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HomeMy WebLinkAbout2024-03-19 Planning Board Minutes I Tows? of North Andover �I2� 2a2`� PLANNING BOARD Eitrrrr GoNberg, Chair Gernnra Wilkens Peter I3oyntvrr Chi istopher•rf oskol es, Assoc. John Simons Serra Kevlahan i Trresda March 19 2024 c 7 .rn. 566Mrrirr St. -School Administration Building,North Andover• MA 01845 1 Present/Planning Board: E. Goldberg, J. Simons, P. Boynton, G. Wilkens, C. Koskores, Assoc. 2 Absent: S. Kevlahan 3 Staff Present: J. Enright 4 5 E. Goldberg, Chairman: The Pla►ming Board meeting for Tuesday,March 19, 2024,was called to order at 7 pan. 6 7 ,STAFF REPORT S 9 BOND RELEASE 10 350 Winthrop Avenue,Delta MB LLC: Request for release of three performance bonds:(3/19/2019)$10,000 performance 11 bond associated with site improvements to correct ADA deficiencies, (9/211998)$5,000 performance bond associated with a 12 5,619 SF addition,and(9/12/1996)$5,000 performance bond associated with an expansion. 13 J.Enright: The most recent 2019 bond was for ADA improvements; as-built plan and engineer certification letter is in your 14 packets. It was recommended applicant submit a request to release the 1996& t998 bonds.The 1998 addition was for the 5K 15 SF bump out/foyer area,which will be demolished with the Most recent permit approval;did not receive an as-built for that, 16 however it will be overridden with the new approval. It is not clear whether the 1996 bond is a Conservation bond or a 17 Planning bond. The paperwork referencing"conservation escrow" and an Order of Conditions,but it is Planning Department 18 paperwork that describes the purpose as"Market Basket Expansion"and is signed by the Town Planner.The Treasurer's 19 office confirmed accounts exist for the three bonds; current project work requires new bond. 20 MOTION: P.Boynton made a motion to release the 2019410K bond phis any associated interest,the 1998-$5K bond with 21 any associated interest,the 1996-$5K bond with any associated interest, for 350 Winthrop Ave. C. Koskores seconded the 22 motion.The vote was 4-0,unanimous in favor. 23 24 ANR PLAN 25 91 Quail Run/Lot 28 Monteiro Way_: 26 J.Enright: The original approval of Monteiro Way Definitive Subdivision included Lot 28. In 1990,an ANR plan was 27 approved which extinguished the rear lot line of Lot 28 Monteiro Way and the Lot was combined with 91 Quail Run.This 28 ANR plan proposes to re-establish that rear lot line, There is sufficient access from a public right of way,Lot area and 29 frontage.The Contiguous Buildable Area(CBA)is noted as not yet determined.They acknowledge it is to be calculated 30 exclusive of the 100 ft, wetland buffer which comes to the mid-point of the Lot.A note on the plan indicates how the Building 31 Commissioner calculates CBA and it appears that in order to build on this lot,a ZBA variance is required. 32 MOTION: J. Simons made a motion to approve the ANR and direct the Planner to sign the Plan for 91 Quail Ruiu/Lot 28 33 Monteiro Way,P. Boynton seconded the►notion. The vote was 4-0,unanimous in favor. 34 35 CONTINUED PUBLIC HEARINGS 36 189 Willow Street,Vincent J. Grasso: Continued until April 2,2024. Application for a Site Plan Review and Corridor 37 Development District I Special Permits under Article 8 Supplementary Regulations, Part 3 Site Plan Review,Article lb 38 Corridor Development District,and Article 10 Administration(195-10.7)of the North Andover Zoning Bylaw, The 39 Applicant proposes construction of a 6,777 SF single story building with 20 parking spaces, associated driveway,utilities and 40 associated improvements. The project is located within the Corridor Development District 1 (CDD1)Zoning District, 41 J. Enright: Applicant understands they are to appear at the next meeting with an update. 