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Home My WebLink About20022644.tiff HEARING CERTIFICATION DOCKET NO. 2002-71 RE: CHANGE OF ZONE #613 FROM THE A (AGRICULTURAL) ZONE DISTRICT TO PUD (PLANNED UNIT DEVELOPMENT) ZONE DISTRICT FOR EIGHT (8) LOTS WITH E (ESTATE) ZONE USES AND ONE (1) LOT WITH A (AGRICULTURAL) ZONE USES, ALONG WITH 30.13 ACRES OF OPEN SPACE - CATTAIL CREEK GROUP, LLC A public hearing was conducted on October 2, 2002, at 10:00 a.m., with the following present: Commissioner Glenn Vaad, Chair Commissioner David D. Long, Pro-Tern Commissioner M. J. Geile Commissioner William H. Jerke Commissioner Robert D. Masden Also present: Acting Clerk to the Board, Esther Gesick Assistant County Attorney, Lee Morrison Planning Department representative, Sheri Lockman Health Department representative, Pam Smith Public Works representative, Peter Schei Court Reporter, Jane Escobar, Wilson George Court Reporters, Inc. The following business was transacted: I hereby certify that pursuant to a notice dated September 13, 2002, and duly published September 18, 2002, in the Tri-Town Farmer and Miner, a public hearing was conducted to consider the request of Cattail Creek Group, LLC, for Change of Zone #613 from the A(Agricultural)Zone District to the PUD(Planned Unit Development)Zone District for eight(8)lots with E (Estate)Zone uses and one (1) lot with A (Agricultural)Zone uses, along with 30.13 acres of open space. Lee Morrison, Assistant County Attorney, made this a matter of record. Sheri Lockman, Department of Planning Services, presented a brief summary of the proposal and entered the favorable recommendation of the Planning Commission into the record as written. Ms. Lockman gave a brief description of the location of the site and surrounding uses. She stated the property is designated as "Prime" farmland, with a small portion on the east side within the 100-Year Flood Plane, which will be in the open space. Ms. Lockman stated 14 referral agencies reviewed this proposal, and ten responded favorably or provided comments that have been incorporated into the Conditions of Approval. She stated although the Sheriff's Office did not respond, the applicant has provided evidence that they have addressed the Sheriff's concern expressed at the Sketch Plan phase. She further stated the Division of Wildlife submitted a late referral with recommendations, the City of Greeley recommends denial based on the overall density, and various letters and petitions of opposition have been received from surrounding property owners. Ms. Lockman stated the applicant does have an agreement with the North Weld County Water District to service the homes and lawns, and the Agreement includes a fee of $140,000 for off-site improvements to ensure adequate water for the applicant and the neighborhood. She further stated irrigation for the open space will be from 20 shares of Woods Lake Mutual and one-half share of Larimer Weld water, which should be adequate for drought tolerant grasses. Ms. Lockman stated the Department of Public Works is requiring the internal 2002-2644 PL1628 HEARING CERTIFICATION - CATTAIL CREEK GROUP, LLC (COZ#613) PAGE 2 road to be paved and that the applicant proportionately share the cost of improving Weld County Road 70 from the westernmost access east to Weld County Road 31. She stated there will be a bus pull-up at the entrance of the subdivision. The Weld County Department of Public Health and Environment has reviewed and approved the septic plans,which exceed the setback requirements, and Lots 1 through 8 will only be allowed one animal unit each. She further stated the applicant has requested an administrative review of the Final Plan, which will need to be included in the motion if the Board concurs. Responding to Commissioner Geile, Ms. Lockman stated this will be a Planned Unit Development with E(Estate)Zone uses,which only allows one animal unit per acre. Peter Schei, Department of Public Works, stated there is an agreement with the applicant for sharing the proportional costs of improving Weld County Road 70, and staff is also requesting the applicant pave the internal road, which is consistent with similar developments in the area. Responding to Commissioner Geile, Mr. Schei stated Condition of Approval #2.1 requires the Homeowners'Association to maintain the internal road for one year, at which time the County can accept it for maintenance if built to County standards. Mr. Morrison stated the language is also appropriate if paving is not required, because then the maintenance will remain the responsibility of the Homeowners' Association. Responding to Commissioner Jerke, Mr. Schei stated the development will be accessed from Weld County Road 70. Mr. Morrison stated although Weld County Road 70 is gravel, paving the internal road helps mitigate future dust complaints. Mr. Schei stated upon review,staff felt it would be inappropriate to require the applicant to pave Weld County Road 70, rather, they are requiring road stabilization for one mile of Weld County Road 