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HomeMy WebLinkAbout08 August ~ d'~~ Human Services L JEFFERSON COUNTY BOARD OF HEALTH MINUTES AUGUST 26, 1997 BOARD MEMBERS Glen Huntindord, chai""all - COUIlty commissio'ler District 2 Richard wojt, M<mber - COUIlty Commissioller District 3 Dall Haryole, M<mber - COUIlty Commissioner District I Ted shoulberg, M<mber - Pori TOwl1Send City council Jill Buhler, Member - Jeffersoll COUIlty HOspiinl District #2 commisswIler sheik Weste""M, M<mber - Citizen at Large (City) RobertJ! FrisseU, M<mber - Citizen at Large (county) STAFF MEMBERS David syccter, Health Deyariment Dirccwr Jean Baldwtll, Directl" of Nursing Services Lany Fay, Dirccwr of EIlviro'lmel1inl Hcnlth chester mdhomme, Director of SUhsinllCC Abuse Thomas Locke, M.D., Health officer Judi MOrris, Admillistrative suyyori The meeting was called to order by Chairman Glen Huntingford. with the exception ofIed Shoulberg. All Board and staff members were present APPROVAL OF MINUTES Commissioner Wojt moved to approve the minutes of July 22, 1997 as presented. Commissioner Harpole seconded the motion which carried by a unanimous vote. PUBLIC COMMENT PERIOD No public comments. WELCOME / INTRODUCTION OF NEW BOARD OF HEALTH MEMBERS Chairman Huntingford welcomed the new members Jill Buhler, Public Hospital District #2; Roberta Frissell, County Citizen at Large; and Sheila Westerman, City Citizen at Large. After brief introductions, Commissioner Harpole thanked them for their willingness to give of their time to serve on this Board. HEALTH DEPARTMENT 360/385-9400 ENVIRONMENTAL HEALTH 360/385-9444 DEVELOPMENTAL DISABILITIES 360/385-9400 ALCOHOL/DRUG ABUSE CENTER 360/385-9435 FAX 360/385-9401 HEALTH BOARD MINUTES - AUGUST 26,1997 Page 2 Member Sheila Westerman asked about Ordinance #03-0505-97, expanding the Board of Health. She stated that it references an RCW and in clause #8.00.020 Members, it reads that "Appointed members of the Board of Health shall include one elected official from the City of Port Townsend City Council and three non- elected community representatives." It later states "One community representative shall be a Jefferson County Public Hospital District #2 Commissioner..." She said it is her understanding that a Hospital Commissioner is an elected position. This appears to be an error which may need to be corrected the next time this ordinance is amended. David Specter stated that the lanquage was drafted by the Legislature and is specific to the RCW that provided for the expansion. For the purposes of Boards of Health, "elected officials" is defined as county and city officials. Everyone else is considered non-elected. Consequently, this definition is advantageous to the County, as it allows for the appointment of an elected official to a technically non-elected position. ORGANIZATIONAL ACTION ITEMS ELECTION OF CHAIRPERSON: Commissioner Harpole nominated and moved to elect Commissioner Huntingford to serve as Chairman ofthe newly expanded Board of Health. Hearing no further nominations, Commissioner Wojt closed the nominations and seconded the motion which carried by a unanimous vote. Member Sheila Westerman nominated and moved to elect Commissioner Harpole to serve as Vice- Chairman. Commissioner Wojt seconded the motion. Hearing no further nominations, Commissioner Huntingford closed the nominations and called for a vote on the motion. The motion carried by a unanimous vote. ASSIGNMENT OF TERMS: David Specter stated that according to the ordinance, terms will be staggered by appointing an equal number of the four new members to two and three year terms. He added that since Members Jill Buhler and Ted Shoulberg are elected officials, their elected terms of office have the potential to impact their term as Board of Health members. If they no longer held their elected position then the provisions for replacement would be followed, as will be outlined in the bylaws. After a brief discussion of preference of term lengths, Vice-Chairman Harpole moved to appoint Members Sheila Westerman and Ted Shoulberg to serve two year terms and Members Jill Buhler and Roberta Frissell to serve three year terms. Commissioner Wojt seconded the motion for discussion. Member Sheila Westerman asked about the importance of the two citizen at large positions not expiring at the same time, since the city citizen at large position is a two year term and the county citizen at large position is a three year term. Commissioner Wojt explained that the terms are meant to be staggered which is why two ofthe positions are initially given two year terms. After the first cycle, a regular term of appointment will be three years. Vice-Chairman Harpole added that by staggering the terms, the citizen at large positions will not expire at the same time. Hearing no further discussion, Chairman Huntingford called for a vote on the motion. The motion carried by a unanimous vote. MEETING DAYITIMEILOCATION: David Specter stated that the Jefferson County Board of Health has always met monthly, although the frequency of meetings varies among health jurisdictions throughout the State. The ordinance passed by the Jefferson County Commissioners requires the continuation ofthe monthly meetings. The Board members need to determine what day, time and location will be convenient for everyone. Media coverage in the Port