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HomeMy WebLinkAboutminutes.council.20000925Regular Meeting Aspen City Council September 25, 2000 Mayor Richards called the meeting to order at 5:00 p.m. with Councilmembers McCabe, Markalunas, Hershey, and Paulson present. CITIZEN COMMENTS There were none. COUNCILMEMBER COMMENTS 1. Mayor Richards announced a community meeting Wednesday, October 4 at 8:30 a.m. at the High School Commons called by Attorney General Ken Salazar to discuss school safety and violence prevention. 2. Councilman Paulson said he has a copy of the resolution Pitkin County passed on the state measure regarding growth. Councilman Paulson said the county's resolution calls for a two-year exemption with voter approval if amendment 24 passes. Councilman Paulson said he does not want people to get the message that growth is all right. Mayor Richards suggested any resolutions supporting or opposing state ballot amendments be brought to an October meeting. 3. Councilman Markalunas reflected on the life of Margaret Conner who died last week. Ms. Conner lived next door to city hall, was Aspen's oldest citizen born in 1899 and her life spanned the entire twentieth century. Councilman Markalunas said Margaret Conner was a wonderful person, a true pioneer of Aspen, and will be missed. 4. Councilman Hershey moved to add RFTA resolution 4 regarding appropriation for the employee apartment complex in Carbondale to the consent calendar and to continue Resolution #106, Series of 2000, Kaplan Annexation, to November 13, 2000; seconded by Councilman Markalunas. All in favor, motion carried. 5. Steve Barwick, city manager, requested a discussion of Board appointments be added to the end of the agenda. 6. Steve Barwick, city manager, reminded Council there is a CAST meeting in Park City October 26, 27, and 28. 7. Steve Barwick, city manager, told Council the U.S. Forest Service will come to the next brown bag to discuss the Maroon Bells project. Mayor Richards requested staff notify the county of this presentation so that any interested county personnel can attend. 1 Regular Meeting Aspen City Council September 25, 2000 CONSENT AGENDA Councilman Markalunas moved to read Ordinance #46, Series of 2000; seconded by Councilman Hershey. All in favor, motion carried. ORDINANCE #46 Series of 2000 AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF ASPEN, COLORADO, AMENDING CHAPTERS 23.40 AND 23.48 OF THE MUNICIPAL CODE TO INCORPORATE THE GENERAL ADMINISTRATIVE PROVISIONS OF CHAPTERS 23.04 THROUGH 23.28 OF THE TAXATION TITLE OF THE MUNICIPAL CODE AND TO AMEND SECTION 23.28.090 TO CHANGE STATUTE OF LIMITATIONS FOR TAX REFUNDS FROM THREE YEARS TO ONE YEAR Councilman Hershey moved to approve the consent agenda; seconded by Councilman McCabe. The consent calendar is: · Resolution #128, 2000 - Contract Parking Garage · Resolution #129, 2000 - Construction Contract - Yellow Brick Park · Resolution #130, 2000 - Stein Way Street Name Approval · Resolution #131, 2000 – Extension of Ute Mountaineer lease/golf course · Ordinance #46, 2000 - Code Amendments Taxation Title · Board Appointment - P & Z Eric Cohen · RFTA resolution 04-2000 Supplemental Appropriation – RFTA Employee Apt. complex in Carbondale Roll call vote; Councilmembers Hershey, yes; Markalunas, yes; Paulson, yes; McCabe, yes; Mayor Richards, yes. Motion carried. 2 Regular Meeting Aspen City Council September 25, 2000 RESOLUTION #120, SERIES OF 2000 - Eligibility of Burlingame/Bar X Ranch for COWOP Review Joyce Ohlson, community development department, said this first step is to determine if a development proposal should be eligible for review by COWOP. The applicants are the housing authority and Bar/X Ranch LLC and are a partnership. The application proposes a 70/30 split of affordable and free market housing. Ms. Ohlson reminded Council the COWOP process was established to insure a high quality project and benefits from public participation and involvement of interested groups early on in the development plan. Ms. Ohlson pointed out section 2 in Resolution #120 outlines this process starting with convening the task force team and establishing its role, developing a citizen involvement process through formal review and to the final adoption of an ordinance. Ms. Ohlson said these will be legally noticed, public meetings. Section 3 suggests the make up of the task force, which will include 2 Council, 2 P & Z, 1 County P & Z, 2 housing board, 1 Aspen Valley Land Trust, 1 representative from Many Voices, 1 person from the Airport Business Center and 2 public, which could be an ACRA representative and a representative of qualified employees. Other interested parties could be representatives of the school district, hospital, Ski Company, Fire District, MAA, Maroon Creek Club homeowners association, and RFTA. Section 4 shows how the process will fit into a proposed 12-month time frame. Ms. Ohlson said there may be a design competition for this project, similar to Aspen Mass, if Council deems that to be appropriate. Staff recommends Council finds this proposed project be eligible for COWOP as the project will provide much needed employee housing, the property is owned by the city in partnership with a private entity, the development project will be initiated and carried out by the city in their partnership. Mayor Richards opened the public hearing. Joy Caudill said she hopes there is a lot of public notice for this development. Mayor Richards suggested a logo or something to identify these meetings so they are easily recognizable to the public. 