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HomeMy WebLinkAboutCL 01-02 , " 002 REPORT TO COUNCIL CltJ¡ (1~ .-.. FROM: Bruce Taylor, AMCT, CMM City Clerk DATE: January 31,2002 REPORT NUMBER: CL 01-02 SUBJECT: Processing'Development Applications & Public Notification RECOMMENDATION: 1. That Clerk's Report CL 01-02 regarding Processing Development Applications and Public Notification be received. . 2. That the Summary of Recommendations set out in Clerk's Report CL 01-02 respecting improvements to the processing of development applications and public notifications be adopted. ORIGIN: ,... Resolution #129/01 passed on October 15,2001 AUTHORITY: Various sections of the Planning Act and Municipal Act FINANCIAL IMPLICATIONS: Minimal cost increases for postage and other :incidental costs related to an improved development application process. . EXECUTIVE SUMMARY: - As a reslÙt of a resolution passed on October 15, 2001, staff of the PJanning & Development Department and the Clerk's Division, have been reviewing ways in which the process of development applications is made more understandable to the public and to provide the public with a greater awareness of current development applications. This Report also reviews the findings of the staff and makes recommendation to improve the development application process. Report to Council CL 01-02 Date: January 31,2001 003 Subject: Processing Development Applications & Public Notification Page 2 BACKGROUND: Please be advised that CoUncil passed the following resolution at its regular meeting of October 15,2001: .-.. WHEREAS planning reports, by-laws and other agenda items appear with *echnical descriptions that are often difficult for the public to understand in the summary agendas they receive; and WHEREAS public interest in seeing the distributiòn radius and circulation for development applications expanded is high; and WHEREAS notice of development applications within study areas are' not circulated to residents who have expressed interest in the study area; and WHEREAS achieving the highest degree of public understanding, and transparency of our processes is desirable and serves an important public good; NOW THEREFORE the Chief Administrative Officer, with appropriate staff, prepare a report for consideration of Committee of the Whole that would:. . ,.... 1. Seek to create an infonnation line for Council and Committee agenda items that quickly, clearly and simply explains what the item is and where it will be going next. 2. Give options with respect to increasing the circulation radius for development applications and other measures that might increase public knowledge of applications. . 3. Ensure that any development applications that occur within a study area while the study is underway and for a defined period thereafter are properly circulated to those on the mailing list for the study. 4. Modify our process such' that notification of implementing zoning by-laws happens before and after a by-law is to be considered by Council 5. Recommend any additional measures which would make our process more traIJsparent to the public; and. THAT this report come before Committee of the Whole for its first meeting in February, 2002. Please find attached to this Reþort the comment of the Director, Planning & Development with respect to those areas regarding public notification that are in his area of jurisdiction. Although the above resolution directs staff to prepare a report on the issue of public notification as it affects development applications, staff looked at the entire issue of public notification in a global sense. . - The following is a summary of staff comments and recommendations in responsè to the five points set out in the above resolution. LISTING ITEMS FOR CONSIDERATION IN THE AGENDAS Resolution #129/01 directs staff to "Seek to create an infornlation line for Council and Committee agenda items that quickly, clearJy and simply explains what the item is and where it will be going next." , ü 0 4 Report to Council CL 01-02 Date: January 31, 2001 Subject: Processing Development Applications & Public Notification Page 3 . The following is an example of how items are listed in the PJanning Committee Agenda: - PLANNING & DEVELOPMENT REPORT PD 37-01 DRAFT PLAN OF SUBDIVISION APPLICATION S-P 2000-04 ZONING BY-LAW AMENDMENT APPLICATION A 02/01 . SEAN MICHAEL GREENE PART OF LOT 3, PLAN 282 (ROCKWOOD DRIVE. NORTH OF HOGARTH STREET) As can be noted, the above sample entry from a Planning Committee Agenda shows that the item is being generated by the Department, Pla.nnIDg & Development, it involves a Draft PIan of Subdivision and Zoning Application, the me numbers are noted so that any resident can refer to them if they want to speak to a staff person during business hours, the applicant's name is stated because often residents will refer to a development application because they know the applicant and the location of the application is always stated. Items listed in the Agendas of the Finance and Operations Committee and the çommittee of the Whole also show what Dkector or Division Head is originating the Report and the subject of the Report is always stated. An entry will be put on all the Standing Committee Agendas that indicates that all recorinnendations approved at the Standing Committee level will be subject to