China - Zhejiang Multicities Development Project

Document of The World Bank FOR OFFICIAL USE ONLY Reporl No. 11282-CMA STAFF APPRAISAL REPORT CINA ZHEJIANG NULTICITIES DEVELOPKENT PROJECT FEBRUARY 22, 1993 Mi .r~ 'f ' * V: h !F1 (U 'v '. ip~tu N.:Fl i I -K NiA 'Tv>.-: :..i i,. - 7ULt&: ~i3N'; ~ .~ ri. j;r.i5~, A:' t.hs 1''41r-'1 AP ,:- r-;@ iH Environment, Humnn Resources and Urban Development Operations Division Country Department II (China and Mongolia) East Asia and Pacific Regional Office This document bas A restuicted distribudion sud my be used by recipients only in the perfomasnce of their official duties. Its contents may not otherwise be disdosed without Worid Bank authorization.  CURRENCY EQUIVALENTS (as of August 1992) Currency = Renminbi Currency Unit = Yuan (Y) Y 1.00 = 100fen Y 1.00 = $0.18 $1.00 = Y 5.47 FISCAL YEAR January 1 - December 31 WEIGHTS AND MEASURES meter (m) = 3.28 feet hectare (ha) = 10,000 square meters (m)- 15 mu cubic meter (in) = 284 US gallons tione (M) = 1,000 kilograms kilometer (km) = 1,000 meters  Fo0 OMCLIL USE ONLY PRINCEPAL ABBREVIATIONS AND ACRONYMS EA - Environmental Assessment GIS - Geographical Information System GOC - Govenmment of China HCPDI - hou City Planning and Design Institute HMG - Hangzhou Municipal Government HTPD - Hangzhou Traffic Police Detachment HWC - Hangzhou Water Company ICB - Itrmational Competitive Bidding LCB - Local Competitive Bidding LSWM - Liquid and Solid Waste Management MOC - Ministry of Construction MOPH - Ministry of Public Health MURCC - Municipal Urban and Rural Construction Commission NEPA - National Environmental Protection Agency NMG - Nimgbo Municipal Government NUIDO - Ningbo Urban Infrastucture Development Office NWC - Ningbo Water Company PBC - People's Bank of China PCBC - People's Construction Bank of Chini PMO - Project Management Office SAA - State Audit Administration SLDC - Shaoxing Land Development Company SMDI - Shanghai Municipal Engineering Design Instute SMG - Shaoxing Municipal Government SNADCC - Shamxing New Area Development and Construction Commission SWM - Solid Waste Management TOR - Terms of Reference UFW - Unaccounted-for Water UNEP - United Nations Environmental Program UPMIC - Urban Planning Management Information Center WMG - Wenzhou Municipal Government WTP - Water Treatment Plant WWC - Wenzliou Water Company WWTP - Wastewater Treatnent Plant ZEF - Zhejiang EIvironmental Fund ZEP - Zhejiang Environment Project ZEPB - Zhejiang Environment Protecon Bureau ZEPO - Zhejiang Environment Project Office ZFD - Zhejiang Fmance Department ZPG - Zhejiang Provincial Government ZUDPO - Zhejiang Urban Development Pro,.ect Office This document has a restricted distribution and may be used by recipients only in the performance of their official duties. Its contents may not otherwise be disclosed without World Bank authorization.  -i- CHINA ZHFJANG MULTICITIES DEVELOPMENT ]PROJECT CREDIT AND PROJECT SummARY Bu.w People's Repblic of China _endidul.: Thejiag Provinc and the Mumcipalities of Hangzhu, Nimgbo, Shaoxing and Wenzbou A_u: SDR 79.3 million (S110.0 mlllion equivalent) Te : Standard IDA terms, with 35 years' maturity including 10 years of grace Tom: Prceeds of the Credit would be relent to the Municipaities by Zhejiang Province. The Municipalities would in tu relend the poceds to public utlities and land devdopment mpaies fbr 15 years, including five yean of grace, at the 1BRD standard variabie interest rater annum, with the enties bearing the commitment charges and foreign exchange risks. Part of the Credit prceeds would also be relent to the Zhejiang Environmental Fund for industria polludion subprojects by smal and m indusrial etprises at the IB}D variable interest rate plus a spread of 1.5 percen per annum, with de subproject enter bearing the commitment dharges nd foreign exdhange. Prujc Dumrpdm: lhe project would support imp s in wate supply, Iand development, envronmetal pollution control and raffic managew.ent and assist in setting a coherent urbmn plamning and a two.-i ase programming friunewor. It would be the first part ofacomesie two-stage program for the improvement of water supply and removal and diposal of liquid and solid waste in the fbur project cities. The first phase, financed by this project, would support nmprovemens im water supply in the cities of Hangzhou, Nmgbo and Wenzwu, land development inShaoxing, eavironmentalprograms, instionbuilding and tafic management in Hangzw . Water production would be increased by 620,000 m&/day in thee project cities to addess the long-term shortage and poor qualit of their water supplies. More than 207 ha of land area would be deveoped in Showxg to stem ov ding the old city and to povide epansion of indust and cMercial acvities. The eviromen programs would consist of (i) a co ve