70. Commissioner Jerke commented the stabilization will still be a significant cost. Responding to Commissioner Long, Mr. Schei reviewed the traffic counts for Weld County Road 70. He further stated the deep road stabilization is a one-time cost and should last for a significant amount of time. Pam Smith, Department of Public Health and Environment, stated the percolation tests were conducted during the middle of a wetter summer in 2001 and the irrigation season. She stated the percolation rates were all within the State and County guidelines on all of the buildable lots, and will be acceptable for conventional septic systems. Ms. Smith stated the septic envelopes are 100 feet from the flood plain boundary, and each lot has two septic envelopes,which are 2,200 square feet in size. Responding to Commissioner Jerke, Ms. Smith stated Conditions#2.E through#2.G are based on State Air Quality requirements. Mr. Morrison added the State requirements pertain to the construction phase. Anne Best Johnson, Todd Hodges Design, LLC, represented George DuBard, Manager for the Cattail Creek Group, LLC. She reviewed the location of the site and the surrounding uses. She stated most of the lots in the area have been created through the Subdivision and Recorded Exemption processes. Ms. Johnson stated the applicant met with the current oil and gas owner, Thomas Oil and Gas Operating Company, which was not a Condition of Approval; however, they determined the development will not adversely affect the current or future mineral operations. Ms. Johnson stated the property includes a 120-acre agricultural lot which will remain in agricultural production using a pivot sprinkler, with a 5-acre building envelope using the current access from Weld County Road 70. The proposed development has eight lots which have been clustered on the eastern portion of the site,which is the least agriculturally productive land. Ms. Johnson stated the development will be accessed by a paved internal road extending from Weld County Road 70, and there will be a common mail and school delivery station complying with the School District's requests. She stated the site will also have common open space which will be accessible to each of the lots, and it will be planted in drought grasses approved by the NRCS. Ms. Johnson stated 2002-2644 PL1628 HEARING CERTIFICATION - CATTAIL CREEK GROUP, LLC (COZ#613) PAGE 3 a strip of land on the eastern side of the open space is in the flood plain. The Homeowners' Association will be responsible for maintenance and irrigation,and the amount of water delivery will not change as a result of this application. She stated the North Weld County Water District has indicated it has the capacity, willingness, and ability to serve this development, and the water will also be available for irrigating the one-acre lots. Ms. Johnson stated the clustered formation will help protect the local habitat, the Covenants are currently under review, and the applicant has agreed to pay the proportional cost of improving Weld County Road 70 with deep stabilization and pave the internal road. She stated the Health Department has reviewed and approved the percolation rates,and improvements will be made to the water line,which will be available to others in the area, and constructed at the expense of the applicant. She further stated they are currently working with the Eaton Fire Protection District to meet its standards, and appropriate notices were sent to the mineral and surrounding property owners. Responding to Chair Vaad, Ms. Johnson clarified the name of this development changed from the Shepardson PUD to the Cattail Creek PUD between the Sketch Plan and Change of Zone application. In response to Commissioner Geile, Ms. Johnson stated the ownership remains the same. She displayed a map of the surrounding parcels which are less than five acres in size, within three miles of the proposal, and reiterated there will be one internal road, rather than multiple accesses, and it is compatible with the surrounding agricultural area because they will be retaining a large agricultural parcel under irrigation. She further stated the Right to Farm Covenant will be placed on all plats, in the Covenants, and on all sales literature for the individual lots. Responding to Commissioner Geile, Ms. Johnson explained the General Warranty Deed, dated May, 2002, is between John and Deborah Shepardson and Cattail Creek Group, LLC; however, the Shepardsons are still involved. George DuBard, Managing partner,stated he owns 24 percent, the Shepardsons own less than 50 percent, and there are two other partners. He stated the Shepardsons sold the land while retaining interest in the LLC. In response to Commissioner Jerke, Ms.Johnson stated water is available for irrigation,and they have a couple of options for vegetation which will help restrict noxious weeds. She further stated this is not a formal cluster PUD application; however, it does follow some of the same principals. Michael Miller, surrounding property owner, stated he represents 173 people who