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HomeMy WebLinkAboutSHX2019-00020 - SHX Inspections - 8/8/2019 Mason County Planning Division of Community Development 1*'a 615 W.Alder St. Bldg. 8 Shelton,WA 98584 360-427-9670 ext 352 www.co.mason.wa.us F 9-00020 SHORELINE EXEMPTION ESCRIPTION: APPROXIMATELY THIRTY CUBIC YARDS ISSUED: 08/08/2019 WILL BE REMOVED FROM THE ALDERBROOK CREEKULVERT AND THE CREEKS POOLS OFF BOTH ENDS OF EXPIRES: 08/02/2020 RT TO IMPROVE ISH, ASSAGE AND PREVENT CP1614i;gneCr/��olr�ESS: 10 E ALDERBROOK DR UNION PARCEL: 322335000014 APPLICANT: NORTH FORTY LODGING OWNER: NORTH FORTY LODGING P O BOX 609 P O BOX 609 UNION,WA 98592 UNION,WA 98592 1.360.898.2252 FEES: Paid Due PLA-SHORELINE EXEMPTION $800.00 OTHER Totals : $800.00 1 hereby certify that I have read and examined this application and know the same to be true and correct. All provisions of Laws and Ordinances governing this type of work will be complied with whether specified herein or not. The granting of a permit does not presume to give authority to violate or cancel the provisions of any other state�/local law regulating consttnicction or the performance of construction. Issued By: C , Contractor or Authorized Agent: Date: Printed by:Ron Buckholt on:08/08/2019 03:02 PM Page 1 of 1 ------------------------------------- AREGEWED MDate received: US Army Corps p WASHINGTON STATE Sof eatt©Ds"mt ��� 2��J Joint Aquatic Resources Permit Agency refer#; IIQS1r_ Application (JARPA) Form1,2 Tax Parcel#(s): USE BLACK OR BLUE INK TO ENTER ANSWERS IN THE WHITE SPACES BELOW. i ` 2 325 —,5o — oo i i cX C1 •------------------------------------- Part 1—Project Identification 1. Project Name (A name for your project that you create. Examples: Smith's Dock or Seabrook Lane Development) hel Alderbrook Lodge Hwy 106 Culvert Gravel Removal Project Part 2—Applicant The person and/or organization responsible for the project. h[ eM 2a. Name (Last, First, Middle) McGinnis, Brian 2b. Organization(If applicable) North Forty Lodging, LLC 2c. Mailing Address (Street or PO Box) 22526 SE 64t" Place, Suite 210 2d. City, State, Zip Issaquah, WA 98027 2e. Phone(1) 2f. Phone(2) 2 Fax 2h. E-mail (425) 890-5005 ( ) ( ) Additional forms may be required for the following permits: • If your project may qualify for Department of the Army authorization through a Regional General Permit(RGP),contact the U.S.Army Corps of Engineers for application information(206)764-3495. • If your project might affect species listed under the Endangered Species Act,you will need to fill out a Specific Project Information Form(SPIF)or prepare a Biological Evaluation. Forms can be found at http://www.nws.usace.army.mil/Missions/CivilWorks/Regulatory/PermitGuidebook/EndangeredSpecies.aspx. • Not all cities and counties accept the JARPA for their local Shoreline permits. If you need a Shoreline permit,contact the appropriate city or county government to make sure they accept the JARPA. 2To access an online JARPA form with[help]screens,go to http://www.epermitting.wa.goy/site/alias resourcecenteriiarpa iarpa form/9984/iarpa fcrm.aspx. For other help,contact the Governor's Office of Regulatory Assistance at 1-800-917-0043 or help(o7ora.wa.gov. JARPA Revision 2012.1 Page 1 of 14 Part 3—Authorized Agent or Contact Person authorized to represent the applicant about the project. (Note: Authorized agent(s) must sign 11 b of this application.) h[ elpj 3a. Name (Last, First, Middle) Schaumburg, Kimberly 3b. Organization (If applicable) BioResources, LLC. 3c. Mailing Address (Street or Po Box) 10112 Bayview Rd KPN 3d. City, State, Zip Vaughn, WA 98394 3e. Phone(1) 3f. Phone(2) 3 . Fax 3h. E-mail (253) 884-5776 (253) 225-2973 Part 4—Property Owner(s) Contact information for people or organizations owning the property(ies) where the project will occur. Consider both upland and aquatic ownership because the upland owners may not own the adjacent aquatic land. hf eM x❑ Same as applicant. (Skip to Part 5.) ❑ Repair or maintenance activities on existing rights-of-way or easements. (Skip to Part 5.) ❑ There are multiple upland property owners. Complete the section below and fill out JARPA Attachment A for each additional property owner. ❑ Your project is on Department of Natural Resources (DNR)-managed aquatic lands. If you don't know, contact the DNR at (360) 902-1100 to determine aquatic land ownership. If yes, complete JARPA Attachment E to apply for the Aquatic Use Authorization. 