Townsend Leader is difficult when the Board of Health meetings take place on Tuesday and the newspaper comes out on Wednesday. The Health Department would prefer holding the meeting on a different day of the week to allow for more media HEALTH BOARD MINUTES - AUGUST 26, 1997 Page 3 coverage. After reviewing schedules of the staff and the Board members, Commissioner W ojt moved to schedule the monthly meetings of the Health Board on the third Thursday of each month, from 2:30 to 4:30 p.m. Vice-Chairman Harpole seconded the motion for discussion. The Board discussed and agreed to hold the meetings at the Jefferson County Health and Human Services Department conference room. The motion was amended to include the location. Chairman Huntingford called for a vote on the amended motion. The motion carried by a unanimous vote. BYLAWS: David Specter stated that the appointment of two Board members to serve on an ad hoc subcommittee to establish Bylaws for the Board, would be sufficient. Vice-Chairman Harpole and Member Jill Buhler volunteered to serve on the subcommittee. ORIENTATION WELCOME TO PUBLIC HEALTH: Dr. Tom Locke reviewed a guidebook titled "Welcome to Public Health", which was produced by the Northwest Center for Public Health, School of Public Health and Community Medicine, University of Washington, and the Washington State Board of Health. This guidebook was developed to orient and inform new members about local Boards of Health. He feels the three most important aspects of public health as outlined in the guidebook are: 1) Importance of Public Health: Dr. Locke stated that he believes the reason individuals live longer in the 1990's, as opposed to the beginning of the century, is largely due to public health measures. Today's medical care and technology is very impressive, however, it is public health measures that significantly increases life span. What shortens life span can be attributed to bad behavioral choices, environmental factors, heredity, and lack of access to good health care. Public health is critically important and the activity of Boards of Health have an impact on the health and safety of community members. 2) State Public Health System: Protecting public health in the State of Washington relates to a system which began over 100 years ago. Washington State is unique, in that it created a State Board of Health in the State Constitution. Shortly after the formation of the State Board of Health, and with the formation of counties, each county had a local Board of Health and a Health Officer. The main function of the local Board of Health was to quarantine food in ships, control disease outbreaks, regulate water supplies, and practice what was known scientifically, about public health protection. Over the course of this century, as more has been learned about how to prevent disease outbreaks, the systems have become more sophisticated, Health Departments have been created and counties have merged together to form multi-county health districts. The system in place now is composed of local Boards of Health, a State Department of Health (an independent department since 1990), and the State Board of Health. The State Board of Health is comprised of citizens appointed by the Governor. This Board meets once a month and is responsible for developing policies and regulations which are enforced by local health jurisdictions. Local Boards of Health vary due to the difference in health jurisdictions. There are thirty-nine counties in Washington State, and only thirty-three health jurisdictions. Jefferson County is a pioneer in Boards of Health, in that it is one of the first counties that has taken advantage of a change in the law that allows the County Commissioners to expand the Board of Health by ordinance. Dr. Locke is hopeful that Jefferson County can provide leadership to the state and demonstrate that making local Boards of Health more representative of communities is in fact going to be a very effective way to improve the public health system. HEALTH BOARD MINUTES - AUGUST 26,1997 Page 4 3) Local Board of Health Statutory Responsibilities: Dr. Locke read a quotation from RCW 70.05.060 which states that a local Board of Health shall: "have supervision over all matters pertaining to the preservation of the life and health of the people within its jurisdiction..." Following is a list of some of those powers: . Adopt and enforce regulations . Supervise all sanitation (ie. food, water quality, waste disposal) . Prevent dangerous, contagious and infectious disease . Control or abate nuisances . Establish fees for health jurisdiction services Many of these responsibilities are done through the Health Officer. The term "Health Officer", under the law, has a dual meaning: I) There is an official Health Officer position to which a physician with a masters degree and specialized training in public health, is appointed; 2) Anyone acting under delegated powers of the Health Officer is also considered a Health Officer. Dr. Locke stated that there is a very strong tradition in this country of courts affirming virtually anything a local Board of Health does in good faith. The case law oflocal Boards of Health being reversed in the decisions they make is almost non-existent. Dr. Locke stated that in the past, Boards of Health have used their authority to create local ordinances or