Community Development Partnership Planning Committee Purpose and History For Distribution at the Planning & Zoning Workshop June 24, 2014 The purpose of the Greenwich Community Development Partnership is to increase and preserve the supply of moderate income housing to rent or buy to meet the needs of the town’s moderate income workforce, seniors on fixed incomes, young adults entering the workforce, and others challenged to find moderate income Greenwich housing in a manner consistent with the goals of the Town of Greenwich and the Greenwich community. The purpose of the proposed building zone regulations is to provide small scale, scattered site housing that is inclusive – including both market rate and below market rate housing in the same developments – and that is concentrated in areas near public transportation, and to encourage residential development in the business zones and preserve the neighborhood character of residential zones. In June 2009, the RTM approved the town’s Plan of Conservation and Development (POCD). The POCD recommended four committees, including a Housing Task Force, to work on selected POCD action items and recommended that the Housing Task Force develop recommendations for the POCD action items that address affordable and moderate income housing. First Selectman Peter Tesei named individuals representing a broad cross section of citizens and town government and not-for-profit agencies to the Housing Task Force and appointed Nancy Brown, retired community development director, to chair it. The task force also included liaisons from the POCD Implementation Committee, the Housing Authority of the Town of Greenwich, the Board of Estimate and Taxation, and the Representative Town Meeting Land Use Committee. The Housing Task Force (HTF) began its work in the fall of 2009 and presented its report to the First Selectman in 2012. One of its recommendations was to create a committee to implement the HTF recommendations and form a not-for-profit corporation, to be called the Greenwich Community Development Partnership. First Selectman Peter Tesei appointed individuals to the Community Development Partnership Planning Committee and appointed Mary Ellen LeBien to chair it. The proposed Greenwich Community Development Partnership will work for the town’s affordable housing goals, but will be separate from the town and not dependent upon taxpayer funding. The Community Development Partnership Planning Committee (CDP-PC) convened in October 2012 and has met regularly since that time. It gathered information from town agencies, developers, bankers, the town Comptroller, the town Budget & Systems Director, and the chairman of the Board of Estimate and Taxation, and it studied affordable moderate income housing programs in Connecticut and across the country. The CDP-PC will present its proposed building zone regulations at a workshop of the Planning and Zoning Commission on June 24, 2014. Committee members: Stuart Adelberg, Judy Holden, Mary Ellen LeBien, chair, Ken Rogozinski, and George Yankowich. Mark Schroeder resigned in April 2014, when he moved out of state. CDP-PC - Purpose and History – June 17, 2014 Community Development Partnership Planning Committee Bullet Points for Proposed Regulation Changes for Business Zones June 24, 2014, Planning and Zoning Commission Workshop • The purpose of these zoning proposals is to create more moderate income housing in Greenwich. They follow upon the Housing Task Force proposals and the 2009 POCD. The proposals provide incentives for development in such business zone areas as appropriate while controlling density and neighborhood character. • For any development of 4 or more dwelling units in the R-6 and RMF zones, 20% of all units are required to be moderate income multi-family dwelling units. • 20% of all dwelling units in all applications under 6-110 (in all business zones) and in the R-6 and RMF multi-family zones must be deed restricted as moderate income dwelling units. • Since 20% of all residential units must be moderate income, there is no need to have two separate sections, 6-110 and 6-110g. The proposal is to create only one section, 6-110, utilizing most of the existing language with appropriate additions and deletions. • For moderate income dwelling units on lots in the CGB, CGBR, GB and GBO zones, the Commission may reduce the required lot area for each dwelling unit containing not more than one bedroom to 1200 square feet, and the Commission may reduce the additional lot area required per unit for each bedroom in excess of one to 300 square feet in the CGB, GB, and GBO zones and to 200 square feet in the CGBR zone. • On lots in the LB zone, the Commission may reduce the required lot area for each dwelling unit containing not more than one bedroom unit to 2000 square feet and may reduce the additional lot area required per unit for each bedroom in excess of one to 300 square feet. • An increase in the number of stories and an increase in the height of a building may be allowed in certain business zones. • As part of any moderate income housing pre-application process, a workshop shall be convened by the Director of Planning and Zoning that includes ZEO, DPW Engineering, Building Official, Sewer, Highway, and other appropriate agencies/persons at which meeting the developer whose plans include affordable units in the project can present and discuss