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HomeMy WebLinkAbout20211514.tiffJuly 2, 2021 The Honorable Steve Moreno Chair, Weld County Board of Commissioners PO Box 758 Greeley, CO 80632 Dear Mr. Moreno: U.S. Department of Homeland Security FEMA Region VIII Denver Federal Center, Building 710 P.O. Box 25267 Denver, CO 80225-0267 FEMA IN REPLY REFER TO: APPEAL RES RECEIVED JUL 07 2021 WELD COUNTY COMMISSIONERS Community: Weld County, Colorado (Unincorporated Areas) Community No.: 080266 This is in response to a letter dated May 24, 2021 from Diana Aungst, Weld County Planner appealing the proposed regulatory floodway for Big Thompson River as presented on the Preliminary Flood Insurance Rate Map (FIRM) and in the Preliminary Flood Insurance Study (FIS) report for the Weld County, CO and Incorporated Areas, dated September 17, 2020. Please note that your request is considered an appeal because it satisfied the data requirements defined in Title 44, Chapter I, Part 67 of the Code of Federal Regulations (44 CFR Part 67), and was submitted during the 90 -day appeal period for the aforementioned Preliminary FIRM and FIS report. The following scientific and/or technical data were submitted in support of this request: • Memo containing annotated flood maps • WCR54 Bridge Improvements Project drawings • Photos of improved areas • Topographic Map for Weld County Parcels 095730100004, 0957292001, and 0957292011. We received all data necessary to resolve this appeal by May 24, 2021. FEMA has completed their evaluation of the comments and data provided in the submission. It was determined that a change to the model was not warranted for the preliminary study. When more detailed and/or accurate topographic data is submitted on its own, it must be proven that it was available for use in the study prior to the release of the preliminary maps. However, the building may qualify for removal from the Special Flood Hazard Area using the Letter of Map Amendment (LOMA) process or the Letter of Map Revision Based on Fill (LOMR-F) process. The LOMA/LOMR-F process is available through FEMA to issue flood zone determinations for small areas that are not shown on a FIRM due to map scale limitations. ComtAvn:Co.-t;on$ 07114/2.1 cC:oEM(RR) PLCTP), PW (sK/lR/cN/DD) 07/09 /21 www.fema.gov dto2I - ISIy Enclosed is information about the LOMA and LOMR-F process and how to submit an application. Once submitted, FEMA will review the information and make a determination if the building's Lowest Adjacent Grade is above the Base Flood Elevation. FEMA can only issue LOMA and LOMR-F determinations based on an effective map and study. Because the above -referenced preliminary FIRM is not yet effective, an official determination document cannot be issued until the FIRM has been finalized and is effective, which is anticipated in late 2022. LOMA and LOMR-F applications that are submitted 30 days prior to the effective date can be reviewed based on the new FIRM and issued shortly after the effective date. As they become available, the new FIRM effective date and relevant updates will be provided here: https://msc.fema.gov. We have resolved this appeal in accordance with the requirements of 44 CFR Part 67. We have reviewed the submitted data and determined that the proposed SFHA boundary in the area of the Christensen property is correct as shown on the Preliminary FIRM and in the Preliminary FIS report, and that no changes are warranted at this time. Please submit any comments regarding this appeal resolution within 30 days of the date of this letter to the following address: Federal Emergency Management Agency (FEMA) Mitigation Division FEMA Region VIII Denver Federal Center, Building 710 P.O. Box 25267 Denver, CO 80225-0267 Attention: Christine Gaynes, FEMA Region VIII Civil Engineer If you feel that the technical issues originally raised have not been adequately addressed by this resolution letter and that an acceptable resolution will not be feasible through the submittal of additional comments as outlined above, please note that FEMA makes Scientific Resolution Panels (SRPs) available to support the appeal resolution process. SRPs are independent panels of experts in hydrology, hydraulics, and other pertinent sciences established to review conflicting scientific and technical data and provide recommendations for resolution. An SRP is an option after FEMA and a local community have been engaged in a collaborative consultation process without a mutually acceptable resolution. Your community may contact Christine Gaynes at 303-235-4359 for additional information on the specific eligibility requirements for the SRP or refer to the enclosed SRP Fact Sheet. To request that an SRP review your scientific or technical data, your community must complete the enclosed SRP Request Form and submit it to the address above within 30 days of the date of this letter. If we do not receive any comments or the completed SRP Request Form from your community during the 30 -day review period associated with this resolution, we will finalize the FIRM and FIS report by issuing a Letter of Final Determination (LFD). The LFD will explain the adoption/compliance process and will state the date when the FIRM and FIS report will become effective. www.fema.gov We appreciate your community's comments and commitment to having the most accurate flood hazard information available reflected on the FIRM and in the FIS report. If you have any questions regarding this matter, please contact Christine Gaynes of my office by telephone at 303-235-4359 or by e-mail at christine.gaynes@fema.dhs.gov. Sincerely, Jeanine D. Petterson FEMA Region VIII Mitigation Division Director Enclosures: LOMA Fact Sheet SRP Fact Sheet SRP Request Form cc: Diana Aungst, Weld County Planner Terri Fead, Colorado Water Conservation Board Matt Buddie, FEMA Region VIII NFIP Specialist Doug Mahan, CO State NFIP Coordinator Christine Gaynes, FEMA Region VIII Civil Engineer Matt McGlone, Regional Technical Coordinator, RSC 8 www.fema.gov How to Request a Letter of Map Amendment (COMA) or Letter of Map Revision Based on Fill (LOMR F) What is a LOMA or a LOMR-F? The Federal Emergency Management Agency (FEMA) applies rigorous standards to develop Flood Insurance Rate Maps (FIRMs) and uses the most accurate hazard information available. However, limitations in the scale or topographic detail of the source maps used to prepare a FIRM may cause small elevated areas to be included in a Special Flood Hazard Area (SFHA) . SFHAs are high -risk areas subject to inundation by the base (1 -percent -annual -chance) flood. They are also known as 1 -percent -annual -chance floodplains, base floodplains, or 100 - year floodplains. To change the flood hazard designation for properties in these areas, FEMA has established the LOMA process for properties on naturally high ground and the LOMR-F process for properties elevated by the placement of fill. LOMAs and LOMR-Fs are letter determinations that officially amend an effective FIRM. They can establish that a property is not in an SFHA and, by doing so, remove the Federal flood insurance requirement. Obtaining a LOMA or LOMR-F A LOMA application form can be downloaded from the FEMA website at www.fema.gov/change-flood-zone-designation-online-letter-map-change. FEMA does not charge a fee to review a LOMA request, but requesters are responsible for providing the required mapping and survey information specific to their property. For FEMA to remove a structure from the SFHA through the LOMA process, Federal regulations require the lowest ground touching the structure, or Lowest Adjacent Grade (LAG) elevation, to be at or above the Base Flood Elevation (BFE) . The exception to this requirement is when the submitted property information shows that the structure is outside the SFHA. In this case, the property is referred to as "out as shown." If elevation information is required for the LOMA request, the requester should submit the elevation data requested on the MT-EZ form (https://www.fema.govinit-ez-form-instructions). For More Information • For general information, contact the FEMA Map Information eXchange by telephone, toll free, at 1-877- FEMA MAP (1-877-336-2627) and choose "Option 1"; by e- mail at FEMAMaoSnecialist@riskmap cds.com; or by live chat at www.floodmaps.fema.gov/fhm /fmx main.html. • The forms and other documents referenced in this flier are also available on the "Forms, Documents, and Software" portion of the FEMA website at https://www.fema.govflorms- documents-and-software. • For copies of effective National Flood Insurance Program maps and reports, contact the FEMA Map Information eXchange by telephone, toll free, at 1-877- FEMA MAP (1-877-336-2627) and choose "Option 3," or via the FEMA Map Service Center website at www.msc.fema.gov. RiskMAP Increasing Resilience Together http://www.fema.gov/risk-mapping-assessment-and-planning-risk-map • 1--877-FEMA MAP An Elevation Certificate, which includes this required elevation data, may be submitted to meet this data requirement and may be available from the community in lieu of a new survey. If the property has been elevated by fill, the requester will need to use the LOMR-F process. Applications may be submitted online at https://hazards.fema.gov/femaportal/ onlinelomc/signin, or mail -in forms are available at http:// www.fema.gov/change-flood-zone-designation-online- letter-map-change. For a LOMR-F to be issued, the LAG must be at or above the BFE, and community floodplain officials must determine that the land and any existing or proposed structures to be removed from the SFHA are CC reasonably safe from flooding." FEMA charges a fee for the engineering review of LOMR-Fs. Fee information is located at https://www.fema.gov/flood-map-related-fees. Please send completed application forms to the attention of the LOMA Manager at the LOMC Clearinghouse, 3601 Eisenhower Ave., Ste. 500, Alexandria, VA 22304-6426. What if no BFEs have been Determined? In