have signed a petition of opposition. He displayed a Power Point Presentation, marked Exhibit BB, which he reviewed for the record. Mr. Miller stated 80 percent of the petitioners live within 1.5 miles of the development, and 20 percent of the signatures represent people who own property or work within 1.5 miles. He stated a portion of his presentation was not made available to the Planning Commission due to a concern regarding a conflict of interest in relation to his position as a Planning Commissioner. Mr. Miller stated the field is served by a new concrete ditch which provides water for the pivot sprinkler; however, the homes will be situated east of the ditch, separating the open space from the ditch. He stated the area designated for open space is 30 acres of prime farmland which should remain in agricultural production. Debra Page, surrounding property owner, stated she lives directly west of the proposed development and this will damage their prime views of the field to the east and the creek. She stated they purchased their land from Mr.Shepardson,who indicated the remainder of the property could not be developed for at least ten years subsequent to a recent Recorded Exemption. She stated they value the rural lifestyle, and the proposed one-acre lots are not consistent with the current rural setting. Ms. Page stated the eight homes could potentially produce 30 to 50 residents, the homes will be located 50 feet from her eastern windows, which will disrupt her view, and she 2002-2644 PL1628 HEARING CERTIFICATION - CATTAIL CREEK GROUP, LLC (COZ#613) PAGE 4 expressed concern with conflicts during the construction phase. She further stated the applicant has not proposed a buffer for her property, and the internal road will be adjacent to the property line. Responding to Commissioner Geile, Ms. Page stated they purchased their property from Mr. Shepardson who indicated the land to the west would continue to be farmed; however, she does not have a written statement. She stated they own the 10-acre island lot which is surrounded by the proposed site. Mike Page, surrounding property owner, stated the promises made by Mr. Shepardson have not been kept, so he sees no reason to believe statements made regarding this development will be completed. Mr. Miller stated he owns the property to the north, and he expressed concern with their inability to fence the slew because it is located within the flood plain. He stated none of the waterways are owned by the applicant and access to the open space will be limited. He expressed concern with the potential for trespassing by new children living in the area. He stated there are various attractive nuisances in the area, and surrounding property owners will be liable if there is an injury or death. Mr. Miller stated there is no other way to mitigate these issues,than to deny the proposal. He stated he intends to use his property for a wildlife refuge and eight new residences will not be compatible with the area. Barb Perusek,surrounding property owner,stated the approach to the intersection of Weld County Roads 31 and 70 is very hazardous. She reviewed the various traffic routes in the area, and expressed concern with new residents complaining about dusty roads. She stated dust abatement is not very effective and she feels the additional traffic on the dirt roads will ruin their quality of life. Bill Perusek,surrounding property owner,stated the application is not compatible with surrounding agricultural uses. He stated many of the current residents enjoy riding horses along the rural roads, and the additional traffic will hinder those uses. He stated the proposed use is contrary to the historical uses in the area, one-acre lots are not large enough for livestock, and the livestock cannot be kept on the open space. Mr. Miller stated the intersection of Weld County Roads 392 and 31 is very busy. He stated an average of 1,000 cars turn left or right from Road 31 onto Road 392. He stated there have been five deaths at this intersection and numerous more accidents, yet there are no improvements planned for this intersection. He further stated children will likely be attracted to the creek, tail water ponds, and oil and gas tank batteries, which are all very dangerous. Mr. Miler stated the domestic water issue has been addressed with a commitment for a new water line; however, he reviewed the water available for irrigation of the open space and indicated the amounts are not adequate. Vicki Mill, surrounding property owner, stated she lives directly across the road to the west. Ms. Mill stated she is the Secretary treasurer of Woods Lake Mutual, and explained the 20 shares will only be good for seep water, not early or storage water. She stated due to the drought this year, Woods Lake Mutual only delivered six-tenths of a share, which is not enough to irrigate 30 acres of open space. She further stated the half share of Larimer Weld water will only service approximately five acres. Ms. Mill requested the proposal be denied because there is no lateral to carry