a sketch plan prior to actual submission to any agency. • The maximum allowable number of dwelling units and the density bonus is increased from 50% to 60% in the LB, CGB, GB, and GBO zones and from 30% to 40% in the CGBR and LBR zones. • Moderate income dwelling units must be occupied by either the owner(s) or legal lessee(s) only. • A buy-out provision is proposed allowing a developer or qualifying owner to pay a fee in lieu of constructing no more than 50% of the required moderate income dwelling units. CDP-PC – Bullet Points for Proposed Regulation Changes for Business Zones – June 17, 2014 Community Development Partnership Planning Committee Proposed Regulation Changes for Business Zones June 17, 2014 SECTION 6-98 USE REGULATIONS FOR R-6 MULTI-FAMILY AND RMF ZONES. (a)(2) NEW (F): For any development of 4 or more dwelling units on one existing lot or merged adjoining lots, 20% of all units are required to be moderate income dwelling units. The standards of Section 6-110 shall apply to these units. SECTION 6-110 REGULATIONS AND SPECIAL REQUIREMENTS FOR MODERATE INCOME DWELLING UNITS PERMITTED IN THE BUSINESS ZONES. (a) Number of dwelling units The allowable number of dwelling units on any lot shall be computed as follows: ZONE CGBR** LBR CGB GB*, GBO* LB* REQUIRED LOT AREA FOR EACH DWELLING UNIT CONTAINING NOT MORE THAN ONE BEDROOM 1500 /1200 2000 2000/1200 2000/1200 3000 /2000 ADDITIONAL LOT AREA REQUIRED PER UNIT FOR EACH BEDROOM IN EXCESS OF ONE 400/200 400 400/300 400/300 500/300 *See Section 6-110(g) (4/4/87) • Requirements for Moderate Income Dwelling Units in all Business zones. (5/30/2014) (a) For the purpose of promoting the inclusion of below-market-rate housing units, hereafter referred to as moderate income dwelling units, within private sector residential development so as to increase the diversity of the Town’s housing stock, in accordance with the objectives of the 2009 Plan of Conservation and Development and the POCD Housing Task Force recommendations of 2011, and for the purpose of mitigating the shortage of housing units that can meet the housing needs particularly but not exclusively of those employed by the Town and by non-governmental Health, Education and Human Services Agencies and others who are classified as moderate income families households as defined in (6) (H) below, the Planning and Zoning Commission may allow modifications of these regulations, as indicated below, for new construction in the LB,CGB, CGBR GB and GBO zones and for existing buildings in all business zones where dwelling units are permitted pursuant to Sec. 6-110(a), provided the Commission makes a finding that the purposes and requirements of this section are met and the proposal complies with the standards of Sec. 6-15 and 6-17 of the Building Zone Regulations. CDP-PC Proposed Regulation Changes for Business Zones-June 17, 2014-Page 1 of 9 For the purposes of this section, an existing building shall be listed with the Tax Assessor as of January 1 2014. of January 1, 1990. (9/3/90) (b) In all applications under 6-110 it is required that a minimum of 20% of all dwelling units be deed restricted as moderate income dwelling units. The Commission may consider a fraction to be a whole number to meet the requirements that not less than 20% of all units (including bonus units) are moderate income dwelling units. (9/3/90) (c) In all zones, except for lots between a front and rear building line in the CGBR zone, the lot area used for determining the number of permitted units shall be the actual lot area reduced by the amount of floor area devoted to uses other than dwelling units. Upon application for Special Permit pursuant to Sec. 6-17 the Commission may authorize computation of permitted units based upon actual lot area reduced by one-half the floor area devoted to uses other than dwelling units provided the maximum FAR of the zone is not exceeded. (5/11/87) (d) For Moderate Cost units under section 6-110 and 6-110g moderate income dwelling units on lots having a front and rear building line in the CGBR zone, the Commission may reduce the required lot area for each dwelling unit containing not more than one bedroom to 1,000 sq. ft. and reduce the additional lot area required per unit for each bedroom in excess of one to 200 sq. ft. if the use of all floor areas above the ground floor is limited to dwelling units. (Use Group 3) (e) For moderate income dwelling units on lots in the CGB, GB and GBO zone, the Commission may reduce the required lot area for each dwelling unit containing not more than one bedroom to 1200 square feet and reduce the additional lot area required per unit for each bedroom in excess of one to 300 square feet. On lots in the LB zone, the Commission may also reduce the required lot area for each dwelling unit containing not more than one bedroom unit to 1500 square feet and reduce the additional lot area required per unit for each bedroom in excess of one to 300 sq. ft. (1) Distance Requirements. An adequate distance shall be maintained free of all obstructions from any wall containing a dwelling unit window required for light or ventilation. Where minimum side yards are required in Sec. 6-205(b), the Planning and Zoning Commission may find lesser side yards adequate for residential uses. (6/11/86) In all zones other than CGBR the minimum distance in feet between a building containing dwelling units