Marin County Flood Control and Water Conservation District

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1 Marin County Flood Control and Water Conservation District FLOOD CONTROL ZONE 3 ADVISORY BOARD MEETING MARCH 17, 2016 STAFF REPORT Item 1. Election of Chairperson and Vice-Chairperson Article VI of the Advisory Board s bylaws stipulate that officers of the Advisory Board be elected to a one-year term by a majority vote of the Advisory Board. There are two officers chair and vice-chair. Recommended Action: Elect chairperson and elect vice-chairperson. Item 2. Approval of Meeting Minutes: February 1, 2016 Recommended Action: Approve minutes. Item 3. Open Time for Items Not on the Agenda Comments will be heard for items not on the agenda (limited to three minutes per speaker). Item 4. Zone Engineer's Report a. FEMA Community Rating System (CRS) in Unincorporated Areas Update The FEMA CRS program is a voluntary program that provides discounts directly to property owners who are paying for federally backed flood insurance for actions taken by the County above the base level requirements of the federal flood insurance program. The County completed its application and audit with FEMA last spring. The results of the scoring by FEMA have just arrived, and the County has received a CRS rating of Class 7, which is better than anticipated. This class rating translates to a 15% discount directly to rate payers as their flood insurance policies renew after May Future implementation of additional community floodplain management activities that exceed minimum National Flood Insurance Program requirements could result in increased discount rates. The County will be continuously striving to achieve a better Class rating that provides a higher discount rate to its residents. While the result is good, it is important to note that FEMA continues to raise their flood insurance rates, therefore, individual property owners will still likely see their overall rates rise, just at a rate 15% less than otherwise. The County has no input or control over the Federal flood insurance rates or payments. The County's effort under this program only applies to residents in unincorporated areas. b. FEMA Hazard Mitigation Funding Opportunity Last fall, the California Valley and Butte Fires led to the declaration of a major disaster. As a result, the Federal Emergency Management Agency (FEMA) has made available hazard mitigation assistance to the State of California Office of Emergency Services (Cal OES). The District submitted notices of interest to use this funding for potential projects in Zone 3. Cal OES then reviewed all the notices of interest received across the state and selected ones most likely to attract hazard mitigation funding. As a result of this review, the District received an invitation for submittal of a full application for one Zone 3 by June The project for the Advisory Board to discuss and potentially recommend is: Page 1 of 6 FCZ3 AB Staff Rpt. March 17, 2016

2 Marin County Flood Control and Water Conservation District Marin County Structure Elevation Program This is a program whereby individual homeowners can raise their homes above the FEMA base flood elevation with 75% of their costs reimbursed by the federal government. Project Budget: $3,000,000 Federal Share (FEMA) $1,000,000 Local Share (Individual Property Owners) Costs to design and construct home elevations vary, but for reference may range between $100,000 and $250,000, including temporary relocation costs. Thus homeowner contributions would be $25,000-$62,500 per structure. Application costs to the Zone will vary depending on method of outreach and number of applicants from Zone 3, but an initial estimate could be $25,000-$50,000 in staff time and/or consultant costs. c. Coyote Creek Levee Update i. Levee Evaluation Report The public comment period for the Coyote Creek Levee Evaluation reports ended on February 26. The reports will be finalized and posted on the County website in April. Questions and comments received at the 2/1/16 meeting, during the comment period, and following posting of the final reports, will be posted with responses in June. A few select findings from the evaluation: Overtopping of the concrete channel (right and left banks) may occur upstream of Ross Drive with high runoff conditions. Overtopping of the earthen channel (right and left banks) may occur under high tide conditions near Flamigo Road Bridge. Overtopping of Nyhan creek (right and left banks) between Marin Ave and Enterprise Concourse may occur under high tide and/or high runoff conditions. Costs to provide a level of protection against the original design flow water surface elevation could exceed $10 million. Costs to build a FEMA accredited levee (reduces flood insurance rates) would likely exceed $20 million, not including required interior drainage work. Costs increase significantly with sea level rise. ii. USACE Rehabilitation & Inspection Program Compliance In 2011 the U.S. Army Corps of Engineers (Corps) notified staff that, based on their assessment of the Coyote Creek Flood Control Project (project), the project s right (i.e., south) bank did not meet all of the criteria necessary to achieve a minimally acceptable rating in the Corp s Rehabilitation and Inspection program (RIP). The Corps assessment also indicated that the project s left (i.e., north) bank did meet all of the criteria necessary to achieve a minimally acceptable rating. Since that time staff has been working with the Corps to ensure that the right bank attains no less than a minimally acceptable rating. A minimally acceptable rating or higher in the RIP is required for the District to be reimbursed for the cost of repairs to the project following a federally declared emergency. The specific items identified in the 2011 inspection as basis for an unacceptable rating were: Page 2 of 6 FCZ3 AB Staff Rpt. March 17, 2016

