August 1st, 2016 SMITH RESIDENCE MICHAEL LEE ARCHITECTS SITE ADDRESS: 127 VIA MARINA, MARINA DEL REY, CA 90292 REQUEST: A COASTAL DEVEPLOMENT PERMIT, ZONING ADMINISTRATORS ADJUSTMENT AND PROJECT PERMIT COMPLIANCE FOR THE CONSTRUCTION OF A 4784 SQ. FT. SINGLE FAMILY RESIDENCE, A 560 SQ. FT. THREE CAR GARAGE OVER A FULL SUBTERRANEAN BASEMENT (581 SQ. FT.) IN THE R1-1 ZONE Per the LAMC Section 12.2,8 an adjustment from LAMC Section12.08-C,2 to permit a westerly side yard of 3-1/2 feet in lieu of the required 5-1/2 feet in conjunction with the construction of a four-story single-family dwelling in the R1-1 Zone, Per the provision of LAMC Section 11.5.7 and the Venice Coastal Zone Specific Plan Specific Plan Project Permit Compliance, for the construction of a single-family dwelling on a vacant lot in the dual permit jurisdiction area of the California Coastal Zone Per the provision of LAMC Section 12.2.2, a Coastal Development Permit for the construction of a single-family dwelling on a vacant lot in the dual permit jurisdiction area of the California Coastal Zone BACKGROUND The subject property is a rectangular undeveloped 3,150 square-foot lot and is zoned R1-1. The property has a 35-foot frontage on the north side of Via Marina in the Silver Strand Sub-area of the Marina Peninsula. The property is located between Marina Del Rey and the Grand Canal, approximately one mile west of Lincoln Boulevard. This property is within the dual permit jurisdiction of the Coastal Zone, a Methane Zone, and a Liquefaction Zone. The project consists of a request for an adjustment to permit reduced side yards of 3-1/2 feet in lieu of the required 5-1/2 feet, and a Venice Coastal Zone Specific Plan Project Permit Compliance and Coastal Development permit in conjunction with the construction of a four-story 4784 square-foot dwelling with a 560 squarefoot attached three-car garage and a 581 square-foot full subterranean basement. The lot is partially surrounded by Low Residential properties zoned R1-1 to the north and west. To the far west, lies a small Low-Medium Residential neighborhood zoned RD1.5-1. To the south, and far west is the entrance channel of Marina Del Rey and the Grand Canal zoned A1-1 and OS-1. The property to the east is unincorporated community of Marina Del Rey. 1|Page Via Marina is a Collector Street improved to a width of 40 feet. Via Marina Court is a Local Street dedicated to a variable width. Previous zoning related actions on the site/in the area include: Subject Property Case No. CDP 86-005- On September 23, 1986, the Zoning Administrator issued an approval for the construction of curbs and sidewalks prior to the development of a 36-lot subdivision, in the R1-1 (single family) Zone, in the dual permit jurisdiction area of the California Coastal Zone. Case No. ZA 89-0762(ZAI)- On October 13, 1989, the Zoning Administrator issued an interpretation for multiple properties within the Del Rey Beach Tract of the Silver Strand Subarea of the Venice Specific Plan which allowed the following: a) 0-foot rear yards for 36 R1-1 zoned lots, in lieu of the 15 feet required, for Lots 6 through 23 of Block 16 and Lots 6 through 23 of Block 17; b) the construction of 6-foot fences, walls and hedges in the front yards of 27 lots, in lieu of the 3-1/2-foot height permitted, for Lots 6 through 23 of Block 16 and Lots 6, 8, 10, 12, 14, 16, 18, 20 and 22 of Block 17; c) the construction of 8-foot fences and walls, with 8-foot raised patios and hedges, in the required front yards of nine R1-1 zoned lots, in lieu of the 3-1/2-foot height permitted for Lots 7, 9, 11, 13, 15, 17, 19, 21 and 23.of Block 17. The fences or walls structurally relate to and support patio decks which extend 13 feet into the front yard having a height of 8 feet above the natural grade level in lieu of the 6 feet permitted; d) 3-1/2-foot side yards for the construction of two-story over basement, 45 feet in height, single-family dwellings for 36 lots, in lieu of the required approximately 4-1/2-foot side yards, for Lots 6 through 23 of Block 16 and Lots 6 through 23 of Block 17; and, e) construction of 8-foot over-in-height fences, walls and hedges; and 13-foot 10-inch over-in-height platforms all in the side yards of 36 lots, in lieu of the 6Jeet permitted, for Lots 6 through 23 of Block 16 and Lots 6 through 23 of Block 17. Surrounding Properties Case No. DIR 2011-2380(SPP)- On December 19, 2011, the Director of Planning approved a Specific Plan Project Permit Compliance to allow the construction of a 6,005-square-foot t h r e e -story single-family dwelling over a basement with an attached 629 square-foot three-car garage on a vacant R1-1 zoned lot in the dual jurisdiction of the Venice Coastal Zone, located at 147 Via Marina. Case No. ZA 2011-2378(ZAA)-On June 13,2012, the Zoning Administrator denied an adjustment for side yard setbacks of 3-1/2 feet in lieu of the required 5-1/2 feet in conjunction with the construction of a 6,005 square-foot four-story single-family dwelling, located at 143 Via Marina. 