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HomeMy WebLinkAboutItem B: Bascom Village ECC UGENE ITY OUNCIL AIS GENDA TEM UMMARY Work Session: Bascom Village Meeting Date: November 16, 2011 Agenda Item Number: B Department: Planning & Development Staff Contact: Becky Wheeler www.eugene-or.gov Contact Telephone Number: 541-682-5532 ISSUE STATEMENT This work session provides the City Council with an opportunity to discuss the results of the 2011 Affordable Housing Request for Proposals (RFP) as well as related affordable housing funding policies and processes. This RFP is the mechanism used by the City to identify projects eligible to receive land, federal pass-through funds, and local subsidies for affordable housing. The 2011 Housing RFP solicited proposals for development of the City-owned landbank site located at 2990 County Farm Road. The Housing Policy Board (HPB) made a draft recommendation to fund Bascom Village, a 101-unit development affordable to those at or below 50 percent Area Median Income. BACKGROUND The following information summarizes: 1) the City’s guiding plans related to affordable housing; 2) the annual Housing RFP process; 3) the Eugene Landbanking Program for Affordable Housing and Housing Dispersal Policy; 4) relevant background information about the County Farm landbank site and surrounding neighborhood; and 5) the 2011 Housing RFP process and draft recommendation received to fund Bascom Village, a 101-unit development affordable to those at or below 50 percent Area Median Income. Annual Action Plan and Housing Request for Proposals The City of Eugene subsidizes the development of housing affordable to low- and very low-income people using federal pass-through funding and local resources. The City of Eugene established current goals and programs for the development of affordable housing through the adopted 2010 HUD Consolidated Plan. The Consolidated Plan guides the use of HOME Investment Partnerships (HOME) funds and Community Development Block Grant (CDBG) funds over a five-year period. Each year, the City Council adopts a One-Year Action Plan, which establishes development goals and allocates funds at a program level. For fiscal year 2012, the One-Year Action Plan sets a goal for developing 100 units of affordable housing and allocates up to $601,206 in HOME Investment Partnerships funds for construction or acquisition of affordable housing units. In addition to use of federal funds, the City of Eugene has established System Development Charge (SDC) waivers and the Low-Income Rental Housing Property Tax Exemption to further enable the development of affordable housing. The City uses an annual Housing RFP to solicit specific affordable housing development projects eligible to receive land and other federal and local subsidies specifically designated for affordable housing. The City Council is advised directly by the Intergovernmental Housing Policy Board on housing proposals received through the RFP and other housing policy matters. The RFP content and S:\CMO\2011 Council Agendas\M111116\S111116B.doc criteria were developed through a lengthy consultation process with HPB. HPB appoints members of the Evaluation Committee to review and score the proposals, holds public hearings to collect comments on proposed projects, and makes funding recommendations to the City Council. Final decisions regarding awards of land and other federal and local subsidies are made by the City Council. Following the City Council’s decision, developers seek Low Income Housing Tax Credits and other funding through the State’s Consolidated Funding Cycle. Eugene Landbanking Program for Affordable Housing and Housing Dispersal Policy The Landbanking Program for Affordable Housing has served as a cornerstone of Eugene’s overall affordable housing program. The Landbanking Program was conceived as a way to address the need for affordable housing among low-income families. In 1968, the City Council adopted a broad platform through Resolution 1551, which formed an enduring foundation for Eugene’s approach to affordable housing. The resolution included direction to purchase and landbank sites for low-income housing, to support the formation of nonprofit affordable housing developers, and to promote the dispersal of affordable housing throughout the community. The Housing Dispersal Policy (HDP) is the tool used by the council to ensure affordable units are dispersed throughout the community (see Attachment A for complete Housing Dispersal Policy). Originally