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HomeMy WebLinkAboutItem 16 Annexation of Territory to the City of Springfield - Property Located off South 5th Street and East of Central Boulevard in Willamette Heights AGENDA ITEM SUMMARY Meeting Date: 3/3/2014 Meeting Type: Regular Meeting Staff Contact/Dept.: Andy Limbird, DPW Staff Phone No: Ext. 3784 Estimated Time: 15 Minutes S P R I N G F I E L D C I T Y C O U N C I L Council Goals: Encourage Economic Development and Revitalization through Community Partnerships ITEM TITLE: ANNEXATION OF TERRITORY TO THE CITY OF SPRINGFIELD – ANNEX 4.16 ACRES OF PROPERTY LOCATED OFF SOUTH 5TH STREET AND EAST OF CENTRAL BOULEVARD IN WILLAMETTE HEIGHTS, SPRINGFIELD. ACTION REQUESTED: Conduct a public hearing and first reading on the following ordinance: AN ORDINANCE APPROVING THE ANNEXATION OF CERTAIN TERRITORY TO THE CITY OF SPRINGFIELD, AND WILLAMALANE PARK AND RECREATION DISTRICT; AND WITHDRAWING THE SAME TERRITORY FROM THE WILLAKENZIE RURAL FIRE PROTECTION DISTRICT (FIRST READING). ISSUE STATEMENT: A request for annexation to the City of Springfield has been received from Springfield Utility Board for publicly-owned property in the Willamette Heights neighborhood. The subject property is located on the east side of Central Boulevard just south of the terminus of South 5th Street. The 4.16-acre site requested for annexation is inside the City’s Urban Growth Boundary (UGB) and is partially within the City limits. The Springfield Utility Board is requesting annexation to facilitate future upgrades and expansion of the water utility infrastructure. ATTACHMENTS: Attachment 1: Staff Report and Recommendations Attachment 2: Area, Vicinity and Site Maps Attachment 3: Ordinance with Exhibits Exhibit A: Map and Legal Description Exhibit B: Application DISCUSSION/ FINANCIAL IMPACT: The City Council is authorized by ORS Chapter 222 and SDC Article 5.7-100 to act on annexation requests. In accordance with SDC 5.7-155 and ORS 222.040, 222.180 and 222.465, if approved the annexation will become effective 30 days after signature by the Mayor or upon acknowledgement by the State – whichever date is later. The subject site is bisected by the existing City limits line, which runs east-west through the middle of the property. The site is currently developed with water utility infrastructure including a steel reservoir tank, two abandoned concrete reservoir basins, and a gravel access driveway. The tax lots requested for annexation have an aggregate assessed value of $119,792. Because the site is an existing public utility installation and no additional urban services should be required for its continued operation, an annexation agreement is not required with this request. Upon annexation, potential transportation and utility improvements required to serve the proposed development site would be subject to the Site Plan Review process. The property requested for annexation is zoned Low Density Residential with an Urbanizable Fringe Overlay (UF-10) in accordance with the Springfield Zoning Map. Upon annexation, the UF-10 overlay will be removed. As outlined in the attached staff report (Attachment 1), the annexation area can be served with the minimum level of key urban facilities and services as required in the Eugene-Springfield Metropolitan Area General Plan. The attached staff report also confirms the annexation request meets the criteria established in Section 5.7-100 of the Springfield Development Code. Recommendation: Staff finds the proposal complies with the annexation criteria of approval listed in SDC 5.7-140, and Council is within its authority to approve annexation of the subject territory to the City of Springfield and Willamalane Park and Recreation District; and withdrawal of the subject territory from the Willakenzie Rural Fire Protection District. Staff recommends the City Council schedule the ordinance for second reading and adoption. TYPE IV – ANNEXATION STAFF REPORT AND RECOMMENDATION ______________________________________________________________________________ File Name: Springfield Utility Board Willamette Heights Annexation Applicant: Springfield Utility Board Case Number: ANX14-00001 Proposal Location: Central Boulevard off South 5th Street (Map 17-03-35-34, TL 7100; Map 18-03-02-12, TL 301; and Map 18-03-02-21, TL 100) Current Zoning: Low Density Residential with Urbanizable Fringe Overlay (UF-10) Plan Designation: Low Density Residential Applicable Comprehensive Plan: Metro Plan Application Submittal Date: Jan. 28, 2014 Associated Applications: PRE13-00039 (Development Issues Meeting for Annexation); PRE14-00004 (Pre-Submittal Meeting for Annexation) CITY OF SPRINGFIELD’S DEVELOPMENT