Loading...
HomeMy WebLinkAboutLeep Annexation and Variance Request Commission Memorandum REPORT TO: Honorable Mayor and City Commission FROM: Doug Riley, Associate Planner Tim McHarg, Planning Director SUBJECT: Leep Annexation #A-12001 MEETING DATE: May 21, 2012 AGENDA ITEM TYPE: Action RECOMMENDATION: 1) The City Commission grant a variance to Section 38.23.180, BMC, that provisions for water rights or cash in-lieu of water rights shall be provided upon further development or subdivision of the property. (Quasi-Judicial Item) and 2) The City Commission adopts the provided findings and approves the annexation, with the 9 recommended terms of annexation listed on pages 2-3 of the Staff Report, and directs staff to prepare an annexation agreement for signature by the parties. (Legislative Item) RECOMMENDED MOTION(S) 1) Based upon the analysis and findings in the Staff Report, I move to grant a variance to Section 38.23.180, BMC, that provisions for water rights or cash in-lieu of water rights shall be provided upon further development or subdivision of the property. and 2) Based upon the analysis and findings in the Staff Report, I move to approve Annexation #A-12001, with the 9 recommended terms of annexation listed on Pages 2-3 of the Staff Report, and direct staff to prepare an annexation agreement for signature by the parties. BACKGROUND: The property owner and applicant, Leep Dairy LLC, represented by Madison Engineering, proposes to annex the 2.0 acre subject property to the corporate limits of the City of Bozeman and establish an initial municipal zoning designation of R-3 (Residential Medium Density District). The purpose of the annexation and zone map amendment request is to obtain municipal infrastructure and services in order to develop the property for residential purposes as outlined in the Bozeman Community Plan. The underlying land use designation for 235 the property is “Residential”. The property is currently vacant. It is the Department of Planning and Community Development’s understanding that this property is proposed for annexation and the corresponding zone map amendment in order to be marketed for development in conjunction with the 6.6 acre Christenot property to the immediate east which was approved for annexation and R-4 (Residential High Density District) zoning in late 2011. This property is approximately 140 feet wide and 640 feet long. Note: This agenda item is related to the following (corresponding) Zone Map Amendment (ZMA) request on the agenda but procedurally is required to be reviewed prior to the ZMA. UNRESOLVED ISSUES: Similar to the Christenot annexation, the Applicant has made a couple of requests as part of their annexation application as follows: 1) Defer the payment to the Durston Road payback district for Special Improvement District No. 684 until occupancy of new construction; 2) Defer the provision of or payment of cash-in-lieu of water rights until occupancy of new construction. Considering the ties of this project to the Christenot property to the immediate east, the same approval as the Christenot annexation, or conditions of approval, in regards to these requests are recommended. Note: The Commission’s passage of Resolution 4359 in March of this year details how the Durston Road payback is now structured for annexations. These items have been additionally discussed within the framework of the Staff Report under the “Review Criteria & Findings” section and the respective staff recommendation on these requests is addressed under Engineering Department “Recommended Terms of Annexation” #8 and #9 on page 3 of the Staff Report. ALTERNATIVES: 1) The City Commission can decide to modify the “Recommended Terms of Annexation” (including the requested variance to cash- in-lieu of water rights). 2) The City Commission could decide to not annex the property. FISCAL EFFECTS: Annexing the property and establishing the new municipal zoning will enable future development with connection to City sewer and water services and service by the public services (police, fire, streets, etc.) of the City. This would increase tax values and corresponding revenue from the property. The City will accrue additional costs to service the property with municipal services. Attachments: Staff Report, Applicant’s submittal materials Report compiled on: May 10, 2012 236 #A-12001 Leep Annexation Staff Report 1 City Commission Staff Report for the Leep Annexation - File #A-12001 Item: Annexation #A-12001, an application requesting annexation of 2.0 acres located south of 5170 Durston Road. Applicant/Owner: Leep Dairy LLC 781 Hwy. 437 Toston, MT 59643 Representative: Madison Engineering 895 Technology Blvd., Suite 203 Bozeman, MT 59718 Date: Bozeman City Commission on Monday, May 21, 2012 at 6:00 PM in the Commission Meeting Room, City Hall, 121 North Rouse Avenue, Bozeman, Montana Report By: Doug Riley, Associate Planner Recommendation: Approval with Terms of Annexation ______________________________________________________________________________ Project Location The subject property is located south of 5170 Durston Road approximately 150 feet east of Valley Drive. (NOTE: This property is immediately west and adjoins the 6.6 acre Christenot property that was approved for annexation and R-4 zoning by the City Commission in late 2011). The approximately 2.0 acres is legally described as Tract 6B, Smith Subdivision located in the NW 1/4 of Section 11, T2S, R5E, PMM, Gallatin County, Montana. Please refer to the vicinity map below. Proposal 237 #A-12001 