2|Page Case No. DIR 2008-4534(SPP)(MEL) - On January 28, 2009, the Director of Planning approved a Specific Plan Project Permit Compliance to allow the construction of a 5,400 square-foot 45-foot single-family dwelling with basement and attached garage on a vacant lot in the Venice Coastal Zone, located at 147 Via Marina. Case No. ZA 2008-0864(ZAA)(SPP) - On September 17, 2008, the Zoning Administrator denied an adjustment to allow a zero easterly side yard setback and a 3-foot westerly side yard setback in lieu of the required 5-foot setback in conjunction with a construction of a single-family dwelling, located at 147 Via Marina. Case No. ZA 2007-2459(ZAA) -On November 14, 2007, the Zoning Administrator approved an adjustment to allow a reduced side yard setback varying from 2-1/2 feet to 3 feet in lieu of the required 5 feet for the construction of an approximately 3,380 square-foot single-family dwelling proposed at 150 Voyage Mall. Case No. ZA 2007-1646(ZAA) - On November 14, 2007, the Zoning Administrator approved an adjustment to allow reduced side yards of 3-1/2 feet in lieu of the required 6-1/2 feet and a raised deck of 10 feet in height for a three-story singlefamily dwelling over a basement, located at 146 Voyage Mall. Case No. ZA 2007-0405(ZAA) - On April 13, 2007, the Zoning Administrator approved an adjustment for the construction of a three-story (over habitable basement) single-family dwelling with a 9-foot in height raised entry landing along the easterly property line and reduced side yards of 3 feet to the west and 0 feet to the east, located at 151 Voyage Mall. Case No. ZA 2006-0333(ZAA)(SPP)(MEL) - On March 17, 2006, the Zoning Administrator approved an adjustment to allow a side yard of 3-1/2 feet for the southerly 48 feet 10 inches of the east side yard with the remainder of the east side yard to observe at least 4-1/2 feet in lieu oftheA-1/2 feet approved under Case No. ZA 2004-3307(ZAA)(SPP)(MEL), located at 126 East Voyage Mall. Case No. ZA 2004-4665(ZAA)(SPP) - On November 10, 2004, the Zoning Administrator approved an adjustment to permit the construction of a three-story (over h. bitable basement) single-family residence with a 9-foot in height raised entry landing along the westerly property line and side yards of 3-1/2 feet, and; Project Permit Compliance, located at 114 Union Jack Mall. Case No. ZA 2004-3307(ZAA)(SPP)(MEL) - On October 25, 2004, the Zoning Administrator approved an adjustment to allow a side yard of 4-1/2 feet in lieu of the required 5 feet 5 inches and to allow a 9-foot high raised deck along the easterly side yard for the construction of a four-story single family dwelling, located at 126 East Voyage Mall. Case No. ZA 2003-7834(ZAA)(MEL)-On March 11, 2004, the Zoning Administrator denied an adjustment to allow the construction of a four-story 44-foot in height, 5,892 square-foot single-family dwelling to observe a 3-1/2-foot side yard in lieu of the 5-1/2 feet required; and approved an adjustment to allow a 9-foot high deck along the westerly side yard for a linear distance of 11 feet, located at 126 East Voyage Mall: 3|Page Case No. ZA 2001-4750(ZAA) - On April 24, 2002, the Zoning Administrator approved an adjustment to allow side yards of 3-1/2 feet in lieu of the required 5-1/2 feet for the development of a third story addition and roof deck to a singlefamily dwelling, located at 135 West Via Marina. Case No. ZA 96-0989(YV) - On January 27, 1997, the Zoning Administrator approved a request for an adjustment to allow side yards of 3-1/2 feet in lieu of the required 4-1/2 feet for a single-family dwelling, located at 147 Voyage Mall. FINDINGS Following (highlighted) is a delineation of the findings and the application of the relevant facts of the case to same: 1. Describe what site characteristics or existing improvements make strict adherence to the zoning regulations impractical or infeasible; a nd ex pl ai n w h y the project nonetheless conforms with the intent of those regulations. The subject property is a vacant rectangular-shaped, approximately 2,888 square- foot interior lot zoned R1-1. The property has a 35-foot width and an 82.5-foot length. It is located in the Silver Strand Subarea of the Venice Coastal Zone Specific Plan; approximately 250 feet northeast of the Grand Canal. The site is in the dual permit jurisdiction area of the Coastal Zone, a Methane Zone, and a Liquefaction Zone. The applicant is requesting an adjustment to permit 3-1/2-foot side yards in lieu of the required 5-1/2 feet, and a Venice Coastal Zone Specific Plan Project Permit Compliance Review in conjunction with the construction of a four-story 4784 square-foot dwelling with a 560 square-foot attached