42 43 Annual Town MeetinI4 ZoninI4 Bylaw Amendment Articles: 44 • Article 28: MBTA Corn mu►►ities Multi-Family Housing Overlay District 45 • Article 29. MBTA Communities Multi-Family Housine Overlay District Zoning Man Amendment 46 J.Enright:No public comment has been received;Warrant is closed.Redline edits shown at the last meeting were accepted; 47 draft was submitted to the Town Manager's office. Quantum of Vote Statement and article Explanation have been added to 48 the Warrant article.The proposed Zoning Map amendment is being held as a placeholder.Town Counsel has confirmed with 1 Town of North Andover PLANNING BOARD Gennna Wilkens Eitan Goldberg, Cltair' tfinl Clrristoplrer'1vslcvres, Peter Boynton. Johrr Sinrorrs Assoc. Sean I(evlahan Tuesday March 19 2024 7 .m. 566 Main St. -SehoolAdnrinistration Brrildin)Z,North Andover• MA 0.1845 49 the AGO the language she proposed to be included in the bylaw amendment to eliminate the need for standalone map 50 amendment article is sufficient. If the Board approves of withdrawing the map amendment,withdrawal will be coordinated 51 with Town Manager's office.(Board approved the withdrawal of the zoning map amendment article). Presented results from 52 recent meeting with DHCD (HLC),where feedback was provided based on bylaws they have been reviewing.Board may 53 want to include a fall back provision for the Inclusionary Zoning portion of the draft bylaw. 54 Ian Burns,MVPC: Presented preliminary findings:North Andover's Inclusionary Zoning is economically feasible.Not much 55 room for error if Economic Office of Housing and Livable Communities(HLC)takes issue with any procedures or 56 calculations.Due to current economic conditions and analysis,developers can barely clear their return on investment.We 57 remain confident in our analysis relying on best practice for Economic Feasibility Analysis'(EFA)however unknowns 58 remain;has not seen an approved EFA from the state yet. 59 E. Goldberg: We don't have to do any of this economic feasibility for the statute, in fact you aren't required to build. 60 However, if you have Inclusionary Zoning in place,the guidelines cap it at 10%.If you want to require more affordable 61 housing as part of this exercise,then you need to demonstrate feasibility. We prefer to do this because the zoning bylaws we 62 passed has zoning at 15%; if we only consider I0%we'd be rolling back our own bylaw in this district. It doesn't make sense 63 to require it to be 15%everywhere else. It doesn't make sense to have large-scale apartment complexes not meeting our 15% 64 requirement for Inclusionary Zoning. Questioned whether the state takes into consideration that we passed Inclusionary 65 Zoning several years ago?Do you look at whether it is mixed-use or just residential? 66 I. Burns: The challenge the state was anticipating was if communities tried to put obscene affordability requirements on 67 purpose to prevent any development. You can't put extreme burdens into this bylaw to prevent development.The state will 68 allow you to get away with it if you have done an EFA as part of passing your original Inclusionary Zoning within the past 69 couple of years and if that EFA meets the requirements put forward. You're putting forward a housing best practice with 70 Inclusionary zoning. We don't include if there is mixed-use because we are not mandating mixed-use as a part of the bylaw. 71 P. Boynton: The effort may not be worth it,but it seems we have good basis to challenge the state. 72 E. Goldberg: Why wouldn't we consider mixed-use;that is what makes these projects feasible. 73 1.Burns: Key factors in calculating the EFA include interest rates,high at 7%plus,creating higher cost for financing a new 74 development. 80%AMI rents. North Andover is in the Lawrence HUD Metro area;affordable rents based on median income 75 for greater Lawrence,compared to the eastern half region(Newburyport, Salisbury, etc.)developers get less revenue out of 76 affordable units. Density cap in North Andover's bylaw—if higher densities were allowed a developer would have more 77 ability to offset the high cost of land.Threshold that triggers affordability(8 units)or above--the closest call is with 78 developments of less than 20 units.We need to show the state it's economically feasible in a range of development; a 10-unit 79 development that a developer could build vs. a 250-unit development.Larger developments make it easier to get a return on 80 your investment due to cost spread out amongst more units.The lower the threshold we go,the more challenging it becomes 81 to prove feasibility.North Andover's bylaw,with a low nut requirement,is a challenge.Also considered are construction 82 costs,costs of land,revenue the developer is making is factored in,rent,parking, and any miscellaneous costs incurred i.e., 83 property taxes,loan payments,etc. 84 E.Goldberg: Can you factor in that our Inclusionary Zoning allows for different options;you don't have to build all the units, 85 you could make a payment in lieu which may save costs increasing margins for a developer? 