3 Regular Meeting Aspen City Council September 25, 2000 Mayor Richards closed the public hearing. Councilman McCabe moved to adopt Resolution #120, Series of 2000; seconded by Councilman Hershey. Councilman Markalunas said this is an opportunity for all citizens of Aspen to have input into housing and open space and a project that will be a great amenity to Aspen. Councilman Paulson asked where in the process could more or less housing be added. Ms. Ohlson said the process has the opportunity for the project to go in many different directions. Ms. Caudill asked if both the housing and free market projects go through this process. Mayor Richards said the plans will be developed jointly; they will go through the review process at the same time. Councilman Paulson said this process bothers him. It sets a bad standard for a government to decide something is good for the welfare of the public. Councilman Paulson said this project is sprawl, it does not answer environmental questions. Councilman Paulson said he feels this process could be abused by Council. Councilman Hershey supports this process as it will get the Boards involved earlier. The end decision still rests with City Council. Mayor Richards said she hopes the process integrates design and the cost of the design so that the city knows that the design is buildable. John Worcester, city attorney, said one of the benefits of the process is that the task force members will be acting as owners of the property as well as reviewers the project. Cost should be an issue that the task force looks at throughout the process. Mayor Richards suggested childcare providers, someone from the Kids First Board, should be part of this. Mayor Richards said the county should be contacted as county emergency workers will be included and they should have input. Mayor Richards said the task force team should include a representative of the Bar X Ranch. Mayor Richards said she would like outreach as early as possible for potential partners so they are part of the design. Mayor Richards said she would like the task force to host public outreach sessions, not just notifying the public by newspaper notice. Mayor Richards said the pre-annexation agreement is the framework for this project. There should be an outline of the points approved in the pre-annexation agreement before this task force starts its process. Mayor Richards said she looks forward to P & Z using their design expertise on this project rather than just reviewing a completed project. 4 Regular Meeting Aspen City Council September 25, 2000 Mayor Richards said she feels this will be a much more interactive process and does not take any rights away from the public. Councilman Paulson said in the past, projects have been reviewed by Boards made up of 5 to 7 members. In this process, Boards will be relying on the 1 or 2 members to report back. Mayor Richards said any members can attend any of the task force meetings. Any Board could also request a full presentation of the project during the process. Councilman Paulson suggested the representatives of various Boards take the project to their Board somewhere in the process for review and comment. Councilman McCabe suggested a representative from the disabled be invited to comment so their expertise will be part of the design. Council indicated they wanted this person to be part of the task force, if possible. Roll call vote; Councilmembers McCabe, yes; Markalunas, yes; Mayor Richards, yes; Hershey, yes; Paulson, no. Motion carried. ORDINANCE #43, SERIES OF 2000 - Sandunes Subdivision Fred Jarman, community development department, showed the location of this property, 86% in the county and 14% in the city, near the intersection of th 7 and Main street. Lot 1 is 51,811 square feet; lot 2 is about 20,000 square feet. This property is zoned R-15 in the county. Jarman noted when the county had a 50% density reduction lot split in 1992; the city participated in an advisory role. The city's conditions at that review were no further development take place on the city portion of the parcel, the Sandunes will adopt the city's FAR regulations and the current lighting code, they will grant a fisherman's easement, and enter into a curb and sidewalk agreement. Jarman told Council this does meet the review standards for an exempt lot split. At first reading, Council requested