Liquid and Solid Waste  - ii - Management Study for ii four project cities, support to dte prvincial environmental agency and the detaied prepartion of an Environment Project as a follow-up project; () a basic urban services upgrading component for the city of Ningbo; and (iii) an Environmental Fund for pollution control investments to provide finacial assistance to small- and medium-sized industrial enterprises. The project would furffher support uban planning and manage- ent systems and traffic egineing and maagement The future second phase would be a comprehensive enronment project for the four cities, aimed at developing residential and industrial sewage collection and treatment systems, and improving on-site industi wastewater treatment and nonsewered systems. The preparation of this proposed follow-up environment project, including feasibility studies, prelimiDnary engineering studies and at least 20 percent of the detailed design, would be included in the proposed Zhejiang Multicities Development Project. Project Benefits: Wit its water supply aion, the proposed project would meet the quantity demands of the rapidly growing population of the four project cities and the projected increase in industial water demand sutanig economic growth. It also would improve the water quality and thus health security of a large segment of the urban population. By establishing firm linkage to the follow-up environment project, the ctes' wastewater problems will be addressed in a systematic manner. In addition, the project would improve the environmental condiions in the city of Nmgbo and establish a line of credit (S5 million) for industrial pollution control investments thmughout the province. The project would further create a much needed urban extension area in haoxing, provide trsport improvement in Hangzhou, and stregthen the urban planning service delivery in all four cities. PIroject Risks: Risks of the project include: (i) possible delays in implementation and underutilization of invesmebecause of constints in the management capabilities of the responsible provincial and municipal agencies; and (u) inexperience on the part of the cities widt fill cost recovery on land development These risks have been addressed initially through analysis and supr during project preparation. During project implementaion, additional support will be given in the form of tecdnical assistance and training. The additional risk that the follow-up Environment Project may not come to fruition has, to a large extent been reduced by integating its full preparation into this project, as well as reuiring mobilization of the consultants to carry out key studies prior to Credit effectiveness.  - ull - E _timated Costs: Local Foreign Total -(S million) Water Supply Hlangzhou 20.8 21.9 42.7 Ningbo 16.3 17.4 33.7 Wenzhou 11.6 12.0 23.6 Shaoxing Land Development 23.3 13.4 36.7 Environmental Management 1.4 4.1 5.5 Instituon Strengthening 0.4 6.2 6.6 Ningbo Urban Upgrading 18.5 12.1 30.6 Industrial Pollution 0.5 4.3 4.7 Bhase Cost m2 EA 4 I4.Z Physical Contingency 11.5 11.1 22.6 Price Contingency 15.5 8.8 24.3 Total Proect Cost MU 1. 23LO :Financing Plan: Hangzhou Municipality 27.3 0.5 27.8 Ningbo Municipality 45.0 0.6 45.6 Wenzhou Municipality 14.7 0.3 15.0 Shaoxing Municipality 31.0 0.3 31.3 Zhejiang Environmental Protection Bureau 1.2 0.1 1.3 IDA 0.5 109.5 110.0 Estimated Disbursements: IDA FY 1993 1994 1995 1996 1997 1998 1999 (S Million) Annual 9.4 38.7 31.7 22.4 6.9 0.7 0.2 Cumulative 9.4 48.1 79.8 102.2 109.1 109.8 1:0.0 Economic Rate of Return: Iftastructure Improvements (comprising 94 percent of total project coss): 19 percent Notr TotlEs may not add up exacty due to rounding.  - iv - CONTENS 1 Urba Devdopment Z!ijn Provnce ...................... 1 A. Backcrouzd ..................................... I B. Institutonal Framework ............................. 4 C. Demand fbr Services ............................... 6 D. KeySectorImues ................................. 6 E. World Bank Grops Role nd Eqxiee with PastL ig .....Lendn . 7 2 Mm eProje ......................................... 9 A. Ba ckground..................................... 9 B. O bje c t ives ...................................... 9 C. Scope ........................................ 10 D. Description ..................................... 11 Wate Supply o........................ 11 L n DenShig ...................... 11 Urban Enim n Man 1agmenaPt andc Protection. . . 12 Udn Plng Sysem, IuihtaDvlpmn dt ad Traffic Magement in bnpioz ...12 Bsic Urbn Svics Upradig in o . ............. 14 Zhiag Enviomental F ZE ......Fnd E.. .......... iS Status of Proect Prparatio ........................ 15 E. Project Cost Estiates ............. ................. 16 F. FnncingPlan ............ . 