and any other building on the same lot shall be equal to the sum of the number of stories of the two buildings multiplied by eight, unless the Commission finds a lesser distance consistent with the purposes of this sub-section (b). (6/11/86) (2) Special Requirements (a) For CGBR and LBR zones, dwelling units shall be permitted only above floors having uses of Use Groups permitted in said zones other than Use Group 3. (b) Special Permit Required. A Special Permit shall be required for any development with five or more two or more dwelling units. (9/1/84) CDP-PC Proposed Regulation Changes for Business Zones-June 17, 2014-Page 2 of 9 (c) The Commission, when it deems appropriate, may require outdoor recreation space of suitable size, shape and location to serve the recreational needs of the residents. Such areas may include balconies, roof areas designated for recreation, lawn areas, and the like. (4/19/2006) (d) For moderate income dwelling units under Section 6-110 on lots having a front and rear building line in the CGBR zone, the Commission may reduce the required lot area for each dwelling unit containing not more than one bedroom to 1000 square feet and reduce the additional lot area required per unit for each bedroom in excess of one to 200 square feet if the use of all floor areas above the ground floor is limited to dwelling units only. (Use Group 3) Notwithstanding any other provision of these regulations, floor area devoted to Use Group 3 uses, dwelling units in business zones, may not be converted to any other Use Group and may not be used for resident professional offices. unless a Special Permit and Site Plan approvals have been granted in accordance with the standards and requirements of Sec. A6-15 and A6-17 of these regulations. (8/13/90) (e) For moderate income dwelling units on lots in the CGB, GB and GBO zones, the Commission may reduce the required lot area for each dwelling unit containing not more than one bedroom to 1000 square feet and reduce the additional lot area required per unit for each bedroom in excess of one to 200 square feet provided that the use of all floor areas above the ground/first floor is limited to dwelling units only. (Use Group 3) For any and all developments in the business zones having residential uses and units, a minimum of 20% of the total permitted units must be moderate income dwelling units. as defined in section 6-110g below. (f) On lots in the LB zone, the Commission may also reduce the required lot area for each dwelling unit containing not more than one bedroom unit to 1500 square feet and reduce the additional lot area required per unit for each bedroom in excess of one to 250 square feet provided that the use of all floor areas above the ground/first floor is limited to dwelling units only. (Use Group 3) All modifications of these regulations as indicated below may be allowed for conversion of space in an existing building provided that any new floor area added to the building is necessary to meet the Town Building and Fire Code for construction of the moderate income dwelling units, and does not exceed the permitted FAR with the .75 bonus limit. (3) Procedure: The housing development proposal shall be subject to Special Permit procedures and standards pursuant to Sec. 6-17. As part of any moderate income housing pre-application process, a workshop shall be convened by the Director of Planning and Zoning that includes ZEO, DPW Engineering, Building Official, Sewer, Highway, and other appropriate agencies/persons at which meeting the developer whose plans include moderate income dwelling units in the project can present and discuss a sketch plan prior to actual submission to any agency. (4) Incentives: To provide incentives to include below-market-rate housing units for moderate income households within private-sector development in the business zones, the Commission may allow the following modifications of the Building Zone Regulations: (A) A Floor Area Bonus: An increase in Floor Area Ratio up to .75; CDP-PC Proposed Regulation Changes for Business Zones-June 17, 2014-Page 3 of 9 (B) A waiver of non-residential ground floor use, as may be required pursuant to other sections of these regulations; (C) A density bonus: an increase in the allowable number of dwelling units per lot as follows: 1) The maximum allowable number of dwelling units and the density bonus shall be determined by calculating the number of one-bedroom dwellings possible under the provisions of Sec. 6-110 (a) and increasing the resulting number of dwellings (excluding fractions) by (50%) 60% in the LB, CGB, GB and GBO zones and by (30%) 40% in the CGBR and LBR zones. for all other business zones ; for residential density calculations and required number of moderate income dwelling units in the CGBR zones, see Section 6-110 (a). The larger figure is the maximum allowable number of dwelling units; the difference is the density bonus of which 50% must be constructed and offered as moderate income dwelling units. (9/3/90) Such units shall have not less than one-bedroom and shall contain, on the average, the same number of bedrooms as the market rate units in the development, unless the Commission finds a different allocation of bedrooms per dwelling to be more responsive to current housing needs. The total number of bedrooms on site shall not exceed two (2) times the maximum allowable number of