Town Commission

TOWN OF LAUDERDALE-BY-THE-SEA TOWN COMMISSION REGULAR MEETING MINUTES Jarvis Hall 4505 Ocean Drive Thursday, September 12, 2019 6:30 PM 1. CALLTO ORDER Mayor Chris Vincent called the meeting to order at 6:55 p. m. Also present were Vice Mayor Elliot Sokolow, Commissioner Edmund Malkoon, Commissioner Alfred "Buz" Oldaker, Commissioner Randy Strauss, Town Manager Bill Vance, Town Attorney Susan L. Trevarthen, Assistant to the Town Manager Neysa Herrera, Finance Director Lucila Lang, Municipal Services Director Ken Rubach, Development Services Director Linda Connors, Special Projects Coordinator Debbie Hime, Public Information Officer Steve d'Oliveira, and Town Clerk Tedra Alien. 2. PLEDGEOF ALLEGIANCETO THE FLAG 3. INVOCATION Pastor Larry Trotter gave the Invocation. All present observed a moment of silence in recognition of the anniversary of September 11, 2001 . 4. ADDITIONS DELETIONS DEFERRALS OF AGENDA ITEMS Mayor Vincent requested that Item 12. b be deferred until September 26, 2019 so additional due diligence can be performed. 5. PRESENTATIONS 5. a Fisherman's Pier Reconstruction Update Spiro Marchelos, representing Fisherman's Pier, recalled that the Pier was damaged following Hurricane Irma in 2017 and is currently being reconstructed. Although there have been recent delays due to weather conditions, it is hoped that the middle of the Pier can reopen within the next six weeks. Mr. Marchelos reviewed the technology used in making repairs, noting that some of the materials are produced by Florida businesses. He recognized Town Manager Bill Vance

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 and the Broward SherifTs Office (BSD) for their assistance during the repair process. Roughly 200 ft. of the Pier has been repaired thus far. Building Official Randall Clutter added that he is in regular contact with the contractor's superintendent. The Building Department last received inspectors' reports on the project in July 2019 5. b Update on "Pelican Hopper" Community Shuttle Special Projects Coordinator Debbie Hime provided a brief update on the Pelican Hopper community shuttle. A new propane-fueled bus is now in operation. Route hours now begin at 9 a. m. each day and will end at 6 p. m. through the week, at 9 p. m. on Friday and Saturday nights, and at 5 p. m. on Sundays. Special Projects Coordinator Hime emphasized that the new shuttle route will use designated stop points. Headways are expected to be approximately 65 minutes. The Town is currently developing an improved mobile app that will show the bus's location in real time, and has made improvements to the new Broward County Transit (BCT) route map, which will show the bus's direction. The Town will sign a new interlocal agreement (ILA) with Broward County, which will provide a three-year agreement with two one-year extensions. It is proposed to be executed and in effect by October 1, 2019. Staff will meet with BCT to discuss aspects of this agreement which are different from the previous ILA, including: . The old route will continue until the new route is in effect . BCT will reimburse the Town for the $44 per revenue service hour, which is based on an average ridership of 1. 7 passengers per hour across Broward County . The fiscal year (FY) 2020 budget includes $173, 000 for bus services, of which $149, 908 is proposed to be reimbursable from BCT using Broward County penny surtax funds . New route signage and updated information will be provided Special Projects Coordinator Hime noted that the Town will be responsible for obtaining any necessary permissions to access or encroach upon any property for use as an origin or destination point. This means agreements with entities such as Holy Cross Hospital, the Village Shopping Center, or the Gait Library are necessary. The Town is also responsible for the Americans with Disabilities Act (ADA) compliance of all non-BCT stops. The new route may begin before all these stops are brought into compliance. This expense is not included in the FY 2020 budget, and the Town has Page 2 of 15