REVIEW COMMITTEE POSITION REVIEW OF NAME PHONE Project Manager Planning Andy Limbird 541-726-3784 Transportation Planning Engineer Transportation Michael Liebler 541-736-1034 Public Works Civil Engineer Streets and Utilities Clayton McEachern 541-736-1036 Deputy Fire Marshal Fire and Life Safety Gilbert Gordon 541-726-2293 Building Official Building David Bowlsby 541-736-1029 APPLICANT’S DEVELOPMENT REVIEW TEAM POSITION NAME PHONE MAILING ADDRESS Applicant Ray Meduna Springfield Utility Board 541-726-2396 202 South 18th Street Springfield, OR 97477 Applicant’s Representative Rick Satre Schirmer Satre Group 541-686-4540 375 W. 4th Avenue Suite 201 Eugene, OR 97401 City Limits S 5th St Hill St Park St Area Requested for Annexation Attachment 1, Page 1 of 7 Review Process (SDC 5.7-115): The subject annexation request is being reviewed under Type IV procedures, without Planning Commission consideration. Development Issues Meeting (SDC 5.7-120): A Development Issues Meeting (DIM) is required of all public agency and private landowner-initiated annexation applications. Finding: A Development Issues Meeting for the subject annexation request was held on January 7, 2014. Conclusion: The requirement in SDC 5.7-120 is met. Annexation Initiation and Application Submittal (SDC 5.7-125): In accordance with SDC 5.7-125.B.2.b.i and ORS 222.170(1), an annexation application may be initiated by “more than half the owners of land in the territory, who also own more than half the land in the contiguous territory and of real property therein representing more than half the assessed value of all real property in the contiguous territory consent in writing to the annexation of their land”. Finding: The property owner who owns all of the land and real property, and full assessed value of real property in the contiguous territory, has filed an application and petition requesting annexation to the City of Springfield (Attachment 3). Conclusion: The application requirements in SDC 5.7-125 have been met. Site Information: The territory requested for annexation is portions of three contiguous tax lots located south of the Booth Kelly site in the Willamette Heights neighborhood. The subject site is inside the Springfield Urban Growth Boundary (UGB) and is contiguous to the Springfield city limits along the north boundary. The site contains an operating SUB water utility installation that is partially within the City limits. The subject annexation territory comprises a total of 4.16 acres (approximately 49%) of the 8.43 acre utility site in Willamette Heights. According to the applicant’s submittal, the subject annexation territory is intended to be modified by removing two abandoned concrete reservoir basins, and installing a new steel reservoir tank and pump station (see diagram on Page 3). Modification of the utility installation would be subject to a Discretionary Use and Site Plan Review process once the property is entirely within the City limits. Existing public services are provided to the annexation area as follows: police (Lane County Sheriff, Springfield Police Department), schools (Springfield School District), roads (Lane County and City of Springfield), and Fire (Willakenzie Rural Fire Protection District). Springfield Utility Board (SUB) operates the water utility infrastructure on the site and also provides electricity service to the proposed annexation area. Upon annexation, the City of Springfield will be responsible for all urban services, including sewer, water, electricity and police/fire response to the subject area. Notice Requirements (SDC 5.7-130): Consistent with SDC 5.7-130, notice was provided as follows: Mailed Notice. Notice of the annexation application was mailed February 11, 20 14, which is at least 14 days prior to the public hearing date, to the affected property owner(s); owners and occupants of properties located within 300 feet of the perimeter of the affected territory; affected neighborhood groups or community organizations officially recognized by the city that includes the affected territory; affected special districts and all other public utility providers; and the Lane County Land Management Division, Lane County Elections, and the Lane County Board of Commissioners. Newspaper Notice. Notice of the March 3, 2014 public hearing was published in The Register-Guard on February 17 and 24, 2014. Attachment 1, Page 2 of 7 Conceptual Future Development Plan for Reservoir Site Posted Notice. Notice of the March 3, 2014 public hearing was posted in four public places in the City: at one location along the property frontage on Central Boulevard; at Springfield City Hall and in the Development and Public Works office; and on