Leep Annexation Staff Report 2 The property owner and applicant, Leep Dairy LLC, represented by Madison Engineering, proposes to annex the 2.0 acre subject property to the corporate limits of the City of Bozeman and establish an initial municipal zoning designation of R-3 (Residential Medium Density District). The purpose of the annexation and zone map amendment request is to obtain municipal infrastructure and services in order to develop the property for residential purposes as outlined in the Bozeman Community Plan. The underlying land use designation for the property is “Residential”. The property is currently vacant. It is the Department of Planning and Community Development’s understanding that this property is proposed for annexation and the corresponding zone map amendment in order to be marketed for development in conjunction with the 6.6 acre Christenot property to the immediate east which was approved for annexation and R-4 (Residential High Density District) zoning in late 2011. This property is approximately 140 feet wide and 640 feet long. Similar to the Christenot annexation, the Applicant made a couple of requests as part of their annexation application as follows: 1) Defer the payment to the Durston Road payback district for Special Improvement District No. 684 until occupancy of new construction; 2) Defer the provision of or payment of cash-in-lieu of water rights until occupancy of new construction. In regards to these requests, considering the ties of this project to the Christenot property to the immediate east, the same approval or conditions of approval in these regards are recommended. These items have been additionally discussed within the framework of this staff report under the “Review Criteria & Findings” section and the respective staff recommendation on these requests is addressed under Engineering Department “Recommended Terms of Annexation” #8 and #9 below. Recommended Terms of Annexation Should the City Commission choose to accept the request for annexation, staff and the Development Review Committee (DRC) recommend the following terms of annexation be addressed prior to acknowledging the Annexation Agreement and formal annexation: Planning Department Recommended Terms of Annexation: 1. That the documents and exhibits to formally annex the subject property shall be identified as the “Leep Annexation”. 2. That the applicant execute at the Gallatin County Clerk & Recorder’s Office a waiver of right-to-protest creation of S.I.D.’s for a City-wide Park Maintenance District, which would provide a mechanism for the fair and equitable assessment of maintenance costs for City parks as part of the Annexation Agreement. 3. An Annexation Map, titled “Leep Annexation Map” with a legal description of the property and any adjoining unannexed rights-of-way and/or street access easements shall be submitted by the applicant for use with the Annexation Agreement. The map must be supplied on a mylar for City records (18" by 24"), a reduced 8 ½" x 11" or 8 ½” by 14" exhibit for filing with the Annexation Agreement at the County Clerk & Recorder, and a digital copy for the City Engineer’s Office. This map must be acceptable to the Director of Public Services and City Engineer’s Office, and shall be submitted with the signed Annexation Agreement. 238 #A-12001 Leep Annexation Staff Report 3 4. The land owners and their successors shall pay all fire, street, water and sewer impact fees at the time of connection; and for future development, as required by Chapter 2, Bozeman Municipal Code, or as amended at the time of application for any permit listed therein 5. That the applicant executes all contingencies and terms of said Annexation Agreement with the City of Bozeman within 60 days of the receipt of the annexation agreement, or annexation approval shall be null and void. Engineering Department Recommended Terms of Annexation: 6. Applicant shall provide and file with the County Clerk and Recorder's office executed Waivers of Right to Protest Creation of SIDs for the following: A. Street improvements including paving, curb/gutter, sidewalk and storm drainage facilities for the following streets: a. Fowler Avenue B. Signalization Improvements for the following intersections: a. Durston Road/27th Ave. b. Durston Road/Fowler Ave. c. West Babcock St/Fowler Ave. The documents filed shall specify that in the event an S.I.D. is not utilized for the completion of these improvements, the developer agrees to participate in an alternate financing method for the completion of said improvements on a fair share, proportionate basis as determined by square footage of property, taxable valuation of the property, traffic contribution from the development or a combination thereof. 