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Home My Public Portal About12-13-2001LPFA_sp. 1~ . i'!~ +' ~ « Th6s Agenda contai~ brief ~general ,descrip"tion of eacl~m to be considered Copies of the Staff reports or ofher written documentation relating to each item of busmess referred to on the Agenda are on file in the Office of the City Clerk and ar~ available for public -inspection A person who has a question concerning any of fhe agenda ~tems may call the City Manager at (31D) 603-0220, ext 200 Procedures for Addressinq the Council IN ORDER TO EXPEDITE C1TY COUNCIL BUSINESS, WE ASK THAT ALL PERSONS WISHlNG TO ADDRESS THE COUNCIL FILL OUT A FORM PROVIDED AT THE DOOR, AND TO TURN IT IN TO THE CITY CLERK PRIOR TO THE START OF THE MEETINC~ FAILURE TO FILL OUT SUCH A FORM WILL PROHIBIT YOU FROM ADDRESSING THE COUNCIL IN THE ABSENCE OF THE UNANIMOUS CONSENT OF THE COIJNCIL ~.e ~: AGENDA ITEMS ON FILE FOR CONSIDERATION AT THE SPECIAL MEETING OF THE LYNWOOD PUBLIC FINANCE AUTHORITY TO BE HELD ON DECEMBER 13, 2001 63DPM COUNCIL CHAMBERS 11330 BIJLLIS RD , LYNWOOD, CA 90262 ARTURO REYES PRESIDENT FERNANDO PEDROZA VIC;E PRESIDENT PAUL H RICHARDS, II MEMBER CF~IEF ADMINISTRATIVE OFFICER RALPH W DAVIS, III SECRETARY ANDREA L. HOOPER ~ OPENING CEREMONIES CALL TO ORDER 2 RQLL CALL OF MEMBERS Louis Byrd Ramon Rodriguez Paul H Richards, II Fernando Pedroza Arturo Reyes TREASURER IRIS PYGATT 3 CERTIFICATION OF AGENDA POSTING BY SECRETARY PUBLIC ORAL COMMUNICATIONS (Regarding Agenda Items Only) PUBLIC ORAL COMMUNICATIONS IF AN ITEM IS NOT ON THE AGENDA, THERE SHDULD BE NO SUBSTANTIAL DISCUSSION OF THE ISSUE BY THE LYNWOOD PUBLIC FINANCE AUTHORITY, BUT IT IS ALL RIGHT FOR THE LYNWOOD PUBLIC FINANCE AUTHORITY MEMBERS TO REFER THE MATTER TO THE STAFF OR SCHEDULE SUBSTANTIVE DISCUSSION FOR A FUTURE MEETING (The Ralph M Brown Act, Government Code Section 54950-54962, Part III, Paragraph 5) :~. DEC ~ ; ~nr, ~.!~-~-~ REC IV~D CiTY OF LYNU~J00U CITY Ct FRKS OF~ICE pIW ~'~ ~-~gsg~~p~~wu~:~~2s3~4M5~6 ~ ~~~~ - ~~~~ ~~ LOUIS BYRD MEMBER RAMON RODRtGUEZ MEMBER FINANCE DIRECTOR ALFRETTA EARNEST ~ . 4 Take Out Assessment Comments As part of the Strategic Planning Process, (Goal 1, Ob~ective 8, Strategy 3), it was suggested that the City of Lynwood "review the feasibility of instituting a take out assessment on fast food restaurants" In order to review the alternatives for implementation, an outside consultant conducted a review of revenue alternatives for Litter Abatement Programs This study was presented to this body on June 18, 2001 Recommendation Staff respectfully requests that the President and Members of fhe Lynwood Public Finance Authority prov~de further direction relative to thrs matter and refer this item to the License and Taxation Committee for further consideration ADJOURNIVIENT MOTfON TO ADJOURN TO THE REGULARLY SCHEDULED MEETING ON DECEMBER 18, 2001 AT 6 00 P M, IN THE COUNCIL CHAMBERS OF THE CITY HALL, 11330 BULLIS ROAD, CITY OF LYNWOOD, CALIFORNIA. ~ MEMORANDUM DATE December 13, 2001 ~ TO HONORABLE PRESIDENT AND MEMBERS OF THE LYNWOOD PUBLIC FfNANCE AUTHORiTY ~1~ .. FROM Raiph W Davis, III, Chief Administrative O' ~. ~~~ BY Autra C Adams, Program Development Coordinator ~ SUBJECT Take Out Assessment PURPOSE To have the President & Members of the ~ynwood Public Finance Authority provide further direction relative to this matter and refer this item to the License and Taxation Committee for further consideration BACKGROUND As part of the Strategic Planning Process, (Goal 1, Objective 8, Strategy 3), it was suggested that the City of Lynwood "review the feasibility of instituting a take out assessment on fast food cestaurants" On December 19, 2000 the City Attorney's Offi~e made a presentation to this body regarding the legal issues involved with an anti-litter regulatory fee In orderto review the alternatives for implementation, an outside consultant conducted a review of cevenue alternatives for Litter Abatement Programs This study was presented to this body on June 18, 2001 ANALYSIS 1Nhen this issue was first introduced, staff brought forward the model of the City of Chicago as an example of where such a fee had been implemented elsewhere Citv of Chicaao In Chicago, the anti-litter tax began on March 1, 2000 It is an additionaf'/2 percent ( 5%) tax that applies to the sale of carryout food sold in the City by restaurants, cafeterias and other places for eating Carry out food is