three-car garage and a 581 square-foot full subterranean basement. Pursuant to Los Angeles Municipal Code Section 12.08-C,2, the required side yards for R1 zoned lots in the Coastal Zone are "not less than five feet for a main building of two stories in height, except that where the lot is less than 50 feet in width, the side yard may be reduced to ten percent of the width of the lot. For a building more than two stories in height, 1-foot shall be added to the width of each yard for each additional story above the second story." The proposed fourstory dwelling on a 35- foot wide lot requires 5-1/2-foot side yards. The subject substandard lot is part of a development that was granted approval, pursuant to a 1989 Zoning Administrator’s Interpretation (ZAI), to construct 36 single-family dwellings with 0-foot rear yard setbacks, 3-1/2-foot side yards in lieu of the required 4-1/2 feet, 6-foot front yard walls, and 8-foot side yard walls. The dwellings were permitted a height of 45 feet within twostories over a basement. The Zoning Administrator found at the time that the reduced yards were reasonable given that the volunteered dedications and easements decreased the buildable portion of the lots. Thirty of the lots have been developed with dwellings; the six remaining vacant lots are all located on Via Marina. 4|Page There are nine lots on the subject Via Marina block, three are developed with singlefamily dwellings and six are vacant. The seven interior lots are all approximately 35 feet wide, and the corner lots are approximately 30 feet and 36 feet in width. Two of the dwellings were constructed using the 1989 ZAI and maintain 3-1/2-foot setbacks (119 and 123 Via Marina) and are approximately 4,513 and 4,819 square feet, respectively. The property owner of 135 Via Marina was issued a building permit for a two-story over basement home utilizing the ZAI; and subsequently received approval of an adjustment to add a 500 square-foot, third story addition and a roof deck with 3-1/2-foot side yards. Per ZIMAS, that dwelling is 4,921 square feet. Granting the subject request as proposed would allow the owner to construct a fourstory 4455 square-foot dwelling with a 565 square-foot attached three-car garage and a 1400 square-foot full subterranean basement. The project is consistent with other single family dwelling in the area. The single family home has been designed in such a way that it incorporates a unique building design that has varying sized living space on each of the four stories. The first floor has only 720 square feet of living space and a large ground floor front patio area. It is also important to note the varying wall design of the living space, increases the light air and ventilation on the side yards, via its design. This unique design is continued on the second and fourth floors incorporating a combination of living space and patio areas. The granting of an adjustment for reduced side yards will not compromise the ability to have access and separation between structures and will not result in a development that is incompatible with the predominate character of the area. 2. Describe how: In light of the project as a whole including any mitigation measures imposed, the project's location, size, height, operations and other significant features will be compatible with and will not adversely affect or further degrade adjacent properties, the surrounding neighborhood, or the public health, welfare and safety. The property is in the Silver Strand residential neighborhood which is developed with two- to four-story dwellings with attached garages. The site is one of six vacant lots fronting on Via Marina in the Del Rey Beach Tract. The property located to the west is developed with a four-story house with 3-1/2-foot side yards. The property to the east is vacant. The dwellings on Channel Point Mall maintain side yards of 31/2 to 4-1/2 feet in width. The houses along Via Marina are developed with 6-foot walls located at the front property line. All of the dwellings maintain 0-foot rear yards and have elevated stairwells located in the side yard, leaving only one passable side yard. According to ZIMAS, the adjacent properties range in size from 3,520 to 4,971 square feet excluding attached garages. The proposed single family dwelling will maintain a front yard setback of 15 feet from the walk-street easement on Via Marina and a 0-foot rear yard. The south elevation is a combination of glass windows and doors with balconies on the 5|Page second and fourth floors and a ground floor patio all facing the Marina Del Rey entrance channel. There is a patio deck on the second and fourth stories that is stepped back 13 feet 7 ½ inches and 26 feet 8 inches from the easement respectively. The north elevation depicts four stories of tile siding and walls with large glass windows, and the first story three car garage