adopted in 1968, the 1974 update to the HDP emphasized the importance of landbanking as a way to facilitate the dispersal of affordable housing throughout the community. The first landbank site was purchased in 1979. By 1982, four sites had been purchased and the City was actively seeking development proposals. The first development on a landbank site was completed in 1990. The last update to the HDP was completed in 1996 (Resolution 4477). The HDP only applies to the new development of family housing units and has three specific goals: 1) maximize housing choice for low-income families who have traditionally been limited in the location of housing they could afford; 2) discourage the creation of large areas characterized by low-income families; and 3) encourage the creation of additional housing integrated throughout the community for low-income families. The HDP includes two policies designed to achieve these goals: Policy 1: The City encourages dispersal of low-income families, in subsidized housing, throughout the City. Public assistance for the construction of subsidized housing is discouraged in unsuitable areas. This policy may be balanced by the City Council against other City concerns and policies. [Unsuitable areas are defined in the document as census tract block groups where more than 50 percent of families are low-income and/or already have concentrations of subsidized housing that are greater than 20 percent of total housing units within the block group. Policy 2: The City discourages subsidized housing developments that are larger than 60 units. This policy may be balanced by the City Council against other City concerns and policies. [Subsidized housing units are defined in the document as permanent newly constructed rental housing, for low- income families] County Farm Landbank Site and Area History The site included in the 2011 Housing RFP is located at 2990 County Farm Road, north of Crescent Avenue and west of Coburg Road. In 1997, the HPB directed staff to seek a landbank site between five and 10 acres in size to accommodate more units than sites previously purchased. In June, the City Council approved the purchase of the 5.8 acre site with $390,000 in CDBG funds and $190,000 in S:\CMO\2011 Council Agendas\M111116\S111116B.doc General Fund dollars. Based on the site’s medium-density residential zone designation prescribed in the Willakenzie Area Plan and Metro Plan, staff provided information to the council that estimated the site would accommodate approximately 115 units. Development of the County Farm landbank site and the surrounding area is prescribed by the Willakenzie Area Plan (WAP), the Land Use Code (Eugene Code Chapter 9), and the Metro Plan. The WAP guides the provision of public services, such as wastewater and street improvements, and serves as a basis for evaluating private development proposals, such as zone change requests. The WAP provides a common framework for those engaged in the conservation, development, and redevelopment of the area. The WAP was prepared by a group of residents and property owners who live and work in the Willakenzie area, aided by staff from the City of Eugene, Eugene Water & Electric Board, Eugene School District 4J, Lane Transit District, Lane Council of Governments, City of Springfield, and Lane County. In 1992, the Eugene City Council adopted the WAP as policy direction for public and private decisions affecting the growth and development of the Willakenzie area. To implement the WAP, the City initiated a series of Metro Plan amendments to ensure consistency between the two policy documents. Both plans designate this property (as well as others along the west side of County Farm Road) as medium-density residential (MDR). The WAP indicates that the land subsequently purchased as a landbank site and surrounding parcels are an opportunity area to provide needed housing for all income groups. Broader policy direction found in the WAP (i.e. Residential Policies and Proposed Actions) is provided to encourage greater residential densities in areas, like that of the landbank site and surrounding parcels, that have good access to commercial services, public open space, schools, parks, transit, and other modes of transportation. In 2001, a tentative subdivision application was submitted for the parcel just north of the City’s landbank site. The applicants proposed Mountain Terrace, a 62-lot subdivision. The approval of this medium- density tentative subdivision application was appealed