basically defined as any food prepared for immediate consumption that is wrapped or enclosed in disposable containers that allows a consumer to carry the food out of the establishment and immediately consume it. For example, anything sold at McDonalds wou(d automatically be taxed even if the purchasec consumed the food on premises If a large pizza is purchased for carryout the fax is not a'ssessed, however, if an individual slice of pizza is purchased at same establishment the tax is assessed The anti-litter tax is currently in litigation, however, the courts have ruled that the City can continue to coNect the tax until the court makes a determination on the issue Citv of Lvnwood DMG Maximus worked with staff to determine the current expenditures of the City of Lynwood that can be attributed to fast food establishments and the amount of revenue that is already recovered in fees California State law and the implications of Proposition 218 prevent the City of Lynwood from being able to implement an anti-litter tax in the same fashion as Chicago However, it could be directly replicated with a ballot measure and voter approval !n addition, the consultant provided other recommendations on how the city could recoup revenue for the expenditures associated with litter abatement. Attached is the final copy of the feasibility studythat was conducted that includes several alternatives foc revenue generation RECOMMENDATION Staff respectfully requests that the President & Members of the Lynwood Public Finance Authority provide further direction relative to this matter ATTACHMENT r~ ~ . REVIEW OF REVENLIE ALTERNATIVE FOR L1TfER ABATEMENT PROGRAMS CITY OF LYNWOOD CALIFORNIA FlNAL REPORT )urvE 18, 2001 Max~n~us, ~n~. Oalcland, California '_ . ~ ~ ~ ~ - ~~IMUS Helping Government Serve The People June l$, 200i Autra Ac~ams City Manager's Office City of Lynwoocl l 1330 Bultis Road Lynwood, CA 90262-3693 Dear Ms Adams MAXIMLIS, lnc. is pleased to present you with this report assessing the various a1#ematives for raising revenues related to litter abatement programs in the City oE Lynwooci As always, it has been a~leasure to be of service to the City of Lynwood Please let us know if we may be of service to you again Sincerely, ~ ~% \ _..~Q. ~_-.---- ~ ---~'%~.--~-~ Bri~n A Foster, CMC Senior M~nager r 33~ Hegenberger Ro,~d Suite 333 • Oakland, CA 94621 • 510 635 37i7 • FAX 510 635 377£3 r° • • TABLE OF CONTENTS (NTRODUCTION Background "" 1 ........ 1 Research Metfiods .; 2, Final Comments .. ... . 2 SECTION 1 CITTER ABATEMENT PROGRAM COSTS ,.. ,.,.. 3 .................. 8ackground 3 Cost Overview ;: 3 Current City Programs 4 SECTION 2. REVENUEGENERATING ALTERNATIVES Introduction ,,,, 7 Revenue Alternatives .. 7 ........... Aiternative 1 Regulatory Fee ,,,,,,,,,,,,,,,,,,,,,, .. 7 8 Aiternative 2: Wrapper Tax ... .......... ,,. ., .................. Alternative 3 Street Sweeping Fee lncrease ,,,,,,,,,,,,,,,,,,,,,,,, 11 13 ,,,,,,,,,,,,,,,, Alternative 4 Solid Waste Agreement Provisions 14 Alternative 5 Litter Abatement Fee 15 Alternative 6 Special District Fee Increases i6 Alternative 7 New Special District Fees 1 a Revenue Alternative Summary 20 ATTACHMENT 1 REVENUE ALTERNATIVE MATRIX 21 ~ ~ INTRODUCTION BACKGROUND In May 2001, the City of Lynwood (City) contracteci with DMG-MAXIMLIS, (nc. (MAXIMLIS) to review alternative revenue mechanisms designed to support the City's litter abatement nrograms The intent oE the study was to identify any unfunded costs relateci to litter abatement and to develop a list of alternative revenue sources that could fund those costs The City estimates that its current litter abatement progr~ms are costing the City approximately $540,960 annually in General Funds The detail supporting these costs is included in Section ] of this report The City and MAXIMLIS identified seven alternative revenue mechanisms that could generate some or all of this unfunded amount, as follows 0 Regulatory Fee ^ Wrapper Tax ^ Street Sweeping Fee lncrease D Solid Waste Franchise Agreement ^ Litter Abatement Fee ^ Existing Special District ^ New S~ecial District Each of these revenue alternatives presents opportunities and risl<s Some are more efficient at raising funds, some require popular votes, and others may Ue subject to legal challenge Each of the revenue alternatives is discussed in Section 2 of the report 1:~' P .i _ • ~ SECTION 1: LITTER ABATEMENT PROGRAM COSTS BACKGROUND Litter abatement