ratification by Council the following week and any person wishing to address an item at the Council Meeting will be required to register as a delegation by noon of the Friday preceding the Council Meeting. ,... With respect to items listed in a Couilcil Agenda, the only problems with respect to clarity that, have been identified are Zoning By-laws which are very vague ~cause they do not clearly identify what the purpose of the by-law is, the name of the applicant or the location of the property in question. Since the passage of Resolution #129/01 on October 15, 2001, the Zoning By-laws have been listed in the Council Agendas as follows: . By-law Number 5928/01 Being a By-law to amend Restricted Area (Zoning) By-law 3036, as amended, to implement the Official PIan of the City of Pickering District Planning Area, Region of Durham in Part of Lot 122 and 123, Plan 1051, in the City of Pickering. (A 2/94, 18T-93018). . PURPOSE: ZONING BY-LAW LOCATION: NORTH SIDE OF DUNBARTON RD., EAST OF FAIRPORT RD. APPLICANT: F. MAIDA FAMILY INVESTMENTS LTD. For residents who are reading the Council Agendas, I believe the above sample clearly identifies that the by-law being considered is a Zoning By-law, it states the general location of the subject property and who is the applicant. - INCREASING THE CmCULATION RADIUS FORDEVELOPMENTAPPUCATIONSAND OTHER MEASURES TO INCREASE PUBLIC KNOWLEDGE OF DEVELOPMENT APPLICATIONS Resolution # 129/0 1 directs staff to "Give options with respect to increasing the ckculation radius for development applications and other measures that might increase public knowledge of applications." . ',' Report to Council CL 01-02 , Date: JanUary 31,2001 005 Subject: Processing Development Applications & ,Public Notification Page 4 -- The Planning Act requires that all property owners within a 120 metre radius be notified of the submission of a zoning by-law or Official Plan amendment application and the date and time of the ' Statutory Public Information Meeting in order to be provided with details of the application. Currently, only persons who attended the Statutory Public Information Meeting and sign the "Sign Up" sheet or those who have expressed an interest in writing in the application are notified of the Planning Committee Meeting where the application will be considered by Council. These same people will be sent the Notice of the Passing of a Zoning By-law in the case of a zoning by- law amendment application. There are instances when the tUne between the Statutory Public Information Meeting and the. Planning Committee Meeting is so great that the mailing list of inte.rested parties is no longer credible. Staff recommends that where the time between the Statutory Public Information Meeting and the Planning CoII1II)Ìttee Meeting is greater than one year, all property owners within 120 metres ofthe subject prop~ will again be notified ofthe Planning Committee Meeting. The letter to all property owners within a 120 metre radius of the subject lands setting out the details of the development application and advising of the date of the Statutory Public Information' Meeting is also sent to all ratepayer organizations and a large, number of agencies such as the Ajax-Pickering Board of Trade and Rogers Cable. The applicant is also required to post a sign on the subject property setting out the details of the development application and providing a contact in the Planning & Development Department that a person could call for further information. The Solicitor for the City has advised that the Planning Act provides for a statutory notification requirement that is not intended to be extended as a municipal Council deems fit. It is the opinion of the Solicitor that a Council cannot require a greater radius. To do so would put Council in a position superior to that of the Provincial legislature and that is not a power any municipal Council can claim. .,.... Council should be aware that the imposition of a circulation notice radius greater than the Planning Act provision could be misleading for those who might receive notice beyond the statutory requirement. Such persons might believe that they have a right to all further notice when this is not the case. The Solicitor advises that Council cannot increase the demands on an applicant beyond those requirement set out in the Planning Act. No other municipality within the Region of Durham has increased their notification radius for applications processed under the requirements of the Planning Act. Within the Planning & Development section of the City's Web Site, a memo item could be added entitled "Current Development Applications". Upon double clickipg on this menu ite11l, a list of current applications would appear with the following information: CURRENT DEVELOPMENT APPLICATIONS FILE NUMBER(S) ADDRESS EXPLANATION OP A 15-002/P and A 99/02 123 Main Street The applicant proposes to develop 20 stacked townhouse and street townhouse dwelling units served' by an' internal private road on the subject lands. 