17-100319CIT
� Federal Way
CITY HALL
33325 8th Avenue South
Federal Way, WA 98003-6325
(253) 835-7000
www.cityoffederalway.com
Jim Ferrell, Mayor
March 6, 2017
Pacland
Shawn Nguy
10135 SE Sunnyside Rd, Suite 203
Clackamas, OR 97015
RE: Permit #17-100319-00-SM; Auto Zone, 31660 Pacific Hwy S, Federal Way
Dear Mr. Nguy:
The City of Federal Way has received your variance request dated January 18, 2017. After evaluating the
existing conditions along the referenced street, review of Federal Way Revised Code (FWRC) provisions
(Section 19.135.280-290), and direction provided by the City Council, the Public Works Department
hereby approves the following:
1. WAC 468-52-040 limits access spacing to no less than 250 feet, with only one access per parcel.
As such, no direct access onto Pacific Highway S should be granted if shared access with adjacent
parcels or access to S 3181h Street is feasible. Direct access to Pacific Highway S should only be
granted if the applicant can demonstrate that it is otherwise infeasible to carry out essential and
regular functions of doing business.
Discussion:
AutoZone proposes to replace two existing driveways with a single driveway on Pacific Highway
S. The proposed location would be 124' (centerline to centerline) from S 318`h Place, the
existing private road to the south. It would be 133' (centerline to centerline) from the driveway to
the north. The proposed driveway will increase the distance between accesses in both directions
as compared to existing conditions. The proposal is expected to reduce turning conflicts on
Pacific Highway S.
The applicant has documented that the property to the north is approximately 5 feet higher than this site,
which is a topographic constraint that precludes any ability to combine driveways. The applicant has also
submitted an Autoturn template establishing that a driveway on Pacific Highway S is necessary to
accommodate their weekly delivery truck.
17-I00319-00-SM
\\CFWFILEI\Applications\CSDC\PROD\dots\save\143672_75499_06154939 DOC
The proposed driveway will be restricted to right-in/right-out by an existing median in Pacific Highway
S.
Because the applicant has established that the driveway is necessary for doing business, the proposal will
reduce turning conflicts as compared to existing conditions, and the proposed driveway will be restricted
to right-in/right-out only, this right-of-way modification is approved as proposed. This approval is valid
for a period of one year from the date of this letter. -If you have any questions, please don't hesitate to
contact Ann Dower at (253) 835-2732 or at ann.dower@cityoffederalway.com.
Sincerely,
iEdwa2rdWaz,E.
Deputy Public Works Director
EW:mt
cc: Cole Elliott, P.E.; Development Services Manager
Erik Preston, Senior Traffic Engineer
Dave Van de Weghe, Senior Planner
Had
df
17-100319-00-SM
\\CFWFILEI\Applications\CSDC\PROD\docs\save\143672 75499 06154939 DOC
CITY OF
Federal Way
PUBLIC WORKS
DEPARTMENT
STREET MODIFICATION REQUEST /ACTION
Project Name AutoZone
Permit # 17-100319-SM
Location 31660 Pacific Hwy S
Request
Replace two existing driveways on Pacific Highway S with one driveway that will be
located 133' from the access to the north and 124' from S 3181h Place, the private road to
the south.
Staff Analysis WAC 468-52-040 limits access on state highways to spacing of 250 feet,
with only one access per parcel. As such, no direct access to SR 99 should be granted as
long as shared access with adjacent parcels or access to S 318th Place is feasible. Direct
access to SR 99 should only be granted if the applicant can demonstrate that it is otherwise
infeasible to carry out essential and regular functions of doing business. If the request is
granted, it would reduce turning conflicts by replacing two existing driveways with a single
driveway that is further from both the access to the north and S 318"' Place to the south.
The new access will be restricted to right-in/right-out by an existing median on Pacific
Highway S.
Requirements / Conditions of Approval The applicant has documented that the
combined access with the driveway to the north is infeasible due to a 5' grade difference in
the properties. The applicant has also submitted an AutoTurn template that establishes the
need for a driveway on Pacific Highway S to accommodate their weekly delivery truck.