4a. Name (Last, First, Middle) 4b. Organization (if applicable) 4c. Mailing Address (Street or Po Box) 4d. City, State, Zip 4e. Phone(1) _ 4f. Phone(2) 49. Fax 4h. E-mail JARPA Revision 2012.1 Page 2 of 14 t Part 5—Project Location(s) Identifying information about the property or properties where the project will occur. [heel ❑ There are multiple project locations (e.g. linear projects). Complete the section below and use JARPA Attachment B for each additional project location. 5a. Indicate the type of ownership of the property. (Check all that apply.) [hpjpj x❑ Private ❑ Federal ❑ Publicly owned (state,county, city, special districts like schools, ports, etc.) ❑ Tribal ❑ Department of Natural Resources (DNR) — managed aquatic lands (Complete JARPA Attachment E) 5b. Street Address (Cannot be a PO Box. if there is no address,provide other location information in 5p.) Alderbrook Resort & Spa 7101 East Hwy 106 5c. City, State, Zip (If the project is not in a city or town, provide the name of the nearest city or town.) hel Union, WA 98592 5d. County hLeM Mason 5e. Provide the section, township, and range for the project location. he[�]l 1/4 Section Section Township Range 33 22N 03W [5f. Provide the latitude and longitude of the project location. hel r • Example:47.03922 N lat.1-122.89142 W long. (Use decimal degrees- NAD 83) 47.34812 N -123.06876 W 5g. List the tax parcel number(s) for the project location. [held] • The local county assessor's office can provide this information. 32233-50-00014 5h. Contact information for all adjoining property owners. (If you need more space, use JARPA Attachment C.) heI 1 Name Mailing Address Tax Parcel #(if known) Larry A. Power, Patrick 3430 Pacific Ave SE, Olympia, WA Wheat, & M. Wheat 98501 Larry Power 8934 Buttonwood Lane NE, Olympia WA 98516 Jeffery & Patricia Raikes 3355 E. Laurelhurst Dr. NE, Seattle WA 98105 lBrian McGinnis/North Forty 10 East Alderbrook Drive, Union WA Lodging 98592 JARPA Revision 2012.1 Page 3 of 14 Alderbrook Country Club Inc. East 7090 Hwy 106, Union WA 98592 Allan & Janice Undem/Golf 10950 North La Canada, Gig Harbor WA Villas 98335-5912 Allan & Janice 10 East Alderbrook Drive, Union WA Undem/Cottage #1 98592 ...........__ .................................................................... ...... Barbra Bordeaux 2300 River Rd Unit 11, Yakima WA 98902-1293 L - - 5i. List all wetlands on or adjacent to the project location. hei 5j. List all waterbodies (other than wetlands) on or adjacent to the project location. hei Alderbrook Creek and Hood Canal. 5k. Is any part of the project area within a 100-year floodplain? Lheiip1 I x❑ Yes ❑ No ❑ Don't know 61. Briefly describe the vegetation and habitat conditions on the property, hei Site is moderately to heavily vegetated with native vegetation. 5m. Describe how the property is currently used. hei The property is a commercial lodge, restaurant, and spa. 5n. Describe how the adjacent properties are currently used. hI eM Residential/recreational. 5o. Describe the structures (above and below ground) on the property, including their purpose(s) and current condition. hei JARPA Revision 2012.1 Page 4 of 14 The Alderbrook Lodge and Spa has numerous buildings for lodging, plus the main lodge where there is a restaurant, etc. 5p. Provide driving directions from the closest highway to the project location, and attach a map. hei The site is located off Hwy 106, south of Union on the south shore of the Hood Canal. Part 6—Project Description 6a. Briefly summarize the overall project. You can provide more detail in 6b. hei Approximately thirty (30) cubic yards of gravel will be removed from the Alderbrook Creek/Hwy 106 culvert and the creek's pools off both ends of the culvert to improve fish passage and prevent flooding. 6b. Describe the purpose of the project and why you want or need to perform it. LhpM The Alderbrook Creek culvert will be dredged of alluvial sediments to alleviate flooding and facilitate channel clearance for fish passage. The culvert was improperly installed and lacks the energy to flush itself of sediments. It becomes extremely dangerous if it doesn't flow properly during high precipitation events. 