entrance. There is significate articulation in the design of the building that incorporates setbacks and windows into its overall architectural presents. The east and west side elevations also have tile siding and large widow spaces. Furthermore it is important to note that both side yards are clear and assessable from the front to the back of the lot ensuring there is adequate access in case of an emergency. Vehicular access is from Via Marina Court to the three car garage. As designed, the request will not result in any detrimental impacts to the area. 3. Explain why the project is in substantial conformance with the purpose, intent and provisions of the General Plan, the applicable community plan, and any specific plan. There are 11 elements of the General Plan. Each of these elements establishes policies that provide for the regulatory environment in managing the City and for addressing environmental concerns and problems. The majority of the policies derived from these Elements are in the form of Code requirements of Los Angeles Municipal Code. Except for the entitlements described herein, the project does not propose to deviate from any of the requirements of the Los Angeles Municipal Code. The Land Use Element of the City's General Plan divides the city into 35 Community Plans. The Venice Community Plan designates the property for Low Residential land uses with corresponding zones of R1, RE9, RS, RU, RD6, and RD5 and Height District No. 1. The property is located in the Los Angeles Coastal Transportation Corridor Specific Plan area and the Silver Strand Subarea of the Venice Coastal Zone Specific Plan. A stated purpose of the Venice Coastal Zone Specific Plan is to "regulate all development, including use, height, density, setback, buffer zone and other factors in order that it be compatible with the existing community and to provide for the consideration of the aesthetics and scenic preservation and enhancement, and to protect environmentally sensitive areas." The development of a single-family dwelling is consistent with the site's zoning and land use designation, however, the proposed scale and mass of the dwelling is not consistent with the existing development on the adjacent properties. As designed, the project will be in substantial conformance with the purpose, intent and provisions of the General Plan, the Venice Community Plan, and the Venice Coastal Zone Specific Plan. PROJECT PERMIT COMPLIANCE FINDINGS Four required findings set forth in Section 8.C of the Venice Coastal Zone Specific Plan, as shown below: 4. The Venice Coastal Development Project is compatible in scale and character with the existing neighborhood, and that the Venice Coastal Development Project would not be materially detrimental to adjoining lots or the immediate neighborhood. 6|Page The subject parcel is a substandard lot with a width of 35 feet and a length of 82.5 feet with a total area of 2,888 square feet. The subject property and the surrounding properties are zoned R1-1. The surrounding properties are developed with three- and four-story single-family dwellings and there are several vacant lots. There are four-story dwellings located off of Via Marina Court. The project's proposed 45-foot height is consistent with other dwellings in the surrounding area. For example the property located at 119 Via Marina is four stories. The proposed projects size of 4455 square feet is consistent with others in the area having approximately 4,513 to 4,819 square. There is significate articulation in the design of the building that incorporates setbacks and windows into its overall architectural presents thus reducing the massing of the dwelling while allowing for reasonable use of the property in a manner that will not be materially detrimental to the adjoining lots or the immediate neighborhood. 5. The Venice Coastal Development Project is in Conformity with the Certified Venice Local Coastal Program. The subject property is designated Low Residential Density Housing in the Venice Local Coastal Program Land Use Plan and is zoned R1-1. The proposed project is consistent with the zoning and the intent and purposes of the Land Use Plan and the Specific Plan, which are parts of the Venice Coastal Program. As stated below, the project complies with the applicable development requirements of the Venice Coastal Specific Plan. In addition to the requisite findings set forth in Section 8.C of the Specific Plan, the project as limited will comply with all applicable provisions Sections 9.8, 10.C, and 13.0, as set forth below: Density: The proposed construction of single-family dwelling on a vacant lot is consistent with the Venice Specific Plan maximum density of one dwelling unit per R1-1 zoned lot. · Height: Within 60 horizontal feet of the inland edge of Esplanade East or the mean high tide line of Ballona Lagoon or inland