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HomeMy WebLinkAboutMin 11-17-04 MINUTES OF THE UKIAH CITY COUNCIL REGULAR MEETING WEDNESDAY, NOVEMBER 17, 2004 The Ukiah City Council met at a Regular Meeting on November 17, 2004, the notice for which had been legally noticed and posted, at 6:40 p.m. Roll was taken and the following Councilmembers were present: McCowen, Rodin, Smith, Baldwin (arrived at 7:20 pm.), and Mayor Larson. Staff present: Development Permit Coordinator Ballard, Police Captain Dewey, Water Utilities Project Manager Burck, Civil Engineer Eriksen, Wastewater Treatment Plant Supervisor Gall, Risk Manager/Budget Officer Harris, City Manager Horsley, Fire Chief Latipow, Associate Planner Lohse, Finance Director McCann, Public Works Director/City Engineer Steele, City Attorney Rapport, Planning Director Stump, Police Chief Williams, Public Utilities Director Ziemianek, and City Clerk Ulvila. 2. PLEDGE OF ALLEGIANCE James Mulheren led the Pledge of Allegiance. 2b. SWEARING IN NEW COUNCILMEMBER a. Adoption of Resolution Making Appointment to the City Council to Fill an Unexpired Term of Office and Administration of Oath of Office for New Councilmember City Clerk Ulvila advised that at the November 10, 2004 Council meeting, the City Council heard presentations from six applicants for appointment to fill the Council vacancy created by Councilmember Andersen's resignation, effective October 31, 2004. After discussion by Council, a motion was passed nominating John McCowen to fill the vacancy. Another motion was passed, but later rescinded, to adopt a Resolution making the appointment to the City Council. Council directed Staff to agendize the Resolution and Oath of Office for consideration at this meeting. M/S Smith/Rodin adopting Resolution 2005-18, making the appointment of John McCowen to fill the unexpired Council term of Paul Andersen, carried by the following roll call vote: AYES: Councilmembers Rodin, Smith, and Mayor Larson. NOES: None. ABSTAIN: None. ABSENT: Councilmember Baldwin. City Clerk Ulvila administered the Oath of Office to Mr. McCowen. Mr. McCowen then took his seat at the dais. 3. APPROVAL OF MINUTES 3a. Re_clular Meeting Minutes of October 207 2004 M/S Rodin/Smith approving the Regular Meeting minutes of October 20, 2004, as presented, carried by the following roll call vote: AYES: Councilmembers Rodin, Smith, and Mayor Larson. NOES: None. ABSTAIN: Councilmember McCowen. ABSENT: Councilmember Baldwin. 3. APPROVAL OF MINUTES 3b. Re_aular Meeting Minutes of October 207 2004 M/S Smith/Rodin approving the Special Joint Meeting minutes of the City Council and the Ukiah Valley Sanitation District of October 20, 2004, as presented, carried by the Regular Ukiah City Council Meeting November 17, 2004 Page 1 of 12 following roll call vote: AYES: Councilmembers Rodin, NOES: None. ABSTAIN: Councilmember McCowen. Baldwin. Smith, and Mayor Larson. ABSENT: Councilmember 4. RIGHT TO APPEAL DECISION Mayor Larson read the appeal process. 5. CONSENT CALENDAR City Manager Horsley advised that some corrections were made to the Staff Report for item 'T' of the Consent Calendar and the corrected report was presented to Council prior to the meeting. M/S Smith/Rodin approving item "a" through "i" of the Consent Calendar as follows: a. Approved Disbursements for Month of October 2004; b. Received Annual Review of Traffic Signalization Fund for South Orchard Avenue and East Gobbi Street; c. Rejected Claim for Damages Received from Mark Nance and Referred to Joint Powers Authority, Redwood Empire Municipal Insurance Fund; d. Adopted Resolution 2005-19 Approving Memorandum of Understanding for Employee Bargaining Unit- Department Head Unit; e. Adopted Resolution 2005- 20 Approving Records Destruction; f. Approved Purchase of Infiltration and Intrusion (l&l) Video Inspection and Data Management Equipment From Cues, Inc. in the Amount of $72,000; g. Awarded Bid for Various Pole and Pad Mount Transformers in the Amount of $34,130.17 to Wesco; h. Awarded Sole Source Bid for Police Transcription Services not to Exceed $19,026 and Approved Budget Amendment; i. Adopted Resolution 2005-21 Approving Request for Assignment of City of Ukiah's Base Resource Percentage to NCPA and Assignment Administration Agreement for WAPA Base Resource Percentage and Authorization for City Manager to Execute These Documents. Motion carried by the following roll call vote: AYES: Councilmembers McCowen, Rodin, Smith, and Mayor Larson. NOES: None. ABSTAIN: None. ABSENT: Councilmember Baldwin. 6. AUDIENCE COMMENTS ON NON-AGENDA ITEMS Daniel de la Peza, Ukiah, announced that there will be a memorial on November 20th at the Elks Club for Stephanie McKinley, who passed away last month. He also suggested to Council that if a Proposition 215 marijuana provider wants to be a provider within the City limits, they must live at the location where they are providing the marijuana. He voiced his concern with armed guards protecting marijuana gardens. 