some instances, BFEs for a certain SFHA have not yet been determined. FEMA will attempt to calculate the BFE when a LOMA application is submitted for properties of less than 50 lots or 5 acres. Sometimes, a BFE can be developed from sources such as U.S. Geological Survey topographic quadrangle maps. If that information is not available, the property owner will be asked to supply a survey for the property with the information necessary to allow FEMA to develop a site -specific BFE. National Flood Insurance Program (NFIP) regulations require that the requester determine the BFEs for properties larger than 50 lots or 5 acres. A variety of computational methods can be employed to determine BFEs, but these methods can be expensive. Before computational methods are used, every attempt should be made to obtain information, in the form of floodplain studies or previous computations, from Federal, State, or local agencies. Data obtained from these agencies may be adequate to determine BFEs with little or no additional research, calculation, or cost. The FEMA document Managing Floodplain Development in Approximate Zone A Areas, A Guide for Obtaining and Developing Base (100 -Year) Flood Elevations provides guidance on computing BFEs. This document, which can be viewed on the FEMA website at bttps://www.fezna.gov/ awijj&Aarary/assets/doc men s 1911, provides methods for developing BFEs, as well as a list of agencies that can be contacted to determine whether BFE data are already available. How will a LOMA or LOMR-F Affect my Flood Insurance Requirement? The Federal flood insurance requirement applies to structures in SFHAs that carry a mortgage backed by a federally regulated lender or servicer. If you have a LOMA or LOMR-F proving that your property is not in the SFHA, the mandatory Federal flood insurance requirement no longer applies. However, your lender still has the prerogative to require flood insurance as a condition of the loan. Even if your lender requires flood insurance, however, premiums are lower for structures outside the SFHA. If FEMA issues a LOMA or LOMR-F and your lender agrees to waive the flood insurance requirement, you may be entitled to a refund of the premium paid for the current policy year. To cancel your policy, you can submit a copy of the LOMA or LOMR-F and the lender's waiver to your flood insurance agent or broker. The agent will send these documents and a completed cancellation form to the appropriate insurance provider. It is important to note that the issuance of a LOMA or LOMR-F does not mean the risk of flooding has been eliminated. Therefore, not having a flood insurance policy could have disastrous consequences, leaving you with no financial protection from future flood losses. FEMA recommends flood insurance coverage even if it is not required by law or a lender. The good news is that you may be eligible to pay much less for flood insurance coverage if your property is removed from the SFHA. Quick Facts LOMA requests involving one or more structures: the LAG must be at or above the BFE. LOMR-F requests: the LAG must be at or above the BFE, and community floodplain officials must determine that the land and any existing or proposed structures to be removed from the SFHA are CC reasonably safe from flooding." LOMA requests involving one or more lots: the lowest point on each lot must be at or above the BFE. Review and processing fee: FEMA does not charge a fee to review a LOMA request, but there is a fee for the engineering review of LOMR-Fs. Required information: the requester is responsible for providing all the information needed for the review, including (if necessary) elevation information certified by a licensed land surveyor or registered professional engineer. RiskMAP Increasing Resilience Together http://www.fema.gov/risk-mapping-assessment-and-planning-risk-map • 1-877-FEMA MAP ,� OVERVIEW SCIENTIFIC RESOLUTION PANELS The Federal Emergency Management Agency (FEMA), through its flood hazard mapping program, Risk MAP (Risk Mapping, Assessment, and Planning), identifies flood hazards, assesses flood risks, and partners with states, tribes and local communities to provide accurate flood hazard and risk data to guide them in taking effective mitigation actions. The resulting National Flood Insurance Program (NFIP) maps provide the basis for community floodplain management regulations and flood insurance requirements. What is a Scientific €2esolution Panel? FEMA's Scientific Resolution Panel (SRP) process reinforces FEMA's commitment to work with communities to ensure the flood hazard data depicted on Flood Insurance Rate Maps (FIRMs) are developed collaboratively, using the best science available. Flood hazards are constantly changing, and FEMA updates FIRMs through several methods to reflect those changes. When proposed changes to a FIRM are met with conflicting technical and/or scientific data during a regulatory appeal period, an independent third -party review of the information