side of the Esplanade, whichever is furthest from the water, Venice Coastal Development Projects shall not exceed a maximum height of 30 feet. Beyond 60 horizontal feet, one additional foot in height is permitted for each additional two horizontal feet to a maximum height of 45 feet. No portion of any structure (including Roof Access Structures, roof deck railings and Architectural Features) shall exceed the 30- foot height limit within 60 horizontal feet of the mean high tide line of Ballona Lagoon, or inland side of the Esplanade, whichever is furthest from the water. The proposed project height to the parapet is within the maximum permitted height of 45 feet. Access: The driveway and vehicular access to the property is provided from Via Marina Court as required. 7|Page Parking: Single-family dwellings located on a lot less than 40 feet in width in the Silver Strand Subarea require two covered parking spaces and one uncovered space with access from the adjacent alley. The project will provide three covered parking spaces. 6. The applicant has guaranteed to keep the rent levels of any Replacement Affordable Units at an affordable level for the life of the proposed project and to register the Replacement Affordable Unit with the Los Angeles Housing Department. The subject property is vacant and has never been developed with affordable units. The project is the construction of a single-family dwelling. No Replacement Affordable Units are required. 7. The Venice Coastal Development Project is consistent with the special requirements for low- and moderate-income housing units in the Venice Coastal Zone as mandated by California Government Code Section 65590 (Mello Act). · The subject property is vacant. The applicant is proposing to construct one singlefamily residence. Projects involving the construction of nine or fewer net new units, pursuant to Part 2.4.2 of the Interim Administrative Procedures, are not required to provide inclusionary Residential Units. COASTAL DEVELOPMENT PERMIT FINDINGS Coastal Development Permit findings maintained in Section 12.20.2 of the Los Angeles Municipal Code t h e f ollowing is a delineation of the findings and the application of the facts of this case to same. 1. The development is in conformity with Chapter 3 of the California Coastal Act of 1976. Chapter 3 of the California Coastal Act provides standards by which "the permissibility of proposed developments subject to the provision of this division are determined". In the instant case, the Coastal Act provides that: "New development, except as otherwise provided in this division, shall be located within, contiguous with, or in close proximity to, existing developed areas able to accommodate it or, where such areas are not able to accommodate it, in other areas with adequate public services and where it will not have significant adverse effects, either individually or cumulatively, on coastal resources". The subject property is a rectangular undeveloped 3,150 square-foot lot and is zoned R1-1. The property has a 35-foot frontage on the north side of Via Marina in the Silver Strand Sub-area of the Marina Peninsula. The property is located between Marina Del Rey and the Grand Canal, approximately one mile west of Lincoln Boulevard. This property is within the dual permit jurisdiction of the Coastal Zone, a Methane Zone, and a Liquefaction Zone. The project consists of a request for an adjustment to permit reduced side yards of 8|Page 3-1/2 feet in lieu of the required 5-1/2 feet, and a Venice Coastal Zone Specific Plan Project Permit Compliance and Coastal Development permit in conjunction with the construction of a four-story 4784 square-foot dwelling with a 560 square-foot attached three-car garage and a 581 square-foot full subterranean basement. The lot is partially surrounded by Low Residential properties zoned R1-1 to the north and west. To the far west, lies a small Low-Medium Residential neighborhood zoned RD1.5-1. To the south, and far west is the entrance channel of Marina Del Rey and the Grand Canal zoned A1-1 and OS-1. The property to the east is unincorporated community of Marina Del Rey. The property is not adjacent to the shoreline, and the project will not affect marine resources, coastal waters, wetlands, any environmentally sensitive habitat area, archaeological or paleontological resources. In light of the above, it can be found that the project will not have significant adverse effects, either individually or cumulatively, on coastal resources. 