HomeMy WebLinkAboutV 02-03; Arco AM/PM at Tamarack; Variance (V)The City of Carlsbad Planning Department
Application complete date:
A REPORT TO THE PLANNING COMMISSION
August 3 1,2001
Applicant requested extension
Item No. @
Project Planner:
Project Engineer:
Christer Westman
Jeremy Riddle
P.C. AGENDA OF: September 4,2002
SUBJECT: CUP 01-19N 02-03 - ARCO AM/PM AT TAMARACK - Request for
approval of a Negative Declaration and Addendum, and Conditional Use Permit
for the construction of a new 2,997 square foot ARCO AM/PM facility with 12
heling stations and a 968 square foot car wash, and a Variance request for
reduced setbacks at the northeast comer of Tamarack Avenue and Jefferson Street
in Local Facilities Management Zone 1.
I. RECOMMENDATION
That the Planning Commission ADOPT Planning Commission Resolutions No. 522 1, 5222 and
5223 RECOMMENDING ADOPTION of a Negative Declaration and Addendum, and
RECOMMENDING APPROVAL of Conditional Use Permit CUP 01-19, and Variance V 02-
03 for the construction of a new 2,997 square foot ARCO AM/PM facility with a 968 square foot
car wash with reduced setbacks based on the findings and subject to the conditions contained
therein.
11. INTRODUCTION
The application is for the redevelopment of a closed gas station with a new ARCO MM
convenience store with gas pumps and car wash. The existing gas station has not been in
operation for several years.
The new facility proposes reconfiguration of the property access fi-om Tamarack Avenue at a
location farther away fi-om the Jefferson Street intersection, revised onsite circulation, parking,
and landscaping.
The property is located in the CommerciaWisitor-Serving Overlay Zone and is therefore subject
to the review and approval of the City Council. The site is also in a deferred certification area of
the Coastal Zone and is subject to review and approval by the California Coastal Commission.
111. PROJECT DESCRIPTION AND BACKGROUND
The proposed project is subject to the following regulations:
A. Neighborhood Commercial Zone (C-1) (Chapter 21.26 of the Carlsbad Municipal
B. Conditional Use Permit Regulations (Chapter 21.42 of the Carlsbad Municipal Code);
Code);
CUP 01-19N 02-03 - ARCb AM/PM AT TAMARACK
September 4,2002
C. CommerciallVisitor-Serving Overlay Zone (Chapter 2 1.208 of the Carlsbad
D. Variances (Chapter 21.50 of the Carlsbad Municipal Code); and
E. Mello I1 Segment of the Carlsbad Local Coastal Program.
Municipal Code);
IV. ANALYSIS
The recommendation for approval of this conditional use permit and variance was developed by
analyzing the project’s consistency with the applicable City regulations and policies. The
project’s compliance with each of the above regulations is discussed in detail in the sections
below.
Neighborhood Commercial Zone
The site is designated as a neighborhood commercial site yet it is also located adjacent to the
freeway and is expected to provide freeway facility, commercialhisitor-serving related services.
The proposed service station, convenience market and car wash can provide fkeeway facility,
commercialhisitor-serving services that can also be beneficial services to the neighborhood.
The development standards of the Neighborhood Commercial zone limit building height to 35
feet. There are no building setback requirements for the C-1 zone.
The project has been proposed consistent with the C-1 zone development standards in that the
greatest building height is nineteen feet at the comers of the convenience market. The gas pump
canopy is proposed at sixteen feet and the carwash building at fourteen feet.
Conditional Uses
Uses subject to a Conditional Use Permit (CUP) are declared to possess characteristics of such
unique and special form as to make impracticable their being included automatically in any land
use class. Automobile service stations which include washing services may be permitted by
conditional use permit in any zone other than residential or professional when it is developed as
part of a freeway service facility. The proposed project and the adjoining restaurant together
qualify as a freeway service facility.
In granting a CUP, certain safeguards to protect the health, safety and general welfare of the
public may be required as conditions of approval. In addition, CUPS may only be granted when
the appropriate findings of fact can be made. Those findings can be made for the proposed
project.