123456 Ontario Limited , January 17, 2002 at 7:00 p.rn. in Council Chambers ...... APPLICANT DATE OF PUBLIC INFORMATION MEETING LAST DAY FOR COMMENT CONTACT' January 24, 2002 John Doe, Planner 2 at 905-420-4660, ext. 23 006 Report to Council CL 01-02 Date: January 31, 2001 . Subject: Processing Development Applications & Public Notification Page 5 NOTE """ IF YOU WISH TO BE NOTIFIED OF FUTURE MEETINGS RESPECTING ANY OF THE ABOVE DEVELOPMENT APPLICATIONS, PLEASE SEND A LETTER OR E-MAIL TO: Bruce Taylor, AMCT, CMM City Clerk One The Esplanade Pickering, Ontario. LIV 6K7 E:MAIL: btaylor@city.pickering.on.ca It is important to note that the list of Current Development Applications should only be listed on the Web Site for the duration of the public comment period (30 days) while the application is in its initial stages. To' provide this information for a period that is any longer would only mean that the list of Current Development Applications would become long and complicated and would loose its relevance. If any person has an interest in an applicatio~ they will notify me in writing and this will provide for notices of future meetings respecting the application to be sent to them. ".. APPLICATIONS WITHIN A STUDY AREA Resolution #129/01 directs staff to "Ensure that any development .applications that occur witlrin a study area while the study is underway and for a defined period thereafter are properly circulated to those Oli the mailing list for the study." . Notice of any development application submitted within a' formal study area, during the study perio~ could be circulated to all persons identified on the mailing list associated with the study. Once Council adopts a study, that project should be considered to be complete. Staff then evaluate any new applications received within the study area based on Council's newly establiShed policy. It is not recommended that spécial notification practices apply following completion of the study. Also, the previous comments of the City Solicitor with respect to circulations being conducted in strict compliance with the Plamllng Act would apply once the study has been completed. NOTIFICAtION OF IMPLEMENTING ZONING BY-LAW Resolution #129/01 directs staff to "Modify our process such that notification of implementing zoning by-laws happens before and after a by-law is to be considered by Council." , ..... An Ünplementing Zoning By-law is merely the legislative instrument that the Province requires to implement a zoning decision made by Council. A Zoning By-law cannot be enacted until at least two public meetings are hetd; those being the Statutory Public Infunnation Meeting where the details of the zoning application are made public and the Planning Committee Meeting where the Planning staff forward a Report to Council making a recommendation on the disposition of the application. Ofte~ additional public meetings are held with the local residents in an informal atmosphere to discuss the application with the applicant and City staff. .. ,¡¡fIlII>. Report to Council CL 01-02 Subject: Processing Development ~-pplications & Public Notmcation . Date: January 31,2001 007 Page 6 As noted in the memo of the Director, Planning .& Development, it is not recommended that' notice of Council's intent to consider passage of an implementing by-law be circulated to. all property owners in the initial circulation radius because such an action would tend to draw out the public in matters for which Council has already made a land use decision and would introduce significant delays to the application review process. By the time an application reaches the stage where Council is considering the Zoning By-law, residents have been given ample opportunity to comment on the application. The Planning Act requires that all Zoning By-laws, once passed, be circulated to persons who have expressed an . interest in the application to provide them with an opportunity to appeal the By-law. to the Ontario Municipal Board if they so chose. OTHER MEASURES I TRANSP AREN CY . Resolution #129/01 directs staff to "Recommend any additional measures which would make our process more transparent to the public." ,.... """,.., . . In the attached memo of the Director, Planning & Development, the following measures have been noted that could make the development process more transparent not only to the public, but also to Members of Council and other staff members: . . The staff of the Planning & Development Department could endeavour to make Reports to Council pertaining to applications and studies available to Members of Council at least a week before the Planning Committee Meeting where they are scheduled to be considered. It is important to note that this may not occur in every case because of scheduling and process implications. At the commencement of every Statutory Public Information Meeting; the staff of Planning & Development outline the Planning process and "next steps" of an application. If invited by a Community Association, Planning & Development staff will attend their Association meeting prior to the Statutory Public Information Meeting in order that the Association has all relevant information prior to preparing their comment. If requested at Statutory Public Information Meeting,' staff will meet with a resident working group to further discuss the issues of an application. Staff are in the process of preparing citizen guides for use by the public to assist in understanding the various development application processes. Plain language brochures, prepared by the Province, are available for viewing at the Planning & Development counter that helps describe various planning