9. CITY MANGER/CITY CLERK REPORTS City Manager Horsley announced that on December 15th at 4:00 p.m. a Joint Meeting of the City Council and the Ukiah Valley Sanitation District is planned in the Council Chambers. She also reported on December 1st, prior to the commencement of the Regular Ukiah City Council Meeting November 17, 2004 Page 2 of 12 Council meeting, there will be a reception welcoming the new Councilmembers and saying thank you to those who are leaving office. 7. PUBLIC HEARING 7a. Adoption of Resolution Approving the Proposed Mitigated Negative Declaration for the Wastewater Treatment Plant Improvement Project (Continued from November 37 2004) Planning Director Stump explained that at the November 3, 2004 City Council meeting, the Council conducted a public hearing and heard from the public on the matter of the proposed Mitigated Negative Declaration for the Wastewater Treatment Plant Improvement Project. There was considerable public testimony; specifically Council heard comments from an attorney representing an adjoining property owner. At the conclusion of that hearing, while the Council appeared to be comfortable with the document, the City Attorney suggested that the matter be continued to this meeting to allow him time to review the comments made by that attorney. City Attorney Rapport has completed his review and his memorandum is attached to the Agenda Summary Report. City Attorney Rapport's conclusion is that he continues to be comfortable, in light of those comments, with the City moving ahead with a Mitigated Negative Declaration for this project. City Attorney Rapport advised that in his memo he listed the various arguments made by Mr. Belzer, an attorney speaking on behalf of the Matterns, and responded to each of them separately. Councilmember Rodin requested the City Attorney respond to the second issue: "The Negative Declaration defers the development of mitigation measures in violation of CEQA." City Attorney Rapport advised that it was the most complicated issue. Mr. Belzer contends that there is some additional evaluation and additional mitigation that the proposed Mitigated Negative Declaration requires to be completed after the Council approves the Mitigated Negative Declaration. Mr. Belzer contends that it violates requirements as set forth in a case called Sundstrum v. the County of Mendocino. The City Attorney went through a detailed analysis of that case and the CEQA Guidelines which that case interprets, and in his view, this situation is very different. In the Mitigated Negative Declaration before the City Council, there aren't unknown future impacts which the Mitigations say have to be studied after the Mitigated Negative Declaration is approved, based on future studies that will be conducted by the City. There were two things going on in Sundstrum that the court found to violate the CEQA Guidelines. He reviewed the information contained in his Memo concerning this case. The court said there was a violation of the Guidelines because it involved the County doing additional evaluation of the project through an applicant supplied expert and then relying on the expert to develop mitigations after the Negative Declaration was approved. The Court said that the Guidelines require any mitigation to be proposed before the Mitigated Negative Declaration is released for public comment. The County procedure would result in those proposed mitigations completely evading public review. Regular Ukiah City Council Meeting November 17, 2004 Page 3 of 12 Richard Mattern, Ukiah, advised that their attorney, Mr. Belzer, was unable to attend this Council meeting. He asked for a two weeks continuance because Mr. Belzer did not receive the materials from Mr. Rapport until this morning and he didn't have time to adequately review them and respond. He stated that when there is a plan to build on property and there isn't a complete plan, and it is difficult to know if you are mitigating all of the problems. He did not think the City's plan was mitigated completely with regard to the impacts of the project on adjacent property owners. Jeff Ward, one of the owners of Wardway Lumber Co. located directly to the west and adjacent to the sewage treatment plant, stated that one of the challenges his company has had to deal with is the smell from the plant. Some of the employees working on the east side of the plant wear masks to take care of some of the bad smell. He recently found out that if they have a problem with the smell, they need to contact the Mendocino County Air Quality Control Board. He is, however, supportive of the project if it takes care of the smell problem. Donna Mattern, Ukiah, stated that she and her husband did not receive notices on the project. She feels it would be a help to them if they would be notified of things that are going on near their property and it would allow them to possibly take a steps on their own. Public Hearing Closed: 7:05 p.m. Councilmember McCowen inquired if there will be sewer ponds located within 100 to 200 feet of the residences on Norgaard Lane. Paul Scheidegger, consultant for the project, calculated that the ponds would be