Planning Commission

AGENDA Meeting Location: Sloat Room—Atrium Building Phone: 541-682-5481 99 W. 10th Avenue www.eugene-or.gov/pc Eugene, Oregon 97401 The Eugene Planning Commission welcomes your interest in these agenda items. Feel free to come and go as you please at any of the meetings. This meeting location is wheelchair-accessible. For the hearing impaired, FM assistive-listening devices are available or an interpreter can be provided with 48 hour notice prior to the meeting. Spanish-language interpretation will also be provided with 48 hour notice. To arrange for these services, contact the Planning Division at 541-682-5675. MONDAY, MAY 22, 2017 – REGULAR MEETING (11:30 a.m.) I. DELIBERATIONS/POSSIBLE ACTION: OAKLEIGH COHOUSING PUD 2017 REMAND (PDT 13-1) 11:30 AM Lead Staff: Erik Berg-Johansen, 541-682-5437 Erik.berg@ci.eugene.or.us Commissioners: Steven Baker; John Barofsky (Vice Chair); John Jaworski; Jeffrey Mills; Brianna Nicolello; William Randall; Kristen Taylor (Chair)  AGENDA ITEM SUMMARY May 22, 2017 To: Eugene Planning Commission From: Erik Berg‐Johansen, Associate Planner, Eugene Planning Division Subject: 2017 Remand Deliberations: Oakleigh Co‐housing PUD (City File PDT 13‐1) ACTION REQUESTED The Planning Commission will hold deliberations on the Oregon Land Use Board of Appeals (LUBA) remand of the Oakleigh Cohousing tentative PUD application (PDT 13‐1). The Planning Commission will consider the entire Oakleigh Co‐housing tentative PUD record, including evidence and testimony submitted during the recent open record period, and then decide whether to affirm, modify, or reverse the Hearings Official’s approval of the tentative PUD application. BACKGROUND The City received the tentative PUD application for Oakleigh Meadows Co‐housing in April of 2013. The City’s Hearings Official approved the tentative PUD application in November of 2013. The Hearing’s Official’s decision was appealed to the Planning Commission. On December 16, 2013, the Planning Commission approved the application. The Planning Commission’s 2013 decision was appealed up through the Oregon court system. Because the City did not give notice of the original 2013 Planning Commission hearing to a particular individual, the court decided that the City was required to hold a second public hearing on the application. That second hearing took place in 2015. Consistent with the court’s ruling, the City’s notice for the 2015 hearing explained that:  At the 2015 hearing, the Planning Commission would accept testimony only from the development applicant and from the individual who did not receive notice in 2013. Other people could not provide testimony to the Planning Commission.  The Planning Commission would base its decision on the evidence submitted into the record during the 2013 process; it would accept only arguments from the applicant and the particular individual who did not receive notice in 2013, and would reject any new evidence about the proposal. However, during the deliberations that followed the 2015 hearing, the Planning Commission decided to proceed differently than described in the 2015 hearing notice. The Planning Commission decided to re‐open the record to accept additional written evidence (not only arguments) pertaining to the safety of the access to the development site in terms of: (1) the right‐of‐way width of Oakleigh Lane; (2) the pavement width of Oakleigh Lane; and (3) parking on Oakleigh Lane. In addition, the Planning Commission accepted testimony on those issues from other people, not Page 1 Page 1 just from the applicant and the individual who did not receive notice in 2013. The City did not send out a public notice of this post‐hearing change in the process to alert all interested parties to the opportunity to provide additional testimony. Following the 2015 hearing, and after considering the additional testimony, the Planning Commission, again, approved the development application. The City’s approval was, again, appealed through the Oregon court system. As a result of that second appeal, the court has again remanded the application. The court decision required the City to provide notice to all parties of the opportunity to submit new evidence and testimony related to the safety of the access to the development site in terms of: (1) the right‐of‐way width of Oakleigh Lane; (2) the pavement width of Oakleigh Lane; and (3) parking on Oakleigh Lane. CURRENT REMAND RECORD The Notice of Opportunity to Submit Written Testimony for the current remand proceeding provided three “open record periods” to allow submission of written evidence and testimony (see Attachment A). Staff has provided a road map to