7. The owner shall provide a public street and utility easement for West Villard Street. The easement shall be 60 feet wide which is the local street standard as shown in the Greater Bozeman Area Transportation Plan. 8. Upon approval of a variance from 38.23.180, BMC, that provisions for water rights or cash in-lieu of water rights shall be provided upon further development or subdivision of the property. If the variance is not approved, water rights or cash in-lieu thereof shall be made as required in Section 38.23.180, BMC. 9. The Durston Road SID payback shall be in accordance with Resolution 4359. Zoning Designation & Land Uses The following existing land uses and zoning are adjacent to the subject property: North: Residential (5170 Durston Road); Unannexed County Land – Designated “Residential” on the City of Bozeman Future Land Use Map South: Vacant; Approved for Zoned R-4 (Residential High Density District) East: Vacant; Approved for Zoned R-4 (Residential High Density District) 239 #A-12001 Leep Annexation Staff Report 4 West: Vacant and Residential: Unannexed County Land – Designated “Residential” on the City of Bozeman Future Land Use Map Adopted Growth Policy Designation The subject property is recognized as “Residential” on Figure 3-1 (Future Land Use Map) of the Bozeman Community Plan. The Residential land use designation of the Bozeman Community Plan indicates that: “This category designates places where the primary activity is urban density dwellings. Other uses which complement residences are also acceptable such as parks, low intensity home based occupations, fire stations, churches, and schools. High density residential areas should be established in close proximity to commercial centers to facilitate the provision of services and employment opportunities to persons without requiring the use of an automobile. Implementation of this category by residential zoning should provide for and coordinate intensive residential uses in proximity to commercial centers. The residential designation indicates that it is expected that development will occur within municipal boundaries, which may require annexation prior to development. The dwelling unit density expected within this classification varies between 6 and 32 dwellings per net acre. A higher density may be considered in some locations and circumstances. A variety of housing types can be blended to achieve the desired density. Large areas of single type housing are discouraged. In limited instances the strong presence of constraints and natural features such as floodplains may cause an area to be designated for development at a lower density than normally expected within this category. All residential housing should be arranged with consideration of compatibility with adjacent development, natural constraints such as watercourses or steep slopes, and in a fashion which advances the overall goals of the Bozeman growth policy. The residential designation is intended to provide the primary locations for additional housing within the planning area.” Agency Review The Planning Department requested written summary-review comments from the Bozeman Development Review Committee (DRC) and other applicable review agencies regarding the request for annexation. Comments received as of the writing of this Staff Report have been outlined within this report according to the goals and policies of City Commission Resolution No. 3907. Additional comments and/or recommendations received prior to consideration of this request for annexation will be forwarded to the Commission as received. Public Comment As of the writing of this staff report, the Department of Planning and Community Development has not received any written public testimony specific to the annexation. (Public comment has been received regarding the zoning of the subject property and is addressed under that agenda item and those packet materials). Any written comments received by the Planning Office specific to the annexation will be forwarded to the City Commission prior to or during the public hearing. Review Criteria & Findings Resolution No. 3907 Goals Goal 1: It shall be the goal of the City of Bozeman to encourage annexations of land contiguous to the City. 240 #A-12001 Leep Annexation Staff Report 5 Upon the finalization of the annexation of the Christenot property to the east, the property in question will be contiguous to the City limits on its east and south boundaries. Goal 2: The City shall seek to annex all areas that are totally surrounded by the City, without regard to parcel size. The subject property, (and some additional un-annexed neighboring properties), are completely surrounded by the exterior boundaries of the City. Goal 3: The City shall seek to annex all property currently contracting with the City for services such as water, sanitary sewer and/or fire protection. The subject property is not currently contracting with the City for any services. Goal 4: It shall be the goal of the City of Bozeman to require annexation of all land proposed for development lying within the service boundary of the existing sewer system as depicted in the Bozeman Growth Policy, and to encourage annexations within the urban growth area identified in the Bozeman Growth Policy. The subject property lies within the 20-year sewer service boundary as depicted in the adopted 2007 Bozeman Wastewater Facilities Plan. The subject property also lies within the Bozeman Community Plan planning boundary and the “Capital Facilities Overlay District.” The “Capital Facilities Overlay District” is intended to establish a priority area for development within the larger scope of the Bozeman Community Plan. It designates an area within the long-range growth area of the City where services would be most efficiently provided in the near term and where development in the near term would advance the goals of the Community Plan. Resolution No. 3907 Policies Policy 1: Annexations shall include dedication of all easements, rights-of-way for collector and arterial streets, water rights, and waivers of right-to-protest against the creation of improvement districts necessary to provide the essential services for future development of the city. The Recommended Terms of Annexation include requirements for waivers of right-to-protest against the creation of