Staff Recommendation:
Development Services Reviewer
Development Services Manager
Traffic Division Reviewer
Traffic Division Manager
Deputy Director
Director Decision
Initial
Date
k/D 37 ;7
� S
I
Approve
Deny
—�
❑
Cd�
❑
L\AutoZone Street Mod Request Form.docx Scan completed form into Amanda folder
9500
SUITE SE SUNNYSIDE RD T 503.659.2227
suiTE200 F503.659.2227 �
CLACKAMAS, OR 97015 WWW.PACLAND.COM
LETTER OF TRANSMITTAL
Date: January 18, 2017
To: David Van De Weghe
City of Federal Way
33325 81h Avenue South
Federal Way, WA 98003
From: Shawn Nguy �ri
Re: 4396 AutoZonee; Federal Way, WA
Right -of -Way Improvement Modification Request
Remarks:
The following documents are enclosed for the Right -of -Way Improvement Modification Request submittal
for the above referenced project.
• One copy of the Roadway Modification Narrative Statement
• AutoZone Check 001036894 in the amount of $290.00 for payment of fees
• One 11" x 17" copy of the below'iisted plans sheets
o Exhibit A Existing Driveways
o Exhibit B Proposed Site Plan
o Exhibit C Autoturn Truck Template
Please call me at 503-659-9500 ext 1318 if you have any questions on this submittal.
Thank you.
azw8dty.dwtr01
20366041-23A
41k
CITY OF
Federal Way
PUBLIC WORKS DEPARTMENT
33325 8'h Avenue South
Federal Way, WA 98003-6325
253-835-2700; Fax 253-835-2709
w.ci[ ffederalwgy.CoM
RIGHT-OF-WAY IMPROVEMENT
MODIFICATION REQUEST
WHEN PUBLIC IMPROVEMENTS MUST BE INSTALLED
In accordance with Chapter 19.135.030 of the Federal Way Revised Code (FWRC), right -of --way
improvements are required when an applicant engages in any activity that requires ,a development permit.
There are two exceptions to this requirement. The first exception is if the proposed improvements do not
exceed 25 percent of the assessed or appraised value of all structures on the subject property, whichever is
greater. The second exception is if within the preceding four years, public right-of-way improvements were
installed as part of any subdivision or discretionary land use approval under the city code or any prior
zoning code.
WHAT PUBLIC IMPROVEMENTS MUST BE INSTALLED
Required improvements are determined by the classification of the roadway as defined in FWRC
19.135.210 and 19.135.220. Improvements may include right-of-way dedication, minimum pavement
widths, curbs, sidewalks, street trees, streetlights, or landscaping/utility strips. The improvements are
required along the entire frontage and width of each abutting right-of-way.
HOW TO APPLY FOR A MODIFICATION, DEFERMENT, OR WAIVER
The applicant must apply for a development permit on the subject property and pay a Right -of -Way Code
Variance Request fee of $140.00. The applicant must make a written request to the Director of Public
Works to modify, defer, or waive the requirements of FWRC Title 19, Chapter 135, "Development
Improvements," for the following reasons:
I. The improvement as required would not be
harmonious with existing street
improvements, would not function properly
or safely or would not be advantageous to the
neighborhood or City as a whole.
2. Unusual topographic or physical conditions
preclude the construction of improvements as
required.
3, Proper vertical or horizontal alignments
cannot be determined because the existing
streets do not have correct alignments.
4. The required improvement is part of a larger
project that has been scheduled for
construction in the city's adopted six year
transportation improvement program.
For more complete information, see the latest edition of the FWRC Chapters 19.135.010—19.135.080,
Bulletin #200 — March 31, 2016 Page 1 of I k:\Handouts\ROW Improvement Modification Request
ROADWAY MODIFICATION NARRATIVE STATEMENT
AutoZone
Parcel #092104-9248
Located in SW % of SW % Section 9, Township 21 North, Range 4 East of the Willamette
Meridian, Federal Way, King County, Washington
31660 Pacific Highway
Introduction
The subject site is currently developed with a Shell gas station. The project proposes to redevelop
the site as needed to construct an approximate 6,000 SF AutoZone retail store with associated
parking, landscape, storm, and utility improvements.
WAC 468-52-040 limits access on state highways to access spacing of 250 feet with only one
access per parcel. The subject site currently has two existing driveways onto Pacific Highway -
SR99. The first driveway is located approximately 69 feet north of S 3181h PI and the second is
located approximately 123 feet north of the first one. Refer to Exhibit A.