the City of Springfield website. Finding: Upon annexation of the subject territory to the City the Low Density Residential zoning will be retained, but the Urbanizable Fringe Overlay District (UF-10) will no longer apply. Due to this change, the Oregon Department of Land Conservation and Development (DLCD) was notified in writing of the annexation proceedings, but less than 35 days prior to the public hearing. Notification to DLCD regarding the proposed annexation was sent on January 28, 2014, which is 34 days prior to the public hearing. No written objection to the public hearing has been received from the public, applicant, or DLCD. Existing Reservoir Basins Proposed for Removal Proposed Reservoir (Future) Attachment 1, Page 3 of 7 Conclusion: Notice of the public hearing was provided consistent with SDC 5.7-130. Recommendation to City Council (SDC 5.7-135): The Director shall forward a written recommendation on the annexation application to the City Council based on the approval criteria specified in Section 5.7-140, which are provided as follows with the SDC requirements, findings, and conclusions. The Director’s recommendation follows SDC 5.7-140, Criteria. Criteria (SDC 5.7-140): The application may be approved only if the City Council finds that the proposal conforms to the following criteria: A. The affected territory proposed to be annexed is within the City’s urban growth boundary; and is 1. Contiguous to the city limits; or 2. Separated from the City only by a public right of way or a stream, lake or other body of water. Finding: The subject annexation territory is located within the acknowledged urban growth boundary (UGB) of the Eugene-Springfield Metropolitan Area General Plan (Metro Plan). The area requested for annexation abuts the Springfield city limits along the north boundary. Therefore, this annexation application meets the statutory definition of contiguity as found in ORS 222.111(1). Conclusion: The proposal meets this criterion. B. The proposed annexation is consistent with applicable policies in the Metro Plan and in any applicable refinement plans or Plan Districts; Finding: The Metro Plan was acknowledged by the Land Conservation and Development Commission (LCDC) in August, 1982 and has been subsequently amended. The annexation area is located within the acknowledged UGB of the Metro Plan. Territory within the delineated UGB ultimately will be within the City of Springfield. Finding: The territory requested for annexation is not located within an adopted Refinement Plan area and there are no proposed changes to the current zoning or plan designation. Finding: The continued annexation of properties and public street rights-of-way to the City of Springfield is consistent with the Metro Plan, which will result in the elimination of special districts within the urbanizable area. The Metro Plan recognizes that as annexations to the City occur, the special district service areas will diminish incrementally and eventually will be dissolved. Finding: The territory requested for annexation is within the Willakenzie Rural Fire Protection District. The Fire Protection District has a service arrangement with Eugene/Springfield for provision of fire response to unincorporated areas of Willamette Heights. After the public hearing and upon Council adoption of the annexation Ordinance, the annexation area will be withdrawn from the Willakenzie Rural Fire Protection District consistent with ORS 222.510, 222.520, and 222.525 and the Cities of Eugene & Springfield will provide fire protection service directly to the annexation area. Finding: After the public hearing and upon Council adoption of the annexation Ordinance, the annexation area will be annexed into the Willamalane Park and Recreation District as authorized by an intergovernmental agreement between the City of Springfield and Lane County. The park district provides park and recreation facilities and services to territory within the City of Springfield. Conclusion: The proposal meets this criterion. Attachment 1, Page 4 of 7 C. The proposed annexation will result in a boundary in which the minimum level of key urban facilities and services as defined in the Metro Plan can be provided in an orderly efficient and timely manner; and Finding: The Metro Plan recognizes annexation as the highest priority for extending the minimum level of key urban facilities and services to urbanizable areas. Finding: The territory requested for annexation will take advantage of urban service delivery systems that are already in place or can be logically extended to serve this area. In addition to urban utilities, the following facilities and services are either available or can be