO ORDER 2. ROLL CALL 3. PUBLIC COMMENTS 4. APPROVAL OF MINUTES - October 18, 2004 5. ADDITIONS/REVISIONS (The Committee may add an item to the Agenda after making a finding that there is a need to take immediate action on the item and that the item came to the attention of the Committee subsequent to the posting of the agenda. An action adding an item to the agenda requires 2/3 vote of the Committee. If there are less than 2/3 of the Committee members present, adding an item to the agenda requires a unanimous vote. Added items will be placed for discussion at the end of the agenda.) • Transit Policy Committee Agenda January 6, 2005 Page 2 6. STATUS REPORT ON TRANSIT POLICY COMMITTEE'S ACCOMPLISHMENTS Page 1 Overview This item is for the Committee to receive and file a status report on the goals, remaining tasks, and accomplishments of the Transit Policy Committee. 7. RESERVE POLICY FOR LOCAL TRANSPORTATION FUNDS Overview This item is for the Committee to: Page 2 1) Establish a transit operators' reserve policy of 10% for Coachella Valley and Palo Verde Valley apportionment areas; 2) Establish a transit operators' reserve policy of 10% for each of the transit operators (public bus and commuter rail) in the western Riverside County apportionment area; 3) Revise the Funding Disbursement Policy so that 100% of the operating funds are allocated and disbursed with two -twelfths of the 100% disbursed the first month and the remainder (ten -twelfths) disbursed over the next eleven months; and, 4) Forward to the Commission for final action. 8. ADJOURNMENT • • • • AGENDA ITEM 4 • MINUTES • • RIVERSIDE COUNTY TRANSPORTA TION COMMISSION TRANSIT POLICY COMMITTEE October 18, 2004 Minutes 1. CALL TO ORDER Chairman Ameal Moore called the meeting to order at 1:04 p.m., on Monday, October 18, 2004, at the Riverside County Transportation Commission's Conference Room "A", 4080 Lemon Street, 3' Floor, Riverside, California 92501. 2. ROLL CALL • Members Present: Roger Berg Frank Hall Terry Henderson Dick Kelly Member Absent: Percy Byrd John Tavaglione Jeff Miller Ameal Moore Roy Wilson Frank West 3. PUBLIC COMMENTS There were no public comments. 4. ADDITIONS/REVISIONS Revisions to Agenda Item 5 relating to Fund Balances were noted. 5. FINANCIAL POLICIES ADMINISTERING TRANSPORTATION DEVELOPMENT ACT FUNDS Theresia Trevino, Chief Financial Officer, reminded the Committee of Commission's FY 2001-03 Triennial Performance Audit stating its fiduciary responsibility to ensure that the transit operators are utilizing Transportation Development Act (TDA) funds efficiently and effectively. This item is a review of the Commission's financial practices used as part of its fiduciary responsibility. Under the TDA, there are two funding sources for public Transit Policy Committee Minutes October 18, 2004 Page 2 transportation that the Commission administers - Local Transportation Fund (LTF) and State Transit Assistance (STA). For LTF, the County receives one -quarter cent of the 7.25% State retail sales tax collected and the Commission prepares the written allocation instructions for disbursement and funds are disbursed to transit operators based on planned operating levels and capital projects identified through a Short Range Transit Plan. STA fund sources are from statewide sales tax on motor vehicle fuel and funds are appropriated to the State Controller for allocation, by formula, to each of the regional transportation planning agencies in the State. The Commission allocates these funds for Riverside County by formula - 50% on the basis of the region's population compared to the State's population and 50% in accordance to prior year proportion of the region's transit operator passenger fare and local support revenues. There are three steps in order for operators to obtain TDA funds: 1) apportionment; 2) allocation; and, 3) payment. There are three apportionment areas in Riverside County: 1) Western Riverside with six transit operators; 2) Coachella Valley with one transit operator; and, 3) Palo Verde Valley with one transit operator. Every year, the Commission determines each of the apportionment area's share of the projected TDA funds, in addition to any unapportioned carryovers from the prior year. The determined share is the area's apportionment. Allocation of funds to operator(s) within each of the apportionment area is determined based upon their service levels and identified capital projects in the annual Short Range Transit Plan. Allocated funds are disbursed monthly after a claim is received from the operator. An annual audit is conducted of each of the operator. One of the outcomes of determining any deferred operating and capital revenue. Deferred revenue represents TDA funds that are received by the operator but not yet spent for eligible for operating or capital. Deferred operating balance should be applied against future operating allocations and the deferred capital balance relate to specific projects, which may be carried over if not completed within that year. If an operator does not require the entire allocation for its operating cost, the remaining allocation should be reduced and returned to the