located about 1400 to 1500 feet from the Norgaard Lane residences. He pointed out the sewage facilities displayed on a large map. Councilmember McCowen inquired if Staff is aware of complaints from any of the surrounding property owners or residents regarding odors. Mr. Scheidegger responded that during the preparation of the Initial Study, they always consult with the plant manager and get debriefed on the historical performance of the plant. In this case, Jerry Gall who has been at the plant from eight to ten years and never has known an odor to be a nuisance issue. There wasn't anything conveyed to him that demonstrated that there was a significant odor issue. They also consulted with the Mendocino County Air Quality Control District (District) and received a historical perspective on odor complaints. There have not been any documented odor complaints associated with the Wastewater Treatment Plant. They did note for the record that there was one occurrence at the Brewery treatment plant that caused a complaint to be reported and started the process whereby the District investigates the source of odor. In that situation, it was not the Wastewater Treatment Plant, but the Brewery facility causing the odor. From a regulatory standpoint, the wastewater treatment plant is not considered to be a nuisance, nor a potential nuisance. Regular Ukiah City Council Meeting November 17, 2004 Page 5 of 12 Councilmember McCowen inquired if the improvements to the plant could be expected to reduce odor even with the expansion, that is, if there were an odor problem. Mr. Scheidegger responded affirmatively. He explained that there is a modest increase in flow. The current permitted flow is 2.8 MGD; the increase would go to 3.01 MGD. He advised that Brown and Caldwell Engineering consultants identified all of the design measures that would be included in the treatment plant that would provide for more efficient treatment of the flows and thereby further reduce the odor potential. Councilmember McCowen inquired if there would be a problem with having a two week delay. Mr. Scheidegger responded by discussing the 404 permitting process involved with the Army Corp of Engineers. All of that permitting work is contingent upon having a Notice of Determination issued. To the extent that delays occur, that would extend the permitting process. There are broader issues associated with the design, cost, and start of construction next summer that are important. City Attorney Rapport explained that he called Mr. Belzer shortly after the last City Council meeting and Belzer didn't get back to him until Monday. He volunteered to email Mr. Belzer his memorandum to the City Council and sent it to him at 8:00 a.m. this morning. It is his understanding from the last meeting that the public hearing portion of the meeting was closed after receiving public comment on November 3 and the continuance was to obtain his analysis of the issues raised by Mr. Belzer at the previous meeting. He was of the opinion that Council could agree to hear additional public comment at this meeting; however, he didn't think Council had a legal obligation to do so or to extend the public hearing portion of the meeting any further than tonight's meeting. Council has already extended the meeting once and has allowed additional public comments tonight, even though that was not legally required. Planning Director Stump explained that the Public Utility Staff is concerned with a delay and worried about getting through the regulatory process with the other agencies in order to make the next construction season. If the City does not make the next construction season, the project would be delayed another year and that would be very problematic, financially. Staff has indicated that the cost of materials, such as concrete, may increase. A two week delay would potentially create a hardship if it kept Staff from getting through the other regulatory processes. City Manager Horsley noted that the design phase for the water plant is at 80% and the sewer treatment project is at 100%. The contractor is ready to begin after this hearing is complete. Mr. Scheidegger advised that the project which is scheduled to begin next summer consists of everything within the existing treatment plant boundary. Future plant expansion is expected to occur within the next five to ten years. The City will be conducting an additional environmental review under CEQA at that time because the project will be subject to further design efforts. That CEQA review will then look back on this review if any conditions have changed in this project area and see if the analysis Regular Ukiah City Council Meeting November 17, 2004 Page 6 of 12 that was conducted was appropriate and accurate. If not, then additional review would be necessary and the City would need to go through the whole process again. The project that is in the plant expansion area is not part of the construction scheduled to begin next summer. City Attorney Rapport advised that he also addressed that issue in his memo because that was one