6c. Indicate the project category. (check all that apply) h( elpl x❑ Commercial ❑ Residential ❑ Institutional ❑ Transportation ❑ Recreational ❑ Maintenance ❑ Environmental Enhancement I 6d. Indicate the major elements of your project. (check all that apply) [help] ❑ Aquaculture ❑ Culvert ❑ Float ❑ Retaining Wall ❑ El Dam /Weir (upland) Bank Stabilization ❑ Floating Home ❑ Boat House ❑ Dike / Levee /Jetty ❑ Geotechnical Survey ❑ Road ❑ Boat Launch ❑ Ditch ❑ Land Clearing ❑ Scientific Measurement Device ❑ Boat Lift ❑ Dock/ Pier ❑ Marina / Moorage ❑ Stairs ❑ Bridge x❑ Dredging ❑ Mining ❑ Stormwater facility ❑ Bulkhead ❑ Fence ❑ Outfall Structure ❑ Swimming Pool ❑ Buoy ❑ Ferry Terminal ❑ Piling/Dolphin ❑ Utility Line ❑ Channel Modification ❑ Fishway ❑ Raft ❑ Other: JARPA Revision 2012.1 Page 5 of 14 �6e. Describe how you plan to construct each project element checked in 6d. Include specific construction methods and equipment to be used. hel • Identify where each element will occur in relation to the nearest waterbody. • Indicate which activities are within the 100-year floodplain. As per the Mason County Shoreline Code, the Alderbrook Creek/Hwy 106 culvert and the creek's pools off both ends of the culvert will be dredged of alluvial sediments to alleviate flooding and facilitate channel clearance for fish passage. Approx. 30 cu/yds of alluvial sediments will be removed and stored (off-site) for use in future stream or beach restoration projects. Work will be done during dry weather in August, before fall chum or coho salmon return to spawn. Work will be done from the roadside or streamside, using a track excavator and/or a vacuum pump truck. The stream will be dewatered by diverting flow thru the existing SR Hwy 106 culvert, using a pump and portable culvert. The stream will be screened above the pump inlet to prevent the intake of fish. All activities are within the 100-year flood plain. The nearest waterbody is Alderbrook Creek. 6f. What are the anticipated start and end dates for project construction? (Month/Year) hf elpl • If the project will be constructed in phases or stages, use JARPA Attachment D to list the start and end dates of each phase or stage. Start date: unknown End date: approx. 2 days, after issuance of all required permits. ❑ See JARPA Attachment D 6g. Fair market value of the project, including materials, labor, machine rentals, etc. hel Unknown. 6h. Will any portion of the project receive federal funding? h`eM • If yes, list each agency providing funds. ❑ Yes x❑ No ❑ Don't know Part 7—Wetlands: Impacts and Mitigation ❑ Check here if there are wetlands or wetland buffers on or adjacent to the project area. (If there are none, skip to Part 8.) Lhel 7a. Describe how the project has been designed to avoid and minimize adverse impacts to wetlands. x❑ Not applicable 7b. Will the project impact wetlands? hel ❑ Yes ❑ No ❑ Don't know 7c. Will the project impact wetland buffers? hei ❑ Yes ❑ No ❑ Don't know JARPA Revision 2012.1 Page 6 of 14 7d. Has a wetland delineation report been prepared? Lelp] i • If Yes, submit the report, including data sheets,with the JARPA package. J ❑ Yes ❑ No 7e. Have the wetlands been rated using the Western Washington or Eastern Washington Wetland Rating System? [heV • If Yes, submit the wetland rating forms and figures with the JARPA package. ❑ Yes ❑ No ❑ Don't know 7f. Have you prepared a mitigation plan to compensate for any adverse impacts to wetlands? [help] • If Yes, submit the plan with the JARPA package and answer 7g. I • If No, or Not applicable, explain below why a mitigation plan should not be required. ❑ Yes ❑ No ❑ Not applicable 7g. Summarize what the mitigation plan is meant to accomplish, and describe how a watershed approach was used to design the plan. [Lem 7h. Use the table below to list the type and rating of each wetland impacted, the extent and duration of the impact, and the type and amount of mitigation proposed. Or if you are submitting a mitigation plan with a similar table, you can state (below) where we can find this information in the plan, h[ eM Activity (fill, Wetland Wetland Impact Duration Proposed Wetland drain, excavate, Name' type and area (sq. of impact3 mitigation mitigation area flood, etc.) rating ft. or type (sq. ft. or category2 Acres) acres) If no official name for the wetland exists,create a unique name(such as"Wetland 1"). The name should be consistent with other project documents,such as a wetland delineation report. 