by James Spickerman, representing a group of neighbors living primarily west of the site on Park View Drive. The appellants challenged the Planning Director’s approval of the proposed subdivision based on density, compatibility, traffic and parking impacts, lack of open space, and the extension of Park View Drive. Public notices of the application, and then following approval, the appeal hearing were mailed to nearby residences. The tentative subdivision approval was upheld by Eugene’s Hearing’s official. In 2009, City staff submitted an annexation application for the landbank site. In accordance with City requirements, City planning staff sent notices of the proposed annexation to more than 175 neighbors and other interested parties, including the Cal Young Neighborhood Association (CYNA). On May 11, 2009, the City Council unanimously approved formally bringing the land into city limits, and allowing the property to be potentially rezoned for multifamily affordable housing. During the public forum at the City Council meeting, one neighbor requested a park be provided for the area of north Eugene. In 2010, City staff submitted a zone change application for the landbank site. In accordance with City requirements, City planning staff posted a sign on the site and sent notices of the proposed zone change to more than 175 neighbors and other interested parties, including the CYNA. In addition to informing neighbors of how to provide comments, the notice informed neighbors that the change request was for an affordable housing landbank site The Eugene Hearing’s Official received one piece of written testimony, along with verbal testimony from two County Farm landbank site neighbors. The Hearing’s Official approved rezoning the property to Medium-Density Residential (MDR) on July 28, 2010, S:\CMO\2011 Council Agendas\M111116\S111116B.doc consistent with the WAP and Metro Plan designations. A second notice was sent to the CYNA, applicant, and interested parties (including three neighbors who provided testimony) informing them of the Hearing’s Official’s decision and the right to appeal. No appeals were received. The 2011 Housing RFP Process and Results HPB commenced creation of the 2011 RFP in October 2010 for development of the County Farm site. Between October 2010 and March 2011, input was solicited on multiple occasions from developers, service providers, the neighborhood association, and community members as the RFP document was drafted. A summary of early efforts made to solicit input is attached (Attachment B). The City announced the 2011 Housing RFP for affordable housing projects in The Register-Guard and via an HPB interested parties list March 11, 2011, with proposals due the last day of May. The 2011 Housing RFP sought proposals for: (1) New affordable housing development on the 5.8-acre County Farm landbank site, including use of HOME funds, Eugene SDC waivers, and Eugene Water & Electric Board (EWEB) SDC grants; and (2) acquisition/rehabilitation of existing housing to be converted to affordable housing, including use of HOME funding, Eugene SDC waivers, and EWEB SDC grants. Through the RFP process, $601,206 in HOME funds, approximately $805,000 in Eugene SDC waivers, and $100,000 in EWEB SDC grants were made available, for a total of $1,495,000 in development subsidies. Two proposals were received for the development of new housing on the County Farm landbank site. A single proposal was received for acquisition of existing housing, but was deemed incomplete and not evaluated. The two proposals for the landbank site were reviewed by staff and the HPB-appointed Eugene Evaluation Committee (see Attachment C for member list). In June, the Evaluation Committee held a public meeting and scored the development proposals using criteria developed by the HPB. In July, the HPB reviewed the scores for each proposal provided by the Evaluation Committee. The HPB acknowledged the thorough technical analysis of the proposals by the Evaluation Committee and made a draft recommendation to award resources to the Bascom Village proposal (Attachment D). Bascom Village includes 101 units (comprising of 74 units with two or more bedrooms targeted to families and 27 units targeted to seniors, singles, and couples) and two community centers within 29 structures constructed in two phases (53 units in phase I and 48 in phase II). The 29 structures consist of 17 two-story townhome style duplexes, eight three-story apartment buildings, one single-story community