information on the impacts in the city versus leaving the lots in the county. Jarman said there can be greater density in the city. County R-15 does not allow duplexes. Jarman said there could be 3 ADUs in the city and not as many in the city. Mayor Richards asked if there is a slope reduction calculation on lot 1 and what would that make the FAR. The applicant is working with a civil engineer on these calculation; however, a rough estimate is between 5500 and 5700 square feet. 5 Regular Meeting Aspen City Council September 25, 2000 Mayor Richards asked without the lot split, what size house could be built and would this approval increase the free market square footage. Mayor Richards said she would be more inclined to support the lot split if the two lots were closer in size. It appears they are being divided in order to get the largest floor area available in the city. Mayor Richards said if the lots were closer to equal size or the larger one was under 49,900 square feet, there would be a 4500 square foot house, rather than two houses totaling over 10,000 square feet. Councilman Paulson asked if there anything in the city's code that will keep this house from being built down the slope and having 60 feet of exposure. Jarman said there are restrictions in the code and this has had stream margin review by P & Z. There is a highly sensitive riparian area below, which will be protected. Councilman Paulson said he would like to make sure this is set back from the bluff. Jarman noted the 1992 county approval set the building envelope. If this is annexed into the city, that building envelope approval will be dissolved and the structure will have to meet the R-15 setback requirements. Councilman Paulson asked where the entrance to these parcels is and if it will be affected by the entrance to Aspen. Jarman said there is an access th easement over lot 3, Adams subdivision. Access to lot 2 is a curb cut on 7 street. Councilman Markalunas asked if the access easement is of record. Jennifer said it is. Councilman Paulson asked if the proposed access would th interfere with a future closure of 7 street. Mayor Richards asked what the FAR would be in the county. Jarman said it would be same as required in the city. Mayor Richards said she is concerned about claims against CDOT for the highway coming through this location. Jarman said one of the parcels will be directly affected by the entrance to Aspen, whether it remains in the city or the county. Councilman Paulson asked how moving the Berger cabin would affect this lot split. Randy Ready, assistant city manager, said there is a taking of some of the Berger property by the relocation of the highway. There is an issue with access to the Berger cabin in the event the new Castle Creek bridge comes across below current grade. This is hypothetical at this point and will be further explored in the design process when CDOT funds the entrance to Aspen. John Worcester, city attorney, noted this ordinance does not include all the conditions that are usually included but are appended as a staff report. 6 Regular Meeting Aspen City Council September 25, 2000 Worcester recommended this be continued to include those conditions and as well as look at the access issues. Councilman Hershey moved to continue Ordinances #43 and 28, Series 2000, to October 23 in order to look at access issues and add the conditions; seconded by Councilman McCabe. Mayor Richards requested staff meet with CDOT to see to what level this will affect the highway corridor and if it is appropriate to make a condition of annexation that the property owners agree not to enter into any lawsuits to prevent the development of the entrance to Aspen. All in favor, motion carried. ORDINANCE #41, SERIES OF 2000 - Aspen Mountain PUD Code Amendment Chris Bendon, community development department, noted this is a follow up to conceptual approvals from earlier in the year. Bendon said there are two code amendments. One is to the LTR district. The city's zone districts contain uses and dimensions. In the LTR, single family or duplex units can be constructed only on parcel of 6,000 square feet or less. The dimensions require a lot of 6,000 square feet. So currently one can only build a single family or duplex on a lot exactly 6,000 square feet. Bendon noted in a PUD, only dimensional requirements can be varied; not uses. Bendon said staff recommends adding a maximum lot size so as not to change any substantive requirements. This can be amended as a dimensional requirement under PUD. Bendon told Council the second code amendment provides a process in the land use code for converting residential reconstruction credits. During the negotiations with the applicant, a conversion rate of 1 residential credit equals 2 lodge credits was decided on. The applicant would still need to compete for 32 lodge units. Bendon told Council P & Z recommended the applicant be allowed to use whatever credits they have to equal 150-unit hotel. The 