In the pre -application conference summary for the proposed project, city staff indicated that due to
the current spacing of adjacent driveways and access roads, the subject property should either use
S 31811 Place to access SR99 or pursue a shared access driveway with the property to the north.
Additionally, staff indicated that no access to SR99 will be allowed while other access options
exist.
Pursuant to FWRC Title 19, Chapter 135 states that the Director may grant a modification to the
adopted standards under the following reasons:
1. The improvement as required would not be harmonious with existing street improvements,
would not function properly or safely or would not be advantageous to the neighborhood
or City as a whole.
2. Unusual topographic or physical conditions preclude the construction of improvements as
required.
3. Proper vertical and horizontal alignments cannot be determined because the existing
streets do not have correct alignments.
4. The required improvement is part of a larger project that has been scheduled for
construction in the city's adopted six -year transportation improvement program.
Proposed Modification
This request for modification is associated with the intent to maintain access to SR99. The strict
adherence to the 250ft driveway spacing standards would significantly and negatively impact the
operation of the site and the proposed store, as well as the ability to redevelop the site. Access to
SR99 is critical to vehicular movements through and around the site. Due to existing built
conditions surrounding the site, it is not possible for delivery trucks to service the store with just
one access driveway on S 31811 PL. Due to the size of site, trucks are not able to enter the site
AutoZone -Modification Request - Driveway
Spacing Page 1 of 2
Federal Way, WA
through the one driveway and be able to turn around to leave the site through the same driveway.
We have attached an Autoturn exhibit demonstrating the necessity of access to SR 99 to site
operations. Refer to Exhibit C. It should be noted that due to the existing median conditions in
SR99, the site's driveway access to SR99 will be limited to right in / right out movements only.
The project would reduce trips to and from the site because a retail store use is a lower trip
generator than the current gas station use. The proposed improvements would minimize the points
of conflicts onto SR99 by removing the two existing driveways and replacing them with a single 30
feet wide driveway. Additionally, driveway spacing is improved on S 31811 by relocating the
existing driveway to the east side of the site, increasing the spacing from 69ft to 108ft. This not
only improves spacing, but also maximize the stacking length to SR99. Refer to Exhibit B for the
proposed site plan and driveway location.
The site has approximately 205 feet of frontage on SR99 so meeting the 250 feet driveway spacing
within the site is not physically possible. City staff suggested the applicant to pursue a shared
access driveway with the adjacent property to the north. Due to topographical constraints (the
adjacent site is approximately 5ft higher), property rights, and the footprint of the store, it's not
possible to properly connect to this existing driveway.
There are currently multiple existing driveways in the vicinity of the site that are located spaced
less than 250 feet along SR99. The proposed access driveway to SR99 would be consistent and in
harmony with surrounding developments, while providing greater spacing than most existing
driveways in the area.
Based on the reasons provided above, the applicant requests approval for modification of the
standard to serve the proposed project properly and safely. This proposal is consistent with the
surrounding area and does not negatively impact the surrounding street system. The proposed
driveway locations will improve public safety due to the increased spacing and fewer vehicle trips
anticipated with the proposed use.
AutoZone — Modification Request — Driveway
Spacing Page 2 of 2
Federal Way, WA
11
i
S 318TH PL (PRIVATE)
A
X
< 25
¢
e
m
AutoZane STORE DEVELOPMENT
■
AutoZone, Inc.