water to the site for irrigation of the open space. Responding to Commissioner Jerke, Ms. Mill stated on an average year, they would be able to deliver 20 acre feet of water, and explained 2002-2644 PL1628 HEARING CERTIFICATION - CATTAIL CREEK GROUP, LLC (COZ#613) PAGE 5 the share holders receive seep water that comes into Woods Lake, proportionate to the amount of shares they hold. Ruben Hergert, surrounding property owner, stated he farms 237 acres south of the proposed development,and he has been president of the Woods Lake Mutual Water and Irrigation Company since it started. He stated there is no way the Woods Lake system can deliver water to this development. He indicated the location of an old ditch, which has since been removed to accommodate the pivot sprinkler. Mr. Hergert reviewed the necessary route to provide water to this site and explained the Cattail Group has no rights to the overflow water from Meyers Lake. He stated the applicant has created two points of diversion using tail water from two other farms,which is not consistent with Colorado water law. He further stated the half share of Larimer Weld water will also be difficult to deliver. He stated the applicant has no ownership of stored water rights to contribute to the Woods Lake Mutual Company, and the applicant has also entered into a Dry-up Covenant,which places further restrictions on the farm and he requested the proposal be denied. Responding to Commissioner Jerke, Pat McNear, Scott Realty Company, stated the old ditch was removed to accommodate the pivot sprinkler,and the applicant has illegally diverted water he does not own to irrigate the 40 acres of the proposed development. He further stated the agricultural portion does decreed water; however, it does not have any ownership in stored water rights. He submitted a letter of opposition, marked Exhibit II, which he read for the record. He stated the applicant intends to sell each lot for $150,000, with custom homes ranging from $350,000 to $500,000. Mr. McNear stated the real estate market in this area will not support those prices, and he proposed that larger lots,created through the Recorded Exemption process,are more desirable. He stated Farm Credit Services has indicated the location does not suit this project, market will not support the proposed prices,and there is already an adequate supply of improved and unimproved properties in the area to supply the market. He commented that covenants are difficult to enforce, and the developer does not have a history of completing a development of this nature. Responding to Commissioner Geile, Mr. McNear stated there is an adequate supply of unimproved lots in this rural sector, and the anticipated sale amounts will not cover the purchase price. Chair Vaad recessed the hearing until 1:30 p.m. Upon reconvening, Mr. Miller stated Coalbank Creek originates 15 miles to the north through seepage. He explained the State owns the water, various people have rights to use it for irrigation, and use is limited to those who own decreed rights. He reviewed the water routes and stated the property owner does not have rights to the water currently being diverted to the proposed site. Harlan Simonson, surrounding property owner, stated he purchased a neighboring farm in November and the primary source of water is from the Woods Lake system. He stated due to the illegal diversion by the applicant, his farm was short of water this past summer, and he plans to take action to ensure this diversion activity ceases. Joe Hoff,surrounding property owner,stated the water allotment changes every year based on the Big T Project, and next year's allotment will only be 30 percent, compared to 70 percent received this year. He stated an average residence in this area uses approximately 100,000 gallons per year,with no livestock, and a moderate yard. Mr. Hoff stated surcharges will be assessed for any usage more than 100,000, and it is unlikely the amount of public water will be adequate for one- acre lots with livestock. 2002-2644 PL1628 HEARING CERTIFICATION - CATTAIL CREEK GROUP, LLC (COZ#613) PAGE 6 Mr. Miller stated it is unlikely the lots will sell at the proposed prices, which will result in unmaintained vacant lots. He stated the use is incompatible, it will increase the local traffic hazards, and it will impose unreasonable liabilities upon the surrounding property owners. He further stated the development will remove prime agricultural land from production, it will change the character of the community, and it will create unmanageable open space. He stated the Covenants have not been available for review, and there are 173 area residents opposed to the proposal with valid concerns. Mr. Miller displayed a list of suggested conditions if this proposal is approved. Responding to Commissioner Geile, Mr. Miller stated this is a prime piece of farmland, which has been farmed profitably with irrigation in the past. He stated the residents in this area value the sense of community and current lifestyle in the area and they are opposed to