86 L Burns: Has not considered that yet; agreed to research this. 87 E. Goldberg: Questioned if this bylaw passes now and the state says you cannot do the 15%,or we pass it at 10%,could we in 88 3 years,providing economic conditions change,amend the bylaw to 15%. 89 I. Burns: Yes. 90 P. Boynton: Stated we have a basis to challenge it. 91 E. Goldberg: We really want this to pass so that we don't lose out on grant funding and want to be in compliance with the law. 92 We may be able to leave it at 15%,if not approved it reverts to 10%in the bylaw.Then we still have a functioning legal 93 bylaw. I believe we can amend it;wants to be in compliance. 94 J.Enright: If you don't have that insurance and it passed at Town Meeting with the 15%requirement the entire bylaw gets 95 submitted to the state again along with this EFA. If they say no,the EFA doesn't meet the requirements you have we'd still 2 f North oTolv nAndover nrlo v PLANNING BOARD Eitan Goldberg, Chair Gerttrtta Wilkens E ¢ tier C her I�oskores, Peter Boynton 5 ''. ! ,Tolttt Sitrtotis Assoc. Sean Kevlahart Trresday March 19, 2024 rr,_7'P.m., 566Main St -School Administration Brrildir1g,North Andover, MA 01845 96 have a bylaw at 15%,tine requirement would still be 15%in this district,but the bylaw would no longer be compliant with 97 MBTA Communities, 98 E. Goldberg: Challenging that finding may take l-3 years in court;prefers to comply while we do that. 99 P.Boynton: If that becomes a multi-year process,how can the town be held liable to lose grants if the state tells its after town 100 meeting? 101 E. Goldberg:Agreed;but we would technically not be compliant. 1 would be in favor of adding a clause to our proposed 102 bylaw that our affordability requirements are 15%but they would move back to 10%if the state does not approve the EFA. 103 Believes cleanest way to stay in compliance would be to amend to reflect the 10%. 104 J. Enriglit: During this webinar,they recommended to have an insurance policy.We just won't know until after Town 105 Meeting if they approve of the EFA. The recent approval for the building on Main Street required 3 affordable units and they 106 have their financing and are ready to move forward. It was feasible for them to construct 3 affordable units on 24 total units. 107 I.Burns: We will reference that in the EFA narrative;it is great to have a permitted, approved development to reference. 108 P. Boynton: Disagrees with including the 10%fall back clause; it seems bureaucratic and defeats the state's purpose. 109 J. Simons: Commented it is not the kind of thing you would include in a zoning bylaw, 110 E.Goldberg: Inquired as to timeline of submission. 111 1.Burns: If submitted right after Town Meeting,the state's determination may be received earlier than if submitted toward the 112 end of the year.Does not know the exact timeline,but the state has been giving signals as they know towns may want a 113 determination so they may have a second chance at Town Meeting in the year,if anything goes wrong,Deadline for 114 compliance is the end of the calendar year. If submitted by 12/31/24,the town is technically in compliance until the state has 115 reviewed and provided a determination. 116 E. Goldberg: From a zoning perspective,it seems we should keep it at 15%;we've done everything right to develop 117 Inclusionary Zoning and for this bylaw. Prefers to hear from the Town Manager,Town Counsel, Select Board prior to a 118 decision by this Board. 