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 been advised that they can seek reimbursement through surtax funds. Town Manager Vance added that the Town is also working with the County on new bus shelter locations, which may be funded by the penny surtax as well. The Action Plan for the Pelican Hopper identifies current transit services and evaluates options that may improve the efficiency of the shuttle. Another aspect of the Action Plan addresses alternative transit services that may be provided in addition to the Pelican Hopper. The Downtown . Fort Lauderdale Transportation Management Association (DFLTMA) has applied for funds to connect their Sun Trolley to the Pelican Hopper for shared on-demand service along the Gait Ocean Mile. This service is currently being tested in Pompano Beach. Commissioner Malkoon observed that if all issues are addressed, the Town may be able to extend shared service on the Gait Ocean Mile throughout the rest of Lauderdale- By-The-Sea. He noted, however, that while the new route is primarily in the north part of the Town, it misses some of the northern neighborhoods. Special Projects Coordinator Hime advised that this was because ridership in those areas did not meet the required threshold for community bus service. Commissioner Strauss requested that a shelter be considered within the Downtown area north of Commercial Boulevard. Special Projects Coordinator Hime noted that while this is a BCT stop, it is not currently ADA-compliant. 5. c Overview of FY20 Business Development and Marketing Budget Special Projects Coordinator Hime provided an overview of the Town's Business Development and Marketing Budget for FY 2020. The Town has a three-year Strategic Marketing Plan, which contractor Conceptual Communications was selected to develop and implement. The first year of this plan is coming to an end. Specific items from this Plan will be presented to the Commission in October. Primary goals of the Strategic Marketing Plan include development and implementation of programs that draw positive awareness to the Town by augmenting its unique character, enhancing economic development, and increasing the sense of community through programs and events. The Plan targets couples, families, and tourists in the 35- 54 age range and promotes a clean, wholesome, and family-oriented image. The Plan also includes development of community outreach programs and events to increase residents' interest and involvement, bring foot traffic to the West Business Page 3 of 15

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 District Plazas and other commercial areas, and promote the Town's walkability. Special Projects Coordinator Hime characterized this development as a collaborative effort between Staff, the Commission, and members of the community. The proposed budget includes line items for advertising and marketing, professional/contractual services, special events, printing and binding, new and existing special events, and neighborhood outreach. Line items are included in other budgets, such as the Capital Improvement Program (CIP) and General Fund, for commercial street lighting upgrades and electronic Town Hall street marquees. The total combined budget is just over $322, 000, not including capital projects. Mayor Vincent emphasized the need for greater collaboration between the Town and its businesses in promoting Lauderdale-By-The-Sea. He recalled that lighting on Commercial Boulevard has been previously discussed, although no action was taken. Municipal Services Director Ken Rubach advised that while lighting was originally included for the Plazas, it was removed from the plans due to its cost. Commissioner Oldaker asked if the Town has reached out to the cruise industry. Special Projects Coordinator Hime confirmed this, noting that some ads geo-targeted cruise ship passengers near the port. Commissioner Oldaker added that there was discussion in a previous year of using marketing funds to attract potential residents as well as tourists to Lauderdale-By-The-Sea. It was clarified that there are no funds designated for this purpose in the FY 2020 budget. There was consensus that a workshop could be scheduled to further discuss marketing efforts. 6. PUBLIC COMMENT At this time Mayor Vincent opened public comment. Barbara Cole, resident, addressed Item 12. a, stating that a walkway in the median of the proposed El Mar Greenway is not necessary. She suggested that the Commission hold roundtable meetings to further discuss plans for the Greenwaywith residents. Charles Mangano, resident, requested more information on a project proposed for the former Holiday Inn property by Concord Wilshire. He felt the investors may wish to hear greater detail regarding the El Mar Greenway project before committing to this development. Page 4 of 15