of the arguments made by Mr. Belzer; that CEQA required the City to completely design the improvements in the expansion area before approving the Mitigated Negative Declaration. Mr. Mattern made that same point today. In Mr. Rapport's opinion, the case law does not support that position. If plans for the Plant Expansion Area were so uncertain that the City couldn't make any meaningful comment about it, it wouldn't have to analyze the impacts from that development at all. However, that is not the case here. The City has undertaken to evaluate the environmental impacts from the projected development within the Plant Expansion Area, even though it won't take place for 5-10 years, because that development is a necessary part of the overall design. However, the City is only required to conduct that evaluation based on the information currently available. It is his opinion that the City has satisfied its obligations under CEQA to look at what the impacts of that future expansion project are going to be, based on what the City knows right now. When it is further designed and more specific information is available, then the City will have to reevaluate that environmental review to see if there are additional impacts that need to be addressed. Councilmember Smith advised that it is his recollection that at the conclusion of the Council's last meeting, it was agreed that the City Attorney would explore Mr. Belzer's comments and it is now his opinion that the City Attorney has satisfactorily explored them and that Mr. Belzer's legal arguments do not prevent the Council from approving the Negative Declaration, nor compel the City to prepare an EIR. He opposed a delay on the project. Mayor Larson was of the opinion that the City has shown due diligence in this matter and the requirements regarding legal issues have been satisfied by the City Attorney. There will be further environmental review for the future component of the expansion of the project. M/S Rodin/Smith adopting Resolution 2005-22 approving a Mitigated Negative Declaration for the City Wastewater Treatment Plant Improvement Project, carried by the following roll call vote: AYES: Councilmembers McCowen, Rodin, Smith, Baldwin, and Mayor Larson. NOES: None. ABSTAIN: None. ABSENT: None. 7. PUBLIC HEARING 7b. Consideration and Action on Appeal Filed by Fred Bellows and Catherine Indermill of the Planning Commission's Conditional Approval of the ,.Graeber Use Permit and Variance for Project at 290 Hi.qhland Avenue Mayor Larson explained that the lack of a site visit is grounds for recusal on this matter and in polling the Councilmembers it was determined that Councilmember Smith had not visited the site. Regular Ukiah City Council Meeting November 17, 2004 Page 7 of 12 City Attorney Rapport advised that Councilmember Smith should not vote on the matter because all of the Councilmembers are basing their decision on the same evidence and if one Councilmember has not visited the site, then the information is not equally available to all of the Council. Planning Director Stump explained that Dr. Graeber has proposed a 2,500 square foot home on the parcel that is located in the lower portion of the Hillside District at 290 Highland Avenue. Due to the narrow 60-foot width of the parcel, as well as the large yard setback requirements of the Hillside Zoning District, Dr. Graeber is proposing to locate the house closer to the property lines than typically allowed on steep property. Accordingly, in addition to the required Use Permit for construction in the Hillside Zoning District, front and side yard setback variances are being sought for the project. He reviewed his Staff Report and explained the setbacks for properties with a slope over 15%. Dr. Graeber is proposing a six foot side yard setback on the north and 14 foot side yard set back on the south, and is asking for 20 feet in the front where 30 feet is required. On September 22, 2004, the Planning Commission conducted a public hearing, and after considerable public testimony and discussion, voted 4 to1 to adopt a Mitigated Negative Declaration and conditionally approved a Use Permit and Variance to allow the construction of a single family residence on the narrow vacant parcel. Mr. Bellows and Ms. Indermill, the property owners to the north, filed a timely appeal. During the Planning Commission meeting, the appellants raised a number of concerns about the project. Those issues included drainage, soils investigation, invasion of privacy, and a belief that the parcel could not be developed. Mr. Stump discussed the Planning Commission's findings on issues related to the project, which are addressed in the Staff Report. He recommended the City Council agree with the Planning Commission's decision and deny the appeal. Public Hearing Opened: 7:29 p.m. Fred Bellows, 280 South Highland Avenue, explained that he and his wife made a written response to the Negative Declaration for the Major Use Permit last year and noted that the Hillside Zoning Ordinance was not mentioned in the document. He discussed his concerns