the three open record periods below. First Open Record Period (Initial) Closed on April 12, 2017; anyone could submit written testimony (evidence or argument) addressing the safety of the access to the development site in terms of any or all of the following issues: (1) the right‐of‐way width of Oakleigh Lane; (2) the pavement width of Oakleigh Lane; and (3) parking on Oakleigh Lane. Copies of all testimony submitted during the first open record period have been provided to the Planning Commission. The testimony submitted during the first open record period is summarized below: Table 1: Summary of First Open Record Period Testimony Submitted From Summary of Testimony 3‐29‐17 Paul Conte Comments regarding remand proceedings. 3‐30‐17 Planning Staff Recap of 2015 Remand Appeal Issues. 3‐30‐17 City Attorney Letter to the PC regarding process. 4‐1‐17 Phyllis Temple Email stating support for “The Trautman arguments.” Email stating that parties are entitled to address the application's compliance with 4‐4‐17 Paul Conte Eugene Code 9.8320(7), irrespective of this issue not being raised in the local Appeal Statement. An excerpt from a LUBA decision is attached. Comments regarding emergency access and traffic on Oakleigh Lane. Photos of cars 4‐8‐17 Rich Dambrov parked on Oakleigh Lane are attached. Letter stating that the owner of Tax Lot 17‐04‐24‐24‐10100 does not grant permission for 4‐12‐17 Jim Brandt use of their property that is abutting the south boundary of the Oakleigh Lane right‐of‐ way. Page 2 Page 2  Letter stating that the owner 160 Oakleigh Lane does not grant permission for use of 4‐12‐17 Lauren Regan their property that is abutting the south boundary of the Oakleigh Lane right‐of‐way. Maureen 4‐12‐17 Letter of support stating the safety of Oakleigh Lane will be increased. McCauley Letter regarding emergency response, the transportation system, and local street 4‐12‐17 Paul Conte standards. Multiple attachments including a traffic assessment of a segment of Oakleigh Lane from Haregu Nemariam, P.E. Letter from “Oakleigh McClure Neighbors” stating agreement with conclusions from the 4‐12‐17 Sandy Thoms Nemariam traffic assessment. Comments regarding traffic safety hazards, neighborhood character and environmental 4‐12‐17 Scott Stedman issues. Memo regarding street standards, comments from City Attorney, Fire Department and 4‐12‐17 Planning Staff Public Works. Second Open Record Period (Response) Closed on April 26, 2017; anyone could submit written testimony (evidence or argument) that directly responds to testimony received during the first open‐record period. Copies of all testimony submitted during the second open record period have been provided to the Planning Commission. Testimony submitted during the second open record period is summarized below: Table 2: Summary of Second Open Record Period Testimony Submitted From Summary of Testimony 4‐13‐17 Paul Conte Challenge to impartiality of Planning Commissioner Kristen Taylor. 4‐13‐17 William Heinze Comments regarding width of Oakleigh Lane and drainage problems on the street. 4‐17‐17 Bill Randall Declaring conflict of interest and recusing from the Planning Commission deliberations. 4‐17‐17 Paul Conte Records request related to “Challenge of Impartiality.” 4‐17‐17 Planning Staff Email correspondence between Planning, Fire and Public Works staff. Comments regarding paving width of Oakleigh Lane, and stating disagreement with 4‐19‐17 Bryn Thoms Public Works’ comment that the configuration of Oakleigh Lane is “common” in Eugene. 4‐19‐17 Paul Conte “Motion to Strike” city staff testimony submitted on April 12, 2017. Comments regarding paving width, jurisdiction of Oakleigh Lane, and queuing streets. 4‐19‐17 Sandy Thoms Attachments include “Eimstad Survey”, tax lot map from City website, and Lane County document regarding Local Access Roads (LARs). 4‐24‐17 Paul Conte “Public Records Request Form” related to the “Challenge of Impartiality.” Response to the Nemariam “traffic assessment” and other testimony regarding 4‐25‐17 Planning Staff jurisdiction and street standards. Page 3 Page 3  Comments regarding emergency response, the transportation system, and public 4-26-17 Applicant facilities. Attachments include new engineer letter from Access Engineering, LLC. Comments regarding paving width of Oakleigh Lane, and stating disagreement with 4-26-17 Bryn Thoms Public Works’ comment that the configuration of Oakleigh Lane is “common” in Eugene. Comments regarding mandatory approval criteria, clarifications regarding Nemariam 4-26-17 Paul Conte report, and clarification of the applicable roadway standards. Comments and attachments regarding the right-of-way