is a common function of local governments throughout the State of C~lifornia These services are proviNed through government programs, communiry groups, special districts, and contract providers- voth public ancl priv~te In Lynwood, these services are provicled by a variety of inethods This Section ] documents current littler abatement programs, methods. of service delivery, program costs,. and revenues (where applicable) This study used a broad definition of the term "litter abatement " S~ecifically, NIAXIMLIS included for analysis in this study those City-identifiec~ nrograms (or program components) that moved litter (or potential litter) from public are~s to a landfill or processing facility COST OVERVIEW The City has~ four categories of litter abatement programs currently in pl~ce, as follows 0 Alley and Street Maintenance ^ Street Sweeping O Bus Stop Reftise Remova{- ^ Community Programs 3 r~ ~ Street Sweeping The City contracts with, Nationwide Environmental Services (NES) to provide sweeping of all City streets on a weelcly basis The City separately pays for the bin and dumping charges for all w~ste collected throu~h street sweeping The contract for this service is monitorecl by the Dep~rtment of Pu~lic Worlcs Table 3, below, summarizes the Street Sweeping Program's $243,300 estimated costs in FY 2000-p] Table 3 Street Sweeping Program Costs Cost Cateqorv Costs Street Sweeping Seryice Contract (NES) $ i 72, ] 00 Bin 8. Dumping Fees 30,600 Em~lovee Costs 8. Overhead 40 600 Total $243,300 Inc. The Street Sweening Program is supported by fees charged to property owners In FY 2000-0 ], the City is expected to generate $] 82,000 in revenues for its Street Sweeping Program, which would leave the ~rogram with ~n annual deficit of $6];300 Bus Stop Refuse Removal The City contr~cts with Western Waste Management to provide removal of refuse from containers such as Uus shelters The Department oF Public Worlcs monitors this contract Western Waste Man~gement ~rovic~es bin and dumping services as part of the contract fee TaUle 4, below, summarizes this program's $20,160 estimated costs in FY 2000-Ot Table 4 Bus Stop Refuse Removai Program Costs Cost Category Costs Service Contract $ ] 6,800 Ern~lovee Costs 8, Overhead 3.360 Total $20, l 60 The City does not generate any special .revenues to support this program Thus, the City's unsupported expenditures related to Bus Stop Refuse Remov~l are approximately $20, l 60 in FY 2000-O1 Community Programs There ~re two eommunity programs that provide litter abatement assistance within Lynwooci-the Young People of Lynwood (YPL) Program and the Bloclc Watch (BW) Pro~ram )ust as with street sweeping refuse, the City's Public Worl<s Department provides for the dispos~l of YPL's collectecl refuse at the City's Corpor~tion Yarci, anci supports the YPL program by paying for the bin and dumping fees ~ i ~ SECTION 2: REVENUE GENERATING ALTERNATIVES 1NTRODUCTION Section l oE this report provided a summary of the Gity's four major litter a~atement progr~ms, and it det~iled the unfunded ba]ance of approximately $540,960 in FY 2000-01 Section 2 provides an outiine of various alternative mechanisms for generating the revenue needed to support the Ciry's .litter abatement programs The alternatives are cornpared with respect to economic efficiency, political acceptance, administrative complexity, revenue generation potential, and implementation timing REVENUE ALTERNATIVES Whi1e one coulci develop an exhaustive list oF alternative revenue- generating mechanisms to su~port any given ~rogr~m, tynically a City will focus on only those alternatives that have the most relevancy and appropriateness to support any given program There are seven alternative mechanisms. reviewed in this report, as follows ^ Regulatory Fe~-A regulatory fee for fast food restaurants and ~ pacl<age Iiquor stores would allow the City to mitigate the specific litter impacts ~enerateci by~these businesses This fee would - resemble the City of Chicago's Litter Tax ^ Wrapper T~c- A tax on item wrapners from fast food restaurants would target a specific form of litter ~ ~A~vi~~ these estaUlishments contribute to the City's overall litter problem The City does not have a testeci model to replicate in this regard, as there are no lcnown agencies that have undertai<en a similar anaiysis of this nature There are at least two possible appr.oaches to estimating the litter im~acts, as fol lows O The