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 Steve Silverstein, resident, advised that the Town consider allowing short-term rental properties less than 60 ft. in width in the RM-25 zoning district as a potential source of revenue. This would allow them to be taxed appropriately. Mr. Silverstein concluded that this issue should be brought back before the Commission for a vote. Bradley Kady, resident, also addressed short-term rentals less than 60 ft. wide in the RM-25 district, stating that they would add significantly to the Town's tax base. He did not feel Code prohibiting these rental properties has had any positive impact on the Town. Jim Rogers, resident, expressed concern with speeding traffic in the Silver Shores neighborhood, particularly on East Tradewinds Avenue. He requested an update on how the Town plans to address this issue, suggesting a four-way Stop sign as a possible solution, and asked if Sunday nights could be designated a "quiet night" within the Town in which outdoor music would not be permitted Downtown. He concluded that power lines should be buried on El Mar Drive to allow for improved sidewalks. Stuart Dodd, resident, addressed Item 12. a, stating that he took issue with approving an expenditure from Flynn Engineering in the absence of plans from the Florida Department of Transportation (FDOT) regarding the proposed El Mar Greenway. He added that many local residents did not want a concrete walkway in the median of El Mar Drive. Mr. Dodd recommended that the Item be tabled until a full set of plans are available and there has been more discussion with the public regarding the Greenway's features. Linda Thompson Gonzalez, resident, also asked that Town residents' opinions be taken into consideration with regard to a concrete walkway on the proposed El Mar Greenway. She felt the walkwaywould be unnecessary and could distort the space available. With no other individuals wishing to speak at this time, Mayor Vincent closed public comment. 7. PUBLIC SAFETY DISCUSSION 7. a BSO August 2019 Report Captain Tom Palmer of the Broward Sheriffs Office (BSO) addressed speeding traffic in Silver Shores, recalling that this concern was raised in June 2019 by several residents. Page 5 of 15

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 Because they did not have specific information regarding unsafe traffic conditions, BSO engaged in enforcement efforts and traffic counts to gather information. Town Manager Bill Vance added that he, Municipal Services Director Rubach, and Captain Palmer met with Silver Shores residents to discuss potential improvements. They hope to schedule a follow-up meeting to share further information. Commissioner Oldaker suggested that electronic speed limit signs be deployed to address the problem. Vice Mayor Sokolow made a motion, seconded by Commissioner Oldaker, to approve. Motion carried 5-0. 8. TOWN MANAGER REPORT 8. a Town Manager Report Town Manager Vance reported that Town Hall, Municipal Services, Development Services, BSO, and the Volunteer Fire Department (VFD) will receive new phone installation within 30 days. Town facilities are also receiving comprehensive information technology (IT) upgrades. The Town is also submitting final Florida Department of Emergency Management applications related to reimbursement for Hurricane Irma, totaling roughly $135, 000, with the assistance of Broward County Commissioner Chip LaMarca. Town Manager Vance also recommended that Item 11 .e be pulled from the Consent Agenda for additional discussion. Regarding the former Holiday Inn property, Town Manager Vance recalled that he had discussed the issue of the developers' conceptual plans following their presentation at a public meeting over the summer. The developer indicated that they understood the public had not wished to see any closure of El Mar Drive, and planned to investigate other ways to connect both sides of their proposed development. Commissioner Oldaker requested an update on Bougainvillea Drive/Poinciana Street construction. Municipal Services Director Ken Rubach advised that the project is on schedule and is currently working on the middle of the roadway. He anticipated the project would be complete by late September or mid-October, weather permitting. Page 6 of 15