area's apportionment balance. In previous years, unclaimed allocated TDA funds that are administered by the Commission have been associated with specific operators and deferred operating revenues that have been received by the operators have not been consistently applied against the subsequent year's funding allocation. In order for the Commission to carry out its fiduciary responsibility that TDA funds are used efficiently and effectively, • • • Transit Policy Committee Minutes October 18, 2004 Page 3 the Commission will work with the operators to draw down the accumulated and unclaimed allocations as of June 30, 2004 and to apply deferred operating revenues against future allocations. Theresia Trevino continued and stated that TDA funds represent approximately 55% of the transit operators' operating and capital budgets. As defined by TDA, the operators must meet fare box recovery ratio requirements. Last year, LTF revenues were approximately $58.4 million, and STA revenues were $2.9 million. While revenues have increased, there was significant increase in operating cost. Thus, some operators are having difficulty meeting fare box requirements. For 2005, transit operators requested about 4% TDA funding over the projected funds available. Due to prior year carryover, the Commission was able to fund the extra 4%. At year end, there typically have been excess LTF funds available for various purposes, as well as STA. She then reviewed the summary report of the reserve fund balances by apportionment area. M/S/C (Mil/er/Kelly) to receive and file the presentation on Transportation Development Act funding. 6. RESERVE POLICY FOR LOCAL TRANSPORTATION FUNDS Theresia Trevino stated that operator costs are outpacing the LTF revenues and had to use prior year carryovers to fund excess costs of the project revenue. Because of increase in operating cost over available revenues, staff recommends a change in the reserve policy. This is to assist in managing the periods when higher than anticipated costs as well as periods of lower than expected revenues. It is recommended that effective the FY 2005-06 Short Range Transit Plan process, the Commission establish a 10% county- wide reserve for operations and/or capital for each of the three apportionment areas (Western Riverside, Coachella Valley, Palo Verde Valley). The proposed reserve policy would provide unallocated reserve of $5,031,161 and the amount available for apportionment would be $45,280,451. Operators may request additional funding through the SRTP amendment process and would be considered based on its own merit. Any set asides of reserves would need to be adequately supported as to purpose and need prior to approval by the Commission. Staff will work with the operators to ensure that existing unclaimed allocations are used prior to unallocated reserves. Currently, 10% of the annual allocations for operators are not disbursed until June, after the Commission has determined that sufficient revenues have been received, and the remaining 90% over the next 10 months. Under the proposed reserve policy, if approved, this approach is no longer necessary as the 10% reserve can cover costs if Transit Policy Committee Minutes October 18, 2004 Page 4 revenue comes in lower than projected. Thus, staff recommends that 100% of the annual allocation be disbursed with two -twelfths in the first month and the remainder of the 100% over the next 11 months. Commissioner Dick Kelly stated that he would like the opportunity to discuss the proposal with the SunLine General Manager. SunLine has operated on the same budget over the past three years, even with increasing sales tax revenues collected in the area. Jon Winningham, Riverside Transit Agency Chair, reviewed the expenditures of the transit agency over the past years. He stated that RTA and SunLine should have available reserve funding. The current reserve policy has been working and do not see a need to change it. Cathy Bechtel, Director of Transportation Planning and Policy Development, stated that staff agrees that reserves should be in place. There is a reserve policy in place. To date, RTA was the only transit agency that has requested for allocation from the reserve funds. With regards to the transit agency holding the reserve funds, the Commission is not able to allocate reserves to transit agencies because of TDA regulations. She noted that staff's proposed amendment to the reserve policy would actually raise the reserves to 10% for each of the apportionment area in Riverside County. Commissioner Terry Henderson asked if staff has had meetings with the transit operators regarding the current and proposed reserve policy. Tanya Love, Program Manager, responded that there have not been any official meetings where the reserve policy was discussed. Two meetings are held annually with transit operators to discuss available funding, carryover funds, allocation, etc. Commissioner Kelly reiterated a need to discuss this matter with the SunLine General Manager and, therefore, requested that the item be continued. Jon Winningham suggested that the General Managers and the Chair of the transit agencies meet with