1. The requested use is desirable for the development of the community, is essentially in
harmony with the various elements and objectives of the General Plan, and is not
detrimental to existing uses specifically permitted in the zone in which the proposed use
is located. The proposed use is desirable for the community at large and is generally in
harmony with the objectives of the General Plan since the proposed use will replace a
previous freeway service facility. Since the site is separated from other properties in the
area by streets and the project is designed with a low physical profile, it is physically
compatible with the surrounding land uses including the other freeway service facilities,
CUP 01-19N 02-03 - ARLO AM/PM AT TAMARACK
September 4,2002
Page 3
2.
3.
4.
5.
high density housing, single family residential and the elementary school. The adjoining
intersections will continue to function at acceptable service levels.
Data provided to the City indicates that noise generated by the car wash facility will be
below the maximum threshold of 60 &A at the nearby residential property lines on Carol
Place, but will still be audible. Regardless, approval of the car wash includes a condition
limiting car wash operation to daytime hours between 7:30 am and 9:00 pm.
The carwash may be beneficial to the greater community in that it is designed to treat the
wash water before it is introduced into the storm drain system and if it is used would
reduce pollutants reaching the storm drains. Redevelopment of the site may be more
beneficial to the greater community than retaining the site as an abandoned gas station
both visually and physically because it will include landscaping and a human presence.
The site for the intended use is adequate in size and shape to accommodate the gas pumps
and convenience market without benefit of a variance from the development standards of
the C-1 zone or the CommerciaWisitor-Serving Overlay Zone. The site can also
accommodate the carwash facility within the development standards of the Neighborhood
Commercial zone (C-1) but requires a variance to the CommerciaWisitor-Serving
Overlay Zone setback requirements.
All the yards, setbacks, walls, fences, landscaping, and other features necessary to adjust
the requested use to existing or permitted hture uses in the neighborhood will be
provided and maintained. The site will be landscaped consistent with the Carlsbad
Landscape Manual and the guidelines of the CommerciaWisitor Serving Overlay Zone
including minimum six foot width planter areas and planting adjacent to the building.
The street system serving the proposed use is adequate to properly handle all traffic
generated by the proposed use. The project will generate approximately 1,863 Average
Daily Traffic (ADT). Tamarack Avenue is a “Collector” street with a capacity of up to
10,000 ADT. Between Jefferson Street and Adams Street, Tamarack Avenue is
constructed to Secondary Arterial standards which increases its car carrying capacity and
is more than adequate to handle the amount of trafic that the proposed project is
expected to generate.
The project is to be developed as part of a freeway-service facility, containing a
minimum of two freeway oriented uses, which are the project and the restaurant on the
adjacent parcel to the east.
CommerciaWisitor Serving Overlay
As a commercialhisitor-serving use, the Planning Commission will first review the project and
make a recommendation to the City Council for action.
Consistent with the procedures of the overlay zone, the applicant completed the pre-filing
requirements and subsequently filed a formal application for review. The pre-filing site plan
reviewed by staff did not include the car wash component. The car wash was added to the site
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CUP 01-19N 02-03 - ARC4 AM/PM AT TAMARACK
September 4,2002
plan and the size of the convenience market reduced when the applicant was informed that
alcohol sales at this location was unlikely. The site was posted with a notice that the project
would be considered by the City of Carlsbad.
In addition to the development standards of the C-1 zone, the project is subject to unique
development standards of the commercialhisitor-serving overlay.
Buildings must be located a minimum of 30 feet from the public street and parking may be
located 20 feet from the public street. The applicant is requesting a variance for reduced
setbacks to accommodate the car wash facility, access to the car wash and parking. (The
findings for granting a variance are discussed under the Variance heading below).
Parking is required at a ratio of one space per 300 square feet of building. The project proposes a
2,997 square foot building and therefore is required to provide ten parking stalls plus three for
employees. A total of fourteen stalls are provided.
Pursuant to Zoning Ordinance section 21.208.100 H.l.(a), new gas stations may only be located
at intersections where at least one of the streets is classified as a prime, major or secondary
arterial on the General Plan. This is the redevelopment of a previously existing gas station and
Tamarack Avenue is improved as a Secondary Arterial from the project site to Adams Street
therefore satisfying the location criterion.
The minimum lot size required for new gas stations is 15,000 square feet with a minimum 150
foot lot frontage along the non-arterial street. Although this is the redevelopment of a previously
existing gas station, the lot length is more than 200 feet and the lot is 36, 927 square feet thereby
satisfylng the lot size criterion for new gas stations.