y =
m Cn
i
�
7
_
- 31M PACIFIC HIGHWAY
i
=
z
' rESERAL WAT, WAS6i3
123 S. FRONT STREET, 3rd FLOOR
mnvsr• r
{ fi'
S
2
MEMPHIS, TENNESSEE 38103
.1122EbZ9EEll .n :Q`IEIli D2h90:1 muW39EDIDO oi
SAVO 081 'dH13tl Q10A
--------------------�
00'06Z *** ; $
----------------------
AACICI N
L1190110 alga
1,6'89£0T00
81L6-£9086 VM AVM IVIdgU3,4
8IL6 XOH Od
H100S 3f7I13AV H.L8 SZ££E 30 aaplo
AVM 7VHgGHd 30 A110 aq.L a,L
uv,iiOa 001/00 aNV AlaNIN (YA2IQN M OtAl**** sud
IEOL-56b 106
I OI8£ N L='SIHdNaW
£GIBE tU slNdLuoW 861Z X08 '0'd
onuanV u091PVW 59I
xUuu aassauua,L )slid
00'06ZS
V689£0190
;unowV Plgd I9301
iagwnN 3133q:)
00'06Z 00'0 00'06Z b8LZb6ZO L1150/10
Q7171
;unowd P1gd ualml,;unoaslQ ;unowd ssoj0 aI aayanoA a;ga aalonul #NSS
awgN 1aq wnN aaionul
b689£0I00 :oN )taagj L00698=jagwnN aopuaA
L1190110 :a;ga 13343
r
m
0
m
Z
p
E)a MG ELM
f
n
S 318 PL (PRNATE ROAD)
-------------------
I X
D
i
�
Do
f
i m
Z
n
w
+
ED
c
c
o
1 m
rn
-------------------
z
L7
EXISTING DRIVEWAY
m
v
1p
Y N
-
AutoZone STORE DEVELOPMENT
■
AutoZone, Inc.
m =
p
5
31660 PC= HIGHWAY
i A r
=
123 5, FRONT STREET, 3rd FLOOR
[T7
z m
FEDERAL WAY, WA 9W33
q`+
MEMPHIS, TENNESSEE 38103
0
.I �N •! •ti ��,
y,� I
. [ . O- � sC• .!_rife• i
• _ I n
I rsua: r--
co -
CD t .
4 1
i f S 318 PL (PRIVATE ROAD) -
m
m
o
f
_
AuloZome STORE DEVELOPMENT
° ¢° f T
AutoZone, Inc.
■
L7 =
C
— 31660 PACIFIC HIGHWAY
,
�
6ED9KWAr,WA9=
123 S. FRONT STREET, 3rd FLOOR
i^'••'r ' �'6�'�
m z
MEMPHIS, TENNESSEE 38103
• mr;awu:�
Erik Preston
To: snguy@paciand.com
Cc: Ann Dower; Rick Perez
Subject: RE: ROW Modification Request - AutoZone
Hi Shawn,
We have questions about the truck that you show in the Auto Turn exhibit. It appears much larger than other delivery
trucks for similarly sized stores and what we think would normally be used for weekly deliveries. It seems that this size
of truck might be used for the initial stocking of the store, but not likely for the daily or weekly deliveries. Can you please
answer or confirm the following for us:
1. What is the size and class of vehicle shown?
2. How often would this vehicle visit the site?
3. If this is not the normal (daily/weekly) delivery vehicle please show that vehicle turning through the site and
attempting to turn around in the site.
Thanks for your help,
Erik
From: Shawn Nguy [mailto:snguy@paciand.com]
Sent: Thursday, February 16, 2017 2:33 PM
To: Erik Preston
Cc: David VanDeWeghe
Subject: RE: ROW Modification Request - AutoZone
Thanks, Erik.
Shawn Nguy, P.E. (OR & WA)
Engineering & Development Consulting Services
10135 S.E. Sunnyside Road, Suite 200 1 Clackamas, OR 97015
Office: (503) 659-9500 x1318 I Mobile: (971) 409-4042 1 Fax: (503) 659-2227
www.paciand.com
www.finkedin.com/in/shawnnqu
CONFIDENTIAL NOTICE: This communication (including any attachments) is for the sole use of the intended recipient and may
contain privileged or confidential information intended for a specific individual and purpose, and is protected by law. If you are not the
intended recipient you should delete this communication and/or shred the materials and any attachments and are hereby notified that
any disclosure, copying or distribution of this communication, or the taking of any action based on it, is strictly prohibited. Thank you.
From: Erik Preston mailto:Erik.Preston cit oflederalwa .com]
Sent: Thursday, February 16, 2017 2:31 PM
To: Shawn Nguy <snguy@pacland.com>
Cc: David VanDeWeghe <David.VanDeWeghe citvoffederalway.com>
Subject: RE: ROW Modification Request - AutoZone
Shawn,
I should know more tomorrow about where it is in process. A few key people were out of the office yesterday and today.
Stay tuned!
Erik Preston, PE
Senior Traffic Engineer
City of Federal Way — Public Works
d:253.835.2744
m:253.261 .3786
10135 SE SUNNYSIDE RD T 503.659.9500
SUITE 200 F 503.659.2227 AMI
CLACKAMAS, OR 97015 WWW.PACLAND.COM - - i.