2:1 rate would require the applicant go through the GM process; there would be fewer allotments left for other applicants. P & Z suggests 2.95:1 rate which equals 150 room hotel. This would not reduce Council's review over heights, dimensions, parking, FAR; it does not reduce the public input. This would be a simpler process as an exemption review rather than a 7 Regular Meeting Aspen City Council September 25, 2000 scoring competition. This suggested procedure would leave more lodge units available for competition. This would not require growth management committee review. Bendon said the GMC is made up in part of county P & Z members. Staff conferred with county staff who did not feel there was a benefit for this project to go through GMC because the major concessions have already been obtained, like the employee units and mitigation at 1 to 1. Mayor Richards asked how many unallocated lodge units are available. Sunny Vann, representing the applicant, said there are 66 units in the August 2000 competition. Julie Ann Woods, community development director said having more lodge units available in the metro area is a positive. Mayor Richards said she was comfortable with the proposal when it was going to extinguish an additional 32 lodge units. Mayor Richards said she feels this is major tinkering with the community growth plan. The applicants have already prepared their application and are ready to go to the GMC. Bendon said there are public protections in the process to address height, parking, etc. The issue is whether 32 lodge units being available for other competition is good for the community or not good for the community. Mayor Richards said this is adding units to the growth management pools without looking at the overall growth plan. Councilman Paulson asked if this can be done for one project only. Ms. Woods said staff feels this was an easier way to process this project. It can be done the traditional way. Councilman Markalunas noted Aspen has been losing their bed base, which seems to be at odds of trying to maintain a viable ski resort. Councilman Markalunas said this proposal helps hold on to the bed base. Councilman McCabe noted this will help address the economic sustainability of the resort and will do it inside the growth boundary and will simplify the process. Mayor Richards said there is no documentation why the growth management allocation for lodges needs additional units, nor is there any documentation how this would affect growth management plan. Mayor Richards said this project is prepared to go through a growth management competition. Mayor Richards said this seems arbitrary when all other projects go through the process. Mayor Richards opened the public hearing. There were no comments. Mayor Richards closed the public hearing. 8 Regular Meeting Aspen City Council September 25, 2000 Councilman Markalunas moved to adopt Ordinance #41, Series of 2000, on second reading; seconded by Councilman Hershey. Councilman Markalunas moved to amend Ordinance #41, Series of 2000, to show a conversion rate of 2.95:1; seconded by Councilman Hershey. Mayor Richards moved to increase the affordable housing pool available in the Aspen Area Community Plan to 825 to 1325 units to compensate for this increase in commercial growth; seconded by Councilman Paulson. Roll call vote; Councilmembers McCabe, no; Markalunas, no; Mayor Richards, yes; Hershey, no; Paulson, yes. Motion NOT carried. Roll call vote; Councilmembers McCabe, yes; Markalunas, yes; Mayor Richards, no; Hershey, yes; Paulson, no. Motion carried. Roll call vote; Councilmembers McCabe, yes; Markalunas, yes; Mayor Richards, no; Hershey, yes; Paulson, no. Motion carried. ORDINANCE #42, SERIES OF 2000 - Yellow Brick PUD and Code Amendment Fred Jarman, community development department, said the requests in this PUD are to rezone the Yellow Brick school, currently R-6, to Public, and to amend the Public zone district to allow 3 additional uses; private schools, daycare centers, and non-profit organizations as permitted uses. The code amendment also requests to amend the purpose of the public zone to include "non-profit facilities for cultural, educational, civic and other non-profit rd purposes". The 3 request is an GMQS exemption to establish the yellow brick as an essential public facility. The last request is to establish the dimensional requirements as a PUD. Jarman showed the location of the Yellow Brick School. The asphalt area to the south is being worked on as a park. Staff recommends the PUD not extend to this area. The Yellow Brick school is currently being used as daycare and non-profit offices and staff would like to legitimize those uses. Tim Anderson, recreation director noted these requests are all consist with Council's direction in the past. 9 Regular Meeting Aspen City Council September 25, 2000 Mayor Richards opened the public hearing. There were no comments. Mayor Richards closed the public hearing. Councilman