City could assess the litter impact of fast food restaurants and liquor stores based on a survey This survey might include ~ measure of specific surface litter, iitter collecteci through street sweeping, litter found in pubiic trash receptacles, and litter removed by the street maintenance crews The level of litter and method of removal could then be com~ared to the overati City program costs to assess the specific impact Once the City determines tlie cost im~act, it could allocate those costs to select ~usinesses in specific areas A survey of this nature would be a major undertalcing and require a substantial commitment of resources This method would also lilcely face a great deal of opposition from individual business owners who would c~uestion the linic between litter and their business Owners may also contend that they are neg~tively impacted by other businesses in the area or the presence of hi~h litter areas such as bus stops, parlcs, and schools. The legat ramifications and uncertainties related to this model have not been considered Nor has the impact of ~ny ~usiness's possi~le mitigation measures designed in response to the fee been considered For example, if a business instituted a new neighborhood clean-up program to reduce that business's contribution to litter, would that business receive a revate on the litter fee? ^ A second rnethod involves determining the litter impact based on professional judgrnent With this method, the City Manager would develop an impact estimate based on the opinions of subject experts, general research of litter ~atterns, and ~rofessional experience Once the impact has been assessed, the fee can be equitably distributed ~mong the concerned businesses by apptying an appropriate rate to gross receiPts With this method, gross receipts are used~ as an indicator of business volume, and therefore serve as a rneasure of actual or anticipated litter generation This methocl would be rel~tively easy to impiement, with the greatest controversy being in cietermining the litter impacts of the business categories i~here would Iilcely ~e some levei of o~position from business owners who would claim that more successful businesses pay a larger fee, regardless of actual litter impacts Inc. Revenue Generating Alternatives r I I t • ~ ~ MAXIMI IC ; _ In orcier to generate $2] 7,000 in annual revenue, the City would have to ~ estabfish a fee level of 0 765 percent on gross receipts among its 86 Fast food establishments and 1 l paclcage liquor stores (rounc~ing u~ to 0 765) _ The Ciry wouid assess this 0 765 percent fee to the 97 establishments' ; ~ ` $28 5 miilion in annual sales to~generate the $2I 7,000 '__ Tabie 6, Uelow, iliustrates the fee that would be ~aid Uy businesses in samnle gross receipts levels Actual business names are not used to ' maintain confidentiality of sales information Table 6 Regulatory Fee Example Selected Rate Businesses Business Type Sales fee Rate Fee Fast Food Establishments High Volume $~,940,700 765% $14 846 Medium Volume 578,400 765% , 4 425 Low Volume 82, l 00 765 % , 628 ~ Padcage Lic~uor Stores ; High Volume 519,100 765% 3,n7 i ~ Medium VolUme 266,300 765% 2 037 " Low Volume 110,200 765% 843 ~ ~ Table 6, above, shows the typical fees that business would pay under a ` m~cimum revenue model Even with these maximum rates, the City would ~ only be ~vle to generate $217,000, leaving an unfunded annual balance of ' $323,960 Thus, this model's capability of raising revenue rnust be ` considereci poor ~ ~ Timing , This regulatory fee could be implemented once the City determines the litter impacts of the specific businesses Depending on the method chosen, the ' City could be able to implement this fee within a 3-6 month time frame, ~ which rates this altemative hi~uh with respect to timing ALTERNATIVE 2. WRAPPER TAX Description The Wrapper Tax altern~tive places a llse T~c on item wrap~ers at fast food restaurants or other items sold at businesses As such, the City would assess business a tax on all wrappers that pass through the establishment The City venue Generating Alternatives r i MAXIMUS, Inc. ALTERNATNf 3: STREET SWEEPING FEE INCREASE bescription A relatively simple method of raising revenue would be to increase the City's existing Street Sweeping Fee The City currently assesses a fee of $18 84 per year for a typieal property owner This fee level does not currently recovering all street sweeping program costs-the program