2 Ecology wetland category based on current Western Washington or Eastern Washington Wetland Rating System. Provide the wetland rating forms with the JARPA package. 3Indicate the days,months or years the wetland will be measurably impacted by the activity. Enter"permanent'if applicable. °Creation(C), Re-establishment/Rehabilitation(R), Enhancement(E), Preservation(P), Mitigation Bank/In-lieu fee(B) Page number(s) for similar information in the mitigation plan, if available: 7i. For all filling activities identified in 7h, describe the source and nature of the fill material, the amount in cubic yards that will be used, and how and where it will be placed into the wetland. h[ elp� I JARPA Revision 2012.1 Page 7 of 14 7j. For all excavating activities identified in 7h, describe the excavation method, type and amount of material in cubic yards you will remove, and where the material will be disposed. [tLei J Part 8—Waterbodies (other than wetlands): Impacts and Mitigation In Part 8, "waterbodies" refers to non-wetland waterbodies. (See Part 7 for information related to wetlands.) hf eM ❑ Check here if there are waterbodies on or adjacent to the project area. (If there are none, skip to Part 9.) 8a. Describe how the project is designed to avoid and minimize adverse impacts to the aquatic environment. htelpi ❑ Not applicable ' BMP's will be followed during construction to protect water quality at the site. The WDFW's HPA provisions and construction rules will also be strictly adhered to. I 8b. Will your project impact a waterbody or the area around a waterbody? he► x❑ Yes ❑ No JARPA Revision 2012.1 Page 8 of 14 8c. Have you prepared a mitigation plan to compensate for the project's adverse impacts to non-wetland waterbodies? h[ elp] I • If Yes, submit the plan with the DARPA package and answer 8d. • If No, or Not applicable,explain below why a mitigation plan should not be required. ❑ Yes x❑ No ❑ Not applicable The project will improve fish passage by removing an unnatural aggradation of sediments, which are the result of upstream anthropogenic development. lil i r 8d. Summarize what the mitigation plan is meant to accomplish. Describe how a watershed approach was used to design the plan. • If you already completed 7g you do not need to restate your answer here. 9_1121 8e. Summarize impact(s) to each waterbody in the table below. n[ elpl Activity (clear, Waterbody Impact Duration Amount of material Area (sq. ft. or dredge, fill, pile name' location of impact (cubic yards) to be linear ft.) of drive, etc.) placed in or waterbody removed from directly affected waterbody Alderbrook Creek Approx. 1 Approx. 30 Approx. 150 Creek day lineal feet, including the 110' culvert If no official name for the waterbody exists,create a unique name(such as"Stream 1")The name should be consistent with other documents provided. 2Indicate whether the impact will occur in or adjacent to the waterbody. If adjacent, provide the distance between the impact and the waterbody and indicate whether the impact will occur within the 100-year flood plain. Indicate the days. months or years the waterbody will be measurably impacted by the work. Enter"permanent"if applicable. 8f. For all activities identified in 8e, describe the source and nature of the fill material, amount (in cubic yards) Lyou will use, and how and where it will be placed into the waterbody. hpM J JARPA Revision 2012.1 Page 9 of 14 No fill will be placed in the waterbody. II 8g. For all excavating or dredging activities identified in 8e, describe the method for excavating or dredging, type and amount of material you will remove, and where the material will be disposed. ljhel See 6e, please. ail i Part 9—Additional Information Any additional information you can provide helps the reviewer(s) understand your project. Complete as much of this section as you can. It is ok if you cannot answer a question. 