Paulson said he would like to make sure the new landscaping for the park area does not interfere with the solar panels. Anderson said this vegetation will be low and will not interfere. Councilman Paulson asked if this building is capable of supporting employee housing on the second floor. Anderson said the preliminary engineering does not eliminate that. Jarman said rezoning public does not preclude affordable housing. Councilman Hershey moved to adopt Ordinance #42, Series of 2000, on second reading; seconded by Councilman Markalunas. Roll call vote; Councilmembers Markalunas, yes; McCabe, yes; Mayor Richards, yes; Paulson, yes; Hershey, yes. Motion carried. RESOLUTION #114, SERIES OF 2000 - Meadows Lots 8, 9, 10 SPA Supplement Agreement Sarah Oates, community development department, reminded Council they reviewed a similar proposal for lot 7 in the spring. Ms. Oates said 4 single family lots were approved as part of the Meadows SPA and were approved with 500 square foot ADUs deed restricted to mandatory occupancy, to be rented to category 1 employees. The buyers of lot 7 requested the mandatory occupancy deed restriction be lifted and the ADU be voluntary and the buyer purchased and deed restricted a unit in town. The purchasers of lots 8, 9, and 10 propose to give cash-in-lieu and have voluntarily occupied ADUs. The housing board recommends these purchasers provide a housing unit rather than cash-in-lieu. Mickey Herron, representing the applicants, told Council the housing board was not specific in their recommendation about finding replacement housing. Herron requested this application be tabled until after the executive session. Herron suggested Council confer with the city attorney on where this application is and a solution that can be negotiated. The recommendation from staff is not clear as to what has to be replaced and how to accomplish that. John Worcester, city attorney, noted staff recommended a cash-in-lieu payment of $158,000. Herron asked if Council is willing to accept $100,000/unit. 10 Regular Meeting Aspen City Council September 25, 2000 Mayor Richards said the minimum Council should accept is $158,000/unit. These ADUs were approved with mandatory occupancy, which makes paying cash a bargain. Herron said he would like to work out a compromise. Mayor Richards said these ADUs were the only mitigation toward affordable housing in the entire Meadows master plan. Mayor Richards said she does not feel an offer of $50,000/ADU is adequate. Councilman McCabe moved to table Resolution #114, Series of 2000, until the end of the meeting; seconded by Councilman Hershey. All in favor, motion carried. ORDINANCE #45, SERIES OF 2000 - Visitor Benefit Tax John Worcester, city attorney, told Council this ordinance is conditioned on the passage of the ballot measure. The funds collected from this tax will be split 50% to RTA and 50% to tourism promotion activity. Worcester said the city will contract with an organization like ACRA to conduct the tourism promotion. Councilman Markalunas moved to read Ordinance #45, Series of 2000; seconded by Councilman Hershey. All in favor, motion carried. ORDINANCE #45 Series of 2000 AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF ASPEN, COLORADO, AMENDING TITLE 23 OF THE MUNICIPAL CODE OF THE CITY OF ASPEN TO IMPOSE A NEW 1.0% VISITOR BENEFIT TAX; TO ESTABLISH A TOURISM PROMOTION FUND FOR DEPOSIT OF SAID TAX RECEIPTS; TO PROVIDE FOR THE RESTRICTED EXPENDITURE OF SAID TAX RECEIPTS; AND TO ESTABISH PENALTIES FOR VIOLATIONS THEREOF was read by the deputy city clerk Mayor Richards said the lodging community would like clarification that this would not supplant any current expenditures of the city to support ACRA and the visitor's center. This tax is for new program. Worcester said 11 Regular Meeting Aspen City Council September 25, 2000 he will meet with representatives of the lodging community before second reading. Councilman Paulson asked if this will affect people renting out their home short term. Mayor Richards said anyone who is renting out his or her houses short term through property management companies will pay this tax. Mayor Richards said the lodging community is concerned about enforcement of this provision so there is not unfair competition. Councilman McCabe asked if this covers timeshare or fractional fee ownership. Worcester said this ordinance covers timeshare if the rental period is 30 days or less. Fractional Interest is different because people are not renting. If a unit is rented, sales tax is collected. When units are sold, the city does collect the real estate transfer tax. Councilman Paulson asked if funding the RTA is ensure free buses in Aspen. Worcester page 4 (e) 50% of the funds will be dedicated to transportation services and they can only be appropriated by Council (1) to meet the city's financial obligations to an RTA or RFTA, (2) to pay for local transportation services within the city of Aspen, and (3) to defray administrative