width, paving width, and vehicle 4-26-17 Sandy Thoms parking on Oakleigh Lane. Final Open Record Period (Final Argument) Closed on May 3, 2017; only the applicant could submit written argument (not evidence) that directly responded to testimony received during the first and second open-record periods. In the final open record period, the applicant submitted final argument, dated May 3, 2017. A copy of the applicant’s final argument has been provided to the Planning Commission. Items in the Record Below The Planning Commission must consider the entire record for the applicant’s tentative PUD application (PDT 13-1), back to 2013. To review the entire record related to this application, see http://pdd.eugene-or.gov/LandUse/SearchApplicationDocuments?file=PDT-13-0001 If any Commissioner has difficultly locating something in the record, please contact Erik Berg-Johansen. PLANNING COMMISSION’S REVIEW ROLE Based on procedural requirements set forth in the Eugene Code (see EC 9.7655), the Planning Commission would consider only those appeal issues set out in the original appeal statement. However, because the Planning Commission reopened the record in 2015, Oregon law requires the Planning Commission to also consider “new issues which relate to the new evidence, arguments, testimony or criteria for decision-making which apply to the matter at issue.” The issues for Planning Commission consideration, as identified by Planning staff, are set out in Attachment B. Further, in addressing these issues, the Planning Commission limits its consideration to the established evidentiary record, which is discussed above. In this case, the Planning Commission’s role on remand is to consider the evidence and argument in the record, including the new evidence and argument submitted during the most recent open record period, and decide whether to affirm, modify, or reverse the Hearings Official’s decision on the tentative PUD application. In the event that the Planning Commission finds the new evidence and testimony submitted in the recent open record period does not alter the Commission’s previous decision to affirm the Hearings Official’s approval of the application, the Planning Commission may simply adopt its previous decision along with supplemental findings in support of that affirmation. If the Planning Commission decides to reverse the Hearings Official’s decision and deny the application, the Planning Commission is required to provide specific findings of fact as to why the application does not meet the applicable approval criteria. Page 4 Page 4 It is critical that the Planning Commission’s decision on this remand be issued no later than June 8, 2017, to meet the 120‐day statutory time limit. SUMMARY OF APPEAL ISSUES The appeal issues from the 2015 Oakleigh Co‐housing remand, which must be considered during the current remand, as well as the following new appeal issue, identified by Planning staff, based on the review of the materials submitted during the most recent open record period, are included as Attachment B. DELIBERATIONS ON REMAND Below is a brief outline of staff’s recommended approach to deliberations: Task #1: Procedural Issues As an initial matter, prior to deliberations, the Planning Commission will need to address procedural issues raised in submittals from Paul Conte. The City Attorney will walk the Commission through its consideration of these issues at the meeting. Task #2: Review and Consider the Record and Decide Whether to Affirm, Modify, or Reverse the Hearing’s Official’s Approval of the Tentative PUD Application. Based on the limited scope of the re‐opened record (pertaining only to the safety of the access to the development site in terms of: (1) the right‐of‐way width of Oakleigh Lane; (2) the pavement width of Oakleigh Lane; and (3) parking on Oakleigh Lane) and the materials submitted, staff recommends that the Planning Commission consider and discuss the appeal issues in the following order:  Issue #3 regarding EC 9.8320(6)  Issue #11 regarding EC 9.8320(7)  Issue #2 regarding EC 9.8320(5)  Issue #4 regarding EC 9.8320(11)(b)  Issue #5 regarding EC 9.8320(12)  Issues #1, and #6‐10 NEXT STEPS The Planning Commission must affirm, modify, or reverse the Hearing Official’s decision to approve the Oakleigh Meadows Co‐housing tentative PUD application. Once the Commission has completed its deliberations, staff will prepare a revised final order for the Commission’s consideration and action at a subsequent meeting. For reference, the Planning Commission’s 2015 Final Order is included as Attachment C. The Planning Commission will need to adopt supplemental or revised findings as part of its new Final