processes. Copies of Reports to Council that are included in a Planning Committee agenda will be made available to the public in the Lobby of the Civic Complex on the evening of the Planning Committee Meeting. It should be noted that these same Reports are also available to the public upon request once the agenda for the Planning Committee Meeting has been prepared. '. . Staff have reviewed and revised the various c:irculation notices to ensure that "plain language" is used to describe a planning proposal or process, the date of the Statutory Public Information Meeting is stated in a more prominent location withiIi the notice letter and the name and telephone extension of the Planner dealing with the application is clearly noted. The wording for notification signs required to be posted on properties subject to a development application has been sÙI1plified over recent years. Advertisements are placed in the Community Page advising of all public meetings respecting studies and broad zoning iSsues. In some very limited instances, notifications of development applications that are located within a study area have been sent to all persons on the mailing list for the study. This occurred in the Liverpool Road South Study and the Notion Road Study. . . . . . . . . 008 ..... - ¡/I81f<o. Report to Council CL 01-02 Date: January 31, 2001 Subject: Processing Development Applications & Public Notification Page 7 SU MARY OF RECOMMENDATIONS The following is a summary of the recommendations con tamed ill this Report that staff believe will lead to a more transparent development process for not only the public but also for Members' of Council and staff. . . An entry will be put on all the Standing Committee Agendas that indicates that all recommendations approved at the Standillg Committee level will be subject to ratification by Council the following week and advising the public on how to register as.a delegation , to a Council Meetillg. . Zoping by-laws will be clearly identified in the CoUncil Agenda by stating the purpose of the by-law, the location of the lands affected by the by-law and the applicant's name. Where the time between a Statutory Public Information Meeting and a Planning Committee Meeting is greater.than one year, Notices of a 'Planning Committee Meeting will be sent to all property owners within 120 metres ofthe subject property. Newly submitted development applications will be listed on the City's Web. Notices of a development application submitt~d within a fot:JIUl1 study area, during the study period, will be circulated to all persons identified on the mailing list associàted with the study. . Citizen guides will be prepared by staff to assist the public in understandirig the various development application processes. Copies of Reports to ColUlcil that are included in a Planning Committee Agenda will be made available to the public in the Lobby of the Civic Complex on the evening of the Planning Committee Meeting. Staff are' currently investigating the feasibility of providing the agendas for both ColUlcil and Standing Committee Meetings on the Monday or Tuesday preceding the meeting. . . . . . . . ATTACHMENTS: 1. Memo of Director, Planning & Development dated January 4, 2002 ( ---- Copy: Director, Planning & Development Recommended for the consideration of Pickering City Council Tho ", ATTACHMENT#-L TO REPORT#..£!::-- () 1- 0"'2- 009 PLANNING & DEVELOPMENT D~P ARTMENT MEMORANDUM , January 4,2002 To: Bruce Taylor City Clerk - From: Neil Carroll, , Director, Planning & Development Subject: Council Notice öfMotion Measures to Make the Process More Transparent to the Public , , The following comments are provided for your consideration as input into thè joint report to City Council on the above-not{(d Notice of Motion. The comments are provided in point form under headings reflective ofth~ Notice of Motion. ' Circulation Radius I Increase Public Knowledt!e of Apulicatiom (a) ,.... . the currently applied 120-metre notification radius is estal:;JIished'in the Planning Act for zoning by-law and official plan amendments . any increase in the Planning Act 120 metre notification !adius should not be at the discretion of the Plannfug & Development Department, nor on an application specific basis ' . . if Council wishes to establish a wider circulation notice radius it should be consistent in application - not application specific, and should be' adopted às Council policy by resolution ' . prior' to receiving comments from 'the Solicitor, for, the City, Plani1Î1lg and Development staff were considering r~commending that Council consider a .500 'metre notification radius in the rural area (exclusive of Hamlets) as the land parcels are typically larger and an increase will,piovide additional residents / land owners with information pertaining to the application. ' Further, staff were considering recommending that C9uncil consider, a 150 metre notification radius in the urban area and Hamlets, to provide an jncreaséd level of notice. However: .:. the City Solicitor has advised that the Planning Act provides for a statutory' notification requirement that is not intended to be extended as a municipal Council deems fit. Itis the opinion of the City SoliCItor that a Council, cannot require a greater radius, To do so would put Council in a position superior to that of the Provincial legislature and that is not a power any municipal Council can claim ' ...... 