3 Marin County Flood Control and Water Conservation District Encroachments on levee embankments such as structures and vegetation. Culverts/discharge pipes penetrating the creek bank and within the interior drainage system were in unknown condition. To address these items, to date staff has: resurveyed the project, provided a draft update of the project s Operation & Maintenance (O&M) Manual to the Corps, updated the O&M manual's plans set, including pump stations and pipes, under a grant from the CA Department of Water Resources (DWR), prepared a draft emergency action plan, also under the DWR grant, maintained vegetation which was identified as a concern, completed a video inspection of pipes draining to the concrete channel and earthen levees, and drafted a preliminary work plan for the remaining work needed to achieve a minimally acceptable rating on the project's right bank. Additionally, in 2013 the District submitted a letter of intent (LOI) to create a System-wide Improvement Framework (SWIF) plan and received Corps approval of the LOI. The District has until August of this year to create its SWIF plan, which will include a description of the tasks and schedule for addressing items currently not meeting the criteria necessary to receive a minimally acceptable rating. The District received the Corps approval of the LOI so Coyote Creek will remain eligible for reimbursement for the cost of repairs to the project following a federally declared emergency while the SWIF is being created and, following the SWIFs approval, while improvements are being carried out. Work performed under the SWIF will include completion of updates to the project s O&M Manual, creation of an emergency action plan, and a resolution to encroachments on the levee and floodwall. Much of this work was funded through the recently completed Coyote Creek Levee Evaluation Grant which, in addition to the levee evaluation itself, funded updating the plans set in the O&M Manual, and drafting of the emergency action plan. The schedule for completing this work will be detailed in the SWIF and the majority of items are expected to be completed within a one to two year timeframe following the Corps approval of the SWIF. iii. Next Steps for Coyote Creek Levee Staff meet with AB and community in June to review proposed near-term work plan (FY ). Utilize recently purchased muscle walls and/or sandbags in areas that were identified as more likely to overtop when high water levels are anticipated. Following completion of the Southern Marin Watershed Guide, discuss process for arriving at preferred improvement alternatives and funding strategies (see item 5). Finalize the SWIF work plan and begin first phase of implementation. d. Update on Manzanita Area Staff is working with Caltrans staff on their proposed topographic survey of the Manzanita area and reach of Shoreline Highway that experiences regular high tide flooding. Staff met with Caltrans on Monday, March 7 th to walk the area and determine the limits of their Page 3 of 6 FCZ3 AB Staff Rpt. March 17, 2016