improvement districts for park maintenance, street and stormwater improvements (Recommended Terms of Annexation #2 & #6). The annexation agreement would also require the dedication of street and utility easements for W. Villard Street through the subject property (Recommended Term of Annexation #7). Water rights and the applicant’s requested variance are discussed under Policy Item No. 5 later in this report. Regarding the applicants request to defer the payment to the Durston Road payback district for Special Improvement District No. 684 until occupancy of new construction, this policy issue was discussed and resolved by the City via Resolution #4359 which the Commission adopted on March 19, 2012. Essentially, this new resolution requires a financial contribution from all properties within the Durston Road Improvement Annexation Area for all existing residential units and sets that formula. If the property is vacant, such as the Leep property, the payback is made at the time of future subdivision or development (i.e. site plan approval) based on the number of lots or units being proposed on the 241 #A-12001 Leep Annexation Staff Report 6 property. This resolution was passed with the intent of encouraging annexation of these infill properties. Therefore, Recommended Term of Annexation #9 makes reference to this new Resolution. Policy 2: Issues pertaining to master planning and zoning shall be addressed in conjunction with the application for annexation. a. The initial application for annexation shall be in conformance with the current Bozeman Growth Policy. If a Growth Policy Amendment is necessary to accommodate anticipated uses, said amendment process may be initiated by the applicant and conducted concurrently with the processing for annexation. The property is designated “Residential” within the Bozeman Community Plan. This annexation, and the applicant’s proposed R-3 zoning (#Z-12044), would be in compliance with this designation. b. Initial zoning classifications of the property to be annexed shall be determined by the City Commission, in compliance with the Bozeman Growth Policy and upon a recommendation of the City Zoning Commission, prior to final annexation approval. The applicant has applied for a Zone Map Amendment (#Z-12044) to establish an initial municipal zoning designation of R-3 (Residential Medium Density District) on the 2.0 acres. The Zoning Commission held a public hearing on the Zone Map Amendment application on May 1, 2012, and voted 2-1 against a recommendation for approval of the proposed R-3 zoning. (The zone map amendment and the Zoning Commission’s recommendation are addressed under that respective action item and packet materials). c. The applicant may indicate his or her preferred zoning classification as part of the annexation application. The applicant/owner has indicated that they prefer a zoning designation of R-3 (Residential Medium Density District) and that item is addressed under that respective agenda item and packet materials. Policy 3: Fees for Annexation procedures shall be established by the City Commission. No fee will be charged for any City-initiated annexation. The appropriate application processing and review fees accompanied the application. Policy 4: It shall be the general policy of the City that annexations will not be approved where unpaved county roads will be the most commonly used route to gain access to the property. This property does not currently have any road frontage and is technically landlocked. Coordinating development of this site with the property to the east (i.e. Christenot) will allow a transportation connection to Durston Road which is classified as an arterial in the Bozeman Transportation Plan. Annexation of this property will also include a condition regarding the granting of right-of-way for the extension of Villard Street across this property (the same as what was required for the Christenot Annexation). The extension/connection of the streets and pedestrian systems with adjacent paved City streets to serve this property will be required as part of any future development proposal. Note: As a currently “landlocked” property, the annexation and the placement of a zoning district designation on the property by the City does not guarantee available services, especially if this property is not proposed for development in conjunction with the property to the east. Section 38.07.010.C of the Unified Development Code states: “Placement of any given zoning district on an area depicted on the 242 #A-12001 Leep Annexation Staff Report 7 zoning map indicates a judgment on the part of the city that the range of uses allowed within that district are generally acceptable in that location. It is not a guarantee of approval for any given use prior to the completion of the appropriate review procedure and compliance with all of the applicable requirements and development standards of this chapter and other applicable policies, laws and ordinances. It is also not a guarantee of immediate infrastructure availability or a commitment on the part of the city to bear the cost of extending services”. The Annexation Agreement will include the above notice as well as that, prior to future development, the applicant will be responsible for installing any facilities required to provide full municipal services to the property in accordance with the City of Bozeman’s facility plans and all City policies that may be in effect at the time of development. Policy 5: Prior to annexation of property, it shall be the