119 Andrew Shapiro,Asst. Town Mgr. & Director Community&Economic Development: Recognizes the imperfections of this 120 mandate and the approach that all communities in this state have to address;agrees it's an imperfect process.The approach 121 the town is taking is of compliance. With that in mind, it's not inappropriate to include in the clause that we would back down 122 to the 10%ensuring compliance. Does not know that the mixed-use piece is what makes things economically feasible for 123 people,housing is really the piece. Most developers prefer entirely multi-family vs.retail mixed-use first floor with housing 124 above.Agrees with the initial approach to have 15%.We'd like to preserve the 15%and if the state feels it is not possible sees 125 there is nothing wrong with stepping back to 10%for a temporary period of time;we can fight that while being in compliance. 126 G. Wilkins: Inquired how density affected the margins; in lieu payment may be useful. 127 1. Burns: When we started putting more units on less land,the margins increase favorably.Our approach was to abide by 128 North Andover's bylaw which is 15 units per acre. Other communities had higher densities which results in more profit for 129 the developer. Will look into payment in lieu. 130 E. Goldberg: Can we ask the agency reviewing this,the AG's Office, our State Reps,as to what type of a risk we are putting 131 ourselves at if we don't put in a clause to go fro€n tile 15%to 10%?We need to consider the risk. 132 I.Burns: Tine state will be releasing approved EFA's shortly. We have asked to see examples to see how we align with their 133 standard. 134 J.Enright:The Board should be prepared to make recommendations at the April 2,2024 Planning Board meeting.The 135 warrant prints on April 13,2024. 136 [Continued to the April 2,2024 Planning Board meeting] 137 (Peter Boynton recused himself from tine meeting rr 7:42 p.m.) 138 Citizen Petition Warrant Article,James Worden: 139 • Article 25: Historic Bat-it Overlay District 140 • Article 26: Historic Barn Overlay District Zoning Man Amendment 141 J.Enright: Town Manager's office advised tile this has to ren-tain a Citizen Petition;any amendments may be made by the 142 Board via your recommendation motion. We also talked about combining the map amendment with this article as was done in 143 the MBTA Multi-Family Overlay District bylaw. Displayed a proposed amendment that would incorporate the map 3 Town of North Andover PLANNING BOARD Genuna Wilkens Eitarr Goldberg, Chair . , • Christopher•I�oslrares, Peter Boynton • Johrr Simons Assoc. Sean Kevlahan Tuesday March 19, 2024(a), 7 p.m., 566 Main St. -School Administration Bu_ildin�,North Andover,MA 0.1845 144 amendment within the bylaw. If in the end the Board wants to make a favorable recommendation it would be with the 145 proposed amendment and at motion time,the motion would state"as shown on the screen". 146 J.Worden: Does that mean the Planning Board might never take this tip? 147 1?. Goldberg: Based on the tuning and when the Warrant closed,we cannot because it is already submitted as a Citizen 148 Petition article.What will happen is it goes to the Planning Board for recommendation,you'll go to the Select Board who will 149 make their recommendation,then to Town Meeting and presented as a Citizen Petition Article.We'll speak to the Town 150 Moderator,let him know the Board has reviewed it and we are willing to explain it. We will let everyone know we are 151 familiar with it and worked closely with the applicant on it and fully support it. 152 J.Enright: As the applicant you will need to email the Town Manager to withdraw the map amendment article.Board will 153 need to vote on recommendations at the next meeting. 154 (No public present for comment) 155 [Continued to the April 2,2024 Planning Board meeting] 156 (Peter Boynton rejoined the meeting @ 7:45 pmmi) 157 158 DISCUSSION ITEMS 159 P1a11ni1s Board Report: 160 • Article 23: Street Acceptance Rea Street 161 • Article 24: Street Acceptance Woodlea_Villae 162 J.Enright: In addition to the zoning bylaw amendment articles in the Planning Board Report you have the typical,non-zoning 163 articles 3 accept easements,4 grant easements, 10 CPC,23 street acceptance--Rea St. and 24 street acceptance—Woodlea 164 Road. 165 Article 3: 166 MOTION: J. Simons made a motion to recommend favorable action on Article 3, authorization for the Select Board to accept 167 grants of easements.P.Boynton seconded the motion.The vote was 4-0,unanimous in favor. 