staff to discuss a reserve policy that would make sense, and bring a report back to the Committee. Commissioner Jeff Miller said that if the change in the policy would shut down the operators, then it would not be the direction that he would go forth. He added that it is important to know how the proposed policy will impact the operators on their day to day operations. • • • • • Transit Policy Committee Minutes October 18, 2004 Page 5 Tanya Love explained that this has nothing to do with any funds currently on reserve such as the $4 million BRT funds for demonstration program, $2.2 million for land acquisition, and the one -twelfth ($2 million) on reserve. These funds are protected and would not go away. For 2004-05, more revenues are being utilized than what is anticipated. The consequence is that service may be reduced in the future and she noted the importance of amending the reserve policy in order to avoid such actions in future years. She reiterated that this does not apply to any funds that RTA currently has identified. Commissioner Roger Berg noted the demographic changes occurring at the various areas that the operators serve and may not have sufficient funding to provide services. Commissioner Henderson reminded the Committee members that this matter is before the Committee as a result of the audits. It is a point of public policy to have a reserve in place. She asked if the reserve policy should be consistent throughout the operators or should it be inconsistent for city -run public transit services. Cathy Bechtel stated that the policy being recommended by staff is to have a consistent policy by apportionment area as funds are held by the Commission by apportionment area. However, it is up to the Commission to make the final determination. Commissioner Henderson asked that with the Commission holding the reserve funds if the transit operators still have the ability to go through the process and to access the reserve funds. Cathy Bechtel responded that operators may access the reserve funds which RTA and SunLine have done in the past. Commissioner Kelly stated that he is not in favor of putting a high percentage of funds in reserve, and reducing funds to provide service. Commissioner Hall said that he would like staff to meet with each of the operators and return to the Committee with a report which includes issues agreed/disagreed upon, and any additional information regarding the proposal to assist the Committee in making a determination regarding the reserve policy. • Transit Policy Committee Minutes October 18, 2004 Page 6 At Commissioner Miller's request, Tanya Love reviewed the process in determining the apportionment for each of the area — rail and transit, as well a determined the amount of reserves, as shown in the attachment to the staff memorandum. The staff proposal would be to set aside 10% from each of the apportionment area which would change the apportionment as follows: Western Riverside County, from $39,003.324 to $35,102,991 Coachella Valley, from $10,480,606 to $9,432,546 Palo Verde Valley, from $827,683 to $744,914 Tanya Love continued and stated that the apportionments are currently not being spent in Western Riverside County. As Mr. Jon Winningham has indicated, approximately 79% or $2.9 million was carried over but the amount was actually more than 79% this year. She noted that there was a need to use reserves in the past year to front RTA them with the 5307 funds. Without the reserves, funds could have been taken out of the unallocated balance ($3.9 million) but not up to $5.3 million. She stated that if operating costs continue to escalate beyond the projected revenues, there may be a problem in the future. In accordance to Commission policy, staff has been directing the transit operators to utilized federal funds first because it has a time line for using the funds. It is important to note that RCTC will not be taking away the reserves that were allocated to RTA. Larry Rubio stated that RTA drew $4.3 million from the reserves. If the proposed policy was in effect and they have no reserves, the $3.042,000 allocated to Western County area was not sufficient to cover until the end of the year. He said that he asked RCTC staff if there were funds to cover the shortfall, the response was no. M/S/C (Miller/Kelly) to: 1) Continue this item on the proposed reserve policy; 2) Direct RCTC staff to meet operator staff to discuss the proposed reserve policy; and, 3) Bring back a report to the Transit Policy Committee on the status of the meetings as well as recommendation. Note: It was further determined that RCTC staff members meet staff of the transit operators. Transit operator Board members may submit their comments/input to the Transit Policy Committee at the meeting. • • • Transit Policy Committee Minutes October 18, 2004 Page 7 7. STATUS REPORT ON TRANSIT POLICY ISSUES Tanya Love reviewed the policy issues that were identified at the May 2004 Commission workshop regarding: 1) State Mandated Fare box Recovery Ratio - this was developed and approved on October 13, 2004; 2) Route Productivity - staff continues to meet with transit operators; 3) Reserve