2. The permitted development will not prejudice the ability of the City of Los Angeles to prepare a local coastal program that is in conformity with Chapter 3 of the California Coastal Act of 1976. The Land Use element of the Venice Local Coastal Program (LCP) has been adopted in June 2001. Currently, there is no adopted LCP for this portion of the Coastal Zone; in the interim, the adopted Venice Community Plan, and Venice Specific Plan serve as the functional equivalent in conjunction with any pending LCP under consideration. The Venice Community P l a n designates the property for Low Residential uses, with corresponding zones of RE9,RS,R1,RU,RD6,RD5 , Height District No. 1. The property is zoned R1-1, consistent with the Plan land use designation. The property is also located within the Venice Specific Plan area and the Coastal Transportation Corridor Specific Plan Area. A project Permit Compliance for the Venice Specific Plan is processed incident to the instant Coastal Development Permit. The project is designed to be in conformance with all applicable provisions of the Venice Specific Plan and is in conformance with both the zoning classification and the plan designation. The proposed development is in compliance with the current regulations, policies of the California Coastal Act and the adopted Venice Plans, and as such will not prejudice the ability of the City to prepare a Local Coastal Program in conformity with Chapter 3 of the California Coastal Act. 3. The Interpretive Guidelines for Coastal Planning and Permits as established by the California Coastal Commission (revised October 14,1980) and any subsequent amendments thereto have been reviewed, analyzed and considered in light of the individual project in making this determination. The subject property is designated Low Residential Density Housing in the Venice Local Coastal Program Land Use Plan and is zoned R1-1. The proposed project is consistent with the zoning and the intent and purposes of the Land 9|Page Use Plan and the Specific Plan, which are parts of the Venice Coastal Program. As stated below, the project complies with the applicable development requirements of the Venice Coastal Specific Plan. In addition to the requisite findings set forth in Section 8.C of the Specific Plan, the project as limited will comply with all applicable provisions Sections 9.8, 10.C, and 13.0, as set forth below: Density: The proposed construction of single-family dwelling on a vacant lot is consistent with the Venice Specific Plan maximum density of one dwelling unit per R1-1 zoned lot. · Height: Within 60 horizontal feet of the inland edge of Esplanade East or the mean high tide line of Ballona Lagoon or inland side of the Esplanade, whichever is furthest from the water, Venice Coastal Development Projects shall not exceed a maximum height of 30 feet. Beyond 60 horizontal feet, one additional foot in height is permitted for each additional two horizontal feet to a maximum height of 45 feet. No portion of any structure (including Roof Access Structures, roof deck railings and Architectural Features) shall exceed the 30- foot height limit within 60 horizontal feet of the mean high tide line of Bailona Lagoon, or inland side of the Esplanade, whichever is furthest from the water. The proposed project height of 44 feet 7 inches to the parapet is within the maximum permitted height of 45 feet. Access: The driveway and vehicular access to the property is provided from Via Marina Court as required. Parking: Single-family dwellings located on a lot less than 40 feet in width in the Silver Strand Subarea require two covered parking spaces and one uncovered space with access from the adjacent alley. The project will provide three covered parking spaces. 4. The decision of the permit-granting authority has been guided by any applicable decision of the California Coastal Commission pursuant to Section 30625(c) of the Public Resources Code. This section of the California Public Resources Code provides that "prior decisions of the Coastal Commission, where applicable, shall guide local governments in their actions in carrying out their responsibility and authority under the Coastal Act of 1976". This request conforms with such known applicable decisions. 5. If the development is located between the nearest public road and the sea or shoreline of any body of water located within the coastal zone, the development shall be in conformity with the public access and public recreation policies of Chapter 3 of the California Coastal Act of 1976. The development is not located between the nearest public road and the shoreline. 10 | P a g e 6. Mello Act The Venice Coastal Development Project is consistent with the special requirements for low- and moderate-income housing units in the Venice Coastal Zone as mandated by California Government Code Section 65590 (Mello Act). · The subject property is vacant. The applicant is proposing to construct one singlefamily residence. Projects involving the construction of nine or fewer net new units, pursuant to Part 2.4.2 of the Interim Administrative Procedures, are not required to provide inclusionary Residential Unit. 11 | P a g e
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