LETTER OF TRANSMITTAL
Date: January 18, 2017
To: David Van De Weghe
City of Federal Way
33325 81h Avenue South
Federal Way, WA 98003
From: Shawn Nguy 6r,
Re: 4396 AutoZone; Federal Way, WA
Right -of -Way Improvement Modification Request
Remarks:
The following documents are enclosed for the Right -of -Way Improvement Modification Request submittal
for the above referenced project.
■ One copy of the Roadway Modification Narrative Statement
• AutoZone Check 001036894 in the amount of $290.00 for payment of fees
• One 11" x 17" copy of the below listed plans sheets
o Exhibit A Existing Driveways
o Exhibit B Proposed Site Plan
o Exhibit C Autoturn Truck Template
Please call me at 503-659-9500 ext 1318 if you have any questions on this submittal.
Thank you.
azw8cityAwtr0l
20366041-23A
4ik
CITY OF
Federal Way
PUBLIC WORKS DEPARTMENT
33325 81h Avenue South
Federal Way, WA 98003-6325
253-835-2700;Fax 253-835-2709
ww w. c i tyoffe dera I way. co rn
RIGHT -OF -'WAY IMPROVEMENT
MODIFICATION REQUEST
WHEN PUBLIC IMPROVEMENTS MUST BE INSTALLED
In accordance with Chapter 19.135.030 of the Federal Way Revised Code (FWRC), right-of-way
improvements are required when an applicant engages in any activity that requires ,a development permit.
There are two exceptions to this requirement. The first exception is if the proposed improvements do not
exceed 25 percent of the assessed or appraised value of all structures on the subject property, whichever is
greater. The second exception is if within the preceding four years, public right-of-way improvements were
installed as part of any subdivision or discretionary land use approval under the city code or any prior
zoning code.
WHAT PUBLIC IMPROVEMENTS MUST BE INSTALLED
Required improvements are determined by the classification of the roadway as defined in FWRC
19.135.210 and 19.135.220. Improvements may include right-of-way dedication, minimum pavement
widths, curbs, sidewalks, street trees, streetlights, or landscaping/utility strips. The improvements are
required along the entire frontage and width of each abutting right-of-way.
HOW TO APPLY FOR A MODIFICATION, DEFERMENT, OR WAIVER
The applicant must apply for a development permit on the subject property and pay a Right -of -Way Code
Variance Request fee of $140.00. The applicant must make a written request to the Director of Public
Works to modify, defer, or waive the requirements of FWRC Title 19, Chapter 135, "Development
Improvements," for the following reasons:
1. The improvement as required would not be
harmonious with existing street
improvements, would not function properly
or safely or would not be advantageous to the
neighborhood or City as a whole.
2. Unusual topographic or physical conditions
preclude the construction of improvements as
required.
3. Proper vertical or horizontal alignments
cannot be determined because the existing
streets do not have correct alignments.
4. The required improvement is part of a larger
project that has been scheduled for
construction in the city's adopted six year
transportation improvement program.
For more complete information, see the latest edition of the FWRC Chapters 19.135.010—19.135.080.
Bulletin #200 — March 31, 2016 Page 1 of 1 k:\Handouts\ROW Improvement Modification Request
ROADWAY MODIFICATION NARRATIVE STATEMENT
AutoZone
Parcel #092104-9248
Located in SW '/4 of SW '/4 Section 9, Township 21 North, Range 4 East of the Willamette
Meridian, Federal Way, King County, Washington
31660 Pacific Highway
Introduction
The subject site is currently developed with a Shell gas station. The project proposes to redevelop
the site as needed to construct an approximate 6,000 SF AutoZone retail store with associated
parking, landscape, storm, and utility improvements.
WAC 468-52-040 limits access on state highways to access spacing of 250 feet with only one
access per parcel. The subject site currently has two existing driveways onto Pacific Highway -
SR99. The first driveway is located approximately 69 feet north of S 3181h PI and the second is
located approximately 123 feet north of the first one. Refer to Exhibit A.
In the pre -application conference summary for the proposed project, city staff indicated that due to
the current spacing of adjacent driveways and access roads, the subject property should either use
S 3181h Place to access SR99 or pursue a shared access driveway with the property to the north.
Additionally, staff indicated that no access to SR99 will be allowed while other access options
exist.