16 G. Procurement .................................... 18 H. Disbursent and Special Accowt ....................... 20 L onioingCre ................ ................ 21 This report is baSed on findins of an appraisa mission to China in FebruaryMarch 1992. Mission members comprised Herbert Bodam Crask NMager), Geoffre Read (Senio Municipal/ SanitaryEngneer), Adrienne Nassau (Senior ianciaAnalyst), David Cook (Consultant, Urban De dopmen Specialist), Gtard Tenaille (Consultant, Senior Engine), Zhag hUn (Costt Senior Adviso), ZbaMg Chongu Engi , ASTEN) and Linda Mih (a Asdstat). Alfvd Picardi (Cos ppared the Annx. PeK revieerswere Art Brauese (Pirincipal Eime Eninr, ASE), Andrw Maoun (Smnti Enginee, INUWS), Songsu Choi (Sor Urban Poi ASTIN) and George Plant (Sior Sitay Eqinr, SA3E). Te Division Chief is Zafer Ecvt and the Dn PEprten Director is Shd Javed Buri.  3 Projed Organhation and ....................... . 22 A. Project Organzation ............................... 22 B. ProjectManagemen .......t........................ 23 C. Land Marketmg .................................. 24 D. OperAtions andM .aintenance .......................... 26 4 Finanue ............................................. 27 A. Financial Systm................................... 27 Taxation .................. .................. 27 AccountingSystems ............................. 28 Project Accounting .............................. 28 B. Audit ......................................... 29 C. Provinci Finance ................................. 29 D. Municipl Finance ................................. 29 Impact of Project Investment ......... .. ............ 29 E. Water Company Finances.. 30 Fiscal Relationship between ihe Water Companies and the Municipal Governments .......................... 30 Tadfs, M teig and Collections ..................... 30 Past Performance ............... ................ 31 F. Financial Objectives and Rislcs .......... .. ............. 32 G. Futue Fimancial Pefm ce and Sustinability ..... .. ....... 33 Hi. Shaoxing Land Development Component ....... .. .......... 33 S Project Justifrcation and Risks .............................. 35 A. Project Benefits .................................. 35 B. Economic Benefits ................. ................ 35 C. Environmental Impact ............... ............... 36 D. Resettlement .................. .................. 37 E. Risks ......................................... 37 6 Agreements Readhed and Recommendation ........ .. ........... 38 1. Project Cities ....................................... 41 2. Water Demand Projections ................................ 48 3. Selected Urban and Environmental Laws, Regulatons and Standards in Force . 54 4a. Water Supply Com-onent .57 4b. Shaoxing: Land Development Component .61  -vi - 4c. Urban Environmental Management and P rot ton ......... 68 Atachment 1: Liquid and Solid Waste Management StrategicPlnig ad Pblicy Study for the Cities of Hangzhou, NHigbo, Shaoxing and Wenzhou mcd. TOR) ..................... 72 Attachment 2: Consultany Sevces for Prefeasibflity, Feasibility and Engineerig Studies of Urban Enviromental Services nwestment Program(mcl. TOR) ........ 78 Attachment 3: Technical Assistance and Training in Upgrading the Management and Operation of Zhejiang Environmental Protection Bureau (icl. TOR) ................... 88 Attachment 4: Program and Timing of Environment Studies and ZEP Project Preparation Timetable .91 4d. Urban Planning Systems, Institutonal Development, and Traffic Mnagemen in Hangzhou .92 Attachment 1: Consulting Services for Urban Management Systems, Land-Use Planning, and Traffic Management (mcl. TOR) .102 Attachment 2: Technical Assistance and Training of the Water Supply and Land Development Components (mcl. TOR) .113 4e. Basic Urban Semices Upgrading Component, Ningbo .123 4f. Zhejiang Environmental Fund .130 S. Detailed Cost Tables .141 6a. Project Implemctation Schedule .150 6b. Project Disbursement Schedule .............................. 151 6c. Procrement Metods .152 6d. Superision Plan .157 7a. Financial Status of Zhejiang Province .159 7b. Financial Position of Municipalities .161 8a. Public Utilities' Finances .164 Bb. Shaoxing Land Development Financial Projections .179 Sc. Medtodology and Assumptions for Economic Analysis .182 9. Organization and Staffing of the Six Project Offices .184 10. Selected Documents and Data AvailUable in Project File .193 11. Environment Annex .194 CHARTS Organizatin Charts MUS IBRD 24008 Zhejiang Province IBRD 23917 Project Cities  -viu- TAKS IN TExT 2.1 SummaryCostEsimate .................................. 16 2.2 FmancingPan ........................................ 17 2.3 Procuremeut Arr=ngeuem ................................. 19 3.1 EsidmatedAvuragad dlnitiaLa dUseP id ................... . 