4 Marin County Flood Control and Water Conservation District topographic survey work. We believe this survey is an essential first step towards our goal of working with Caltrans to develop and implement near-term solutions that reduce the direct bay tidal flooding of the highway. There is no current schedule for completion of the survey and the identification of any flood reduction measures but this is a priority for flood control staff and updates will be provided as information from Caltrans is received. e. Update on Marin City Drainage Study RFP The Marin City RFP was released on February 19 after review by Caltrans. The selected consultant will develop an urban drainage model for the Marin City watershed to evaluate the current level of flood protection, identify potential areas for improvement in the current system, and develop a range of practical and self-mitigating modifications. A primary goal of the project is to increase the level of flood protection for southbound Interstate 101 and the area around the Donahue Street/North Bridge Boulevard interchange. Consultant selection will occur in early April. Staff do not recommend proceeding with awarding the contract until a grant agreement is reached with the Transportation Authority of Marin (TAM) for the Lifeline Grant which will provide a 50% funding match for this work. TAM has prioritized several transportation projects in Marin City, including this drainage study. Delays in awarding the grant agreement are due to the need for TAM to formally swap funding sources with Marin Transit in order for the funding source constraints to align with project goals. f. Potential Projects in Mill Valley The City of Mill Valley has submitted the attached request for grant funding from Zone 3. The programs and projects they are considering include expanding the creek maintenance program (current budget is $35,000), completing flood studies, and constructing drainage improvements associated with the Miller Avenue Streetscape Project which begins in June The total request is for an additional $1,025,000 in grant funding above what they already receive. The District has included $55,000 this year and $90,000 next year in the proposed creek maintenance budget. It is recommended that the Advisory Board review the other Mill Valley requests, in the context of the 5-year budget projection and Resolution No Establishing Policy with Regard to Drainage Systems in Flood Control Zone #3, and make a recommendation as to which projects should be funded by Zone 3. Staff will consult with the City of Mill Valley and provide additional context at the meeting. Item 5. Watershed Program Update a. Southern Marin Watershed Guide The Southern Marin Watershed Guide (WG) will be available for public review at in mid to late March. Comments will be accepted through May 1. The Guide describes existing conditions and summarizes flooding conditions at the watershed scale in a user-friendly, graphics-rich format. The purpose of the Guide is to organize information and data for the sub-watersheds draining to Richardson Bay (Marin City, Coyote Creek, Arroyo Corte Madera del Presidio, Ryan Creek, Sutton Manor/Alto/Strawberry, and East and West Creeks) and to identify a list of project Page 4 of 6 FCZ3 AB Staff Rpt. March 17, 2016

5 Marin County Flood Control and Water Conservation District concepts to address both short term and long term flood and creek management needs. The goal of the WG is to effectively communicate information, findings and recommendations to partner agencies and the community in a concise manner to guide decision making and future commitments. b. Draft Project List Staff reported that a draft project list was created in tandem with the Watershed Guide to communicate the status of potential watershed and flood protection projects. Additional community meetings are anticipated in Mill Valley to coincide with the work of their Flood Task force. c. Richardson Bay Shoreline Study: Sea Level Rise Impacts Assessment and Concept Level Alternatives Evaluation The Shoreline Study is available for comment and can be viewed at The Shoreline Study was presented at a November 18, 2015 community meeting. The comment period for the Shoreline Study is scheduled to close by May 1, d. Video of Arroyo Corte Madera del Presidio Watershed A video of the Arroyo Corte Madera del Presidio (ACMdP) watershed has been produced to illustrate how topography and land use influences the flow of storm water on its way to the bay. The 8-10 minute video integrates low altitude aerial imagery with hand held footage to provide a cohesive image of how flood water courses through the watershed from its headwaters to Richardson Bay. Ground level footage of choke points and other areas of known flooding have been incorporated. The purpose of the video is to highlight the causes of flooding as well as potential strategies for reducing flood risk. e. Marin Bay Waterfront Adaptation Vulnerability Evaluation (BayWAVE) Marin BayWAVE is a focused vulnerability assessment (VA) of the bayside shoreline from the Golden Gate Bridge to the northern end of Novato at the county line. BayWAVE will evaluate the extent of impacted assets, assess the sensitivity and adaptability of selected assets, and work with the local cities and towns to plan implementation of adaptation strategies. Assets are defined as built and natural features from roads, utilities, and parcels, to natural resources and recreation. The fundamental goal of the BayWAVE project is to increase awareness and preparation for future sea level rise (SLR) impacts by using this coordinated, multi-jurisdictional assessment. The vulnerability assessment will describe the impacts given sea level rise scenarios for each community and asset. The Richardson Bay Shoreline Study above is a more focused evaluation of the alternatives, which BayWAVE will not do as part of the vulnerability assessment. For more information about BayWAVE, visit Item 6. Zone 3 FY Budget Review Page 5 of 6 FCZ3 AB Staff Rpt. March 17, 2016

6 Marin County Flood Control and Water Conservation District The Zone 3 budget for FY (begins July 1, 2016 and ends June 30, 2017) will be presented to the Board of Supervisors at a hearing this spring. A proposed budget summary will be presented to the AB by staff for review. Recommended Action: Recommend Board of Supervisors approve budget. Item 7. Schedule Next Meetings Staff recommend the next regular meetings be held between June 6 and 10, and on November 17. Page 6 of 6 FCZ3 AB Staff Rpt. March 17, 2016