9a. If you have already worked with any government agencies on this project, list them below. hf eMI Agency Name Contact Name Phone Most Recent Date of Contact ( ) 9b. Are any of the wetlands or waterbodies identified in Part 7 or Part 8 of this DARPA on the Washington Department of Ecology's 303(d) List? bgjpj • If Yes, list the parameter(s) below. • If you don't know, use Washington Department of Ecology's Water Quality Assessment tools at: http:/Awww.ecy.wa.gov/programs/wq/303d/. ❑ Yes x❑ No r9c. What U.S. Geological Survey Hydrological Unit Code (HUC) is the project in? [helg] • Go to http://cfpub,epa.gov/surf/locate/index.cfm to help identify the HUC. 17110018 JARPA Revision 2012.1 Page 10 of 14 9d. What Water Resource Inventory Area Number(WRIA#) is the project in? h( elpl • Go to http://www.ecy.wa.,qov/services/gis/mapslwria/wria.htm to find the WRIA#. WRIA 14 9e. Will the in-water construction work comply with the State of Washington water quality standards for turbidity? h( eM • Go to http://www.ecy.wa.gov/programs/wq/swgs/criteria,html for the standards. x❑ Yes ❑ No ❑ Not applicable 9f. If the project is within the jurisdiction of the Shoreline Management Act, what is the local shoreline environment designation? h[ ell • If you don't know, contact the local planning department. • For more information, go to: http://www.ecy.wa.gov/programs/sea/sma/laws rules/173-26/211 designations.html. x❑ Rural ❑ Urban ❑ Natural ❑ Aquatic ❑ Conservancy ❑ Other Urban Residential_ 9g. What is the Washington Department of Natural Resources Water Type? hbgm • Go to http://www.dnr.wa.gov/BusinessPermits/Topics/ForestPracticesApplications/Pages/fp watertyping.aspx for the Forest Practices Water Typing System. ❑ Shoreline x❑ Fish ❑ Non-Fish Perennial ❑ Non-Fish Seasonal 9h. Will this project be designed to meet the Washington Department of Ecology's most current stormwater manual? h( eM • If No, provide the name of the manual your project is designed to meet. x❑ Yes ❑ No Name of manual: Stormwater Management Manual for Western Washington. 9i. Does the project site have known contaminated sediment? hel • If Yes, please describe below. ❑ Yes x❑ No J 9j. if you know what the property was used for in the past, describe below. Lpipj For recreation. 9k. Has a cultural resource (archaeological) survey been performed on the project area? LLLeM • If Yes, attach it to your DARPA package. ❑ Yes x❑ No JARPA Revision 2012.1 Page 11 of 14 91. Name each species listed under the federal Endangered Species Act that occurs in the vicinity of the project area or might be affected by the proposed work. [hel The Chinook salmon, the bull trout, the Puget Sound steelhead, the killer whale, the leatherback turtle, the humpback whale, the marbled murrelet, the green sturgeon, and the Puget Sound rockfish are some of the ESA listed aquatic threatened or endangered species in the area. 9m. Name each species or habitat on the Washington Department of Fish and Wildlife's Priority Habitats and Species List that might be affected by the proposed work. hC ep] See above, plus chum, coho, & cutthroat trout. Part 10—SEPA Compliance and Permits Use the resources and checklist below to identify the permits you are applying for. • Online Project Questionnaire at http://apps.ecy.wa.gov/opas/. • Governor's Office of Regulatory Assistance at (800) 917-0043 or helpna.ora.wa.gov. • For a list of addresses to send your JARPA to, click on agency addresses for completed JARPA. 10a. Compliance with the State Environmental Policy Act (SEPA). (Check all that apply.) hel • For more information about SEPA, go to www.ecy.wa.gov/programs/sea/sepa/e-review.htmi. ❑ A copy of the SEPA determination or letter of exemption is included with this application. ❑ A SEPA determination is pending with _Mason County (lead agency). The expected decision date is ❑ I am applying for a Fish Habitat Enhancement Exemption. (check the box below in 10b.) h[ elpl ❑ This project is exempt (choose type of exemption below). Categorical Exemption. Under what section of the SEPA administrative code WAC is it exempt? ❑ 9 P ( ) P ❑ Other: 10b. Indicate the permits you are applying for. (Check all that apply.) Lhpjd ---- --- ----- LOCAL GOVERNMENT Local Government Shoreline permits: ❑ Substantial Development ❑ Conditional Use ❑ Variance ❑ Shoreline Exemption Type (explain): Other city/county permits: ❑ Floodplain Development Permit ❑ Critical Areas Ordinance STATE GOVERNMENT JARPA Revision 2012.1 