resolutions that codify many of their responsibilities such as food safety ordinances, onsite sewage ordinances, drinking water quality, etc. Member Jill Buhler asked if the approach to dealing with issues is proactive, or reactive due to complaints, or a combination of both? Dr. Locke answered that it is his impression that Boards of Health typically have been reactive in Washington State, responding to complaints and problems as they come up. However, the direction that public health reform is taking in this state is to become proactive. David Specter stated that at one time Jefferson and Clallam Counties were combined as the Olympic Health District. He added that Dr. Locke is also the Health Officer for Clallam County and the Medical Director for the Jamestown S'Klallam and Port Gamble S'Klallam tribes, and he serves as the Public Health Associations representative to the State Board of Health appointed by the Governor. PROPOSED ORIENTATION PLAN: David Specter presented a model outline of the essential responsibilities of public health. This format is being used as a possible framework for rewriting the Washington Administrative Code (WAC) for public health. David Specter noted that Dr. Locke is the Chairman of the committee, at the state level, that is rewriting the WAC's. Vice-Chairman Harpole commented on the format of the orientation plan, stating that he thinks it is an interesting format, but his preference would be to discuss three items at a time during each monthly meeting. David Specter reported the Health Department will be putting together a binder for each new Board member containing various reference materials. Jean Baldwin added that the Board members will also be receiving the final copy of the Washington Health Foundation Report. Vice-Chairman Harpole asked Chairman Huntingford ifhe supported the orientation plan format presented by David Specter? Chairman Huntingford answered that he does support the format and discussing a few topics at a time. HEALTH BOARD MINUTES - AUGUST 26, 1997 Page 5 Member Westerman suggested that since the items are going to be split up and discussed at separate meetings, maybe the items could be grouped according to related topics. This would allow the Board to maintain a focus. All Board members agreed. David Specter will work on the grouping. OLD BUSINESS WAIVER POLICY FOR MINIMUM LOT SIZE: ONSITE SEWAGE PROGRAM: Larry Fay presented a draft policy statement number 97-02, relating to minimum land area requirements. He explained that in making a decision on the issuance of a permit for an onsite sewage/septic system, a number of factors must be considered, such as soil conditions, critical areas, water, and property limitations. The State Onsite Sewage Code specifies a minimum land area, which is dependent on the above factors. This State regulation allows for some exceptions to the minimum land area requirements. One exception has to do with whether or not property is a "lot of record". This issue came to the Board of Health in February, as there was confusion about the definition of a "lot of record". According to the State Onsite Sewage Code, property considered a "lot of record" and which is !!Q1 being considered for any other waiver, can be considered for a permit, even though it does not meet the minimum land area requirements. Larry Fay stated that after having various discussions about the de[mition of a "lot ofrecord", it was decided that a definition is irrelevant. A small lot has the potential to have problems with a septic system. If property does not meet the minimum land area requirements as outlined in the State regulations, it will not be permitted, unless a waiver from the land area requirements is applied for, which indicates that the property owner will meet the intent of the regulation to protect public health. Larry Fay developed this policy based on meetings with various septic system engineers and designers that work regularly in Jefferson County. The policy has been reviewed and approved by the Prosecuting Attorney. This policy outlines a number of provisions which must be met in order to receive consideration for a waiver. If inconsistencies exist between the State Onsite Sewage System regulations and County or City zoning requirements, the more restrictive will apply. Another provision deals with Method II analysis or critical aquifer recharge report and is designed to look at the impacts onsite sewage systems may have on aquifers in a specific area with regard to potential contamination. Member Westerman asked about the method I analysis, as mentioned in the provision? Larry Fay answered that Method I is just a table for use as a reference. Method II is used in evaluating a particular area to determine an appropriate density of septic systems for that area. She stated that this provision references that a street right-of-way may be included in the minimum land area application, if the right-of-way"... is dedicated as part of the development, and land area is at least 12,500 square feet in area..." She asked ifthe words "land area", in that sentence, refer to the site itself, or the total land area? Larry Fay answered that it refers to the total land area. Member Westerman stated that in the minutes of the last Board of Health meeting there is an outline of class "A", "B", and "C" waivers as established by the