eight houses located right next door to each other, which is incompatible with the area. He stated this will have a negative impact on the neighborhood and only profit a small group of people. In response to Commissioner Jerke, Mr. Miller stated he has a decree from 1800 for Coalbank Creek, which is sufficient to irrigate his property. He further stated it would be more preferable to develop the land with five or six, 5-acre lots, which are more spread out; however, there would still be significant concerns regarding water, traffic, etcetera. In response to Commissioner Masden, Mr. Miller stated until last year the subject property had adequate water; however, the owner sold 95 shares for$0.5 Million, so the property is no longer irrigated. Responding to Commissioner Jerke, Ms. Page returned to state she owns 10 shares of Woods Lake and 10 shares of the lateral used to run the water. She explained Mr. Shepardson also promised them Larimer/Weld water; however, it was never delivered. Mr. McNear responded to Commissioner Jerke by stating Mr. Shepardson has no late-season rights, Cattail Group only receives a small amount of seepage, and the delivery is not guaranteed, rather it depends on availability. He further stated it is not feasible to deliver the 0.5 share of Larimer/Weld water. There being no further comments, Chair Vaad closed public testimony. Ms. Johnson reiterated the applicant will pave the internal road, the Homeowners'Association will maintain the road for one year and request the County to accept maintenance after that. She stated Weld County Road 70 will be improved with deep stabilization,they will continue agricultural production using the pivot sprinkler system, and they are providing an upgraded water line, with hydrants, for use by others in the area. She clarified that Coalbank Creek is not located on the applicant's property,and the water designated for the property will be used specifically for the open space. Responding to Commissioner Jerke, Mr. DuBard stated the water for the sprinkler system is adequate, the unneeded water was sold, and 20 shares of Woods Lake water was retained, in conjunction with the 0.5 share of Larimer/Weld water, which will be deeded to the Homeowners' Association. He further stated the Homeowners'Association will receive the same amount of water received in the past 10 years, based on availability. He further stated they also have shares of the east lateral to transfer the water to the site. In response to Commissioner Geile, Mr. DuBard stated the open space will be planted in native grasses, maintained by the Homeowners' Association. Responding to Chair Vaad, Mr. DuBard explained it is their intension to run 20 shares of Woods Lake down the east lateral into the concrete ditch, and then through each of the ditches located on the southern side of each home leading under the road to the open space. In response to Commissioner Long, Drew Scheltinga, Department of Public Works, stated the traffic counts on Weld County Road 70, between Roads 29 and 31, averages 89 vehicles per day, and the proposed homes will generate less than 90 trips per day. He stated they anticipate 60 percent will go east to Road 31 and then north or south. In response to Chair Vaad, Mr. Morrison 2002-2644 PL1628 HEARING CERTIFICATION - CATTAIL CREEK GROUP, LLC (COZ#613) PAGE 7 stated the surrounding property owners may be liable for the attractive nuisances,and they will also need to take reasonable steps to help prevent trespassing. He stated the Board does not have the ability to shift liability from one party to another. He further stated it is difficult to require provisions and assurances of indemnification when there are multiple homeowners. (Switched to Tape #2002-34.) Responding to Chair Vaad, Ms. Lockman stated a fence along the slew, within the floodplain, would be allowed; however, it would still require a flood hazard permit. Commissioner Jerke stated if this is approved, he does not support the addition of the conditions requested by the surrounding property owners because most are not reasonable or practical for the Board to enforce. In response to Chair Vaad, Mr. Morrison stated marketability of the lots is not a criterion for consideration. Chair Vaad commented if the subdivision is not completed and the lots remain vacant, there may be some concern for the health, safety, and welfare of the neighborhood. Mr. Morrison stated the developer will be required to provide collateral to ensure services are available if the lots are sold. He further stated the quality of the residences will be tied to the Estate Zone standards. Ms. Lockman reviewed the Estate Zone bulk requirements, and stated the average home will be 1,740 square feet. Responding to Chair Vaad, George DuBard stated he has reviewed and agrees with the Conditions of Approval. Commissioner Geile expressed concern with the issue of private property rights and the many residents opposed to this development who may want to develop their own land in the future. He also expressed concern with the