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10 BOARD OF SUPERVISORS OF THE MARIN COUNTY FLOOD CONTROL AND WATER CONSERVATiON DISTRICT RESOLUTION NO. 71-1L8 RESOLUTION ESTABLISHING POLICY WITH REGARD TO DRAIAGE SYSTEMS IN FLOOD CONTROL ZONE WHEREAS Section of the Nariri County Flood Control and Water Conservation District Act is the authority for establishing policy with regard to drainage systems within the District arid WHEREAS the District must direct its efforts and resources in the most efficient manner possible NOW THEREFORE BE IT RESOLVED THT 1. The District intends to consider the drainage systems named in Exhibit ItAt and as shoi on Exhibit which Exhibits are attached hereto and by this reference incorporated herein as being the major drainage systems within Flood Control Zone No. and 2. The District shall direct its primary efforts and resources toward the efficient control of these systems. PASSED AND ADOPIED at the regular meeting of the Board of Supervisors of the Narin County Flood Control and Water Conservation District held on the 22nd day of June 1971 by the following vote AYES NOES SUPERVISORS SUPERVISORS Arnold M. Baptiste John F. Mclnnis Peter R. Arrigoni Michael Wornuni Louis H. Baar ABSENT SUPERVISORS Attachment Exhibit Exhibit GhairmÆK Board of Suisis of the Mann County Flood Control and Water Conservation District ATTEST 17 It..tL Clerk CM000113

11 EXHIBIT AU The major drianage systems and their limits for which the Mann County Flood Control and Water conservation District shall direct its prinlaly efforts and resources pursuant to this resolution are as follows Name of Liwits of Drainage System Drainage System Sausalito Canal Richardson Bay Valley Harbor to Mill Roseclale Canal Confluence with Sausalito Canal to Donahue Street Coyote Creek Confluence with Sausalito Canal to the origin of the North and South branches Tennessee Creek confluencewith Coyote Creek to its origin Mann Avenue Creek CorLfluene with Tennessee Creek to its origin Oakwood Creek Confluence with Tennessee Creek to its origin Arroyo Corte Madera confluence with Mill Valley Del Presidio Harbor to the origin of the East Peak and Nob Hill Forks High School Creek Confluence with Arroyo Corte Madera Del Presidio to Miller Avenue Reed Creek confluence with Arroyo Corte Madera Del -Presidio to its origin Warner Creek Confluence with Arroyo Corte Madera Del Presidio to its origin Old Hill Creek Confluence with Arroyo.orte Madera Del Presidio to its origin Cascade Creek Confluence with Old Miii Creek to its origin Ryan Creek Confluence with Mill Valley Harbor to the Westerly end of Al to Pvenue Sutton Manor Branch Confluence with Mill Valley Harbor to its crigin CM000114

12 ca Name. of Limits of Drainage System Drainage System East Fork Sutton Manor Confluence with Sutton Manor Branch to Lomita Drive Reservoirs General All Reservoirs and their out let channels Niscellarteous Systems AU land which is below ele vation MSL and all facili ties which and/or pumping require pondage ii East Blithedale culvert confluence with Sutton Manor Branch to the Easterly Rightof-Way of Tower Drive -2- CM000115

13 \\ iitga1t/7 --- _. %n- -- -r NOTE ADDITIONAL SYSTEM$ MESERVOIRS GENERAL OUTLETCHAb.tNELS AND THEIR 3BLlN // J/ Th \\ CITY OF LARKSPUR %-s.. \\ MISCELLENED1JS SYSTEMS ALL LAND WI-ItCH IS BELOW ELEVATION MSL AND ALL racilitres WHICH REQUIRE PONDAGE AND/OR PUMPING.-.. \\tc \\L1 Uo _N fl- PA 11 ii ft el T21 Tt 1\\t\ C8c4 C7 \L I4 4ti Ic T7t ctsr 7Thi_ /- te /T EASTBLITHEDALE t_\ ct QL L6/r_1 \\\ 4TWOD S_ s1e uir2 2K71 Mi 4/ \ojt/ / - 7 1c15c TATE 4cJ- QY -7 %o t\ -K lt II -r 6J RCt.. tb 79 4L TLfr /t SC 82 34C II /t.t \\ por r/ \\ cj \t MAJOR DRAINAGE SYSTEMS AND THEIR LIMITS FOR WHICH THE MARIN COUNTY FLOOD CONTROL AND WATER CONSERVATION DISTRICT SHALL DIRECT ITS \\ PRIMARY EFFORTS AND RESOURCES /2 FORApDTIONAL \\ TMS t4r \\ PANS.. \\ PA.y // 4w6.. Rr SC _1- Cl7- HL z/\\ cc7 \\ NN 25C fl AC CN MARIN COUNTY FLOOD CONTROL ZONQ3Th7 bey 24C NHA N\ t\t \. ki sj RICHARDSON BAY JIIDIAC SCALE It 1/4 MILE SEPTEMBER i4 AC /7A SQQNDARY LINE Th\ r\ COUNTY OF MARIN DERT. OF PUBLIC WORKS 2tc 2C. T\ in Ac 1. If Thzt \\ /1 IODO W iao 5cKX 6a lcxxy SOW FT nr CM000288