dwelling units approved for the site. 2) The requirement for subtraction of floor area devoted to uses other than dwelling units, for the purposes of computing the number of units, may be modified by the Commission. (D) An increase in the number of stories: by one (1) story only over the number of stories otherwise allowed in the underlying business zone; and (6/19/2013): 1) For the GB and the GBO, CGBR and CGB business zones only, an increase by one (1) story only over the number of stories otherwise allowed in these zones and provided the number of moderate income dwelling units is twice the number otherwise required under Section 6-110(g)(2)(C)(1) and Section 6-110(g)(3) above this Section 6-110 (4)(C)(1) above, an increase in the height of a building up to 45 feet; all as measured according to the requirements of the particular underlying business zone; and 2) for the LB and LBR business zones no increase in the number of stories but an increase in the height of a building up to 40 feet, all as measured according to the requirements of the particular underlying business zone provided it meets the required minimum of moderate income dwelling units. (E) A waiver of maximum coverage standards provided the scale of proposed structures is compatible with surrounding uses and open spaces; and provided sufficient landscaping, screening and decorative planting is provided to enhance the residential quality of the development and to screen refuse, transformer, storage and parking areas. CDP-PC Proposed Regulation Changes for Business Zones-June 17, 2014-Page 4 of 9 (F) A modification of requirements, if any, of the underlying zone that all parking spaces for the units be surface spaces on the same level as street level businesses. The Commission may allow up to one-third of the required spaces for Use Group 1 to be located in an on-site underground parking level provided that the underground spaces are designated for long-term parking by employees, and further provided that the Commission finds such location of spaces will result in an enhancement of the residential quality of the development through an increase of landscaping, screening and decorative planting. The total number of on-site parking spaces shall be determined in accordance with Division 15 of these regulations. (10/2/87) (5) Required Number of moderate income dwelling units: Any of the above modifications of the Building Zone Regulations may be permitted by the Commission subject to the following: a) The applicant/owner shall construct and maintain at least 50% of the gross floor area of buildings to be in residential use except in existing buildings as defined above (as noted in the Tax Assessor records of January 2014) where existing or new floor area is to be devoted to moderate income dwelling units. Regardless of the total number of units, applicant must guarantee 50% of the density bonus units are offered and maintained as moderate income dwelling units, in accordance with the provisions of this 6-110 section (9/3/90) b) In calculating the required number of moderate income dwelling units, taking into consideration the modifications requested under (2) above, the Commission may require a fraction to be considered a whole number in order to meet the intent of the bonus incentives. (6) Criteria and Requirements of inclusion of moderate income dwelling units: (A) General Requirements: 1) Moderate income dwelling units shall be offered for sale, resale or continuing rental to moderate income households as defined below; or to a Commission-approved Agency which may be a non-profit agency, a municipal agency, or other organization, which shall offer the dwellings to moderate income families as set forth herein. 2) Such units shall be physically integrated into the design of the development in a manner satisfactory to the Commission. 3) Parking shall be provided in accordance with the standards of Sec. 6155 for multi-family dwellings. 4) Moderate income dwelling units must be owner occupied or occupied by the legal lessee only. If there is more than one owner of a unit, both owners must occupy the unit as their primary residence. Moderate income dwelling units cannot be rented or leased out or occupied by others not legally allowed or qualified by the Town. An annual affidavit is required from the owner/renter indicating they are residing in the unit as their primary residence. This annual affidavit should be submitted to the Planning and Zoning Department or its designated agent. CDP-PC Proposed Regulation Changes for Business Zones-June 17, 2014-Page 5 of 9 (B) Buy-Out Provision: In lieu of construction of the required moderate income dwelling units as required by Section 6-98 or Section 6-110, a developer/owner may, with Town approval, pay a qualifying fee to the Town’s special fund. The amount of the per unit qualifying fee shall be equal to the average total development cost of the total proposed project units (defined as the sum of the total construction costs outlined in the project’s building permit application and the acquisition cost of the building lot). This per unit fee is then multiplied by the number of required moderate income dwelling units to be satisfied by payment of the fee. If a developer/owner chooses to select this option, such fee is payable to the Town after approval of the project by the Planning and Zoning Commission and prior to