may be appropriate. An SRP serves as an independent third party. The SRP process benefits both FEMA and the community: / It offers a neutral review process by independent third parties. ► It confirms FEMA's commitment to using the best science for the purpose of accurately depicting flood hazards on flood maps. ► It provides an additional opportunity for resolving community appeals involving conflicting technical and/or scientific data. While FEMA had previously established an SRP process, the Biggert-Waters Flood Insurance Reform Act of 2012 formally established a statutory SRP process. The Appeal and Comment Processing Guidance for Flood Risk Analysis and Mapping, which incorporates the legislative requirements for the SRP, is available at www.fema.gov/guidelines-and-standards-flood-risk- analysis-and-mapping. as For Additional Information For more information on appeals, see the FEMA document Appeals, Revisions, and Amendments to National Flood Insurance Program Maps: A Guide for Community Officials at www.fema.govJmedia- library/assets/documents/17930 Part 67 of the NFIP regulations, which pertains to appeals, is available at http://www.fema.gov/gu ida nce- docu ments-other-published-resources FEMA's Guidelines and Standards for Flood Risk Analysis and Mapping webpage includes the Appeal and Comment Processing Guidance for Flood Risk Analysis and Mapping: www.fe m a . gov/guidelines-and-standard s - flood -risk -analysis -and -mapping Templates and Other Resources: www.fema.gov/media- library/assets/documents/32786?id=7577 Other Important Links: • NIBS Scientific Review Panel website: www.floodsrp.org/ • Risk MAP: www.fema.gov/risk-mapping- assessment-and-planning-risk-map • Information on Recent and Upcoming Map Changes: www.fema.gov/status- map-change-requests • Flood Insurance: www.floodsmart.gov RISK MAPPING, ASSESSMENT, AND PLANNING PROGRAM (RISK MAP) The Federal Emergency Management Agency's Risk MAP Program delivers quality data that increases public awareness and leads to action to reduce risk to life and property. Risk MAP is a nationwide program that works in collaboration with states, tribes, and local communities using best available science, rigorously vetted standards, and expert analysis to identify risk and promote mitigation action, resulting in safer, more resilient communities. RiskMAP Increasing Resilience Together FEMA 4 Increasing Resilience Together Who Can Request an SRP? A community, tribe, or other political entity with the authority to adopt and enforce floodplain ordinances for the area under its jurisdiction can request that FEMA use an SRP when conflicting technical and/or scientific data have been presented. For additional information, review the Appeal and Comment Processing Guidance for Flood Risk Analysis and Mapping at www.fema.gov/guidelines-and-standards-flood-risk-analysis-and-mapping. When Can Communities Request an SRP? A community can request an SRP if the following requirements have been met: It has not yet received a Letter of Final Determination (LFD) from FEMA. / Conflicting technical and/or scientific data, submitted daring the 90 -day appeal period, resulted in different flood hazards than those proposed by FEMA. At least 60 days of community consultation with FEMA (but no more than 120 days) have taken place. Additionally, a communitythat receives a FEMA-issued resolution letter and has not previously exercised the SRP process will have 30 days from the issuance of the letter to request an SRP. Independent Panel Sponsor The SRP process is managed by the National Institute for Building Sciences (NIBS), a non-profit organization independent of FEMA. NIBS will administer the SRPs, ensuring that proper guidelines and procedures are employed and maintaining a cadre of experts from which panel members are selected. Panel Member Selection Five panelists are convened for each appeal brought to the SRP request. Panel members are technical experts in surface water hydrology, hydraulics, coastal engineering, and other engineering and scientific fields that relate to the creation of FIRMs and Flood Insurance Studies (FIS) throughout the United States. Based on the technical challenges associated with each request, NIBS develops a list of potential members with relevant expertise, from its cadre of experts. NIBS also checks that those listed are available to serve, do not reside in the state from which the appeal or data were filed, and have no personal or professional interest in its findings for the flood risk project. NIBS provides the list to the community and FEMA to select the panel members. The community selects at least the simple majority (three), and FEMA selects the remaining panel members from the short list of cadre members, based on the technical challenges of the appeal or data suomittal. 