Pursuant to FWRC Title 19, Chapter 135 states that the Director may grant a modification to the
adopted standards under the following reasons:
1. The improvement as required would not be harmonious with existing street improvements,
would not function properly or safely or would not be advantageous to the neighborhood
or City as a whole.
2. Unusual topographic or physical conditions preclude the construction of improvements as
required.
3. Proper vertical and horizontal alignments cannot be determined because the existing
streets do not have correct alignments.
4. The required improvement is part of a larger project that has been scheduled for
construction in the city's adopted six -year transportation improvement program.
Proposed Modification
This request for modification is associated with the intent to maintain access to SR99. The strict
adherence to the 250ft driveway spacing standards would significantly and negatively impact the
operation of the site and the proposed store, as well as the ability to redevelop the site. Access to
SR99 is critical to vehicular movements through and around the site. Due to existing built
conditions surrounding the site, it is not possible for delivery trucks to service the store with just
one access driveway on S 3181h PL. Due to the size of site, trucks are not able to enter the site
AutoZone — Modification Request — Driveway
Page 1 of 2
Spacing
Federal Way, WA
through the one driveway and be able to turn around to leave the site through the same driveway.
We have attached an Autoturn exhibit demonstrating the necessity of access to SR 99 to site
operations. Refer to Exhibit C. It should be noted that due to the existing median conditions in
SR99, the site's driveway access to SR99 will be limited to right in / right out movements only.
The project would reduce trips to and from the site because a retail store use is a lower trip
generator than the current gas station use. The proposed improvements would minimize the points
of conflicts onto SR99 by removing the two existing driveways and replacing them with a single 30
feet wide driveway. Additionally, driveway spacing is improved on S 3181h by relocating the
existing driveway to the east side of the site, increasing the spacing from 69ft to 108ft. This not
only improves spacing, but also maximize the stacking length to SR99. Refer to Exhibit B for the
proposed site plan and driveway location.
The site has approximately 205 feet of frontage on SR99 so meeting the 250 feet driveway spacing
within the site is not physically possible. City staff suggested the applicant to pursue a shared
access driveway with the adjacent property to the north. Due to topographical constraints (the
adjacent site is approximately 5ft higher), property rights, and the footprint of the store, it's not
possible to properly connect to this existing driveway.
There are currently multiple existing driveways in the vicinity of the site that are located spaced
less than 250 feet along SR99. The proposed access driveway to SR99 would be consistent and in
harmony with surrounding developments, while providing greater spacing than most existing
driveways in the area.
Based on the reasons provided above, the applicant requests approval for modification of the
standard to serve the proposed project properly and safely. This proposal is consistent with the
surrounding area and does not negatively impact the surrounding street system. The proposed
driveway locations will improve public safety due to the increased spacing and fewer vehicle trips
anticipated with the proposed use.
AutoZone —Modification Request — Driveway
Spacing Page 2 of 2
Federal Way, WA
ff `
P.O. BOX 2198
MEMPHIS,-TN 38101
901 495-7031
Pay
D1
First Tennessee Bank
165 Madison Avenue
Memphis TN 38103
****TWO HUNDRED NINETY AND 00/100 DOLLAR
To The CITY OF FEDERAL WAY
Order Of 33325 8TH AVENUE SOUTH
PO BOX 9718
FEDERAL WAY WA 98063-9718
001036894
Date 01/06/17
MMDDYY
$ l *** 290.00----------'
VOID AFTER 130 DAYS
0.. J V ' . '
11000 103689411■ 1:064 2043471: 11' L836793 2211'
£OM 339S3NN31'SIHdW3W ie �'24",
80013 PJ£'133HlS 1NONd'S £dL it
•Oul 'auozo;ny
0
I
e
i
�
z Q
=
EWd6 tlM'AtlM 1tltl303�
y
�n' �
AtlMH'JM 9117tld 0991E
L N
i• q
®
U) W
m
1N34dOUA3O 38013 avoZWny
w
S
r
w
w
rJ
o
t3lVnIttd) Id HlOkC S
i
1
1 �
1 _
i !
i
ea 33SS3N _'SIH
eo m a3 -oul\_oo \
0. §
cm
vloal � §[
+.dOI.9A 2 20-Ls_OZWfr
ell ^
« );
)\}
�
,