168 Article 4: 169 MOTION:J. Simons made a motion to recommend favorable action on Article 4, authorization for the Select Board to grant 170 easements. P.Boynton seconded the motion.The vote was 4-0,unanimous in favor. 171 J. Simons: Gave a brief explanation of CPC report exclusions;will provide presentation April 2,2024, several items are 172 changing. 173 P.Boynton:Provided background on 44: Lake Boat Ramp project which is the Old North Pump Station by Butcher Boy. 174 Joined the Board for all monthly project meetings,area is a mess, safety issues with stone wall falling down,old boat ramp is 175 falling apart making it a hazard to hand carry. Initially,proceeded with hand carry only to avoid making the lake accessible to 176 trailers with gas engines.NAFD requires ramp to be trailer capable for fire rescue put-poses,which is supported. Cautioned 177 that unintended use of the ramp for non-NAFD trailers must be prevented or there will be gas boats on the lake.Enforcement 178 will cost money.A bollard system is being designed with a locking bollard that only NAFD will have key access to. If that 179 system fails and it is unlocked,there will be gas engine boats on the lake. 180 Article 10: 181 Continued until the April 2,2024 meeting. 182 Article 23: Street Acceptance,Rea Street: This subdivision was approved in November 2018.Unfortunately,when the lots 183 were conveyed the developer did not hold the fee interest in the roadway.Each of the 7 homeowners and the developer have 184 signed street dedication deeds,which will be recorded after acceptance.All street acceptance requirements are in order;Town 185 Counsel,DPW,Conservation, Health have provided favorable recommendations. 186 MOTION: P.Boynton made a motion to recommend favorable action on street acceptance of Rea Street. J. Simons seconded 187 the motion.The vote was 4-0,unanimous in favor. 188 189 Article 24: Street Acceptance,Woodlea Road:This subdivision was approved in January 1996,permitted as a Planned 190 Residential Development.There is a Conservation Restriction(CR)requirement for the Open Space parcel.The Open Space 191 parcel is owned by the Woodlea Village Homeowners Trust.The subdivision was brought forward for street acceptance in 4 Town of North Andover PLANNING BOARD Gennna Wilkens Eitan Goldberg, Chair Peter Boynton �6 Christopher Ifoskores, John Simons Assoc. Sean Kevlahan Tuesday March 19, 2024 rr, 7 P.m., 566 Main St. -School Administration Building, North Andover, MA 01845 192 2014 by the developer's attorney and the Planning Board motioned favorable action contingent on receiving the CR. The 193 article was subsequently withdrawn because the CR was not received. On March 6,2024 the Executive Office of Energy and 194 Environmental Affairs acknowledged receipt of the draft CR; it has not yet been approved. Favorable recommendations were 195 received from Conservation,Health,Town Counsel(contingent on CR)and DPW(Contingent on CR). 196 Kate Bargnesi,Ayy. Smolak&Vaughan: We have been following up with the state,the CR is in queue for review,hopeful 197 they will turn around a draft prior to Town Meeting so that we may submit it to Town Counsel for review and approval.We 198 are seeking your favorable recommendation subject to the receipt of the CR at this point. It is our intent to motion on the floor 199 at Town Meeting to amend the warrant article. 200 J.Enright: There's placeholders on the April 8,2024 Select Board agenda for a public hearing for each of these petitions. 201 MOTION: J. Simons made a motion to recommend favorable action, on Street Acceptance of Woodlea Road,contingent on 202 the CR being received and reviewed by Town Counsel,P. Boynton seconded the motion.The vote was 4-0,unanimous in 203 favor. 204 205 MEETING MINUTES: Approval of March 12,2024 meeting minutes. 206 MOTION: P. Boynton made a motion to accept the minutes for March 12,2024. G. Wilkins seconded the motion. The vote 207 was 4-0,unanimous in favor. 