Policy - discussed in a previous item with staff to meet with transit operators and bring back a report to the Committee; 4) Accrual of Interest on Allocated, Unclaimed Funds - discussed in a previous item which was received and filed by the Committee; 5) Accrual of Interest on Allocated, Unclaimed Funds - this is no longer a problem as funds allocated will be claimed in a timely manner and the interest accrued will either go to the transit operator's operating funds or to the apportionment area; 6) Timeliness of Spending Allocated Capital Funds - the timeline for completion of outstanding capital projects for FYs 96-97 through 02-03 was approved by RCTC on October 13. From FY 04 forward basis, staff will bring back a proposed policy based on the AB 1012 "Use It or Lose It" provisions as capital projects should be shop ready; and, 7) Allocation of 2009 Measure "A" Funds -Western Riverside - the Committee may want to consider developing a funding formula as part of the TDA discussion for Western Riverside County. M/S/C (Henderson/Hall) to receive and file the status report on policy issues identified at the May 2004 Commission Workshop. 8. ADJOURNMENT There being no other items to consider by the Committee, Chair Moore adjourned the meeting at 3:18 p.m. Respectfully submitted, Naty Kopenhaver Clerk of the Board • AGENDA ITEM 6 • • • • RIVERSIDE COUNTY TRANSPORTA TION COMMISSION DATE: January 6, 2005 TO: Transit Policy Committee FROM: Tanya Love, Program Manager THROUGH: Cathy Bechtel, Director of Transportation Planning and Policy Development SUBJECT: Status Report on Transit Policy Committee's Accomplishments STAFF RECOMMENDATION: This item is for the Committee to receive and file a status report on the goals, remaining tasks, and accomplishments of the Transit Policy Committee. BACKGROUND INFORMATION: Commission staff will provide a power point presentation detailing the goals, remaining tasks and accomplishments of the Transit Policy Committee. Agenda Item 6 1 • AGENDA ITEM 7 • • • • • RIVERSIDE COUNTY TRANSPORTA TION COMMISSION DATE: January 6, 2005 TO: Transit Policy Committee FROM: Tanya Love, Program Manager Theresia Trevino, Chief Financial Officer THROUGH: Cathy Bechtel, Director of Transportation Planning Development and Policy SUBJECT: Reserve Policy for Local Transportation Funds STAFF RECOMMENDATION: This item is for the Committee to: 1) Establish a transit operators' reserve policy of 10% for Coachella Valley and Palo Verde Valley apportionment areas; 2) Establish a transit operators' reserve policy of 10% for each of the transit operators (public bus and commuter rail) in the western Riverside County apportionment area; 3) Revise the Funding Disbursement Policy so that 100% of the operating funds are allocated and disbursed with two -twelfths of the 100% disbursed the first month and the remainder (ten -twelfths) disbursed over the next eleven months; and, 4) Forward to the Commission for final action. BACKGROUND INFORMATION: At the October 18, 2004 Transit Policy Committee (TPC) meeting, staff recommended that a 10% reserve policy be established for each of the three apportionment areas. A reserve policy was recommended due to operating costs outpacing current year revenue. Much discussion followed regarding cash flow issues due to non -receipt of federal funding. It became apparent that additional discussion needed to take place and as a result, the TPC directed Commission staff to convene a staff to staff level meeting to further discuss the issue of operating reserves. In follow-up, a conference call and two meetings were held. Agreement on the proposed policy was quickly reached with staff from SunLine, the City of Blythe and the Commuter Rail Program. The development of a reserve policy in western Riverside County was not as easy due to the number of operators in the area. Agenda Item 7 2 As a result, a subsequent meeting was held to further discuss cash flow issues. At the second meeting, consensus was reached among the municipal operators as follows: a. Ten (10%) reserve should be established for unforeseen cost increases; b. Reserves should be restricted to maintaining current service levels in the event of a revenue shortfall or unforeseen emergency; c. Reserves should not be for service enhancements; and, d. Each operator should have its' own reserve fund. The Riverside Transit Agency proposed that the reserve policy be established between 11% and 17%. Recommendations were also made that reserves be available for infrastructure and service improvements as well as for capital purchases and included "triggers" for drawdown of reserves. Subsequent to the Transit Policy Committee, a letter was received from Jon Winningham, Chairman of RTA's Board, which concluded that RCTC "needs to determine the appropriate reserve level, with documented processes to access the reserve, for all transit operators". Process to Calculate 10% Reserve The amount of the required reserve for the fiscal year would be calculated as 10% of the Local Transportation Fund (LTF) apportionment balance after deductions for administration, planning, and SB 821 program funding. The unallocated