14 ANTICIPATED 5-YEAR ZONE 3 MAINTENANCE NEEDS FY Fund Ending Balance: $ Proposed budget, subject to change FY Expected Expenditure Description Projected Many expenditures include 3% annual increase Staffing Costs Pump Operation & Maintenance 95,000 Creek and Levee Maintenance 95,000 General Zone and USACE Project Administration 160,000 Engineering Planning 100,000 Environmental Planning 60,000 Environmental Permitting and CEQA 15,000 GIS and Surveying 15,000 Outreach 10,000 Zone Meeting and Board of Supervisors Admin 25,000 QA/QC and Strategy 100,000 Engineering and Real Estate 25,000 Flapgate Maintenance and Storm Response 45,000 County Special Cost Allocation 89,787 Salaries, Benefits, and Overhead 834,787 Utilities 15,000 Rent (Storage and Space) 1,500 Association Dues and Memberships 4,200 FY Budget FY Estimate FY Estimate FY Estimate $ $ 94,518 $ 96,003 $ 97,533 $ 99,109 $ $ 99,036 $ 102,006 $ 105,066 $ 108,218 $ $ 173,040 $ 187,143 $ 192,757 $ 198,540 $ $ 103,000 $ 106,090 $ 109,273 $ 112,551 $ $ 61,800 $ 63,654 $ 65,564 $ 67,531 $ $ 13,670 $ 13,670 $ 13,670 $ 13,670 $ $ 10,000 $ 10,000 $ 10,000 $ 15,000 $ $ 10,300 $ 10,609 $ 10,927 $ 11,255 $ $ 25,750 $ 26,523 $ 27,318 $ 28,138 $ $ 103,000 $ 106,090 $ 109,273 $ 112,551 $ $ 80,000 $ 80,000 $ 80,000 $ 80,000 $ $ 46,350 $ 47,741 $ 49,173 $ 50,648 $ $ 89,787 $ 89,787 $ 89,787 $ 89,787 $ $ 910,251 $ 939,315 $ 960,340 $ 986,997 $ $ 15,000 $ 15,000 $ 15,000 $ 15,000 $ $ 1,500 $ 1,500 $ 1,500 $ 1,500 $ $ 4,200 $ 4,200 $ 4,200 $ 4,200 Maintenance & Repair Services - Equipment Cardinal Pump Station Pump #1 $ 30,000 Cardinal Pump Station Pump #2 $ 30,900 Crest Marin Pump Station Pump #1 Crest Marin Pump Station Pump #2 $ 32,782 Crest Marin Pump Station Pump #3 $ 32,782 Crest Marin Pump Station Pump #4 Ryan Creek Pump Station Pump #1 Ryan Creek Pump Station Pump #2 $ 30,000 Seminary Drive Pump Station Pump #1 $ 10,609 Seminary Drive Pump Station Pump #2 $ 10,609 Shoreline Pump Station Pump #1 $ 33,765 Shoreline Pump Station Pump #2 Shoreline Pump Station Pump #4 $ 35,096 Precipitation & Stream Gauge and Alert System $ 10,000 $ 10,300 $ 10,609 $ 10,927 $ 11,255 Clean/Ream and Inspect 54 Pipes at Coyote Creek* $ 60,000 Other (incl. Miltronics for Seminary, Ryan Crk Screens) $ 50,000 $ 51,500 $ 53,045 $ 54,636 $ 56,275 Maintenance & Repair Services - Land District Vegetation/Sediment Maintenance $ 80,900 $ 83,327 $ 85,827 $ 88,402 $ 91,054 Mill Valley Vegetation/Sediment Maintenance (grant) $ 55,000 $ 90,000 $ 90,000 $ 90,000 $ 90,000 Other (Includes Tree/Fence Repair) $ 50,000 $ 51,500 $ 53,045 $ 54,636 $ 56,275 Coyote Creek Levee Rodent Abatement $ 15,000 $ 15,000 $ 15,000 $ 15,000 $ 15,000 Remove Unauthorized Coyote Levee Encroachments* $ 100,000 Professional Services Study Contingency $ 75,000 $ 75,000 $ 75,000 $ 75,000 $ 75,000 Marin City Drainage Study $ 220,000 Website Update $ 8,000 Coyote Creek Levee Incorporate Changes to Coyote Creek into Project* $ - $ 100,000 $ 50,000 Finalize Coyote Creek O&M Manual Update* $ 60,000 Construction Coyote Creek Sediment Removal (w/ Bothin Reuse)* $ 200,000 $ 1,000,000 Rehabilitate Penetrating Pipes* (4 in 2016/17) $ 120,000 $ 120,000 Abandon Penetrating Pipes* (3 in 2016/17) $ 120,000 $ 120,000 Construction Contingency (such as Manzanita) $ 100,000 $ 100,000 $ 100,000 $ 100,000 $ 100,000 Supplies Muscle Wall $ 60,000 Other (Misc. creek, levee, and pump supplies) $ 70,000 $ 72,100 $ 74,263 $ 76,491 $ 78,786 Service and Supplies $ 1,074,600 $ 2,060,327 $ 988,707 $ 651,356 $ 663,206 Total Expenditures $ 1,909,387 $ 2,970,578 $ 1,928,022 $ 1,611,696 $ 1,650,203 Revenues (increase approx. 0.5% annually) $1,492,052 $1,499,512 $1,507,010 $1,514,545 $1,522,118 Fund Ending Balance** $ 7,315,405 $ 5,844,340 $ 5,423,328 $ 5,326,177 $ 5,198,091 *To be updated after additional information is obtained. **Fund ending balance will change with updated information. Note: budgets for projects not expended this fiscal year will roll over into the next fiscal year 7,732,740