010 Bruce Taylor ATTACHMENT#_.Lro REPORT#~...fJ¡-o1-. January 4, 2002 Council Notice of Motion. Page 2 ¡ttIIa ..:. Council should be aware that to impose a circulation notice radius greater than the Planning Act provision that the result could be misleading for . those who might receive notice beyond the statutory requirement. Such persons might believe that they had a right to all further notice. and !?uch is . not the case ..:. the City Solicitor advises that Councils cannot increase the demands on an applicant. . ..:+ a recént telephone. survey indicated that no other Municipality within the Region of Durham has increased their notification radius forápplicatiom; processed under the requirements of 1f.1e Planning Act . . . Considering the concern of the City Solicitor, it is recommended that Council NOT increase notification radius beyond the 120 metre requirements of the Planning Act. The City still requires the posting of a notice sign on all public street frontages of the subject property: Notice is also sent to all community associations registered with the City ClerIL The sign provides notice to those persons falling outside the' written notification area. No matter what radius is selected, there will always be residents that fall just outside the notification area, who may express concern that they were not notified while their neighbour was. ",... . . . . . it should be noted that these comments do not apply to Committee of Adjustment applications that. are presently circ~ated to land owners within 60 metres of the application property. Applications to the Committee of Adjustment are intended to', deal with matters thàt are minor in nature. Wider circulation notice is not considered necessary or appropriatè. Pickering residents appear to be adequately served by the current Planning Act 60 metre notification r~quirement . as applications for land severance fall under Regional jurisdiction, the 60 metre notification radius established under the Planning Act will continue to apply. (b) . Council may wish to consider adding specific information ftom application circulation notices to the City's Web Site . the me number, municipal address, brief explanation of the application I proposal, the applicant's name, date of the Public Information meeting, last date fOf comment and Planner's name could be provide in a simplified format - - Bruce Taylor ATTACHMENT # L TO REPORT #:.S..~. 0 I~ ~'- January 4, 2002 011 Council Notice of Motion -- Page 3 (c) . the same infonnation provided on the W,eb Site (see 'b' above) could also be included in the 'community page' which appears in the local newspaper . this process could be implemented by the Clerk, using the application information provided by Planning & Development in its initial notification request memo . Planning & Development staff will ensuÍe that notification request memo to the Clerk contains a:'clearand brief explanation of the application along with all other relevant infonnàtión, for easy-transfer to the Web Site and Community Page . the Clerk would arrange for the infon;nation to be added to the Web Site and a removal / delete date from the Web Site would be established . , ' .-. Applications within a Study Area: (a) . notice of any development application (other than Cori.:nnittee of Adjustinent) submitted within a formal study area, gurin{r the stuq.y perioq, could be circulated to all persons ídentified on the .mailing list associated with, the .study .' it would not be appropriate to continue mailing'. notice of development applications ~o all persons on the study mailing list following completion of the study . once City Council formally adopts I approves a study, that project should be considered to be complete. Staff then evaluate. any new applicatìons received within the study area based on Council's newly established policy. It is not recommended that special notification practises apply following completion of the study . ~ Notificatîon of Implementine: Zonine: By-law: , (a) . passage of an 'implementing' by-law is the technical impl~mentation of a pi'e~ous Council land use decision, that has already been debated wi~ full public input . currently, only the applicant. is advised (orally) of the date of Council's consideration of an implementing zoning by-law . . currently, notice of passage of an implementing zoning by-law is circulated to those persons who have specifically requested that the Clerk advise of the p~sage of the by-law. This notice is essential, as it provides those persons having an expressed interest in the matter with an up-to-date status of the zoning by-law, and formally provides them with'instruction on. how to appeal the zoning by-law if they are in objection. This system appears to be working well . - , 012 Bruce Taylor ATTACHt"'ENT#...L.,=, TO REPORT#E_O¡"'o1- January 4, 2002 Council Notice of Motion Page 4 - . we do not recommend that D:otice of Council's intent to consider passage of an implementing by-law be circulated to all property owners in the initial circulation radius-such action would tend to draw out the public in màtters for which Council has already made a larid use decision, and would intToduce'significant delays to the application review process, . it is recommended however, that