center, two combination one- and two-story buildings, and one two-story community center that includes a classroom and five flats. The two-story buildings along Park View Drive are similar in height to the existing single- family homes in the Mountain Terrace subdivision, north of Park View Drive. The three-story buildings on the south property line are designed to be within the maximum height of 35 feet. Included on-site are two community centers, laundry facilities and several play areas. The first phase will be completed by St. Vincent de Paul of Lane County (SVDP), with the second developed by the Housing and Community Services Agency of Lane County (HACSA). Once complete, both phases will be managed by SVDP and include resident services delivered by SVDP. SVDP and HACSA formed a team of local professionals to design and develop Bascom Village. The design team includes Eugene-based companies, Bergsund DeLaney Architecture and Planning, P.C. and Meili Construction. SVDP and HACSA have strong development and property management track records. Both vigorously screen prospective tenants (in some cases, more so than market-rate owners). S:\CMO\2011 Council Agendas\M111116\S111116B.doc A written comment period followed the July HPB meeting, and was announced along with the public hearing date in The Register-Guard. The announcement was also provided to the Cal Young Neighborhood Association and to an interested parties list. Due to concerns raised (see Attachment E for summary of concerns) at the public hearing in September, the HPB delayed its scheduled action to make a final recommendation to the council and added a tour of affordable housing sites (October 12), community forum (October 26), and an additional public hearing (November 9). The HPB also extended the written comment period to November 9. The HPB will decide on its recommendation to the City Council on November 14. The City Council will hold a work session to discuss the forthcoming HPB recommendation on November 16 and is scheduled to take action November 28. A summary of the HPB public hearing, public comments received, and the HPB meeting will be provided to the council. RELATED CITY POLICIES The proposed project supports multiple City priorities and policies including the Eugene-Springfield 2010 Consolidated Plan, Growth Management Policies, and the Housing Dispersal Policy. Eugene-Springfield 2010 Consolidated Plan -This plan identifies a need for affordable housing for low-income persons and sets a five-year goal of developing 500 new units of affordable housing. The proposed project directly supports the objective by creating 101 units for low-income families and individuals. Eugene Adopted Growth Management Policies - The City of Eugene affordable housing development programs and Bascom Village support multiple Growth Management Policies. Housing Dispersal Policy - The City Council has established a Housing Dispersal Policy which seeks to maximize housing choices for low-income families and integrate housing throughout the City of Eugene. COUNCIL OPTIONS No formal action is required at this time. CITY MANAGER’S RECOMMENDATION No action is required on this item. Therefore, no recommendations are offered by the City Manager. SUGGESTED MOTION No action is required on this item. Therefore, no motions are suggested. ATTACHMENTS A.Housing Dispersal Policy B.List of Evaluation Committee and Housing Policy Board Members C.Summary of Early Efforts Made to Solicit Input D.Bascom Village Summary S:\CMO\2011 Council Agendas\M111116\S111116B.doc E.Summary of Concerns F.Aerial Map of Landbank Site and Surrounding Area G.Bascom Village Rendering H.Letter from 4J FOR MORE INFORMATION Staff Contact: Becky L. Wheeler, Housing Finance Analyst Telephone: 541.682.5532 Staff E-Mail: Becky.L.Wheeler@ci.eugene.or.us S:\CMO\2011 Council Agendas\M111116\S111116B.doc %88%',1)28% ATTACHMENT B Evaluation Committee Members 1.Robin Boyce, Housing Development Center 2.Joni Hartmann, Network for Oregon Affordable Housing 3.Patricia Thomas, City of Eugene Planning & Development 4.Chris Pryor, Housing Policy Board & Eugene City Council 5.Janet Yood, Anslow & DeGeneault, Inc. Housing Policy Board Members 1.Norton Cabell (chair) 2.Brita Fischer 3.Sid Leiken, Lane County Commissioner 4.Dave Ralston, City of Springfield Councilor 5.Chris Pryor, City of Eugene Councilor 6.Virginia Thompson 7.John Van Landingham 8.Jenna Fribley Wagner 9.Karen Clearwater ATTACHMENT C Summary of Efforts Made to Solicit Input for the 2011 RFP