15 FY Budget Report FCZ #3 Mill Valley Fund Expenses Revenue Budget Summary Account Description FY Budget FY Projected FY Budget Fund Beginning Balance $5,894,493 $7,341,391 $7,264,574 Salaries and Benefits $848,844 $814,298 $856,182 Service and Supplies $1,314,428 $752,991 $1,436,996 Capital Assets $0 $0 $0 Total Expenditures $2,163,272 $1,567,289 $2,293,178 Taxes $1,467,168 $1,467,168 $1,467,168 Revenues From Use of Money and Property $14,984 $4,790 $4,500 Intergovernmental Revenues $9,000 $9,000 $9,000 Miscellaneous Revenues (inc. traffic) $900 $9,514 $900 Total Revenue $1,492,052 $1,490,472 $1,481,568 Fund Ending Balance $5,223,273 $7,264,574 $6,452,964 Major "Services & Supplies" Expenditures Professional Services Services to Support Ongoing Coyote Creek Projects $25,000 $0 $100,000 Balance of previously encumbered contracts $0 $192,541 $0 Study Contingency $50,000 $75,000 $75,000 Total $75,000 $267,541 $175,000 Construction Coyote Creek Middle Reach Dredging $900,000 $0 $900,000 Total $900,000 $0 $900,000 Maintenance & Repair Services - Equipment Major Pump Maintence $80,000 $80,000 $90,000 Balance of previously encumbered contracts $0 $83,075 $0 Miscellaneous $29,900 $30,500 $31,920 Total $109,900 $193,575 $121,920 Maintenance & Repair Services - Land & Buildings Rodent Abatement $15,000 $ 15,000 $15,000 Conservation Corps North Bay $80,900 $ 80,900 $80,900 Mill Valley Creek Maintenance MOU $35,000 $ 35,000 $35,000 Balance of previously encumbered contracts $0 $ 51,447 $0 Miscellaneous $31,100 $ 31,100 $31,100 Total $162,000 $213,447 $162,000 Miscellaneous Services & Supplies $67,528 $78,428 $78,076

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