25 4.1 Wato Tariffs ....................................... 30 4.2 Wate Compan yPastPerfonmanc ............................ 31 FIGURFS IN 1Eff 1.1 Administratie Ogizaion .................... 1.2 Financial Relations ..................................... 5  URBAN DEVELOPIENT IN ZIIEIANG PROVINCE A. BACKGROUND 1.1 Zhejiang Province is located on the East China Sea, directy south of Shanghai and Jiangsu Province. Anhui and Jiangxi Provinces form the border to its west and Fujian Province tD its south. Zhejiang's capital, Hangzhou, lies about 300 km from the city of Shanghai. Thans to temperate dimate and ample rainfall, Zhejiang enjoys a strong agricultural base and boasts a high degree of industriadization Despite the fact that the province occupies, with its abou 100,000 km2. only abou I percent of China's land area, its economic ouQut ran sith among Cns provinces and province-level municipalities. With a population of about 42.4 million (in 1990), Zheiiang houses abou 4 percent of the countrys populai, making it one of the most densely popuareas in China (392 inhabitants per kin. Looldng back on thousands of years of development, the province has inherited a number of ancient cities and monuments. 1.2 Between 1980 and 1990, the prvince's agricultura output increased by an annual rate of 13.8 percent However, industrial out during the last decade grew by 21.7 percnt per annum, exceedig the national industial output by a large margin. This very impressive economic growth reslted in a fst-paced structural rnsormat uf the proncs populaion wit two significant, dearimental effects: rapid urbanzatio and lack of corresponding ifrtcture. Over the same period, the growth rate of the urban areas (more than 2,000 inhabans) averaged 16.6 percent per annum with Zhejiang's urbanizaion incr from 38.1 percent in 1980 to 62.6 percent in 1990. Taking the de facto population (pm and temporary residents) of the inner-city built-up" areas into acount, where the majority of the urban population (about 60 percent) lives, the intense urbaniation process in Zhejiang becomes even more evident. While the provmce's overall population increased by only 1.0 percent per year over the past decade, the built-p areas expanded by 6 percent. Not surpisingly, the largest growth rates are found in the smaller urban areas. Neverthieless, even the core areas of the largest cities, Hangzhu and Nimgbo, both with populations in excess of one million grew by 4.7 and 5.3 percent, respWctively. 1.3 The rapid economic growth of the urb areas, its consequent population increase, and the rising personal incomes of urban dwellers accelerated the demand for urban public services as well as for associated infrastructure and housing. However, due to only gradually danging priorities, outmoded urban planning practices, and insufficient public resources, these demands could not be satisfied adequately. As a result, the cities began to deterorate significandy, presendng symptoms of ura malaise such as excessive population densities, decaying housing, poor quantities and quality of water, lack of sanitation facilities and drainage systems, liquid and solid waste polluion, and insufficient transportation.  -2- 1.4 Although official national policy has since the 1950s discouraged the growth of larger city centers, giving preference to the rural townships, towns, and smaller cities, the built- up areas of Zhejiang's larger cities, such as Hangzhou, Ningbo and Wenzhou, are critical for the province's economic modernization efforts. They will, therefore, have to grow and develop their capacity of urban services delivery commensurately. In Zhejiang these large city centers alone account for about 90 percent of the gross value of industrial output and absorb three fifts of the province's investment in capital construction and 91 percent of all capital investments. In addition, these centers promote the develnpment of modem business and technical services sectors, and are increasingly becoming the "incubators" for international trade and foreign investors. In 1990, Zhejiang accounted for 5.2 percent of China's total foreign trade. Both Ningbo and Wenzhou have received special authorization to enter into direct relationships with foreign investors. In Shaoxing, the authorities are trying to attract foreign firms to its future industrial park and encourage overseas Chinese to purchase or lease housing. 1.5 For the foreseeable fiuture, urban areas in Zhejiang will continue to expand. Even on the basis of moderate hypotheses, the population within the urban built-up areas is expected to increase annually by over 4 percent for the rest of this centuy. Thus, from 1990 to 2000, the population could almost double in these centers. The total urban population within city and town proper areas would expand by growth rates of between 2 to 3 percent, and the province's overall population by less then 1 percent. The clear consequence is that the urbanization process in Zhejiang will continue unabated, with the urban population representing a major portion of the total population of the province. 