City staff contacted the Cal Young Neighborhood Association to notify them that an RFP was under development for the County Farm landbank site and requested comments on its content prior to the release of the RFP in March. The Association provided no comments on the RFP. The neighborhood association placed information about the process and provided city staff’s contact information on its website. A neighbor living in the subdivision north of Park View Drive contacted staff towards the end of March to learn more about the RFP process, the site, and potential housing development. Staff had regular contact with this specific neighbor answering questions, researching concerns with other City staff, and providing updated information as it became available regarding potential RFP applicants and upcoming meetings in the ensuing months. The concerned neighbor was given the contact information for the interested developers and the neighbor’s concerns regarding parking were addressed by Bascom Village’s architect. In an email to SVDP’s development team member, Kristen Karle, the neighbor expressed his gratitude for reaching out early (in the process) for input. In April, both the city and SVDP contacted both the Belle Terra and Mountain Terrace Homeowners Association (HOA) via email. SVDP requested to attend HOA meetings, while the city provided basic RFP information, contact information, and the dates of upcoming meetings. Ms. Karle also spoke on the phone with a Mountain Terrace HOA representative from NW Community Management. Ms. Karle was informed that Mountain Terrace HOA (at that time) was not very active, so it would be difficult to gather any feedback. Nonetheless, he said he would contact the HOA president to see if mailing a letter out regarding the project would be of interest. Ms. Karle never heard back from NW Community Management or the HOA. A Notice of Public hearing was placed in the Register Guard August 5, 2011 notifying residents of a 30-day comment period to provide written testimony related to the proposed use of federal HOME funds for the County Farm landbank site. The deadline to submit written comments was 5:00pm, Tuesday, September 6, 2011. A summary of comments received and copies of written testimony will be provided to Council following the November 9, 2011 Housing Policy Board public hearing. ATTACHMENT D Bascom Village - St. Vincent de Paul Society of Lane County (SVDP) and the Housing & Community Services Agency of Lane County (HACSA): SVDP and HACSA requested funding for Bascom Village, a mixed townhome and flat-style development providing 101 rental units to those earning at or below 50% of area median income, including 5 units set aside for clients of St. Vincent de Paul’s Living Independently Following Treatment (LIFT) Program. Bascom Village includes 101 units and two community centers within 29 buildings constructed in two phases (53 units in phase I and 48 in phase II). The 29 buildings consist of 17 two-story townhome style duplexes, 8 three-story apartment buildings, 1 single story community center, 2 combination one- and two-story buildings, and 1 two-story community center that includes a classroom and 5 flats. The two story buildings along Park View Drive are similar in height to the existing single family homes in the Mountain Terrace subdivision, north of Park View Drive. The three story buildings on the south property line are designed to be within the maximum height of 35 feet. Included on site are two community centers, laundry facilities and several play areas. The first phase will be completed by SVDP, with the second developed by HACSA. Once complete, both phases will be managed by SVDP and include resident services delivered by SVDP. SVDP requested $346,000 in HOME funds, $249,593 in Eugene SDCs, and a $58,671 EWEB SDC grant for Phase I. HACSA requested $244,000 in HOME funds, $224,346 in Eugene SDCs, and a $53,136 EWEB SDC grant for Phase II. Each developer will also apply for Eugene’s 20-year Low-Income Rental Housing Property Tax Exemption. Total local funds requested: HOME - $590,000, Eugene SDC waivers - $473,939, EWEB SDC grant - $111,807. Phase I includes a large community center with a Head Start Classroom and residential units on the second floor, children’s play areas and covered bicycle storage. Phase II includes a smaller community meeting room, children’s play areas and additional covered bicycle storage. Total estimated project cost for both phases is approximately $17.5 million. SVDP and HACSA