with the 19% grade of the parcel, the proposed setbacks for the project compared to the setbacks for his property and other properties in the neighborhood, drainage, soils investigation, invasion of their privacy as an adjacent property owner, and with soils engineering and the hydrology report. He requested the City Council overturn the Planning Commission's ruling on the variance and Use Permit because it doesn't comply with the Hillside Zoning regulations, the project is too large for the lot, and the setback requirements are not acceptable. Upon questioning by Councilmember McCowen, Mr. Bellows stated that he objects to the entire project, not just the 20 foot front setback. Dr. Fred Graeber, 3600 Orr Springs Road, Ukiah, provided a history of how this project began and noted that he worked with an architect, who in turn worked with the City's Planning Department in order to satisfy the Hillside Ordinance setback requirements. He inquired as to why Mr. Bellows obtained first right of refusal on the property. Upon questioning by members of the City Council, Mr. Graeber explained that they originally wanted to have a guest house on the property and didn't look at options for situating Regular Ukiah City Council Meeting November 17, 2004 Page 8 of 12 their home differently on the property. He discussed situating the house closer to the street instead of up on the hill, noting that the adjacent property owner has an easement in the rear of the property. With regard to the shed located on both parcels, as notated on the site map, he explained that the shed has been demolished. He went on to discuss the terrain of the property and Council's inquiry of situating the home at another location on the property. Planning Director Stump referred to attachment #2-2 in the Staff Report that provides an aerial view of the parcel and adjacent parcels, and noted that Staff recommends shifting the location of the house so as to have 10 feet on both sides. He went on to discuss the removal of the shed subsequent to the photos being taken. Dr. Graebber explained that their plan is to build a home for themselves and use the other home on the property as a guest house. He had not considered moving the main house to the south. Public Hearing Closed: 7:52 p.m. Considerable discussion followed between Councilmembers and Staff related to the project. Topics discussed included whether the proposed site plan for the house is too big for the lot, the proximity of the proposed home to the adjacent residence, the roof line of Mr. Bellows' home, whether the Bellows' deck would be looking down on the Graeber home, the quality of the hydrology study, and recommendations for construction of the foundation for the proposed home. It was noted by Planning Director Stump that once the building permit for the project is submitted, the City's consulting engineer will evaluate the design for any inaccuracies and will recommend certain designs to mitigate them. Associate Planner Lohse discussed the Variance previously approved for the Bellows' property. Councilmember McCowen explained that if the project were located further up the hill, it would be more of an intrusion to the Bellows'. It was his recommendation that more landscaping should be located on the east side of the project. Planning Director Stump explained that the Planning Commission adopted conditions of approval related to landscaping. The applicants submitted a site plan with considerable landscaping between their parcel and the Bellows' parcel. He noted that Council could require a landscaping plan be submitted by the applicant to the Planning Department prior to the issuance of a building permit. He went on to discuss condition #40 related to outdoor lighting. Councilmember McCowen drew attention to the existing live oak seedlings in the southern portion of the property and recommended they be protected unless the driveway is enlarged, necessitating their removal. Planning Director Stump referred to condition #32 concerning retaining trees on property. Regular Ukiah City Council Meeting November 17, 2004 Page 9 of 12 Councilmember McCowen discussed the difference between seedlings and trees and noted his concern for the northern boundary of property, and that more landscaping in that location would create more of a fire danger. In this case it may not be advisable. He is satisfied with the conditions concerning landscaping and lighting issues, noting that lighting should be shielded and downcast. Tape 2 Discussion continued with regard to the recommendation of a dark colored roof for Dr. Graeber's home so that it will not be distracting to the Bellows'. Councilmember McCowen voiced his concern with some trees to the north of the property that extend into the property to the south, and questioned the need to have an arborist perform any necessary pruning. Planning Director Stump referred to condition #33, and discussion ensued regarding whether the condition should specify that an arborist prune the trees or if an arborist can supervise the pruning of the trees. He noted that