Order. The Commission’s Final Order must be issued no later than June 8, 2017. A hard copy of the complete record is available for free inspection at the Atrium Building, 99 West 10th Avenue, between 9:00 a.m. and 5:00 p.m. Monday through Friday. Copies may also be obtained by the Page 5 Page 5 public at cost. The entire record of materials will be provided to the PC separately. The full record will also be available at the public hearing. ATTACHMENTS A. Notice of Opportunity to Submit Written Testimony B. Appeal Issues Identified by Staff C. 2015 Planning Commission Final Order FOR MORE INFORMATION: Please contact Erik Berg‐Johansen, Associate Planner, Eugene Planning Division, by phone at (541) 682‐5437, or e‐mail at erik.berg@ci.eugene.or.us Page 6 Page 6  Attachment A y Ai SSi NOTICE OF OPPORTUNITY TO SUBMIT WRITTEN TESTIMONY EUGENE PLANNING COMMISSION LIMITED ISSUES The Planning Commission will consider written testimony on an appeal of the following land use application: File Name Oakleigh Cohousing PUD (PDT 13-1) Location: Located at the.east end of Oakleigh Lane Application: Tentative Planned Unit Development for a 29- unit cohousing development Applicant: Will Dixon, Oakleigh Meadow, LLC Lead City Staff: Erik Berg- Johansen, Associate Planner, ( 541)682-5437 Limited Issues to be Addressed in Testimony The Eugene Planning Commission will accept written testimony that addresses the safety of the access to the proposed Oakleigh Meadow Co- housing development site in terms of: 1)the right- way of- width of Oakleigh Lane; 2)the pavement width of Oakleigh Lane; and 3)parking on Oakleigh Lane. The Planning Commission has already received some public testimony on these three issues (during a previous review of the proposal).To review testimony already received by the Planning Commission or to review staff and Planning Commission materials that addressed that testimony in the previous review, see 0001 http:// PDT- Qov/ eugene- SearchApplicationDocuments? pdd. o 1 f L andUse/ ile= 3- r. or contact Erik Berg- Johansen (contact information on third page).The full official record is available for inspection at the City of Eugene Planning Division office. Timeline for Submitting Testimony Testimony may be submitted to the Planning Commission only according to the following schedule of three open-record" periods: First Open- Record Period When: Received by the City by 5: 00 p. m. on April 12, 2017 Who may submit testimony: Anyone What kind of testimony will be accepted: Written testimony (evidence or argument)that addresses or more)of the three issues described above. It will be helpful to the Planning Commission if one ( Page 7  Attachment A the testimony submitted during the first open- record period explains how it relates to one (or more) of the tentative planned unit development approval criteria from the Eugene Code (EC)listed below or to another party believes the following list is incomplete: criterion, if a. o EC 9. 1) 8 320( o EC 9. 5)( b)( a)( c) 8320( o EC 9. 6) 8 320( o EC 9. 11)( 8320( b) o EC 9. 12) 8 320( o EC 9. 3)( 6505( b) o EC 9. 6870 o EC 9. 6835 Second-Open Record Period - When: Received by the City between 5: m. on April 12, 2017 and 5: 01 p. m. on April 26, 2017 00 p. Who may submit testimony: Anyone What kind of testimony will be accepted: Written testimony (evidence or argument)that directly responds to testimony received during the first open-record period. Testimony submitted during record period should specifically identify the earlier testimony to which it the second open- responds. Record Period Final Open- When: Received by the City between 5: 01 p. m. on April 26, 2017 and 5: m. on May 3, 2017 00 p. Who may submit testimony: Only the applicant (including the applicant's representative) What kind of testimony will be accepted: Written argument (not evidence) directly responding to testimony received during the first and second open-record periods. How to Submit Testimony Any interested person may provide a written statement to the Planning Commission through City Planner Erik Berg- Johansen, via e-mail to eueene. us erik. o b ere@ci.r. or by mail or hand delivery to Erik Berg- Johansen, City of Eugene Planning Division, 99 West 10th Avenue, Eugene, Oregon 97401 for City receipt within the time frames specified above. Please note that failure to provide statements with sufficient specificity to enable the Planning Commission to respond precludes further appeal based on that testimony. Why is the Planning Commission Accepting Additional Testimony? The City held its original public hearing to consider the Oakleigh Meadow Cohousing development application in 2013. After the City