2 June 2016 Increasing Resilience Together The Process To request a review by an SRP, the community's Chief Executive Officer or designee completes an SRP Request Form and submits it to FEMA during the time periods outlined above. Once FEMA confirms that the situation and the conflicting technical and/or scientific data are eligible for an SRP, it forwards the SRP Request Form to NIBS, which will initiate the panel selection process and develop a list of potential members. Once the panel is convened, panel members are provided with a summary of the issue, FEMA's data, and the data the community submitted during the 90 -day appeal period. Panel members review the data and, on a point -by -point basis, deliberate and make a decision based on the scientific and/or technical challenges. If the community feels it is necessary to make an oral presentation in support of its request, it must include a justification on the SRP Request Form. Resolution The panel must present its written report to the community and FEMA within 90 days of being convened, and that report will be used by the FEMA Administrator for making the final determination. A panel determination must be in favor of either FEMA or the community on each distinct element of the dispute, and the panel may not offer any alternative determination as a resolution. In the case of a dispute submitted by the community on behalf of an owner or lessee of real property in the community, the panel determination must be in favor of either FEMA, the community, or the owner/lessee on each distinct element of the dispute. If changes to the maps are recommended in the panel's determination, and FEMA elects to implement the panel's determination, FEMA will incorporate the changes into a revised Preliminary FIRM and, if appropriate, FIS report. The revised products will be available to the community for review, with a resolution letter, before FEMA issues an LFD. Once the SRP provides its determination and FEMA issues its resolution letter to implement the recommendations, the SRP recommendations are binding on all appellants and not subject to judicial review. If the FEMA Administrator elects not to accept the panel's findings, the Administrator will issue a written justification within 60 days of receiving the report from the SRP. Under these circumstances, the appellants maintain their right to appeal FEMA's final determination to the appropriate Federal District Court. 3 June 2016 Increasing Resilience Together Figure 1: SRP Timeline FEMA Flood Mapping Scientific Resolution Panel (SRP) Timeline 2nd news publication of proposed flood hazard determinations 90 -day Appeal Period 4..,.. Community submits scientific/technical data *Community can submit an SRP request to FEMA no less than 60 days and no more than 120 days after the start of the community consultation phase OR within 30 days after receiving the Resolution Letter Community Consultation f a. . . • 0 Resolution Letter issued • . ICommunity submits SRP request* FEMA forwards eligible SRP request to NIBS for Panel selection process i Short -list Panel members Mapping Process continues SRP (Panel) Process FEMA reviews SRP recommendation a Community & FEMA : ! Panel presents written select Panel recommendation (Max. 90 days) Resolution Letter issued FEMA informs community (within 60 days if in agreement with SRP) Mapping Process 4 June 2016 US. Department of Homeland Security 500 C Street, SW Washington, DC 20472 Scientific Resolution Panel Request Form This form is to be completed by the community's Chief Executive Officer (CEO) or the authorized representative of the community for which the appeal is being filed. The CEO will consolidate all unresolved appeals by private persons and submit them on their behalf The CEO will also forward to FEMA copies of appeals not endorsed by the community and certify that no further appeals will be brought to FEMA for the community. Date: Name of Community: County and State of Community: Name of Community CEO or authorized representative: Mailing Street Address: City: State: Zip: Phone Number (Work): Phone Number (Cell): Email Address: Does the data submitted constitute an appeal? (Y/N) r Page 2 If yes, does the submitted data satisfy the data requirements outlined in 44 CFR Section 67.6 (b) of the National Flood Insurance Program (NFIP) regulations and demonstrate that FEMA's proposed flood hazard determinations (proposed flood hazard determinations may include the addition or modification of Base Flood Elevations (BFEs), base flood depths, Special Flood Hazard Area (SFHA) boundaries or zone designations, or regulatory floodways) are: n (1) technically incorrect due to a mathematical or measurement error or changed physical conditions? n (2) technically incorrect due to error in application of hydrologic, hydraulic or other methods or use of inferior data in applying such methods? El (3) scientifically incorrect? If an oral presentation to the SRP is necessary to support this appeal, please justify here. Community Commitment and Certification The community certifies that: 1. the data provided for SRP review was entirely submitted to FEMA during the 90 -day appeal