policy of the City of Bozeman to acquire usable water rights, or an appropriate fee in lieu thereof, equal to the average annual diversion requirement necessary to provide the anticipated average annual consumption of water by residents and/or users of the property when fully developed on the basis of the zoning designation(s). The fee may be used to acquire water rights or for improvements to the water system which would create additional water supply capacity. This policy may be subject to the following exceptions: a. For any annexation in excess of ten acres, it shall be carried out prior to final plat approval, final site plan approval or the issuance of any building permits, whichever occurs first, provided that the applicant executes a promissory note or other appropriate document acceptable to the City. This policy item has now been codified under Section 38.23.180 of the BMC. This section states: A. Prior to a final approval of all development reviewed as a site plan, conditional use permit, planned unit development, or subdivision and prior to an annexation of any land, one of the following must occur: 1. Payment shall be made to the city of a payment-in-lieu of water rights calculated based on the annual demand for volume of water the development will require multiplied by the most current annual unit price; or 2. A transfer to the city of ownership of water rights adequate to provide the volume of water the development will require. A transfer of ownership of water rights must be in a manner approved by the director of public services. B. If adequate water rights or a payment-in-lieu was previously provided to the city for the subject property, evidence of those rights or payment-in-lieu may be offered to demonstrate compliance with this section. If the expected demand for water by the proposed development increases by more than one acre-foot over that for which water rights or payment-in-lieu of water rights were previously provided, additional water rights or payment-in-lieu of water rights equal to the difference between the previously provided water rights or payment-in-lieu and the estimated current demand or payment-in-lieu price shall be provided. C. Provision of water rights or payment-in-lieu may be deferred by phase for phased developments or for annexations when the phase or annexation is in excess of ten acres. D. The city manager may adopt administrative procedures to implement this section. The director of public services shall adopt standards for the calculation of demand for water use. The city 243 #A-12001 Leep Annexation Staff Report 8 commission shall establish the unit cost for payment-in-lieu by resolution. E. The amount paid for a payment-in-lieu shall be calculated using the per unit price in effect on the date the payment-in-lieu of water rights is to be made to the city. The applicant, in their attached letter of April 6, 2012, just as they had done in the previous Christenot annexation application, requested a variance to this section of the code to “defer payment of the fee-in- lieu of water rights for the proposed Annexation…until such time as an application for development of the property is submitted to the City and approved.” The Department of Public Services reviewed the applicant’s variance request to this code standard as required under the variance review criteria of Section 38.35.060.C of the BMC: Staff recommends approval of the variance be granted on the request to defer cash in lieu of water rights until the time of further development or subdivision of the property. (This recommendation is reflected in Recommended Term of Annexation #8). 1. The Variance will not be contrary to and will serve the public interest. The purpose of the annexation is to prepare the property for sale for future development in conjunction with the Christenot parcel/annexation to the immediate east. The City Commission granted a variance to this requirement as part of the Christenot Annexation and coordinating these two approvals (and the approved variances) would seem to make sense. On the Christenot variance, the Director of Public Service granted a temporary waiver to the requirement that the existing home located along Durston Road connect to municipal water; (as it had a functioning well and would likely need to be removed to allow development of the parcel). In this case, the property is vacant and until the density and potential development of this small site can be determined, and there is a proposed demand on the water system. it would make sense to defer the required payment. 2(a)(b) The Variance is necessary, owing to conditions unique to the property, to avoid an unnecessary hardship which would unavoidably result from the enforcement of the literal meaning of this title. Due to the small size and access constraints, even when/if combined with the Christenot parcel, the future density of the property cannot be determined with any certainty. Therefore, staff feels it is reasonable to defer payment until development occurs and the density is determined and/or until the existing structure on the Christenot parcel connects to municipal water. 