1.6 Since China's central grovernment, as part of its decentralization efforts, has consciously limited its influence over the cities to setting broad urban policy guidelines, the cities in Zhejiang and elsewhere are facing the great challenge of having to create almost entirely with their own resource base the improvements in urban development and management necessary to sustain economic growth. These efforts have become particularly burdensome for the cities as they may, to a large extent, run counter to the govermnent's reform program to strictly control public investment and spending. The consequences of this policy began to be felt in 1989 when 18,000 inirastructure construction projects were suspended throughout China, total real estate investments decreased and public enterprises had to reduce new projects. 1.7 The cities' efforts to improve urban service delivery under rapid demographic and economic expansion is further hampered by the shortage of effective and efficient urban plamzing and managam systems. The cities' development has been planner-determined, based largely on academic theories dating back to the 1930s. Rigid and cumbersome planning methods and practices follow Soviet models and primarily focus on enforcement of ngid land-use regulations rather than providing useful management tools. For example, some of the cities' master plans are only updated every 10 years, thus exhibiting substanl discrepancies between actual development and plan. Furthermore, planning personnel lack the tools and know-how to develop and analyze alternative development options on the basis of different physical, financial and economic hypotheses. As planners in China have considerable influence over their cities' long-term development, they must be given the necessary training and equipment to carry out their responsibilities more efficiently and consistendy with reform. In addition, communication and coordinaion between physical planners and the line agencies in charge of infriastructure development need to be improved. l  -3- 1.8 Despite ample rainfall, the average water resource availability per capita in Zhejiang amounts to only 85 percent of the national average, with almost all water originating from unregulated rivers and streams, some of which are, at certain times of the year, subject to saline intrusion from the sea. Water is provided in most larger cities primarily through public water pipes after some degree of treatanent. Within the proposed project cities (Hangzho-, Ningbo, Wenzhou, and Shaoxing), only Hangzhou still uses some standpipes (serving 4 percei. of the population). Commercial, institutional and industrial water use comprises about 68 percent of the total water demand in these cities, with about half of the water needed by industry supplied through their own sources. Overall, the water demand in these four cities exceeds the normal capacity of the water plants by a large margin. Even when regularly overloading the plants by about 30 percent, there. still remains a shortfall of about 150,000 m' per day. This shortfall is projected to increase to over 600,000 nin per day by 1995 as the result of expected population growth and continued industrial expansion in all four cities, but *o a particularly large degree in Ningbo municipality with its petrochemical zone in Zhenhai and the harbor development in Beilun. 1.9 Relative to the investnent needs of the urban areas, in the past insufficient funding has been available to modemize the infrastructure of the cities in Zhejiang and to expand them to allow for rapid urbanization. In particular, water source development, and tratment and distribution facilities suffered from lack of investment and adequate levels of maintenance and replacement. Inadequate pricing policies, which fail to induce conservation and ignore cost recovery principles, have exacerbated the problem. Given the severe budgetary constraints most cities in China are facing, it appears most unlikely that the cities would be in a position to fimd the required infrastructure improvements without external sources of funding, even under the assumption that all tariff and cost recovery policy measures would be filly adopted. 