runs at an annual deficit of $6l ,300 The operating c~eficit will increase if Fees remain the same and program costs increase-as the current service contract al lows Political Consideration v This alternative does not require voter approval, and could ~e implemented by a majority vote of Council As with any fee increase, there would lilcely be some level of public opposition Thus, political consideration of raising the fee for full recovery purposes is low Administrative Jssues Since the City already collects this fee through the consolidated utility vill, there are almost no administrative issues associated with a fee increase, other than changing the rate and notifying ratepayers of the change Economic Efficiency The City would gain revenue to cover program costs that are currently being subsidized using revenue mechanism already in place The efficiency of collecting these fees is very high Revenue Potential In order to recover the full costs of the Street Sweeping Program, the City would need to increase the fee from $] 8 84 per year to $25 00 ~er year, an increase oF 33 percent The City Council has the authority to increase tt~is fee immediately, and any such increase could a~pear on the next utility bill While this ~Iternafive would recover all Street Swee~ing Program costs, it would not raise ftands f.or the other City-provided litter programs Thus, the ~increase in fees would represent only l 1 percent of the City's unfundecl balance for litter programs, or only $61,300 Timing Any increase to the Street Sweeping Fee could be implementeci immediately, thus, there would be no delays in recovering program costs Revenue Generating Alternatives 13 !_ ' ~ MAXlMUS, Inc. ~ , t t' Revenue Potential ~ While this aiternative does not produce direct revenue, it does reduce the i City's overall cost of ~roviding litter a~atement programs by $204,000 per ;, year Thus, implementing this altemative would reduce the City's unfunded ' llalance by 38 percent ,; , Timing ~ The revenue from this alternative would Ue generated subsequent to the ; adoption of a new solici waste franchise agreement, which would delay new E revenues ~y at least a year ALTERNATIVE 5, LITTER ABATEMENT FEE Description Another alternative to raising revenue is to implement a Litter Abatement Fee that is imposed on all property (p~rcel) owners According to the City Attorney., the City provides a needed service to ensure health anci safety and can assess a fee to provide that service Political Consideration the Ciry Councii, through major,ity approval, has the authority to impose a fee for this specific purpose While this type of fee would not require voter appro~al for implementation, the City would have to meet the following cequirements to allow this new fee under Proposition 2l8 ^ Total revenue from the fee cannot exceed actual service costs 0 Revenue coulci only be spent on litter abatement programs ^ There needs to be a linlc between the fee anci the actual or anticipated impact For other fees, this linlcage ~s ty~ically achieved ~y categorizing ~ro~erties--such as residential, commercial, industrial-and developing a fee schedule that addresses the typical impacts of these categories Often, an additional measure such as road frontage footage is used to distinguish ~mong im~act size_within the categories Administrative Issues Initially, implementing this Fee would ~e aciministratively complex The City would have to develop a fee scheciule that meets the I'inlcage requirement described .above There are several consultir~g firms within California, MAXIMIIS being one of them, that develop these types of fee schedules for agencies The City would need to conduct periodic analyszs to measure costs and to ensure that the fee provicies the City with full reim~ursement Once a fee schedule is develo~ed, revenue administration would L~e minimal ~s the fee would be included on the consolidated utility bill- evenue uenerat , MAXIMUS, I Attorney, an argument that litter abatement promotes business activity would be tenuous ^ L~ndscape District and Lightin,g District-These two districts were formed for specific im~rovement.purposes with all property owners paying assessments According to the City Attorriey, incorporatin~ litter abatement programs into these districts' purposes would be tenuous and coulci expose the City to citizen opposition anci possible legal action Political Consideration Any increases in district assessments