approved the application, the City's approval of the development was appealed through the Oregon court system. Because the City did not give notice of the original hearing to a particular individual, the City was required to hold a second public hearing for that individual, regarding the Oakleigh Meadow Cohousing development application, in 2015. The City's notice of the second (2015) hearing explained that: e At the 2015 hearing, the Planning Commission would accept testimony only from the development applicant and from the individual who did not receive notice in 2013. Other people could not provide testimony to the Planning Commission. The Planning Commission would base its decision on the evidence submitted into the public record during the 2013 process; it would accept only arguments from the applicant and the particular individual who did not receive notice in 2013, and would reject any new evidence about the proposal. Page 8  Attachment A After the 2015 hearing, however, the Planning Commission decided to proceed differently than described in the 2015 notice. The Planning Commission decided to accept additional written evidence (not only arguments) pertaining to three issues listed on the previous page and it accepted such testimony from other people, not just the development applicant and the individual who did not receive notice in 2013. The City did not send a public notice of this post- hearing opportunity to provide additional testimony. After considering the additional testimony, the Planning Commission, again, approved the development application in 2015 and the City's approval was, again, appealed through the Oregon court system. The Court has now required the City to provide another opportunity to provide testimony in regards to the three issues listed on the previous page. record period, the Planning Commission will reconsider its 2015 decision in After the third open- consideration of the testimony it accepts in response to this notice, along with other testimony it has already accepted. Appeal Rights The decision of the Eugene Planning Commission will be final at the local level. Persons who appeared before the local government orally or in writing may appeal the decision to the Oregon Land Use Board of Appeals within 21 days of the Planning Commission's decision. Appeals to the Oregon Land Use Board of Appeals are governed by ORS 197.805 to 197.860 and OAR Chapter 661, Division 10. For More Information All documents and evidence submitted on this application will be available for free inspection at the Atrium Building, 99 West 10th Avenue, between 9: 00 a.m. and 5: 00 p. m. Monday through Friday. Copies may also be obtained at cost. The materials can also be accessed by visiting: htt dd.eu ene- or. ov Land Use SearchA licationDocuments? PDT- 0001 1 f ile= 3- The Planning Division staff report to the Planning Commission on this appeal will be provided at least 7 days in advance of the Planning Commission's deliberation/action meeting. be obtained at a Copies can reasonable cost. The report will be available for inspection at the Planning Division or available online at: 2 http:// gov/ eugene- Planning- www. o C A gendaCenter/ ommission- r. If you have questions, or would like more information, please contact City staff at the address or phone number listed below. Erik Berg- Johansen, Associate Planner City of Eugene Planning Division 99 West 10th Avenue, Eugene, OR 97401 Phone: (541)682- 5437 E- mail: eugene. erik. us o b erg@ci. r. Page 9 11 2017 Remand Appeal Issues – Oakleigh Co-housing (PDT 13-1) 1. The Decision erred by finding that the application met EC 9.8320(1) “The PUD is consistent with applicable adopted policies of the Metro Plan.” A. Sub-assignment of Error 1.A: the Decision failed to address the following policy at all: TransPlan Transportation System Improvements (TSP) Pedestrian Policy #1: Pedestrian Environment (Metro Plan Policy F.26) Provide for a pedestrian environment that is well integrated with adjacent land uses and is designed to enhance the safety, comfort, and convenience of walking (Metro Plan III-F-9) B. Sub-assignment of Error 1.B: the Decision failed to address the following policy at all: TransPlan Finance Policy #4: New Development (Metro Plan Policy F.36) Require that new development pay for its capacity impact on the transportation system. (Metro Plan III-F-13) 2. The Decision erred by finding the application met EC 9.8320(5) “The PUD provides safe and adequate transportation systems through compliance with the following…” A. Sub-assignment of Error 2.A: the Decision erred by finding the application met the following criterion: EC 9.6800 through EC 