any permit issuance. This fee or buy-out provision is limited to a maximum of 50% of the required number of moderate income dwelling units. The remaining number of the required moderate income dwelling units not satisfied by payment of the fee must be constructed by the developer/owner. The buy-out provision shall not increase the number of market rate dwelling units on the project site. The Planning and Zoning Commission shall have the discretion to either round up or round down any fractions to whole unit numbers in the computation of required moderate income dwelling units under Sections 6-98 and 6-110. (C) Priority List of Eligible moderate income families households applying for moderate income dwellings shall be selected on the basis of the following categories of priority: 1) Full-time Town of Greenwich Municipal and Board of Education employees and full-time employees of not-for-profit health, education and human services agencies and other not-for-profit agencies located in the Town of Greenwich that provide essential services to the Greenwich Community. (8/13/90) 2) Other residents of the Town of Greenwich. 3) Other persons employed in the Town of Greenwich. 4) All others (D) Guidelines for maximum rent and sales price. For moderate income dwelling units in each housing development, a range of sales prices and/or monthly rentals may be established, subject to the following: 1) The average monthly rent for moderate income dwelling units excluding common charges and utilities (gas, oil and electricity), shall not exceed 2.0% of the median annual Town paid wages for all fulltime municipal employees and teachers during the preceding fiscal year. 2) The first time the units are sold, the average sales price to moderate income families households shall not exceed four times the median CDP-PC Proposed Regulation Changes for Business Zones-June 17, 2014-Page 6 of 9 annual Town paid wages of all full-time municipal employees and teachers during the preceding fiscal year. There shall be no extra upfront charge for minimum required facilities such as, but not limited to, parking and recreational facilities, at time of purchase or for one year after any condominium association has been established. Each unit owner, however, shall pay his fair share of common charges, expenses and assessments as provided in the Common Interest Ownership Act of the State of Connecticut. 3) The developer of housing provided in accordance with this section 6110 shall receive, on average, the maximum sales price and/or rent established (D)(1) and (D)(2) above for the moderate income dwelling units. (E) Resale Restrictions 1) For owner occupied for sale moderate income dwelling units, the title to said property shall be restricted so as to maintain the unit in the moderate income category over the life of the unit. Said restriction shall provide that in the event of any resale of the unit (by the original owner or any successor owner), the maximum resale price shall be limited by the same median income guidelines and rules indicated in (D)(2) above. 2) For rental moderate income dwelling units, the title to said property shall be restricted so as to maintain the units in the moderate income category over the life of the units. This title restriction will survive any sale of the rental project to a subsequent owner. There shall be no limitation on the sales price of any moderate income rental project. (F) Declaration of Restrictions The developer/owner of moderate income dwelling units shall submit to the Planning and Zoning Commission a Declaration of Restrictions as to the ownership, use and occupancy of such moderate income dwelling units. This declaration of restrictions shall be binding upon such developer and all succeeding owners of the moderate income dwelling units and shall incorporate the provisions of this section therein by reference hereto. Final site plan approval shall be given by the Commission only after it has been satisfied that the Declaration of Restrictions binds the developer and all succeeding owners of the moderate income dwelling units and duly restricts the ownership, use and occupancy thereof, and requires adherence to established sales and rental guidelines and administrative procedures, all in accordance with the provisions of this Section 6-110.. The Commission may cause any such Declaration of Restrictions to be reviewed by the Town Attorney. Each deed for the moderate income dwelling units will indicate the restrictions on those units and refer to the Declaration of Restrictions. (G) Administration 1) The Greenwich Community Development Office or other designated agent/agency approved by the Town shall maintain a list of eligible CDP-PC Proposed Regulation Changes for Business Zones-June 17, 2014-Page 7 of 9 moderate income families households in accordance with the priority list set forth in B (C) above. Where the number of those eligible in the same category of priority exceeds the number of available moderate income housing units, the applicant shall be selected by lottery. As the goal of this program is to provide the greatest benefit to the largest number of eligible people, the Town will seek, at its discretion, to match the size of an available moderate income dwelling unit to the most appropriately sized eligible family household. The selected moderate income family household must reside in the moderate income housing dwelling unit. Moderate income dwelling units must be occupied by the qualified owner(s) or legal lessee(s) only. If there is more than one qualified owner or legal lessee, each owner or legal lessee must occupy these units as their primary residence. These moderate income dwelling units cannot be rented, assigned or leased out or occupied by others not legally allowed or approved by the Town or designated agency. 