Page 12 of 14 Washington Department of Fish and Wildlife: x❑ Hydraulic Project Approval (HPA) ❑ Fish Habitat Enhancement Exemption —Attach Exemption Form Effective July 10, 2012, you must submit a check for $150 to Washington Department of Fish and Wildlife, unless your project qualifies for an exemption or alternative payment method below. Do not send cash. Check the appropriate boxes: x ❑ $150 check enclosed. (Check# > Attach check made payable to Washington Department of Fish and Wildlife. ❑Charge to billing account under agreement with WDFW. (Agreement # ) ❑ My project is exempt from the application fee. (Check appropriate exemption) ❑ HPA processing is conducted by applicant-funded WDFW staff. (Agreement # ) ❑ Mineral prospecting and mining. ❑ Project occurs on farm and agricultural land. (Attach a copy of current land use classification recorded with the county auditor, or other proof of current land use.) ❑ Project is a modification of an existing HPA originally applied for, prior to July 10, 2012. (HPA# ) Washington Department of Natural Resources: ❑ Aquatic Use Authorization Complete JARPA Attachment E and submit a check for$25 payable to the Washington Department of Natural Resources. Do not send cash. Washington Department of Ecology: ❑ Section 401 Water Quality Certification FEDERAL GOVERNMENT United States Department of the Army permits (U.S. Army Corps of Engineers): ❑ Section 404 (discharges into waters of the U.S.) ❑ Section 10 (work in navigable waters) United States Coast Guard permits: ❑ General Bridge Act Permit ❑ Private Aids to Navigation (for non-bridge projects) ❑ SEPA is pre-empted by federal law. JARPA Revision 2012.1 Page 13 of 14 Part 11—Authorizing Signatures Signatures are required before submitting the JARPA package.The DARPA package includes the DARPA form, project plans,photos,etc.[hejp] 11a.Applicant Signature(required) help] Q* 1 certify that to the best of my knowledge and belief,the information provided in this application is true, complete, and accurate. I also certify that I have the authority to carry out the proposed activities,and I agree to start work only after I have received all necessary permits. 9 I hereby authoqejpe agent named in Part 3 of this application to act on my behalf in matters related to this { application. (initial) By initialing here, i state that i have the authority to grant access to the property. I also give my consent to the permitting agencies enteh a property where the project is located to inspect the project site or any work related to the project. O'Alk (initial) l Phi'-'/ y h _� /ram Applicant Printed Name Applicant Signature Date 11 b.Authorized Agent Signature tnel,pj I certify that to the best of my knowledge and belief,the information provided in this application is true,complete, and accurate. I also certify that I have the authority to carry out the proposed activities and I agree to start work only after all necessary permits have been issued. Authorized Agent Printed Name Authorized Agent Signature _ Date 11C.Property Owner Signature(if not applicant) Ch ita Not required if project is on existing rights-of-way or easements. I consent to the permitting agencies entering the property where the project is located to inspect the project site or any work.These inspections shall occur at reasonable times and,if practical,with prior notice to the landowner. Property Owner Printed Name Property Owner Signature Date 18 U.S.0§1001 provides that Whoever,in any manner within the jurisdiction of any department or agency of the United States knowingly falsifies,conceals,or covers up by any trick,scheme,or device a material fact or makes any false,fictitious,or fraudulent statements or representations or makes or uses any false writing or document knowing same to contain any false,fictitious,or fraudulent statement or entry,shall be fined not more than$10,000 or imprisoned not more than 5 years or both. ............_.._If you you require this document in another format,contact the Governors Office for Regulatory Innovation and Assistance(ORIA)at(800) 917-0043. People with hearing loss can call 711 for Washington Relay Service.People with a speech disability can call(877)833-6341. ORtA publication number: ENV-019-09 rev.0912015 JARPA Revision 2015.1 Page 14 of 14