illegal diversion boxes and the additional restrictions on the land due to Dry-up Covenants. He stated if this proposal is approved there could be misrepresentation of the parcel as prime farmland with ample water,which does not appear to be true. He stated this proposal would have been better presented using cluster zoning, with the remaining agricultural land under a conservation easement. Commissioner Jerke stated although it may make sense to do a cluster development, there are incompatibility issues with this location. He stated it does not appear the development will create a significant increase in traffic; however, the proposed use of the open space has been vague and his primary concern is with incompatibility. Commissioner Long stated this would not create a great burden on the traffic,and the maintenance would be turned over to the County after one year; however, the proposal appears to be incompatible with the existing and planned uses in the area. Commissioner Masden stated the future residents would have to take responsibility for the water and maintenance issues, and this would impact the private property rights of the surrounding neighbors and land uses in the area. Chair Vaad stated there are many lots in the area that are five acres or less, as well as several subdivisions within a three-mile radius. He stated it appears five-acre sites would be less of a problem for the neighbors, and he expressed concern with developing a site without regard for the neighbors. He also expressed concern with the practicality of getting water to the open space. Commissioner Long moved to deny the request of Cattail Creek Group, LLC, for Change of Zone #613 from the A (Agricultural)Zone District to the PUD (Planned Unit Development)Zone District for eight (8) lots with E (Estate)Zone uses and one (1) lot with A (Agricultural) Zone uses, along 2002-2644 PL1628 HEARING CERTIFICATION - CATTAIL CREEK GROUP, LLC (COZ#613) PAGE 8 with 30.13 acres of open space. The motion was seconded by Commissioner Geile. Each concurred that the proposal is not in conformance with Sections 27-2-30, 27-2-35, 27-2-70, and 27-2-74 regarding buffering and screening, buffer zones, compatibility, and conservation area. There being no further discussion,the motion carried unanimously,and the hearing was completed at 2:45 p.m. This Certification was approved on the 7th day of October 2002. APPROVED: BOARD OF COUNTY COMMISSIONERS WE).D CODU/NJ7Y, QOLORADO ATTEST: a //D�/I , l [/ 4 5 � �n VaaChair Weld County A�/ Clerk to the �.a . Gr cP ,, / vad Da E. g, Pro-Te Deputy Clerk to the Board 4.114, M. J. eile TAPE #2002-33 and #2002-34 47 li J rke DOCKET#2002-71 Robert D. Masden 2002-2644 PL1628 EXHIBIT INVENTORY CONTROL SHEET Case COZ#613 - CATTAIL CREEK GROUP, LLC Exhibit Submitted By Exhibit Description A. Planning Staff Inventory of Item Submitted B. Planning Commission Resolution of Recommendation C. Planning Commission Summary of Hearing (Minutes 09/17/2002) D. Clerk to the Board Notice of Hearing E. Bill and Barb Perusek Letter of Concern (09/19/2002) F. Michael Erbes Letter of Concern (09/23/2002) G. Vicki Mill Two Letters of Opposition (09/10/2002 and 09/25/2002) H. Applicant Letter requesting Court Reporter (09/23/2002) Louis Booth Letter of Opposition (09/26/2002) J. Michael and Debra Page Two letters of Opposition (09/05/2002) and (09/20/2002) K. Lee Anderson Letter of Opposition (09/21/2002) L. Janice and Danny Millett Letter of Opposition (09/29/2002) M. Justin Rapp Letter of Concern (09/29/2002) N. Tricia and James Mangum Letter of Concern (09/27/2002) O. Vicki Mill Petition of Opposition (09/30/2002) P. Vicki Mill Kids' pictures and letters (09/30/2002) Q. Vicki Mill Petition of Opposition (10/01/2002) R. Patrick McNear Letter of Opposition (09/30/2002) S. Joseph and Elaine Hoff Letter of Opposition (10/01/2002) T. Joseph and Elaine Hoff Letter of Opposition (09/06/2002) U. County Attorney Draft Covenants V. Applicant Letter from Otis, Coan and Stewart, LLC (10/01/2002) W. Planning Staff Letter from Division of Wildlife (09/30/2002) X. Planning Staff Map of 100-Year Flood Plain Y. Applicant Copies of Power Point Presentation Z. Kathryn and Jerry Banks Letter of Opposition (09/29/2002) AA. Planning Staff Photo of sign posted on site (09/18/2002) BB. Michael Miller Copy of Power Point Presentation CC. Applicant Letter from Thomas Operating Company, Inc. (09/30/2002) DD. Applicant Letter from NRCS (09/27/2002) EE. Applicant Letter from North Weld County Water District (10/16/2001) FF. Applicant Letter from North Weld County Water District (09/30/2002) GG. Applicant Map of Parcels less than 5.0 Acres HH. Ruben Hergert Letter of Opposition I I. Patrick McNear Letter of Opposition JJ. KK. LL. MM. NN. OO. PP. QQ. RR. n1 — Ni co _ nr, DC k, op 4\ r" o ‘; ICaC � J 1- O re \ \tn la V cd--;_ rir S. .tz 0 N 0 4 m oz ` ( L C� o c~i R �' N 3 � ILA � �j _ v � 3 W O ° `a � � � s 3 � e o r6 14N 'qT cn -1 ? ne N 0 CC N Q 'N0 "YA m ` — m 1. D CD E F W co z W 3 ° t) 3 J g k O. 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