Included in the project exhibits are proposed signs. Pursuant to Zoning Ordinance section
21.208.100 B.l, the maximum allowed sign area for the project is determined by the combined
length of two building sides which face streets multiplied by a factor of 0.9. Therefore, the
project may have up to 109.8 square feet of sign area. The applicant has proposed 174.3 square
feet of sign area for all signs including two monuments. The project has been conditioned to
limit sign area to 109.8 square feet. A separate sign permit is required for the approval of all
signs.
The project is proposed with an “alternative” architectural style. The design is modern. The
design uses a stucco exterior with horizontal reveals and decorative cornice at each of the four
corner elements. The colors are off-white and beige. Final approval of the proposed alternative
architectural style is by the Planning Commission and City Council as a part of the Conditional
Use Permit review.
Variance
When practical difficulties, unnecessary hardships, or results inconsistent with the general
purpose of the property zoning result through the strict and literal interpretation and enforcement
of the development standards of the zone, the Planning Commission has the authority to grant a
variance from the development standard(s) as may be in harmony with its general purpose and
intent, so that the spirit of the development standard(s) shall be observed, public safety and
CUP 01-19N 02-03 - ARC0 AM/PM AT TAMARACK
September 4,2002
Pave 5
welfare secured and substantial justice done. In the coastal zone, a variance shall not be allowed
to diminish or otherwise adversely affect the substantive requirements for protection of coastal
resources.
The sole purpose of the variance shall be to prevent discrimination, and no variance shall be
granted which would have the effect of granting a special privilege not shared by other property
in the same vicinity or zone.
The applicant has stated that since alcohol sales will not be allowed at this location, a car wash as
well as a convenience store and gas pumps are necessary to generate adequate revenues. There
is a practical difficulty and hardship in locating a carwash along with the convenience market
and gas pumps on this site that is encumbered by CommerciaWisitor-Serving Overlay Zone
setbacks.
The extent of the requested variance includes:
0 A six foot parking encroachment into the required 20 foot setback at Tamarack Avenue.
A fifteen foot circulation encroachment into the required 20 foot setback at Jefferson Street
south of the Jefferson Street driveway.
0 A fifteen foot circulation encroachment into the required 20 foot setback at Carol Place.
0 A fifteen foot building encroachment into the required 30 foot setback at Tamarack Avenue.
0 A four foot circulation encroachment into the required 10 foot landscape setback at the
interior side property line
In order to grant a variance, the following findings must be made.
1. That there are exceptional or extraordinary circumstances or conditions applicable to the
property or to the intended use that do not apply generally to the other property or class
of use in the same vicinity and zone.
2. That such variance is necessary for the preservation and enjoyment of a substantial
property right possessed by other property in the same vicinity and zone but which is
denied to the property in question.
3. That the granting of such variance will not be materially detrimental to the public welfare
or injurious to the property or improvements in such vicinity and zone in which the
property is located.
4. That the granting of such variance will not adversely affect the comprehensive general
plan, or in the coastal zone, that the granting of such a variance is consistent with and
implements the requirements of the certified local coastal program and that the granting
of such variance does not reduce or in any manner adversely affect the requirements to
protect coastal resources as specified in the zones included in this title and that the
variance implements the purposes of zones adopted as implementation of the local coastal
program land use plan.
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CUP 01-19N 02-03 - ARC AAUPM AT TAMARACK
September 4,2002
Page 6
There are exceptional circumstances in that the property is part of the CommerciaWisitor
Serving Overlay Zone which properties to the north, west, and south are not. The Overlay zone
has more stringent setback requirements than the underlying Neighborhood Commercial zone or
the surrounding One Family Residential, Two Family Residential, or Residential Density-
Multiple zones. The property is also unique in that it fronts on a public street on three sides
when one or two sides are typical.
Although all properties within the Overlay Zone are subject to the same standards, other
properties in the vicinity and immediately to the north, west and south are not. Other properties
within the overlay zone are the adjacent property to the east, the lot at the southwest comer of
Tamarack Avenue and the 1-5 Freeway and property on the east side of the freeway from
Tamarack Avenue north to Chestnut Avenue making the subject site a peninsula.
The applicant has stated that there are overriding and compelling reasons that the project must
have a car wash and a 2,997 sq. ft. mini market. The applicant states that without both sources of
revenue, the project as a whole will not be profitable.