Department of Health. She asked what class of waiver this policy refers to? Larry Fay answered that this policy refers to class "B" waivers in the State system. He explained that class "A" waivers are a State-wide standard waiver, class "B" waivers can be done programatically by getting the State Department of Health's approval in advance, and class "C" waivers are very specific. Larry Fay stated that this policy has been structured for general provisions which came directly from the State Onsite Sewage Regulations. Larry Fay stated there are blocks of lots owned by individuals which could possibly be segregated and sold and still meet the minimum land area requirements without a waiver. If someone owned 20 lots with good HEALTH BOARD MINUTES - AUGUST 26,1997 Page 6 soil conditions, the property may be approved for 2 permits. Then a block of 10 lots could be sold for a building site. With the possibility of waivers being granted, the property may actually be 4 building sites. The Health Department is doing its best to adhere to the regulation, so a large block oflots would only be permitted for the maximum number of building sites that are possible without a waiver. The waiver process should not be used as a means to increase the number of building sites on property. Commissioner Wojt asked about the accummulative effect on the density ofa 100 acre area that contains many lots that need a waiver because they do not meet minimum standards? Waivers may be approved for the first few applicants, but then, where do you draw the line in approving waivers for other applicants? Larry Fay answered that it depends on what is expected to happen with buildout. Method II was not developed to determine whether existing lots could be built on, it was developed to determine a reasonable density for land before it is developed. Larry Fay feels that provision III. (C)(l), may need some language amendments. It states "The ownership pattern of the land area on which the development is being proposed was established prior to the effective date of this policy". The Health Department is trying to avoid checker boarding of existing large blocks, such as splitting the ownership among several people. On the other hand, it is not the intent of the Health Department to prevent the buying and selling of property. Chairman Huntingford asked about the effects of zoning changes and how they will be dealt with? Larry Fay answered that zoning changes regarding lot consolidation of contiguously owned property will supersede Health Department regulations. The Health Department works with minimum standards that are safe, while the zoning in the Comprehensive Plan may have different thresholds that are far more conservative than is necessary to protect the public health. John Swallow (a member of the audience) stated that in talking with Larry Fay in the past regarding subdivisions, he was told that any lot established after 1972 would be recognized, even if the lot was smaller than what is listed on the method I table, because it was legally subdivided and had gone through the proper health regulations at the time it was subdivided. He asked Larry Fay ifhe is reversing what he had said originally and will no longer recognize these lots if they are below the standards? Larry Fay replied that this policy is different than the information he wrote about in a letter last February. In February, the Health Department was focusing on the definition of a "lot of record". At that time, that information was accurate. After looking at the Onsite Sewage Regulations and talking with the Prosecuting Attorney, the Health Department is under no obligation to issue a permit for any small lot, regardless of when it was created, ifit does not meet the land area requirements. In terms of subdivision vesting, a subdivision is vested for five years after final plat approval, under the regulations that were in place at the time of preliminary plat approval. Carol Swallow (a member of the audience) stated changes in zoning regulations may result in I residential dwelling unit per 10 or 20 acres. She asked if the five year limit will apply to previously platted property in this situation as well? Commissioner Huntingford stated that his understanding of the Subdivision Ordinance is, if nothing has been done within a subdivision during a period of five years, then it can be consolidated into raw acreage. Larry Fay stated that on lots that far exceed the land area requirements of the Onsite Sewage regulations, the Health Department would process permits, unless there is a decision by the Board of County Commissioners set forth in the Comprehensive Plan or land use and zoning ordinances which requires lot consolidation to meet density requirements. HEALTH BOARD MINUTES - AUGUST 26, 1997 Page 7 Chairman Huntingford stated that he feels the Board of Health should table any action on this policy until the Board of County Commissioners has made a decision on "lots of record" and zoning issues, so this can all be tied together. He feels it is ultimately going to be a decision by the County Commissioners on what will happen with zoning. Member Westerman stated that the County Commissioners do not preclude the Board of Health from making decisions. Chairman Huntingford agreed and stated that health requirements do not set land use policy. Member Westerman