the Planning Commission had concerns with regard to pruning of the trees and their comments and directions to Staff are recorded in the minutes of their meeting. The Planning Commission recommended it be part of the conditions of approval. M/S Rodin/Baldwin supporting the Planning Commission's action and deny the appeal filed by Mr. Fred Bellows and Ms. Catherine Indermill, carried by the following roll call vote: AYES: Councilmembers McCowen, Rodin, Baldwin, and Mayor Larson. NOES: None. ABSTAIN: Councilmember Smith. ABSENT: None. 7. PUBLIC HEARING 7c. A;)~roval of Application to Demolish the Structures Over Fifty Years 01~ Located at 308/310 East Perkins Street~ Ukiah Mayor Larson explained that the lack of a site visit is grounds for recusal on this matter and in polling the Councilmembers it was determined that all Councilmembers had visited the site. Planning Director Stump discussed his Staff Report to Council. The reason for the demolition is to prepare the site for future development. He advised that the Demolition Permit Review Committee found the subject buildings to be the oldest commercial structures on East Perkins Street. Rather than recommend denial of the Demolition Permit, the Committee worked with the property owner to identify reasonable and feasible mitigation measures to off-set the impact of demolishing these historically significant structures, which he discussed in detail with Council. It was noted that the property was the former site of the old Farmers Club. Public Hearing Opened: 8:21 p.m. Grant Leschin, Project Manager for Marin Ventures, explained that they have worked in a collaborated effort to develop a plan that would be appealing to the City. He explained that his company is in the early stages of design for their new development Regular Ukiah City Council Meeting November 17, 2004 Page 10 of 12 and has been working with City Staff on a Site Development Plan. He requested Council's approval of the project. With regard to the demolition process, he advised that they would like to begin construction in the Spring of 2005. In response to inquiries by Council, Mr. Leschin advised that they have made an effort to acquire the property to the east of the proposed demolition. They are in discussions with the current tenants of the existing structure, and Marin Ventures plans to develop a commercial project at that location. Councilmember Baldwin stated that he is opposed to a drive through business at that location. Public Hearing Closed: 8:25 p.m. A brief discussion followed relative to design guidelines for commercial developments. Planning Director Stump stated that the applicants are extremely interested in working with the City to meet the design guidelines and they are aware that Perkins Street is a major gateway of the City. He further discussed transportation issues and future development, noting that Staff has discussed these matters with the applicant. M/S Baldwin/McCowen approving the Mitigated Negative Declaration, based on the finding that as mitigated, the impact of demolishing the structures located at 308/310 East Perkins Street will be reduced to a level of insignificance, carried by the following roll call vote: AYES: Councilmembers McCowen, Rodin, Smith, Baldwin, and Mayor Larson. NOES: None. ABSTAIN' None. ABSENT: None. M/S Baldwin/McCowen approving the Demolition Permit for 308/310 East Perkins Street, carried by the following roll call vote' AYES: Councilmembers McCowen, Rodin, Smith, Baldwin, and Mayor Larson. NOES: None. ABSTAIN: None. ABSENT: None. 8. COUNCIL REPORTS Councilmember McCowen reported that, thanks to the Roots of Motive Power, the railroad property on Perkins Street will undergo a cleanup. Councilmember Baldwin reported that he will not be able to attend the Inland Water and Power Commission (IWPC) meeting tomorrow at the Ukiah Conference Center. On the IWPC agenda are a report from the Army Corp of Engineers concerning increasing the height of the dam and a report from Redwood Valley Water District seeking IWPC approval of their two projects. The City Council will have to approve it. The Hop/Kiln project is beginning to go through the Mendocino County Planning Commission process. The project calls for about 500 units to be located east of the former Masonite plant site. He advised that Council should be aware of any impacts to the sewer treatment plant and Ranney collector with this project. After a brief discussion it was decided that Councilmember Rodin and City Manager Horsley would attend the IWPC meeting tomorrow on the City's behalf. Adjourned to sit as the Ukiah Redevelopment Agency: 8:35 p.m. Regular Ukiah City Council Meeting November 17, 2004 Page 11 of 12 10. CLOSED SESSION a. G.C. §54957.6- Conference with Labor Negotiator Employee Negotiations: Directors and City Manager Labor Negotiator: Candace Horsley No Closed Session required. 11. ADJOURNMENT There being no further business, the City Council meeting was adjourned at 8:35 p.m. Marie Ulvila, City Clerk Regular Ukiah City Council Meeting November 17, 2004 Page 12 of 12