No coastal resources would be affected by the depth of the setbacks.
Mello I1 Segment of the Carlsbad Local Coastal Program
The project is located in the Mello I1 Local Coastal Program Segment. It is also in a deferred
certification area of the Carlsbad Coastal Zone and is subject to review and approval by the
California Coastal Commission. However the discussion below describes how the project
complies with the applicable Local Coastal Program provisions. The LCP Land Use Plan
designates the subject site for C-1 Neighborhood Commercial uses. Convenience markets with
gas pumps and car wash services are allowed by Conditional Use Permit.
The proposed project will be located at the northeast comer of Tamarack Avenue and Jefferson
Street near the 1-5 freeway. The proposed single story commercial structure is consistent in mass
with the surrounding development of one-story structures to the north and south, two story
apartments to the west and a restaurant to the east. The building will not obstruct views of the
coastline as seen from public lands or the public right-of-way or otherwise damage the visual
beauty of the coastal zone. No agricultural uses currently exist on the site, nor are there any
sensitive resources located on the property. The proposed building is not located on an area of
known geologic instability or flood hazard. No public opportunities for coastal shoreline access
are available from the subject site since it is not located between the first public road and the
ocean, and no public access requirements are conditioned for the project. The commercially
designated site is not suited for water-oriented recreation activities.
The subject site is located in the Coastal Resource Protection Overlay Zone, however, due to its
location and the absence of slopes steeper than or equal to 25% inclination and/or native
vegetation, additional submittals, standards or requirements do not apply. Construction of the
project will adhere to the City's Master Drainage Plan, Storm Water Ordinance, Standard Urban
Storm Water Mitigation Plan (SUSMP) and Jurisdictional Urban Runoff Management Program
(JURMP) to avoid increased urban run off, pollutants and soil erosion.
CUP 0 1 - 19N 02-03 - ARLO AM/PM AT TAMARACK
September 4,2002
V. ENVIRONMENTAL REVIEW
The project is the demolition of an existing abandoned gas station and the redevelopment of a
gas station with convenience market and car wash.
No environmental impacts which have not been mitigated by project design have been identified
for the project. Because the site was previously used as a gas station, and it is within an urban
area at the comer of two streets, there is no habitat onsite that may contribute to a preserve
system nor are there any sensitive plant or animal species which must be preserved. No
significant environmental impact can be associated with approval of a reduction in the
CommerciaWisitor Serving Overlay Zone public street setbacks. Contaminated soils will be
removed as part of the project site preparation.
The project average daily trafic can be accommodated by the adjoining street improvements.
The access points to the site will be relocated which will create better circulation and access to
the site than the previous design.
The project has also been designed to incorporate all best management practices consistent with
the Regional Water Quality Control Board and the Mello I1 segment of the Carlsbad Local
Coastal Program regarding water quality.
Staff has conducted an environmental impact assessment to determine if the project could have a
potentially significant effect on the environment pursuant to CEQA Guidelines and the
Environmental Protection Ordinance (Title 19) of the Carlsbad Municipal Code. The project
falls within the scope of the City’s MER for the City of Carlsbad General Plan update (EIR 93-
01) certified in September, 1994, in which a Statement of Overriding Considerations was
adopted for cumulative impacts to air quality and traffic circulation. MEIRs may not be used to
review projects if certified more than five years prior to the filing of an application for a later
project except under certain circumstances. The City is currently reviewing the 1994 MER to
determine whether it is still adequate to review subsequent projects. Although the MER was
certified more than five years ago, the City’s preliminary review of its adequacy finds that no
substantial changes have occurred with respect to the circumstances under which the MEIR was
certified. Additionally, there is no new available information which was not known and could
not have been known at the time the MEIR was certified. Therefore, the MER remains adequate
to review later projects. All feasible mitigation measures identified by the MEIR which are
appropriate to this project have been incorporated into the project.
The Planning Director has therefore issued a Negative Declaration on May 24,2002.
c
CUP 01--19N 02-03 - ARLJ AM.PM AT TAMARACK
September 4,2002
Page 8
ATTACHMENTS:
1.
2.
3.
4.
5.
6.
7.
8.