208 209 ADJOURNMENT 210 MOTION: P. Boynton made a motion to adjourn the meeting. The motion was seconded by J. Simons.The vote was 4-0, 211 unanimous in favor.Meeting adjourned @ 8:00 p.m. 212 213 MEETING MATERIALS: Planning Board Meeting Agenda March 19,2024,DRAFT Planning Board Meeting Minutes March 214 12,2024; Staff t: 240319 Staff Report;350 Winthrop Avenue,Delta MAB,LLC: 1996 Bond Paperwork: 960912 215 $5K Perf.Bond, 1998 Bond Paperwork: 980922$5K Perf.Bond,2019 Bond Funds:As-Built& Cert.Letter:2024-03-05— 216 Dwg AB-I —As-Built ADA Accessibility Improvement Plan,2024-03-05--Dwg AB-2--As-Built ADA Accessibility 217 Improvement Plan,2024-03-05—Dwg AB-3--As-Built ADA Accessibility Improvement Plan,2024-03-05—Letter to Jean 218 Enright—Request for ADA As-Built Approval,20190321 Time Stamped Decision 350 Winthrop;91 Quail Ran-Lot 28 219 Monteiro Way, Ryan &Mandy Schruender: 1990 ANR Plan,ANR Application,ANR Monteiro Way ANR, Monteiro Way 220 deed, Monteiro Way definitive subdivision plan, Monteiro Way G1S map,Schruender Nominee Trust Deed; 189 Willow 221 Street,Vincent Grasso: Continuance Request: Con't Req to April 2nd;Annual Town Meeting Zoning Bylaw Amendment 222 Articles: Article 28: MBTA Communities Multi-Family Housing Overlay District: Quantum of Vote: MGL c.40A, s.5 223 quantum of vote legal opinion,240319 Clean MBTA Draft Multi-Family Housing OD;Article 29: MBTA Communities 224 Multi-Family Housing Overlay District„Zoning Man Amendmeat:MBTA Multi-Family Housing OD Map Amendment; 225 Article 25: Historic Barn Overlay District:240222 Copy of Citizen Petition HBOD,240313 PB Redline Historic Barn 226 Overlay District Bylaw;Historic Barn Overlay District Zoning May Amendment: 240222 Copy of Citizen Petition Map 227 Amendment;Planning Board Report: 240319 Planning Board Report;Article 23: Street Acceptance Rea Street: Deeds: 228 Deed 367Rea,Deed 385 rea st,Deed 399Rea,Deed_415Rea,Deed_431Rea,Deed_445Rea,Deed_465Rea,Parcel A and B 229 Deed to Town,Final As Built& Street Layout Plan:2022-03-31 Rea Street Stamped As Built Plan,2024-01-25 STREET 230 ACCEPTANCE PLAN, Form K: Form K--Cert. of Completion,Legals:REA ST HOA 231 AMENDMENT03835320200731083219,Recorded Declaration of trust and Homeowners association,Recorded Drainage 232 and Access Easement,Recorded Form M,Form 1,Lot Certifications:2020-03-15 Lot 5 Certification Letter to NA Planning 233 Board,2020-04-22 Lot 2 Certification Letter to NA Planning Board,2020-07-24 Lot i Certification Letter to NA Planning 234 Board,2020-07-24 Lot 6 Certification Letter to NA Planning Board,2020-08-27 Lot 3 Certification Letter to NA Planning 235 Board,2020-09-27 Lot 4 Certification Letter to NA Planning Board,2021-06-23 Lot 7 Certification Letter,Recommendation 236 Letters:240307 Health Director,240314 Conservation Letter,DPW Rea Street Subdivision Acceptance Letter—3-8-2024, 237 Recorded Plan& Decision:20181113 Recorded Decision-- 0 Rea,Recorded Plan Set- 1-7-19, Street Deeds: Executed—7 238 homes&Developer,Citizen Petition—Rea Street; Article 24: Street Acceptance Woodlea Road: 2024 Street Acceptance 239 Does: As-Built Plan: 130405 As-Built Plan,Conservation Commission Cert.of Compliance:2012 Cert. of Compliance, 5 i Town of North Andover PLANNING BOARD Eitarr Goldberg, Chair �n f Ger nna Wilkens Peter Boynton5� w6 Christopher Ifoskores, Assoc, John Simons Sears Ifevlahau Tuesday March 19 2024 7 P.m., 566Main St. -SchoolAdmirristratiorr Building,North Andover,MA 01845 240 Conservation Restriction:Acknowledgment Receipt of CR 17384,Decisions: 960115 Definitive Subdivision Decision, 241 960619 PIanned Residential Dev. Special Permit,Definitive Subdivision Plan,Deeds: Quitclaim Deed--Dedication of 242 Roadway,Quitclaim Deed--Tancreti as Trustee, Quitclaim Deed—Tancreti to Homeowners Trust,Woodlea-Andover Trust 243 Trustee's Cert.,Easements.Electric Co.Easement,Form M—Conveyance of Easements and Utilities,NE Telephone 244 Easement,Forni K---Cert,of Completion: Form K,Homeowners Trust:Attorney's Certificate, Cert. of Election& 245 Acceptance of Successor Trustee, Woodlea Homeowners Trust Trustee Cert., Woodlea Village Homeowners Trust, 246 Recommendation Letters:240314 Conservation Letter,DPW Woodlea Road Acceptance Letter 3-13-2024,Health Rea Letter 247 3.7.2024, Select Board Hearin:240215 Abutters List,Cert. of Notice to Abutters&Mortgagees, SB Heaving Request,Stone 248 Bound Cert.:230304 Stone bound Cert., Street Layout Plan: 120730 Street Layout Plan,240215 Final Punchlist Request, 249 Citizen Petition—Street Acceptance Woodlea. 250 6