or clerical costs of collecting the tax. Mayor Richards noted if the visitors benefit tax does not pass and revenues have been committed to RTA through a Pitkin County funding question, the RTA will rebate to Aspen $360,000/year to maintain the in-town bus service. Councilman Paulson said there may be arguments that there are existing funds to pay for a RTA. Councilman Paulson said it should be made clear to voters that the funding is not there. Mayor Richards said there is money for transportation; however, it is already allocated for it. The visitor's tax is for shortfall in operating revenue to extend and improve the RTA. Councilman Paulson asked if this funding is sufficient for Aspen's share to make the RTA work. Mayor Richards said the city will still need to take $186,000 from paid parking revenues. Councilman Hershey moved to adopt Ordinance #45, Series of 2000, on first reading; seconded by Councilman Markalunas. Councilman McCabe noted the name for the transportation authority should be consistent throughout the ordinance. Councilman McCabe objected to the ordinance stating it would fund "other similar transportation providers" 12 Regular Meeting Aspen City Council September 25, 2000 as too open ended. Councilman McCabe suggested "to contribute to funding" rather than "to pay for local transportation services" as this funding source. Councilman McCabe suggested a cap on the phrase of "cost of administering and collecting this tax". Council suggested staff look over these for second reading. Mayor Richards said this action ties visitor impact directly to a solution of transportation. This funding source will not come from residents. This will also give the lodging community a promotional fund. Mayor Richards said this is historic cooperation. Roll call vote; Councilmembers McCabe, yes; Markalunas, yes; Mayor Richards, yes; Councilman Paulson, yes; Councilman Hershey, yes. Motion carried. Councilman Markalunas moved to go into executive session for the purposes of litigation, negotiations and personnel matters; seconded by Councilman Hershey. All in favor, motion carried. Councilman Hershey moved to come out of executive session; seconded by Councilman McCabe. All in favor, motion carried. Councilman Markalunas moved to approve Resolution #127, Series of 2000, to settle the Maroon Creek lawsuits; seconded by Councilman Hershey. All in favor. Motion carried. Councilman Markalunas moved to continue Resolution #114, Series of rd 2000, to October 23 ; seconded by Councilman Hershey. All in favor, motion carried. BOARD APPOINTMENTS Mayor Richards moved to appoint Marcia Goshorn to the Housing Board as the city alternate and Steve Elliott to the joint appointment; seconded by Councilman Hershey. All in favor, motion carried. Councilman Hershey moved to adjourn at 9:45 p.m.; seconded by Councilman Paulson. All in favor, motion carried. 13 Regular Meeting Aspen City Council September 25, 2000 Kathryn S. Koch, City Clerk 14 Regular Meeting Aspen City Council September 25, 2000 CITIZEN COMMENTS ................................ ................................ .............. 1 COUNCILMEMBER COMMENTS ................................ ........................... 1 CONSENT AGENDA ................................ ................................ ................. 2 · Resolution #128, 2000 - Contract Parking Garage ................................ 2 · Resolution #129, 2000 - Construction Contract - Yellow Brick Park ... 2 · Resolution #130, 2000 - Stein Way Street Name Approval .................. 2 · Resolution #131, 2000 – Extension of Ute Mountaineer lease/golf course ................................ ................................ ................................ ....... 2 · Ordinance #46, 2000 - Code Amendments Taxation Title .................... 2 · Board Appointment - P & Z Eric Cohen ................................ .............. 2 · RFTA resolution 04-2000 Supplemental Appropriation – RFTA Employee Apt. complex in Carbondale ................................ .................... 2 RESOLUTION #120, SERIES OF 2000 - Eligibility of Burlingame/Bar X Ranch for COWOP Review ................................ ................................ ......... 3 ORDINANCE #43, SERIES OF 2000 - Sandunes Subdivision .................... 5 ORDINANCE #41, SERIES OF 2000 - Aspen Mountain PUD Code Amendment ................................ ................................ ................................ . 7 ORDINANCE #42, SERIES OF 2000 - Yellow Brick PUD and Code Amendment ................................ ................................ ................................ . 9 RESOLUTION #114, SERIES OF 2000 - Meadows Lots 8, 9, 10 SPA Supplement Agreement ................................ ................................ ............... 10 ORDINANCE #45, SERIES OF 2000 - Visitor Benefit Tax ....................... 11 BOARD APPOINTMENTS ................................ ................................ ....... 13 15