Planning Commission Resolution No. 522 1 (Neg Dec)
Planning Commission Resolution No. 5222 (CUP)
Planning Commission Resolution No. 5223 (V)
Location Map
Background Data Sheet
Local Facilities Impacts Assessment Form
Disclosure Statement
Exhibits “A” - “L” dated September 4,2002
cw:cs
SITE
ARC0 AM/PM AT TAMARACK
CUP 01-19N 02-03
- -
BACKGROUND DATA SHEET
CASE NO: CUP 01-19N 02-03
CASE NAME: ARCO AM/PM at Tamarack
APPLICANT: BP West Coast Products LLC. c/o TAIT and Associates Inc.
REQUEST AND LOCATION: Request for approval of a Conditional Use Permit for the
construction of a new 2,997 square foot ARCO AM/PM facility with 12 heling stations and a
968 square foot car wash and a request for reduced setbacks at the north east comer of Tamarack
Avenue and Jefferson Street in Local Facilities Management Zone 1.
LEGAL DESCRIPTION: Lot 1 of Tamarack Plaza. in the City of Carlsbad, County of
San Diego. State of California. according to map thereof No. 5944. filed in the office of the
County Recorder of San Diego Countv on August 23,1967.
APN: 204-292-24-00 Acres: 0.83 Proposed No. of LotsKJnits: N/A
GENERAL PLAN AND ZONING
Land Use Designation: Travenecreation Commercial
Density Allowed: N/A Density Proposed: N/A
Existing Zone: C- 1 Proposed Zone: C- 1
Surrounding Zoning, General Plan and Land Use:
Zoning General Plan
Site c- 1 T-R
North R-2 RM
South R-1 RLM
East c- 1 TR
West RD-M-Q RLM
Current Land Use
Abandoned gas station
Multi family residential
Single family residential
Restaurant
Multi family residential
PUBLIC FACILITIES
School District: Carlsbad Unified Water District: Carlsbad Sewer District: Carlsbad
Equivalent Dwelling Units (Sewer Capacity): 37.6 EDU
ENVIRONMENTAL IMPACT ASSESSMENT
Negative Declaration, issued May 24,2002
0 other,
Certified Environmental Impact Report, dated
- r CITY OF CARLSBAD
GROWTH MANAGEMENT PROGRAM
LOCAL FACILITIES IMPACTS ASSESSMENT FORM
PROJECT IDENTITY AND IMPACT ASSESSMENT:
FILE NAME AND NO: ARC0 AMPM at Tamarack
LOCAL FACILITY MANAGEMENT ZONE: 1 GENERAL PLAN:
ZONING: C-1
T-R
DEVELOPER'S NAME: BP West Coast Products LLC. c/o TAIT and Associates Inc.
ADDRESS: 9089 Clairemont Mesa Blvd. #300 San Diego CA 92123
QUANTITY OF LAND USEDEVELOPMENT (AC., SQ. FT., DU): 0.83 ac; 2,997 sa.ft.
PHONE NO.: 858-278-1 161 ASSESSOR'S PARCEL NO.: 204-292-24-00
A.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
City Administrative Facilities:
Library:
Wastewater Treatment Capacity (Calculate with J. Sewer)
Park: Demand in Acreage =
Drainage: Demand in CFS =
Demand in Square Footage =
Demand in Square Footage =
Identify Drainage Basin =
Circulation:
Fire:
Open Space:
Schools:
Sewer:
Demand in ADT =
Served by Fire Station No. =
Acreage Provided =
Demands in EDU
Identify Sub Basin =
Water: Demand in GPD =
NIA
NIA
36.7
NIA
2.96
Agua Hedionda
Watershed
1.863
NIA
NIA
36.7
VistdCarlsbad
Basin
50 mm
DISCLOSURE STATEMENT - ~ Applicant's statement or disclosure of certain ounership interests on a11 apphcations u*hxh ill requlrr ; discretionary action on the pan of the City Council or any appointed Board. Commission or Committee. 1 I
The following information MUST be disclosed at the time of application submittal. Your project cannot
be reviewed until this infomation is completed. Please print. ..
IYote:
Person is defined as "Any individual, firm, co-parmership, joint venture, association. social club. fraternal
organization, corporation, esrate, trust, receiver, syndicate. in this and any other counv. city and county. ciy
municipality, disaict or other political subdivision or any other group or combination acting as a unit."