formed a team of local professionals to design and develop Bascom Village. The design team includes Bergsund DeLaney Architecture and Planning, P.C. and Meili construction. SVDP and HACSA take a great deal of care and attention in designing developments that will enhance existing neighborhoods. In addition, each has strong histories of dependable and solid property management. Both vigorously screen prospective tenants (more so than market rate owners). ATTACHMENT E Summary of Concerns CONCERN: Bascom Village violates the City’s Housing Dispersal Policy. REPLY: The Bascom Village proposal does not violate the Housing Dispersal Policy. The HDP sets aspirational goals for the dispersal of affordable housing and specifically allows City Council to take other City concerns and policies into consideration. There are two primary policies outlined within the HDP. Policy 1: The City encourages dispersal of low-income families, in subsidized housing, throughout the City. Public assistance for the construction of subsidized housing is discouraged in unsuitable areas. This policy may be balanced by the City Council against other City concerns and policies. [Unsuitable areas are defined in the document as census tract block groups where; 1) Over 20% of the total housing units are subsidized units for low-income families; and/or 2) Over 50% of families have incomes at or below 50% of the area median income.] The County Farm landbank site is currently consistent with Policy 1 and was when purchased in 1997. The site is located in census tract 2202, block group #1. The U.S. Department of Housing and Urban Development’s (HUD) FY11 low- and moderate income data indicates between 10% and 20% of all residents in this block group are either low- or moderate income families. U.S. Census 2010 data tells us that 5.2% of the total housing units in the block group are subsidized. Policy 2: The City discourages subsidized housing developments that are larger than 60 units. This policy may be balanced by the City Council against other City concerns and policies. [Subsidized housing developments are defined in the document as permanent newly constructed rental housing for low-income families.] Bascom Village consists of 101 units and is designed to provide affordable housing for families, seniors, singles, and couples. Twenty-seven units are one-bedroom units targeted to seniors, singles, and couples. Seventy-four units have 2 or more bedrooms. Based on past occupancy patterns, SVDP estimates that about 8% of the one-bedroom units will likely be occupied by households with a child and approximately 61% of the units with 2 bedrooms will likely be occupied by households with at least one child. As previously discussed, the HDP is aspirational, as opposed to prescriptive in manner allowing either of the two policies included within to be balanced by the City Council against other City concerns and policies. In setting the criteria for development proposals for this site, HPB considered the very high demand for additional housing, and the limited resources available for affordable housing development, the limited number of landbank sites, and the size of the site which allows for a greater number of units at densities similar to other affordable housing developments. CONCERN: Bascom Village will increase traffic and the site is not served by public transportation. REPLY: Yes, traffic will increase as a result of the development. The increase in units in this area has been planned for since the 1980s. Therefore, streets were constructed to accommodate anticipated traffic increases from future development Traffic Impacts and Street Capacity - Bascom Village will add 488 trips per day, 80% of which will also be using County Farm and Coburg Roads; and Drake’s Crossing is expected to generate 1,117 daily trips, with 85% utilizing County Farm and Coburg Roads. Current traffic volumes on County Farm have actually dropped (between Coburg and Parkview there is 1,800 ADT, down from 2,450 in 2001). With the addition of both Drake’s Crossing and Bascom Village volumes, the ADT will increase to about 3,140, which is below the design capacity for a Major Collector of 7,500 ADT. Of great concern to the neighborhood is the volume of traffic to and from the west of both developments (Parkview and Lakeview to Gilham or Devon). During the AM peak, which includes school traffic, we expect 30 trips (18 west, 12 east) and in the PM peak period there would be 20 (8 west, 2 east) to and from Drake’s