reserve balance of 10% would be set aside before allocation to the three apportionment areas based on population. Attachment A is an illustration of the calculation using FY 2004-05 amounts. Elimination of 10% Withhold from Annual Allocation In order to implement the revised reserve policy, staff recommends that the Commission also revise the Funding Disbursement Policy adopted on February 13, 2002. Currently, 10% of the annual allocation for each operator is not disbursed until June after the Commission has determined that sufficient revenues have been received. Under the new reserve policy, this approach is no longer necessary as the 10% reserve can cover costs if revenue comes in lower than projected. Accordingly, staff recommends that 100% of the annual allocation be disbursed with two -twelfths in the first month and the remainder of the 100% over the next eleven months. Agenda Item 7 3 • • • • Process to Access Reserve Funds Western Riverside County transit operators requested that RCTC implement some type of automatic trigger mechanism to allow them to tap into reserve funds. Staff recommends that operators access reserve funds by amending their SRTP through the established amendment process. Each request would be considered based on its own merit, and as a result, provide flexibility to the operators. All requests will be presented to the Commission for review. Attachments: 1) Riverside County LTF 2004-2005 Apportionment 2) RTA Letter Agenda Item 7 4 • • • RIVERSIDE COUNTY LOCAL TRANSPORTATION FUND 2004-2005 APPORTIONMENT (REVISED) DRAFT For Discussion Purposes Only Budget FY 2004-2005 Projection Estimated Carryover (Unapportioned) $5,490,333 Est. Receipts 58,580,960 TOTAL 64,071, 293 Less: Auditor 12,000 Less: RCTC Administration 675,000 Less: RCTC Planning (3% of revenues) 1,757,429 Less: SCAG Planning 106,300 BALANCE 61,520,564 Less: SB 821 (2% of balance) 1,230,411 BALANCE AVAILABLE BEFORE RESERVES 60,290,153 Less: 10% Transit Reserves 6,029,015 BALANCE AVAILABLE AFTER RESERVES $54,261,138 Current Policy: Population Revised Budget Population FY 2004-2005 % of Total Apportionment (no reserves) Western 1,322,192 77.52% $46,739,038 Coachella Valley 355,287 20.83% 12,559,275 Palo Verde Valley 28,058 1.65% 991,841 1,705,537 100.00% $60,290,153 Western County: Rail 22% $10,282,588 Transit 78% 36,456,449 Total $46,739,038 Proposed Policy: Population Budget Population FY 2004-2005 % of Total Apportionment (after 10% reserves) Rail Transit 22% 78% Western 1,322,192 77.52% $42,065,134 $ 9,254,329 $ 32,810,804 Coachella Valley 355,287 20.83% 11,303,347 Palo Verde Valley 28,058 1.65% 892,657 1,705,537 100.00% $54,261,138 Reserve Allocation: Western $ 4,673,904 Rail Transit Coachella Valley 1,255,927 $ 1,028,259 $ 3,645,645 Palo Verde Valley 99,184 Total Reserve NOTES: Estimate for Planning Purposes, subject to change $ 6,029,015 Population Source: California Department of Finance, Demographic Research Unit as of January 1, 2003 $ 3,066,713 $ 100,842 $ 105,395 $ 153,735 $ 218,960 70150 EH, TL • • • December 13, 2004 Ms. Tanya Love Program Manager Riverside County Transportation Commission 4080 Lemon Street, 3`I Floor Riverside, CA 92502 RE: Transit Operators' Reserve Policy rink Riverside Transit Agency 1825 Third Street P.O. Box 59968 Riverside, CA 92517-1968 Phone: (951) 565-5044 Fax: (951) 565-5045 DEC 16 2004 Dear Tanya: RIVERSIDE COUNTY TRANSPORTATION COMMISSION RTA has been pleased to participate in the development of a reserve policy for the apportionment area of Western Riverside County. Representatives from both the RTA Board of Directors and staff participated in all policy development meetings and workshops. They were very productive and allowed for discussion and input of ideas and concepts from all stakeholders. Based on those meetings, RTA feels confident that the Riverside County Transportation Conunission (RCTC) will develop a reserve policy that considers all the suggestions and concepts discussed to ensure continued transit operations in the event of a revenue disruption or capital acquisitions. Although I would have preferred to discuss this with the RTA Board of Directors' Budget and Finance Committee, I do understand RCTC's urgency to secure this policy. I thank you for the opportunity to participate in the discussion and trust RCTC staff will determine an appropriate reserve level, with documented processes to access the reserve, for all transit operators. If you have any questions, please feel free to contact Larry Rubio at 951-565- 5022 or by e-mail lrubio(a�riversidetransit.com. Regards, 04 - Winningham Chairman of the Board of Directors JW/mh c/ RTA Board of Directors L. Rubio, RTA E. Haley, RCTC 6 R.23.7 - l D3Ci'lr RIVERSIDE COUNTY TRANSPORTATION COMMISSION TRANSIT POLICY COMMITTEE SIGN -IN SHEET January 6, 2005 NAME AGENCY E-MAIL ADDRESS ,4Mea- Moore__ es, uue6 644 ec & h er CI 0C et v QM...m ci rwarr.44.. P/e.t r�� t/ s T /.1.0/e - a / / Sie.A." Dew&v. i,,.." ,,,..... e. „deg. kraa. I e.... le_. ...c..- 1 1 ii _D -es -e I- - .1-7-' .2 -�+A,S v u dk2c- U ►\r"7"- � F�I� >� - &)0Rw ,7'e, J1v:L1Ie ("0.tie. 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