1.10 Zhejiang does not possess any full domestic wasewaertreautent facilities. Only Hangzhou has two primary-stage treatment plants serving a part of the city. The other cities have constructed some sewerage systems, often in combination with drainage facilities, discharging into nearby rivers and waterways. In all cities, nightsoil transported to agricultural areas is stil the major source for fertilizer, althougb chemical fertilizers are becoming increasingly popular among the farmers, with the effect that nightsoil is increasingly disposed of in the rivers. This, together with industrial effluents-only 40 percent of the industrial efflu- ents have received treatment-has led to a dramatic deterioration of many urban waterways in parallel with the accelerated urbanization and industrialization of Zhejiang's cities. Pollution has, thus, noticeably increased over the past 20 to 30 years. 1.11 While the city governments increasingly recognize these problems, no provincial nor municipal policies or a strategy as to how to cope with liquid and solid waste in their cities in the fiture have been developed. Although most cities have some proposals for the primary treatment of wastewater in their future investment programs, these seem inadequate in light of the pace of population growth and planned industrial development. Lack of resources and the proximity of large bodies of water with good assimilative capacity, which would seemingly allow the continuation of current disposal practices, are the reasons given for not acting faster on this issue. However, the quality of the Hangzhou Bay, receptacle of the waters of many urban waterways in the most populated areas of Zhejiang, is becoming increasingly of concern to national and provincial authorities. The city of Hangzhou is in the forefont in addressing some of these issues. W-ith the assistance of the United Nations Environmental Program (UNEP), it  -4- o enced a comprehensive study in 1991 to address the evironmental degradation by industrial edEuents of the Grand Canal, the ancient waterway running fom Beijing to Hangzhou. 1.12 Durig te lat 10 years, the fic situai in Zbejimng's cities has deteriorated severely, due chiefly to a dramatic increae in nmbers of mor vehicles and bicycles and the consequent incompability of both modes of anspo ion Hangzou, for example, there ae more than one miMion bicycles ompetig with buses, tucks and automobiles in a street system not large enou to accommodate either of them. Traffic ma ent, enginerng and enfin_ are also not capable of providing proper soluto to these problems. As massive investmens for road constuction are not possible under present budgetary constraints, some relief can be sought dtrough more dficient use of the existing road network and by upgrading th existing maagemt and training systems. B. INlll IRNAL FaAIMEWOR 1.13 Ihere are four me levels in the Province: (i) the province or pwvinci auitbority itself, (i) municipality or region; C(i) the city proper; and Civ) nura couties. Zhejiang is divided into nine municipalities and two regions. 1.14 Muidpa6iles. The city proper and municipal administrative cener is made up of a built-up area or urban core and its immedia suburbs which are often rural. The city pue is furtier subdivided into districts, e.g., Hangzho has six districts, and N-mgbo five. he rur counties are also subdivided into sicts and often have their own udran centers. 1.15 eglm are divided into ral counties and admn -_ratey contoled by the prefectr which represents the provincial goverment at the local level. The prefecture has the -e economc and facial power as the municipalities, but does not have a large enough city ID justify making it a m_-ulity. 1.16 AU four cities included in the prject are mmuicipalities. They report to the Pwvici Goverment, which in tun reports to the Central Government. Nigbo, however, has a special stu and direct ties with the Central Govemment in Beijing on account of its status as aleading port 1.17 There are two independent authorities in a municipality which have direct ties with the provhicial gov ent: (i) the muicipality, which controls the city proper and its dticts; and Ci) the counies, which are divided into districts and towns. 1.18 Both cities and counties have their own resources and budget. The only tie between them involves planming; soci and economic development plans are prepared by the mnicipality and divided between the two administrations. Figures 1.1 and 1.2 illustrate: (a) the in anan; and (b) financial relations between the various levels of government. 1.19 Details on sectorai organization are also given in Chapter 3.  -5 - Pu 1.1: ADI3mZNWRATIVE OCtGAmZATmIN inmlctmL !.uhlta,fl4aeludma. ~~0--- m *maa Tint3ite mdvl tutedautetas .n nv beas o, hug. ,orI ga ugznhot Municipal 11 1I L_1l_ -~ Is I Ic 100---- 1_F_ 3elatiens with Noviaclal7 oGntie abelu -~~ Delatiens with Mu ~Ninip gboeMuenicpa -o----C---u---ties -- *~_ _ Th iiaiycnrlstect4rpraddstrict. C s1 TcoHt * Tegu ofme onto tP nbde n eort dEetyt h rvne *SJU 'iIh ndr hedret on o te e 6 Cottftlfw enoet C~~~~~~~~MZMATICIPSI 1-.-4 r~ ~~~^ 5 Countlas" T