Agents may sign this document; however, the legal name and entity of the applicant and property owner rnusr be provided below.
1. APPLICANT (Not the applicant's agent)
Provide the COMPLETE. L EGAL names and addresses of persons having a financial
interest in the application. If the applicant includes a cornoration or uarmershiu. include the
names, title, addresses of all individuals owning more than 10% of the shares. IF NO
APPLICABLE (N/A) IN THE SPACE BELOW If a publiclv-owned cornoration, include the
names, titles, and addresses of the corporate officers. (A separate page may be attached if
necessary.) 3
Person N/A Corp/Pan ARC0 Products Company
INDIVIDUALS OWN MORE THAN 10% OF THE SHARES, PLEASE INDICATE NON-
Title Title
Address Address 4 Centerpointe Drive
La Palma, CA 90623
2. OWNER (Not the owner's agent) Provide the COMPLETE. LEG& names and addresses of persons having any ownership
interest in the property involved. Also, provide the nature of the legal ownership (Le,
partnership, tenants in common, nonprofit, corporation, etc.). If the ownership includes a
cornoration or DartnershiD, include the names, title, addresses of all individuals owning more
than 10% of the shares. IF NO INDIVIDUALS OWN MORE THAN 10% OF THE SHARES, PLEASE INDICATE NON-APPLICABLE @/A) IN THE SPACE BELOW. If a publiclv-
owned cornoration, include the names, titles, and addresses of the corporate officers. (A separate
page may be attached if necessary.)
Person Saa d Attisha CorpiPart
Title Owner Title
Address 4142 Adams Avenue Address
San Diego, CA 92130
1635 Faraday Avenue Carlsbad, CA 92008-731 4 - (760) 602-4600 - FAX (760) 602-8559 @
If any person id /Ged pursuant to (1 1 or (2) above is
names and-addre:
orgnization or as trustee or beneficiary of the.
Eon ProfiVTrust N/A Nan ProfiLTmst
-1 orean~zstron or 2 ms:. its: ::!;a
of A!!?' person serving as an OfictiCEr or director of the non-prorj?
Title Title
Address Address
4. Have you had more than $250 worth of business transacted with any member of Civ staff. Boards, Commissions. Committees and/or Council within the past welve c12) months? a Yes No If yes, please indicate person(s):
NOTE: Attach additional sheets if necessary.
I certify that all the above information is true and correct to the best of my knowledge.
1- b-yi&
Signature of owner/date Signaturi of applicantldate
Print or type name of owner Print or type name of applicant .(
I
Signature of ownedapplicant's agent if applicable/date
Leslie Burnside, Agent
Print or type name of owner/applicant's agent
H:ADMIN\COUNTERDISCLOSURE STATEMENT 5/98 Page 2 of 2
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TO-TAIT AND ASSOCIATES PACE 003 RECEIVED 1UL-31-2001 12:lOpll FRoU-GlP 283 8427
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ARC0 Prodi c"-.rany 4 Cmterljanle Dh. La palm. Caifornia 90623.1056
MaKng Address: Box 5077 Bwna PA, Gablornia 9MP 5077
Reel Estale Dewment
ARCO::
Wednesday. July 25,200 1
Michael Grim, Planner
City of Carisbad - Planning Department
1635 Faraday Avenue
Carlsbad, CA 92008
Subjeet: Arc0 AM/PM at Tamarack
NEC of Tamarack Ave. & Jeffenon St
Carlsbad, CA
Re: Letter of Permission
Process Entitlement Docnments
Dear Mr. Grim:
As applicant for this project, Arc0 Products Company graciously requests your acceptance of this
letter as our granting of permission to Tait and Associates, Inc. to act as our agent in processing
all required applications with the purpose of acquiring all pennits necessary to entitle this
property.
Arc0 Products Company will purchase this property horn Mr. Sad Attisha contingent on
approval of thc Condition Use Permit. Please, if you have any questions, do not hesitale to call
me at (310) 379-6602.
Sincerely,
Arm rodncts Company
Kent &- Allen
Site Acquisitions Manager
CC: L. Bumside, Tait & Associates, Inc.
,xr~ W~B~&TEL~/ Q a Causm ofA&mC Wlhll ChI'W-Y
RECEIVED JUL-Z7-?001 10:26A# FROM- TO-TAIT AND ASSOCIATES PAGE 001
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