9.6875 Standards for Streets, Alleys, and Other Public Ways (not subject to modifications set forth in (11) below). B. Sub-assignment of Error 2.B: the Decision erred by finding the application met the following criterion: Pedestrian, bicycle and transit circulation, including related facilities, as needed among buildings and related uses on the development site, as well as to adjacent and nearby residential areas, transit stops, neighborhood activity centers, office parks, and industrial parks, provided the city makes findings to demonstrate consistency with constitutional requirements. “Nearby” means uses within ¼ mile that can reasonably be expected to be used by pedestrians, and uses within 2 miles that can reasonably be expected to be used by bicyclists. C. Sub-assignment of Error 2.C: the Decision erred by finding the application met the following criterion: The provisions of the Traffic Impact Analysis Review of EC 9.8650 through 9.6880 where applicable. 3. The Decision erred by finding the application met EC 9.8320(6) “The PUD will not be a significant risk to public health and safety, including but not limited to soil erosion, slope failure, stormwater and flood hazard, or an impediment to emergency response.” A. Sub-assignment of Error 3.A: the Decision erroneously found that the PUD would not be a significant risk to public safety. B. Sub-assignment of Error 3.B: the Hearings Official provided no evaluation of PWD’s own analysis that Oakleigh Lane would be an impediment to emergency response unless the right-of-way was widened and the road improved. 4. The Decision erred by finding the application met EC 9.8320(11)(b) “The PUD complies with all of the following…EC 9.6505 Improvement-Specifications (3)(b) Streets and Alleys, (4) Sidewalks, and (5) Bicycle Paths and Accessways A. Sub-assignment of Error 4.A: the Decision erroneously found that Oakleigh Lane, which is not only adjacent to, but also serves as the only vehicular access to and from the development site, would be paved to the specifications in EC 9.6870 (or exempt). Page 10  B. Sub-assignment of Error 4.B: the Decision erroneously found that Oakleigh Lane, which is not only adjacent to, but also is and will be used by pedestrians to and from River road and to and from the public bike/ped path along the river, would provide sufficient sidewalks that are located, designed and constructed according to the specifications in Eugene Code and referenced standards. C. Sub-assignment of Error 4.C: the Decision erroneously found that Oakleigh Lane, which is not only adjacent to, but also is and will be used by bicyclists to and from River Road and to and from the public bike/ped path along the river, would provide sufficient bike accessways that are located, designed and constructed according to the specifications in Eugene Code and referenced standard 5. The Decision erred by finding the application met EC 9.8320(12) “The proposed development shall have minimal off-site impacts, including impacts such as traffic, noise, stormwater runoff and environmental quality.” 6. The Decision erred by finding the application met EC 9.8320(13) “The proposed development shall be reasonably compatible and harmonious with adjacent and nearby land uses.” 7. The Decision erred by finding the application met EC 9.8320(3) “The PUD will provide adequate screening from surrounding properties including, but not limited to anticipated locations, bulk, and height. 8. The Decision erred by finding the application met EC 9.8320(11)(a) “The PUD complies with EC 9.2000 through EC 9.3915 regarding lot dimensions and density requirements for the subject zone.” A. Sub-assignment of Error 8.A: the Hearings Official erred in his calculation of the net density area pursuant to EC 9.2751… B. Sub-assignment of Error 8.B: the Hearings Official erred in his understanding of the concept of “clustering” under EC 9.8300(1)(e). 9. The Decision erred by finding the application met EC 9.8320(11)(k) “All other applicable development standards for features explicitly included in the application except where the applicant has shown that a proposed noncompliance is consistent with the purposes set out in EC 9.8300 Purpose of Planned Unit Development: EC 9.2795 Solar Setback Standards.” 