extended to this annexation area: Water – The Springfield Utility Board currently provides water service to the Willamette Heights neighborhood. Upon annexation, the subject site would be served by the City by and through the Springfield Utility Board. The territory proposed for annexation contains an existing steel water reservoir tank and abandoned concrete reservoir basins. SUB is requesting annexation to facilitate installation of another steel reservoir tank and pump station in the future. Electricity – SUB Electric provides service to developed properties in this area of Willamette Heights including the subject site. Upon annexation, the property owner will be able to request an upgraded electrical service for the proposed utility installation development. Existing electrical system infrastructure within the adjacent public rights-of-way will be maintained by the affected utility providers. Police Services – Springfield Police Department currently provides service to areas of Willamette Heights that are already inside the City. The subject territory is within the joint jurisdiction of Springfield Police Department and Lane County Sheriff’s Department. Upon annexation, this area will receive Springfield Police services on an equal basis with other properties inside the City. Fire and Emergency Services – Fire protection is currently provided to the annexation area by Eugene/ Springfield Fire Department under contract with Willakenzie Rural Fire Protection District. Upon annexation, the City will continue to provide fire and emergency services to the subject territory. Emergency medical transport (ambulance) services are provided on a regional basis by the Eugene/Springfield Fire Department, and Lane Rural Fire/Rescue to central Lane County. The annexation area will continue to receive this service consistent with the adopted ambulance service area (ASA) plan. Mutual aid agreements have been adopted by the three regional ASA providers to provide backup coverage for each other’s jurisdictions. Parks and Recreation – Park and recreation services are provided to the City of Springfield by the Willamalane Park and Recreation District. The park district operates several indoor recreation facilities, such as the Willamalane Park Swim Center, Lively Park Swim Center, Memorial Building Community Center, and Willamalane Adult Activity Center. The park district offers various after-school and other programs for children at schools and parks throughout the community. Also available are pathways and several categories of parks, including community parks, sports parks, special use parks, and natural area parks. Concurrent with annexation to the City of Springfield, the subject area will be annexed to the Willamalane Park and Recreation District consistent with City policy and the adopted Willamalane Comprehensive Plan. Library Services – Upon annexation to the City of Springfield, the subject area will be within the service area of the Springfield Public Library. However, it is not expected that the annexation territory will generate any population requiring library services. Schools – The Springfield School District serves the Willamette Heights neighborhood area. However, it is not expected that the annexation territory will generate any population requiring school services. Attachment 1, Page 5 of 7 Sanitary Sewer – The annexation area is not currently served by sanitary sewer, and it is not expected that existing or future development on the site will require this service. However, the site could be served by extension of a public sanitary sewer line from the alley between South 5th and South 6th Streets should this utility be necessary in the future. Stormwater – The subject annexation territory is not currently served by a piped stormwater management system. Incremental improvements to the public stormwater system will be required as development plans are advanced for the subject site and adjoining properties. The site can be served by a combination of on-site treatment and regulated discharge to adjacent the public street system. There are no immediate planned changes to the public stormwater management system associated with this annexation request. Streets – The subject annexation area has frontage on Central Boulevard, which is classified as an urban local road and is currently under Lane County jurisdiction. Along the property frontage, Central Boulevard is a gravel road that is not improved to urban standards. There are no immediate planned or required street improvements associated with this annexation request. Street frontage improvements, if required, will be reviewed and approved through the Discretionary Use and Site Plan