period. ❑ Y ❑ N 2. no additional data will be submitted for this or any other appeal for SRP consideration. ❑ Y ❑ N 3. there may be no submission of any other appeals not consolidated with this submission. ❑ Y n N Location of Contested Flood Hazard Determination Data 4. Ident the specific river reaches or coastal transects challenged by the data. S. Please identify areas of expertise the community believes are pertinent for representation on the SRP. Page 3 6. Description of information to be submitted by the community indicating that the flood hazard data proposed by FEMA are scientifically or technically incorrect Please include on a separate page labeled "Attachment A: Summary of Appeal Information" a summary of the specific technical issues, errors in FEMA's data, or different technical processes submitted to contest the flood hazard determination data proposed by FEMA. 7. Acceptance by Community of Terms and Conditions for the Initiation of an SRP To initiate the SRP process, the community's CEO or authorized representative must accept the following terms and conditions on behalf of the community and individuals whose appeals are consolidated with this submission. a) The community understands that the FEMA Administrator is not required to accept the recommendation of the SRP, and that upon the Administrator's final determination that no further consideration will be given to the community's appeals. The parties will maintain their right to appeal to the appropriate Federal District Court pursuant to 44 CFR Section 67.12 of the NFIP regulations. b) The community has read the FEMA-prepared Guidance Memorandum titled "Implementing the Scientific Resolution Panel Process" and agrees to work with the National Institute of Building Sciences (NIBS) in the timely completion of the SRP review, including timely selection of panel members and participation in additional review procedures if requested. c) The community agrees that no contact will be made with the Panel members except as expressly requested by NIBS before, during or after the SRP review is undertaken. d) The community agrees that they have read and signed the "Community Submittal Agreement." Signature of Community CEO or Authorized Representive RECEIVED JUN 0 2 2021 WELD COUNTY COMMISSIONERS May 28, 2021 The Honorable Scott James Commissioner, Weld County PO Box 758 Greeley, CO 80632 Dear Mr. James: U.S. Department of Homeland Security FEMA Region VIII Denver Federal Center, Building 710 P.O. Box 25267 Denver, CO 80225-0267 FEMA IN REPLY REFER TO: SUBMITTAL ACK Community: Weld County, Colorado (Unincorporated Areas) Community No.: 080266 This letter acknowledges receipt of correspondence dated May 24, 2021 from Diana Angst, Weld County Planner regarding the preliminary Flood Insurance Rate Map (FIRM) and Flood Insurance Study (FIS) Report dated September 17, 2020 for Weld County, CO and Incorporated Areas. This submittal included a memo with annotated flood maps as well as WCR54 Bridge Improvements Project drawings and photos of improved areas for a private property near Big Thompson River within District 2. FNMA is evaluating the issues raised in the referenced correspondence and the submitted data. If additional data or information are required to resolve the submittal, FEMA will contact your community. If warranted, FEMA will revise the preliminary FIRM and FIS Report and send revised copies to your office for review. Until these submittals are resolved, FEMA will not issue a Letter of Final Determination (LFD). Therefore, processing of the FIRM and FIS Report for your community will not be fmalized until that time. We appreciate your community's submittals and commitment to having the most accurate flood hazard information available reflected on the FIRM and in the FIS Report. If you have additional questions, please contact Christine Gaynes at our FEMA Regional Office in Denver, CO, by telephone at 303-235-4359 or by e-mail at christine.gaynes@fema.dhs.gov. Sincerely, Jeanine D. Petterson FEMA Region VIII Mitigation Division Director Co MRurl:Ca++. nS 06/04 4 /21 CC:OEM(P. ), P1.(r-r), P0(AIER/cH1DD) 06/i6121 www.fema.gov 2021-1514 cc: Diana Aungst, Weld County Planner Terri Fead, Colorado Water Conservation Board Matt Buddie, FEMA Region VIII NFIP Specialist Doug Mahan, CO State NFIP Coordinator Christine Gaynes, FEMA Region VIII Civil Engineer Matt McGlone, Regional Technical Coordinator, RSC 8 www.fema.gov EXHIBIT MAP TOPOGRAPHIC SURFACE For Jamie and Dustin Christensen SO 75 ff TtNIVtY0U1 NO11& 11 150 300 A SCALE IN FIT' SCALE. I AU IOAiont.t coordfnoM an bond r the Council Skit. Pb,. Coating.* Satyrs - teen, Zone tSSS/2011 2-A11 vortical .lerollons ore rel.roocod to IM North Anerlcm+ ..rttcol Notion 1IOU (NAV080) S The nlunnpbn shown nwwn wall o*tp4t.a through pbotegrenrn 1fc nMNf . of aortal inner, flown .n Yot 7. 1071 4 irll I. nog o yang &any not or on Urprt.en.M Sutter fat In. po•pos. 01 tftt. 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