wouid rec~uire a two-thirds voter ap~roval under Proposition 2l 8 llsing revenues of these districts could face legal chalienges as the districts were developed for snecific purposes other than litter a~atement Administrative Issues The administrative of increasec~ assessments through existing special districts would be minimal, as these districts and their revenue collection methods are in existence Economic Efficiency The City would incur costs for a public information cam~aign to seelc voter approval, and there would be the cost of conducting the election itself Otherwise, the collection of fees would lle highly efficient as a~ revenue gener~ting mechanisrn Revenue Potential Revenues generated under these districts could only be spent within the district areas The Landscape and Lighting Districts encom~ass citywide Uounclaries, and have the potential to cover all litter abatement program- costs The PBIA would be aUle to raise revenue only within its district area. Llsing either the Landscaping or Lighting District, the City could generate the full $540,960 in "unfunded programs If one were to assume that 40 ~ercent of all Iitter in Lynwood is concentrated in the physical area encompassed by the I'BIA, then that district could generate ap~roximately $216,400 towards the unmet need Timing This alternative could not be implemented until the City undertoolc a vote, which would delay practical implementation until January 1, 2002 at the earliest Revenue Generating Altematives 17 ~ MAXIMUS, Inc. ' Fin~lly, if collection and distribution of revenues were managed through ' sales tax increments, then the City's ac~ministration would be low, but ~ businesses woulci need to ~dopt anci use a new set oF sales tax rates , Further, the Sta"te charges an adrninistrative fee of 1 percent on the total of ' collected sales t~c revenue. Thus, the overall complexiry could increase to a i high level i ; Economic Efficiency " The City would incur costs for a public information campaign to seelc voter ~ approval There is also the cost of conducfing the election itself further, i with such a broad range of revenue mechanisms available, the economic ' efficiency could range from 1ow to medium overall Revenue Potentiai The following three revenue methods eould be employecl vy these districts 0 Property Assessments-The three types of districts discussed ~bove could all be funcied by property assessments an the property tax vill This method is currently em~loyed for the Landscape and Lighting Distcicts Revenue generation is based on the amount proposed by the City and ~~proved by the affected voters If structurec~ to include all areas of the City, this ~Iternative cou[d raise the full $540,960 needed to support litter aUatement ^ Business Assessments-This revenue method is sometimes used to fund a BID This type of assessment is useful in situations where property owners are not supportive of the district, but business owners have shown supnort. Ag~in, revenue generation is ~ased on the amount accepted by the affected voters If this district inclucled only 40 percent of Lynwood's boundaries, then this district. could gener~te ap~roximately $2] 6,400 towards the unmet need ^ Sales Tax Revenue-It is within the City's power (with voter approval) to impose a sales tax of no greater than 0 5 percent to fund ~ special district While examples of this approach are uncommon, several cities have func~eci special districts for hospitals, public s~fety, and ro~d improvements through additional sales t~ces Given the City's estimated sales tax revenue for FY 2000-O1 of $2.3 million, this mechanism has the potential of raising $] l5 million-far more than needed for litter abatement programs Timing This alternative could not be implemented until the City (or members of the proposeci clistrict area) undertoolc a vote, which woulci delay practical im~lementatiori until )anuary 1, 2002 at the earliest ue ~enerating Alternatives f~' i ATTACHMENT 1' REVENUE ALTERNATIVE MATRIX ~ C~ Revenue MAXIMIJS, lnc. 1 + ~ ,_, 4 a i « ~ a R °1 c ~ c d =a o ~ c ~ ~. ~ a=i ~ ~`o L U ~ Y ~ ~ Q ~ E ~ ~ ~ ~~ a E ~ a~ ~ E> _ °1 a N ~ o D°' - _ ~ N ~ dn no~ _ - = E o ~ ~ ~ o E ~a ~o _ ~ E N ~ a`~~d ,-'-u E ~ ~ o E ~. t - a ~ EL ~ v ~ ~ mo~ ~ ~ ~ ~m a,c,o o.c aL ~= .a~, 5 = ~ o. _ ~'E°"' ~ ~ ~- t. 3 ~~ o S ~ rt~~no ~°E`Om - U m s o' . y ° _ v -i ~c> - - ° o 0 ~.._, .c .~ ~- ~ . d ~3 0 y.. 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