Review process. Solid Waste Management – The City and Sanipac have an exclusive franchise arrangement for garbage service inside the City limits. Upon annexation, solid waste disposal service can be provided by Sanipac. Communication Facilities – Various providers offer both wired and wireless communication services in the Eugene-Springfield metropolitan area. Existing providers and those entering the market have the capability to provide service to this area. Land Use Controls – The annexation area is within Springfield’s urban growth boundary. Through an intergovernmental agreement between Lane County and the City of Springfield, the City already has planning and building jurisdiction for unincorporated areas of Willamette Heights. The City will continue to administer land use controls after annexation. Finding: The minimum level of key urban facilities and services, as outlined in the Metro Plan, are either immediately available or can be provided within a reasonable future time frame as needed. Conclusion: The proposal meets this criterion. D. Where applicable fiscal impacts to the City have been mitigated through an Annexation Agreement or other mechanism approved by the City Council. Finding: The public agency requesting annexation is well aware of the need for extension of urban utilities to serve the site and land beyond the annexation area; and the responsibility of the developer to fund such improvements. Because the site is an existing public utility facility, it is not expected that the annexation request will generate a demand for additional public improvements to serve the site. Therefore, staff has not required the applicant to execute an Annexation Agreement with the City. Future improvements required to serve the site will be reviewed through the Discretionary Use and Site Plan Review process. Conclusion: The proposal meets this criterion. DIRECTOR’S RECOMMENDATION: The proposal complies with the annexation criteria of approval listed in SDC 5.7-140, and Council is within its authority to approve annexation of the subject territory to the City of Springfield and Willamalane Park and Recreation District; and withdrawal of the subject territory from the Willakenzie Rural Fire Protection District. City Council Decision (SDC 5.7-145): City Council approval of the annexation application shall be by Ordinance. Attachment 1, Page 6 of 7 Finding: On March 3, 2014, the City Council will hold a Public Hearing for the subject annexation request and give first reading to the Annexation Ordinance. Based on the staff analysis and recommendation, and on testimony provided at the Public Hearing, the City Council may take action to approve, modify or deny the Annexation Ordinance. Zoning (SDC 5.7-150): The area requested for annexation is zoned and designated Low Density Residential in accordance with the Metro Plan diagram. Properties that are outside the City limits have the Urbanizable Fringe Overlay District (UF-10) applied to the zoning. Upon the effective date of the annexation, the UF-10 overlay will be automatically removed and the site will retain the Low Density Residential (LDR) zoning. Effective Date and Notice of Approved Annexation (SDC 5.7-155): If the annexation is approved by the City Council on March 3, 2014 and granted a second reading on March 17, 2014, the Ordinance will become effective 30 days after adoption by the City Council and execution by the Mayor (anticipated on or around April 17, 2014), or upon acknowledgement of filing with the Secretary of State – whichever date is later. Withdrawal from Special Service Districts (SDC 5.7-160): Withdrawal from special districts may occur concurrently with the approved annexation Ordinance or after the effective date of the annexation of territory to the City. The Director shall recommend to the City Council for consideration of the withdrawal of the annexed territory from special districts as specified in ORS 222. In determining whether to withdraw the territory, the City Council shall determine whether the withdrawal is in the best interest of the City. Notice of the withdrawal shall be provided in the same manner as the annexation notice in Section 5.7-150. Finding: The annexation area is within the delineated service territory of SUB (water and electric) and the Willakenzie Rural Fire Protection District (fire response). The Cities of Eugene/Springfield will provide fire and emergency services after annexation. Consistent with SDC 5.7-160, notice was provided, a public hearing was held, and the City Council determined that withdrawal from the Willakenzie Rural Fire Protection District was in the best interest of the City. The withdrawal decision was codified in Ordinance No.