agreed and stated that the Commissioners' zoning decisions, if more restrictive, will precede any decision made by the Board of Health. That is a common practice when there are overlapping regulations. As a newly appointed member of the Board, she would like to be able to conduct the business of the Board and not have to wait for the County to resolve political issues that may be on the table for an unknown period of time. Carol Swallow asked Larry Fay if the minimum land area requirements will apply to remodels and the replacement of mobile homes? Larry Fay answered that this policy applies to applications for septic permits not building permits. Projects requiring an expansion of a septic system, would require an application for a septic permit and would fall under this policy. Commissioner Wojt moved to adopt the Minimum Land Area Requirement Policy #97-02. Member Frissell seconded the motion for discussion. Vice-Chairman Harpole added a friendly amendment to the motion that Larry Fay will bring forward clarifying language for section IIL(C) Standard Land Area Waiver Conditions (I). Chairman Huntingford asked the effective date of the policy? The Board concurred that the effective date be today. Member Westerman noted that the second sentence in section IIL(A) General Land Area Waiver Provisions (2) states "Justification may be in the form of the standard land area waiver described below or may be specific to the proposed development." The only thing she could find below was the "standard waiver conditions" and she asked if that is what that language refers to? Larry Fay answered yes, and stated that he will change that language for consistency purposes. In that same section m(C) under item (3) she noted that the number of parcels needs to be clarified. The motion was amended to include that Larry Fay will also provide clarifying language for section IIL(A)(2) and (C)(3). Chairman Huntingford noted that at the beginning of this presentation, Larry Fay said that this policy was based on State Health Department regulations and the definition of a "lot ofrecord". He asked Larry Fay about the State's definition of "lot of record"? Larry Fay replied that there isn't a definition by the State. The State's view is that the local zoning codes define a "lot of record". After further discussion, Chairman Huntingford called for a vote on the motion. Vice-Chairman Harpole, Commissioner Wojt and Members Sheila Westerman and Roberta Frissell voted for the motion. Chairman Huntingford voted against the motion. Member Jill Buhler abstained from voting as she did not receive a copy ofthe policy to review prior to the meeting. The motion carried. Commissioner Wojt excused himselfto attend another meeting. UPDATE ON LINDA SEXTON ISSUE: Larry Fay stated that the Health Department sent Linda Sexton a stipulated compliance agreement that was developed in conjunction with the Prosecuting Attorney's office. Ms. Sexton has since fired her attorney, according to a letter received from her yesterday. Her letter also states that she is unable to sign the agreement as it will force her to get rid of all of her recyclable materials which she does not view as solid waste. She goes on to state that she is not operating a solid waste facility, but she does want to continue to work with the Health Department. Due to Ms. Sexton's expressed interest in working with the Health Department, Dr. Locke feels that the Health Department should attempt HEALTH BOARD MINUTES - AUGUST 26,1997 Page 8 to get some effort on Ms. Sexton's part in cleaning up her property, before proceeding with prosecution. Larry Fay stated that if this is the approach the Board wants to take, then the Board should reaffirm that the position of Health Department staff is correct in stating that she is operating an unpermitted solid waste facility and that she must either go through the permitting process for a recycling facility or clean up the property within an agreed upon time frame. Vice-Chairman Harpole moved to reaffirm that the County's intentions are as stated above. Member Westerman seconded the motion. Commissioner Huntingford stated Ms. Sexton sent a letter to the Board and he has tried several times to reach her by telephone to no avail. He called for a vote on the motion which carried by a unanimous vote. UPDATE ON ECOTEC ISSUE: Larry Fay reported that Mr. Foss has not yet applied for a permit for a septic holding tank and has stated that he will be closing his existing holding tank which does not comply with any of the siting standards, however, the Health Department will need to verify that he has done so. He has taken at least two (2) loads of septage to the City of Port Townsend's facility and there is at least one load which has not yet been accounted for. The Health Department sent Mr. Foss another written request for his records over the last year, in order to determine how much septage he has pumped, where it was pumped and where it was taken. The information would assist the Health Department in determining whether or not to get a warrant and conduct an evaluation ofMr. Foss's property, where they believe the septage was dumped. Commissioner Huntingford stated that the Board encouraged Mr. Foss to work with the Health Department in getting the appropriate permits and do what is right to resolve this issue. It appears that