3. The Variance will observe the spirit of the title, including the growth policy, and do substantial justice. The granting of the variance will encourage annexation of the property. Policy 6: Infrastructure and emergency services for an area proposed for annexation will be reviewed for the health, safety and welfare of the public. If it is found that adequate services cannot be provided to ensure public health, safety and welfare, it shall be the general policy of the City to require the applicant to provide a written plan for accommodations of these services, or not approve the annexation. Additionally, annexation proposals that would use up infrastructure capacity already reserved for properties lying either within undeveloped portions of the City 244 #A-12001 Leep Annexation Staff Report 9 limits or lying outside the City limits but within the identified sewer or water service area boundaries, shall generally not apply. When developed or designed in conjunction with the Christenot property to the east, full City infrastructure and emergency services will be immediately available to the subject property. The Annexation Agreement should contain provisions that discuss the developer’s responsibility for extending the necessary services (water, sewer, streets, storm water facilities, etc.) to/into the site under consideration. The purpose of the annexation is to prepare the property for sale for future development. The applicants should be made aware that at the time of any further development on the property, the land owners and their successors shall pay all additional impact fees. At such time that any site plan or further development proposal is considered by the City, the extension of services will be determined in detail based upon the type of development being reviewed by the advisory and decision-making bodies. The DRC considered the annexation request and did not identify any significant impacts to the City’s sanitary sewer and water municipal facilities, or transportation system that could not be addressed or fulfilled by the applicant during any subsequent review for further development of the property Policy 7: It shall be the general policy of the City of Bozeman to require annexation of any contiguous property for which city services are requested or for which city services are currently being contracted. No City services are currently being contracted. With further development of the property, municipal infrastructure will be extended into the site. Policy 8: The annexation application shall be accompanied by mapping to meet the requirements of the Director of Public Service. Mapping to meet the requirements of the Director of Public Service must be provided with the Annexation Agreement. Typically, this includes an 18-inch x 24-inch mylar map, a reduced 8½-inch by 11 or 14-inch annexation map exhibit, and a digital copy containing the metes and bounds legal description of said property. (Mapping requirements are addressed in Recommended Term of Annexation #3). Policy 9: It shall be the policy of the City of Bozeman to assess a system development/impact fee in accordance with Chpt. 2, Art. 6, Div. 9 Bozeman Municipal Code (Impact Fees), and in accordance with the Bozeman Growth Policy and other policies as they are developed. At the time of any development on the property, the land owner or their successors shall pay all impact fees required by Chpt. 2, Art. 6, Div. 9 BMC. Policy 10: Public notice requirements shall be in compliance with Montana Code Annotated. In addition, notice shall be posted in at least one conspicuous location on the site in question, and mailed to all owners of real property of record within 200 feet of the site in question using the last declared county real estate tax records, not more than 45 days nor less than 15 days prior to the scheduled action to approve or deny the annexation by the City Commission, specifying the date, time and place the annexation will be considered by the City Commission. The notice shall contain the materials specified by Section 38.40.020.A, BMC. In addition, where a commonly identifiable street address is not visible on the property to be annexed, the notice shall provide a map of the area in question so as to indicate its general location and proximity to surrounding properties. 245 #A-12001 Leep Annexation Staff Report 10 Notices of the public hearing have been sent and posted along Durston Road in front of property as set forth under this policy. Policy 11: Annexation agreements shall be executed and returned to the City within 60 days of distribution of the annexation agreement, unless another time period is specifically identified by the City Commission. This policy item is specified in Recommended Term of Annexation #5. It is Staff’s understanding that the applicant may request a longer term to execute the annexation agreement at the public hearing. Staff is not opposed to granting an execution duration of 6 months as was done with the Christenot annexation. This would require the Commission to amend Recommended Term of Annexation #5. Policy 12: When possible, the use of Part 46 annexations is preferred. This annexation is being processed under Part 46 provisions. Summary and Conclusion Staff, the DRC and other local review agencies have reviewed the request for annexation and have provided the above comments as they relate to the Goals and Policies set forth in Commission Resolution No. 3907. Should the City Commission choose to proceed with the request for annexation, staff recommends that the terms of annexation listed in this Staff Report be addressed prior to acknowledging the Annexation Agreement and formal annexation of said property. Attachments: Applicant’s Submittal Materials Report Sent to: Leep Dairy LLC, 781 Hwy. 437, Toston, MT 59643 Madison Engineering, 895 Technology Blvd., Suite 203, Bozeman, MT 59718 246 247 248 249 250 251 252 253 254 255 256