10. The Hearings Official made a decision that was not supported by substantial, probative and reliable evidence in the whole record; and the Decision improperly construed the applicable law.” A. Sub-assignment of Error 10.A: The HO errerd by not adequately considering the preponderance of evidence and analysis in the “Constitutional findings for Exaction” produced by the Eugene Public Works Department (PWD). B. Sub-assignment of Error 10.B: the Hearings Official erroneously found that Oakleigh Lane was not an “access lane.” C. Sub-assignment of Error 10.C: The Hearings Official used erroneous data for traffic counts in on or more places…” D. Sub-assignment of Error 10.D: The Hearings Official erroneously allowed the impermissible new and non-responsive evidence submitted by the applicant’s representatives on October 16, 2013, without providing an opportunity for opponents to respond, despite the timely, written request by Paul Conte. 11. “The Hearings Official Erred by failing to correctly assess the lack of adequate fire and emergency services available to the proposed PUD site, as required under EC 9.8320(7).” Page 11 2017 PC AIS - Attachment C Page 12 2017 PC AIS - Attachment C Page 13 2017 PC AIS - Attachment C Page 14 2017 PC AIS - Attachment C Page 15 2017 PC AIS - Attachment C Page 16 2017 PC AIS - Attachment C Page 17 2017 PC AIS - Attachment C Page 18 2017 PC AIS - Attachment C Page 19 2017 PC AIS - Attachment C Page 20 2017 PC AIS - Attachment C Page 21 2017 PC AIS - Attachment C Page 22 2017 PC AIS - Attachment C Page 23 2017 PC AIS - Attachment C Page 24 2017 PC AIS - Attachment C Page 25 2017 PC AIS - Attachment C Page 26 2017 PC AIS - Attachment C Page 27 2017 PC AIS - Attachment C Page 28 2017 PC AIS - Attachment C Page 29 2017 PC AIS - Attachment C Page 30 2017 PC AIS - Attachment C Page 31 2017 PC AIS - Attachment C Attachment B Page 32 2017 PC AIS - Attachment C Attachment B Page 33 2017 PC AIS - Attachment C Attachment B Page 34 2017 PC AIS - Attachment C Attachment C Page 35 2017 PC AIS - Attachment C Attachment C Page 36 2017 PC AIS - Attachment C Attachment C Page 37 2017 PC AIS - Attachment C Attachment C Page 38 2017 PC AIS - Attachment C Attachment C Page 39 2017 PC AIS - Attachment C Attachment C Page 40 2017 PC AIS - Attachment C Attachment C Page 41 2017 PC AIS - Attachment C Attachment C Page 42 2017 PC AIS - Attachment C Attachment C Page 43 2017 PC AIS - Attachment C Attachment C Page 44 2017 PC AIS - Attachment C Attachment C Page 45 2017 PC AIS - Attachment C Attachment C Page 46 2017 PC AIS - Attachment C Attachment C Page 47 2017 PC AIS - Attachment C Attachment C Page 48 2017 PC AIS - Attachment C Attachment C Page 49 2017 PC AIS - Attachment C Attachment C Page 50 2017 PC AIS - Attachment C Attachment C Page 51 2017 PC AIS - Attachment C Attachment C Page 52 2017 PC AIS - Attachment C Attachment C Page 53 2017 PC AIS - Attachment C Attachment C Page 54 2017 PC AIS - Attachment C Attachment C Page 55 2017 PC AIS - Attachment C Attachment C Page 56 2017 PC AIS - Attachment C Attachment C Page 57 2017 PC AIS - Attachment C Attachment C Page 58 2017 PC AIS - Attachment C Attachment C Page 59 2017 PC AIS - Attachment C Attachment C Page 60 2017 PC AIS - Attachment C Attachment C Page 61 2017 PC AIS - Attachment C Attachment C Page 62 2017 PC AIS - Attachment C Attachment C Page 63 2017 PC AIS - Attachment C Attachment C Page 64 2017 PC AIS - Attachment C Attachment C Page 65 2017 PC AIS - Attachment C Attachment C Page 66 2017 PC AIS - Attachment C Attachment C Page 67 2017 PC AIS - Attachment C Attachment C Page 68 2017 PC AIS - Attachment C Attachment C Page 69 2017 PC AIS - Attachment C Attachment C Page 70 2017 PC AIS - Attachment C Attachment C Page 71 2017 PC AIS - Attachment C Attachment C Page 72 2017 PC AIS - Attachment C Attachment C Page 73 2017 PC AIS - Attachment C Attachment C Page 74 2017 PC AIS - Attachment C Attachment C Page 75 2017 PC AIS - Attachment C Attachment C Page 76 2017 PC AIS - Attachment C Attachment C Page 77 2017 PC AIS - Attachment C Attachment C Page 78 2017 PC AIS - Attachment C Attachment C Page 79 2017 PC AIS - Attachment C Attachment C Page 80 2017 PC AIS - Attachment C Attachment C Page 81 2017 PC AIS - Attachment C Attachment C Page 82 2017 PC AIS - Attachment C Attachment C Page 83 2017 PC AIS - Attachment C Attachment C Page 84 2017 PC AIS - Attachment C Attachment C Page 85 2017 PC AIS - Attachment C Attachment C Page 86 2017 PC AIS - Attachment C Attachment C Page 87 2017 PC AIS - Attachment C Attachment C Page 88 2017 PC AIS - Attachment C Attachment C Page 89 2017 PC AIS - Attachment C Attachment C Page 90 2017 PC AIS - Attachment C Attachment C Page 91 2017 PC AIS - Attachment C Attachment C Page 92 2017 PC AIS - Attachment C Attachment C Page 93 2017 PC AIS - Attachment C Attachment C Page 94 2017 PC AIS - Attachment C Attachment C Page 95 2017 PC AIS - Attachment C Attachment C Page 96 2017 PC AIS - Attachment C Attachment C Page 97 2017 PC AIS - Attachment C Attachment C Page 98 2017 PC AIS - Attachment C Attachment C Page 99