______. Attachment 1, Page 7 of 7 20TH ST 19TH S T 16TH S T YOLANDA AVE 21ST S T HARVEST LN VERA DR 17TH S T 17TH P L 15TH S T GRAN D V I S T A D R RANCH D R CHEEK ST DELROSE AVE YENTA AVE HAYDEN BRIDGE RD 15TH S T VERA DR 17TH S T VERA DR DELROSE AVE VIEWMONT AVE Citywide Overview Springfield, OR Site There are no warranties that accompany this product. Users assume all responsibility for any loss or damage arising from any error, omission or positional inaccuracy of this product Within Springfield City Limits Outside Springfield City Limits I 2 0 21 Miles At t a c h m e n t 2, Pa g e 1 of 3 E ST D ST C ST F ST S A ST I- 5 B ST G ST A ST S 2 N D S T FR A N K L I N B L V D 9T H S T 8T H S T 7T H S T 6T H S T 5T H S T 4T H S T 14 T H S T 12 T H S T 10 T H S T M I L L S T W D ST DORRIS ST MAIN ST S B ST PRI V A T E R O A D NU G G E T W A Y E 19TH AVE S 4 T H S T S D ST W C ST S 3 R D S T S ASH ST PIO N E E R P A R K W A Y E A S T W E ST PIO N E E R P A R K W A Y W E S T 1S T S T S 1 5 T H S T NE W M A N S T W F ST W A S T QUARRY R D S 1 4 T H S T PARK ST LEVE L L N HA R B O R D R E 20TH AVE S MILL ST PI N E S T S 5 T H S T S E ST S 7 T H S T S 9 T H S T S 1 0 T H S T S 8 T H S T UNION A V E S 6 T H S T A ST I- 5 PR I V A T E R O A D S B ST PRIVATE ROAD S B ST PRIVATE ROAD B ST DORRIS ST Neighborhood Overview Springfield, OR There are no warranties that accompany this product. Users assume all responsibility for any loss or damage arising from any error, omission or positional inaccuracy of this product Within Springfield City Limits Outside Springfield City Limits Proposed Annexation Tax Lots I 1,000 0 1,000500 Feet Site Attachment 2, Page 2 of 3 CE N T R A L B L V D PRIVA T E R O A D Subject Area Springfield, OR Site There are no warranties that accompany this product. Users assume all responsibility for any loss or damage arising from any error, omission or positional inaccuracy of this product Within Springfield City Limits Outside Springfield City Limits Proposed Annexation Tax Lots I 100 0 10050Feet Attachment 2, Page 3 of 3 At t a c h m e n t 3, Pa g e 1 of 24 At t a c h m e n t 3, Pa g e 2 of 24 Exhibit A, Page 1 of 4 Attachment 3, Page 3 of 24 Exhibit A, Page 2 of 4 Attachment 3, Page 4 of 24 FR S \ U L J K W  ‹       % U D Q F K  ( Q J L Q H H U L Q J   , Q F  sh e e t : re v i s i o n s : de s i g n e r : dr a w n b y : pro j e c t n o : pr o j e c t t i t l e : da t e : ANNEXATION APPLICATION TM 17-03-35-34 TL 7100 TM 18-03-02-12 TL 301 TM 18-03-02-21 TL 100 31 0 5 t h S t r e e t Sp r i n g f i e l d , O R 9 7 4 7 7 p: 5 4 1 . 7 4 6 . 0 6 3 7 f: 5 4 1 . 7 4 6 . 0 3 8 9 Sp r i n g f i e l d O R | S a l e m O R SPRINGFIELD, OREGON 01 / 1 3 / 1 4 13 - 1 8 4 : 0 1 LE G A L D E S C . EX H I B I T M A P 1 Exhibit A, Page 3 of 4 Attachment 3, Page 5 of 24 FR S \ U L J K W  ‹       % U D Q F K  ( Q J L Q H H U L Q J   , Q F  sh e e t : re v i s i o n s : de s i g n e r : dr a w n b y : pro j e c t n o : pr o j e c t t i t l e : da t e : ANNEXATION APPLICATION TM 17-03-35-34 TL 7100 TM 18-03-02-12 TL 301 TM 18-03-02-21 TL 100 31 0 5 t h S t r e e t Sp r i n g f i e l d , O R 9 7 4 7 7 p: 5 4 1 . 7 4 6 . 0 6 3 7 f: 5 4 1 . 7 4 6 . 0 3 8 9 Sp r i n g f i e l d O R | S a l e m O R SPRINGFIELD, OREGON 01 / 1 3 / 1 4 13 - 1 8 4 : 0 1 LE G A L D E S C . EX H I B I T M A P 1 Exhibit A, Page 4 of 4 Attachment 3, Page 6 of 24 Ex h i b i t B , P a g e 1 o f 1 8 At t a c h m e n t 3, Pa g e 7 of 24 Ex h i b i t B , P a g e 2 o f 1 8 At t a c h m e n t 3, Pa g e 8 of 24 Ex h i b i t B , P a g e 3 o f 1 8 At t a c h m e n t 3, Pa g e 9 of 24 Ex h i b i t B , P a g e 4 o f 1 8 At t a c h m e n t 3, Pa g e 10 of 24 Ex h i b i t B , P a g e 5 o f 1 8 At t a c h m e n t 3, Pa g e 11 of 24 Ex h i b i t B , P a g e 6 o f 1 8 At t a c h m e n t 3, Pa g e 12 of 24 Ex h i b i t B , P a g e 7 o f 1 8 At t a c h m e n t 3, Pa g e 13 of 24 Ex h i b i t B , P a g e 8 o f 1 8 At t a c h m e n t 3, Pa g e 14 of 24 Ex h i b i t B , P a g e 9 o f 1 8 At t a c h m e n t 3, Pa g e 15 of 24 Ex h i b i t B , P a g e 1 0 o f 1 8 At t a c h m e n t 3, Pa g e 16 of 24 Ex h i b i t B , P a g e 1 1 o f 1 8 At t a c h m e n t 3, Pa g e 17 of 24 Ex h i b i t B , P a g e 1 2 o f 1 8 At t a c h m e n t 3, Pa g e 18 of 24 Ex h i b i t B , P a g e 1 3 o f 1 8 At t a c h m e n t 3, Pa g e 19 of 24 Ex h i b i t B , P a g e 1 4 o f 1 8 At t a c h m e n t 3, Pa g e 20 of 24 Ex h i b i t B , P a g e 1 5 o f 1 8 At t a c h m e n t 3, Pa g e 21 of 24 Ex h i b i t B , P a g e 1 6 o f 1 8 At t a c h m e n t 3, Pa g e 22 of 24 Ex h i b i t B , P a g e 1 7 o f 1 8 At t a c h m e n t 3, Pa g e 23 of 24 Ex h i b i t B , P a g e 1 8 o f 1 8 At t a c h m e n t 3, Pa g e 24 of 24