Mr. Foss is not willing to cooperate. Vice-Chairman Harpole feels that the Board made every effort to try to work with Mr. Foss. It is disturbing that Mr. Foss does not seem to perceive the seriousness of this issue. Vice-Chairman Harpole stated that this is a very serious issue and moved to suspend Mr. Foss's license to pump septic systems until he complies with the requests of the Health Department. Member Westerman seconded the motion which carried by a unanimous vote. ALCOHOL/DRUG PROGRAM REVIEW: Chester Prudhomme presented copies of the Jefferson County Health and Human Services/Alcohol and Drug Abuse Program Review. This review was developed at the request of the Board of County Commissioners to answer questions regarding services provided for substance abuse rehabilitation in Jefferson County, alternative services, costs of services, etc. NEW BUSINESS SOLID WASTE ENFORCEMENT GRANT: David Specter stated that the Health Department has not been doing much in terms of solid waste enforcement. The Health Department routinely receives complaints on garbage, rats, etc. David Specter stated that there is an opportunity to get additional grant funding for solid waste enforcement and asked the Board members if they want to become more active in dealing with this issue? Vice-Chairman Harpole stated the County is taking the lead in looking at establishing a solid waste district and they are struggling to get the resources/funding for the planning process. The County is undertaking a substantial outreach process on various funding options. He asked if it is possible to use any of these grant funds over the next six (6) months to supplement work being done by the Public Works department on solid waste planning? Larry Fay stated that in looking at the forecast for the end ofthe year, there will be between $6,000-$9,000 spent in the current enforcement grant. An option for the short term would be for the Health Department to continue at their current staffing level. Larry Fay stated that he could notify the Department of Ecology that the Health Department will not spend at least $6,000 of the grant funding so that it could go to Public Works for planning, moderate risk waste, or other types of things. The way coordinated prevention grants and solid , HEALTH BOARD MINUTES - AUGUST 26,1997 Page 9 waste enforcement grants are handled will be fundamentally changed next year. In the past, the County had a pool of money, of which $70,000 was allocated for enforcement over a twcfyear period of time. Funding for which the Health Department did not apply, remained in the County for coordinated prevention grant funding for the moderate risk waste facility, planning and those types of things. In this next grant cycle, the enforcement dollars will be pooled state-wide, separate from the coordinated prevention grants. This means that funding which is not applied for by Jefferson County, is available to other counties for enforcement, and not available to the Jefferson County for other solid waste activities. Indirectly, Jefferson County can stretch some funding by having the Health Department perform groundwater monitoring, which is currently being performed by Public Works. By doing this, the function of groundwater monitoring can be billed under enforcement grant funding. Even if Public Works continues to do the work through an agreement with the Health Department, it is an indirect way to get assisted grant funding for some of these other types ofthings. Additionally, the landfill monitoring wells are getting close to their life expectancy and the Department of Ecology has indicated that the Health Department could apply for replacement of the pumps under the enforcement grant funding as well. Vice-Chairman Harpole asked when the Health Department needs to know the Board's preferred direction for this request. Larry Fay stated that applications must be submitted by the 31 st of September. He will talk with the Director of Public Works regarding this matter. Discussion ensued regarding staffing for these activities. At this time, the Board concurred with the suggested option of making $6,000 available to Public Works. David Specter noted that this was revenue that the Health Department had budgeted for staffing. Vice-Chairman Harpole asked if the transfer of funds can be addressed internally at the Health Department? He added that the Board is not trying to create a problem for the Health Department, but there is a huge issue with planning for long term solid waste needs and maybe the resources could be shared between the Health Department and Public Works. Chairman Huntingford commended David Specter and the Health Department staff for their willingness to always work with the Board in these instances. Meeting adjourned. The next meeting will be held on Thursday, September 18, 1997 at 2:30 p.m. F HEALTH f i ''I ft/;~ II Buhler, Member ~~~ Sheila Westerman, Member ~J:i?v~~~/€ Roberta Frissell, Member Richard E. Wojt, Member Excused Absence (f~ Ted Shoulberg, Member ~r;: 517t../ D WIfSrE," rlfat/"ry Cc r-ltaJ\V-. '1>1/I(n ~ roe fq ( cht~c;(.{m, WtL-, -:;:'1'1 3" Iqq7 '??J~ 71u. 80tud ~ &mrn/5>lbl1t!VS' ..::r- rT!c...lveJ "- r!OCUWl~11 t h 77" as '/oil J/vec f.eJ!he ~p/fh ~R;cer TIf5 Je;c:.tunenJ.- is the Clwlce;PH-e... I', 011 Ilde"! flli" n. C'M/,/y. 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