Crossing. On Parkview, Bascom Village would display a similar pattern with 9 AM and 6 PM trips to and from the west, about 97 daily at full build-out of both projects. School traffic typically coincides closely with the AM peak commuting period, but afternoon school travel is outside normal evening commute times. Gary McNeel, Sr. Transportation Analyst offers the following information: If Bascom Village were developed as a traditional apartment complex (versus an affordable housing project) we would expect the site to generate approximately 603 daily auto trips; however, lower income residents own fewer cars and drive less than average apartment dwellers and we anticipate this project to generate about 488 daily trips. National studies, confirmed by our own observations, show that higher income single family neighborhoods have an average of 2.53 cars per household, while medium income single and multi-family developments own an average of 2.13 cars per household, yet affordable housing developments average 1.24 cars per household. Planned Street Enhancements - There are multiple enhancements that will be made to local streets as a part of the project. The City will complete Park View Drive before the construction of any homes. The addition of eight feet of paving and sidewalks on the south side of the street will add on-street parking to the area and facilitate pedestrian safety. Traffic calming options are being investigated for the area. In addition to completing Park View Drive, Matt Drive will be extended south through the landbank site to improve traffic flow and create additional on-street parking for the neighborhood. Public Transportation - Stops for LTD routes 66 and 67 are located within a ¼ mile of the development site (convenient for pedestrians is defined in Eugene Code as within ¼ mile and is ½ mile for bicyclists). These routes provide 30 minute service between 7 AM and 11 PM (67 buses per day). All LTD buses have bike racks on the front. The city is developing a plan to fill the 300’ gap in sidewalk along the west side of Coburg/County Farm Road. CONCERN: Bascom Village will result in an overcrowding of area schools. REPLY:ALL 4J School District representatives confirmed 4J schools can accommodate an increase in enrollment. In fact, increased enrollment directly results in additional funds for each student from the State. When additional students enroll in a school, 4J assigns additional teachers to that school to maintain the current student-teacher ratio. (See Exhibit A) CONCERN: Bascom Village will decrease area property values. REPLY: Many studies are available regarding the affect(s) affordable housing has on property values. Many factors play into the value of a home. In reviewing multiple studies released by entities such as: The Center for Housing Policy; Arizona State University’s Stardust Center; Habitat for Humanity; New York University; and the National Association of Realtors, the results indicate that effects range from no impact on property values to a positive impact on property values. In fact, according to a 2008 research brief published by ASU’s Stardust Center, “Affordable housing seems least likely to generate negative property value impacts when it is embedded within higher-value, low-poverty, stable neighborhoods and 1 when the affordable housing development is well managed.” 1 http://stardust.asu.edu/research_resources/detail.php?id=49 ATTACHMENTF    2SZIQFIV   1E]SVERH'MX]'SYRGMP 'MX]SJ)YKIRI 4IEVP7XVIIX6SSQ )YKIRI3VIKSR  (IEV1E]SVERH'MX]'SYRGMP1IQFIVW  %XXLIVIUYIWXSJGMX]WXEJJSR3GXSFIV-VITVIWIRXIH)YKIRI7GLSSP(MWXVMGX.EXXLI MRJSVQEXMSREPJSVYQVIKEVHMRKXLITVSTSWIH&EWGSQ:MPPEKIEJJSVHEFPILSYWMRKHIZIPSTQIRX  ;I[IVIEWOIHXSEHHVIWWXLIUYIWXMSRSJ[LIXLIVXLIVIMWGETEGMX]JSVEHHMXMSREPWXYHIRXWEXXLI WGLSSPWMRXLMWEVIE¨+MPLEQ)PIQIRXEV]'EP=SYRK1MHHPIERH7LIPHSR,MKL7GLSSP%W- GSRJMVQIHEXXLIRIMKLFSVLSSHJSVYQEPPXLVIISJXLIWIWGLSSPWHSLEZIVSSQJSVQSVIWXYHIRXW  (YVMRKXLIJSVYQERYQFIVSJTISTPIGSQQIRXIHXLEXXLIWIWGLSSPWEVIEPVIEH]JYPPERHGERRSX EGGSQQSHEXIQSVIWXYHIRXWTSMRXMRKXSXLIMRGVIEWIHGPEWWWM^IWMR.WGLSSPWXLMW]IEV 9RJSVXYREXIP]SYVGPEWWWM^IWEVIKVS[MRK¨FYXXLMWMWHYIXSWXEJJMRKVIHYGXMSRWQEHI HMWXVMGX[MHIXSEHHVIWWEWIZIVIFYHKIXWLSVXJEPP  7GLSSPHMWXVMGXWVIGIMZIJYRHMRKERHWGLSSPWEVIEPPSGEXIHWXEJJMRKFEWIHSRXLIRYQFIVSJ WXYHIRXWIRVSPPIH-JQSVIWXYHIRXWIRVSPPMR.WGLSSPWXLIHMWXVMGX[MPPVIGIMZIQSVIJYRHMRK JVSQXLIWXEXI  8LIMRJSVQEXMSREPLERHSYX[ITVSZMHIHEXXLI3GXJSVYQMWEXXEGLIH   7MRGIVIP]     &EVFEVE&IPPEQ] 'LMIJSJ7XEJJ'SQQYRMGEXMSRW(MVIGXSV )YKIRI7GLSSP(MWXVMGX.