implementing zoniÍ1g by-laws be more clearly identified in the Council. agenda summary. This will provide the public' with a better understanding of the implementing by-laws being considered at any Council meeting. - , " ' . should any Councillor þe concerned about a part~cular implementing zoning by- law coming before Council, they have'the option to request deferral of the by-law (generally, this should not occur as the by-law will be implementing a pr~vious Council resolution on the application). Presently, staff do advise ,Council on a monthly basis of implementing zoning by-laws that are anticipated to be forwarded for Counëil'sconsideration Additional Measures I Transparencv: (a) - . . reports are currently available the Friday prior to the Planillng Committee Meeting (at the time of agenda printing) , . Çouncil may desire to have the reports pert3ming to Planillng applications available the Monday prior to Planning Committee (rather than the Fiiday prior) . this revised time frame would have implicatioij.S on the length of time to process an application as it would add another week to the'sch~duling of the once a month meetings of Planning Committee and less' flexibility is available to Staff for scheduling'ofitems to Committee' , . Council may desire to ,have r~ports pertaining to Planning studies available even further ahead of time than the ,Monday or Friday prior to Planning Committee,- perhaps 10 days or two Fridays in advance of the meeting - - . this will also add additional time onto the process and less scheduling flexibility (b) . to assist in making the application process as tTansparent as 'possible, Planning & Development staff currently outline the Planning process and "next steps" of an application in the initial circulation notice and at the beginning of every Statutory Public Information ,Meeting - Bruce Taylor ATTACHMENT#,L TO REPORT # c¿. () I~ o-i- ._. January 4, 2002 013 Council Notice of Motion Page 5 . if invited by a Community Association, Planning & Development staff will attend their association meeting prior to the Statutory Public Informati?n Meeting in order that the Association has f .ll relevant information prior to preparing their comment. Further, if requested at the Public Information Meeting, Staff will meet with a resident working group to further discuss the issues in a follow-up meeting ...... . (c) . Staff will be developing citizen guides for use by the public. to assist in understanding the various application processes . plain language brochures, prepared by the Province, are available for viewing at the Planning & Development counter that ~elps describe various planning processes (d) . it may assist to have copies of Planning & Development Reports available to the public at the Planning Committee meeting (similar to' the process currently in 'place for Statutory Public Information Meetings 'where copies of reports are available at the security guard desk the evenin~ of the meeting) Other Comments: (a) ""... . Staff have recently revised the circulation notice to: 0 advise residents to contact the Planning & Development,Department and Planner directly, rather than ~e City Clerk as previously done 0 reflect the municipal address of the subject property in the reference line 0 move the 'date of the Information Meeting to a more prominent, "up~:front'" location within the notice letter . Staff are attemptirig to use "plain language" wherever possible to describe a planning proposal or process . . . . although circulation notices have recently evolved to address the above changes, Staff intend to make further revisions to simplify and ensure the .notice is user :friendly, while still providing all information required by the Planning Act . the wording for notification signs required to be posted on properties subject to a development appliçation has been simplified over recent. years (b) . any Planning studies currently undertaken by the Planning & Development Department include advertisem~nts in the local paper for all public meetings related to the Statutory Meeting, and Committee / Council meetings . newspaper advertisements are also used to advise of broader -rezonjng issues, when necessary - n14 - - - Bruce Taylor ATTACHMENT #-1- TO-REPORT # ..::f_~p /-,,"l- January 4, 2002 Council Notice of Motion Page 6 . recent notification of applications within a study are~ has, been sent to all persons on the mailing list for the study (Le.: Liverpo.ol South Study) . the size of the mailing list is not reflective of resident inv9lvement (Le. Notion Road Study mailing was sigriificant, while public interest was very limited) . Community Associations / Groups are generally very effective in disseminating information . (c) . any increase in notification circulation radius for developIQ.ent applications will increase the City's mailing costs. It will be difficult to recover increased mailing costs through application fee increases, if notification radius exceeds ~ose set °':1t in the Planning Act . maintenance of large mailing lists for planning studies incurs significant costs in staff time to ensure lists are cuITent, up-to-date; and non-duplicative (this often involves manual labour-intensive work). Higher levels of service bring associated cost increas~s .' . LDT/NC/kb 1 : 1M GMT\nCUTOIIIOEN!!RAL Idcrkslnuupo rent doc