2) At the time of Site Plan approval for each housing development, the Planning and Zoning Commission shall approve the designation of an administrative agency to monitor and administer guidelines for the rent, sale or resale of moderate income dwellings. Such administrative agency, which may buy the moderate income dwellings units for the purpose of rental or resale to moderate income families households, may be a non-profit corporation, an agency of the Town, a Community Housing Development Corporation pursuant to Section 8-217 of the General Statutes, a 501(c)(3) non-profit corporation such as a Community Development Partnership or other approved organization. Such agency may maintain and submit an eligibility list to the Community Development Office or other designated agent but the choice of families households for available apartments even if owned by the designated agency shall be in accordance with (6)(C) above. 3) The designated agency shall establish the sale price, resale price or annual rental of the individual dwelling in accordance with the guidelines and requirements of (6)(D) and (E) above and with the approval of the Greenwich Community Development Office or other designated organization. There will be an Affordability Plan filed on the Greenwich Land Records indicating the deed restrictions on the specific unit which the designated agency will enforce. 4) The designated agency shall set up such procedures as may be necessary to receive annual certification or other information from owners and or tenants which confirms continuing compliance with the guidelines and requirements of this section and which notifies of any conversion in the form of ownership. This information shall be submitted to the Planning and Zoning department or to the Greenwich Community Development office. CDP-PC Proposed Regulation Changes for Business Zones-June 17, 2014-Page 8 of 9 (H) Definitions 1) Moderate income dwelling units are those set aside for moderate income households whose aggregate income, (including the total of all current annual income of all members of the household, but excluding the earnings of working minors attending school full-time, from any source whatsoever at the time of certification), meets the annual median annual Town paid wages of all full-time Municipal and Board of Education employees and teachers of the Town of Greenwich during the preceding fiscal year. 2) Moderate income households families – families whose aggregate income, including the total of all current annual income of all family household members from any source whatsoever at the time of certification, (but excluding the earnings of working minors attending school full-time) averaged for the preceding two years, shall not exceed the following multiple (listed below) of median annual Town paid wages of all full-time Town of Greenwich Municipal and Board of Education employees during the preceding fiscal year. (3/2/88) In calculating household income, the value of assets must be considered. If the value of assets (not including personal property or vehicles) is $5,000 or less, then the income received from those assets should be added to the household’s annual household income. If the value of assets is greater than $5,000, the greater of the following should be added to the household's annual income: a) Actual income received from the assets or b) The actual value of the assets multiplied by the current passbook savings rate as established by HUD. 1 person family household 1.2 2-3 person family household 1.5 4-5 person family household 1.8 6 person family household 1.9 3) A household, as defined by HUD, is all the people who occupy a housing unit. A household includes the related family members and all the unrelated people, if any, such as lodgers, foster children, wards, or employees who share the housing unit. A person living alone in a housing unit, or a group of unrelated people sharing a housing unit such as partners or roomers, is also counted as a household. CDP-PC Proposed Regulation Changes for Business Zones-June 17, 2014-Page 9 of 9 Community Development Partnership Planning Committee Existing and Proposed Bonus Chart June 17, 2014 10,000 SQUARE FOOT LOT Existing bonus % CGB 50% CGBR 30% LB 50% LBR 30% GB 50% GBO 50% #total units/moderate income units 5+2.5 aff.= 8 units total; 20%=1.6 or 2 units 6+2 aff.= 8 units total; 20%=1.6 or 2 units 3.3+1.6 aff=5 units ; 20%=1 unit 5+1.5 aff.=7 units; 20%=1.4 units aff. 5+2.5=7.5 or 8 units; 20%=2 units aff. 5+2.5=8 units; 20%=2 units aff. PROPOSED BONUS CGB 60% CGBR 40% LB 60% LBR 40% GB 60% GBO 60% 8.3 +3.3=11.6 units or 12 units; 20%= 2.4 units 8.3+3.3=11.6units or 12 units; 20%=2.4units 5+3=8units ;3units aff. 20% 5+2=7units; 20%=1.4 units or 2 8.3+3.3=11.6units or 12 units; 20%=2.4units 8.3+3.3=11.6 or 12 units; 20%=2.4 or 3 units #units #moderate 8 8 5 7 8 8 2 2 1 2 2 2 12 12 8 7 12 12 3 3 2 2 3 3
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