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 Mayor Vincent suggested that a shelter be placed in this area to accompany a pick- up/drop-off area for ride sharing services as well as a bus shelter. He requested that a budget and/or design for this shelter be brought back to a subsequent meeting. 9. TOWN ATTORNEYREPORT None. 10. APPROVALOF MINUTES 10. a August 27, 2019 Town Commission Meeting Minutes Vice Mayor Sokolow made a motion, seconded by Commissioner Oldaker, to approve. Motion carried 5-0. 11.CONSENTAGENDA It was determined that Items 11. b, 11. e, 11. f, and 11. g would be pulled for additional discussion. Vice Mayor Sokolow made a motion, seconded by Commissioner Oldaker, to approve Items 11. a, 11. c, and 11. d. Motion carried 5-0. 11. a Property, Liability, and Worker's Compensation Insurance 11 .b Employee Insurance Benefit Commissioner Malkoon noted that the health reimbursement arrangement (HRA) would be increased to a $1500 minimum, while gap insurance and deductible requirements would be removed. Town Manager Vance explained that he had proposed this change to pursue a $250 increase to employees' benefits card. The intent was to create a gap insurance opportunity that would work better for employees rather than costing them an extra $1500 out of pocket. Vice Mayor Sokolow made a motion, seconded by Commissioner Malkoon, to approve. Motion carried 5-0. 11. c Lauderdale-By-The-Sea Garden Club Request for Parking for Jarvis Hall Events in Fiscal Year 20 Page 7 of 15

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 11. d Lauderdale-By-The-Sea Woman's Club Request for Parking Permits and Jarvis Hall Use in Fiscal Year 20 11. e Special Event Application from The Village Grille and 101 Ocean to Present Live Music on Friday Nights from November 1, 2019 through May 29, 2020, St. Patrick's Day on Friday, March 17, and Other Friday Events Town Manager Vance explained that he wished to recommend the Town assume financial responsibilities associated with the BSO resources required by Friday night events. He requested direction from the Mayor and Commission regarding review of public safety considerations for the upcoming season. Vice Mayor Sokolow asserted that while he was in favor of approving the Application, he did not agree with the suggestion that the Town pay for Police and parking services. Commissioner Malkoon also did not believe the Town should change its policy on Friday night events. Mayor Vincent commented that the suggestion could serve to open further discussion with BSO and Staff to revisit special event applications to determine if there is a need for change. He thanked Town Manager Vance for raising the issue of public safety. Vice Mayor Sokolow made a motion, seconded by Commissioner Oldaker, to approve Item 11. e without the Town contributing to BSO security expenses. Motion carried 5-0. 11 .f Taco Craft's Request to Extend Existing Sunday Music Permit Town Manager Vance advised that he did not feel a weekly event throughout the entire year should be categorized as a special event, and suggested that these types of events no longer be designated as such. While he was supportive of the Applications under Items 11 -f and 11 . g, he recommended that their time frames extend only through the remainder of 2019 while Staff reviews the potential need for change. Vice Mayor Sokolow made a motion, seconded by Commissioner Strauss, to extend the permit through December 31, 2019. Motion carried 5-0. Page 8 of 15

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 11. g Special Event Application for Station 44 Weekly Saturday Night Music Annual Permit 10-5-19 through 10-3-20 Mayor Vincent noted that while the Application was filed on behalf of Station 44, the business no longer uses that name. Town Manager Vance recommended that this Application be tabled until the September 26, 2019 meeting. The Commission agreed to table the Item by unanimous consensus. 12.OLD BUSINESS 12. a El Mar Supplemental Design Pricing Vice Mayor Sokolow clarified that the Agenda Item to which Mr. Dodd had referred under Public Comment was actually Item 12. b. Town Engineer Jay Flynn recalled that at the August 27, 2019 meeting, he was asked to evaluate the additional design services presented to the Town by FDOT consultant Erdman Anthony. This scope of services included design for the following: . Pedestrian lighting . Photometries . Hardscaping/landscaping . Irrigation Mr. Flynn noted that the estimates submitted for them by Erdman Anthony appeared to be high. He had reached out to a local firm, EDSA, to determine comparative costs for these items. He noted that Erdman Anthony's estimate also included general items such as meetings with the Town. EDSA's estimate included all of the additional items with the exception of a maintenance of traffic (MOT) plan. Mr. Flynn continued that FDOT's base contract for this project included the following: . Milling, resurfacing, and reconfiguration of vehicular lanes . Widening of the median . Construction a concrete path in the median . Sidewalks on both sides of the roadway . Improved drainage on both sides of the roadway . a basic irrigation system without sprinkler heads Page 9 of 15

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 There is the possibility that pedestrian lighting may be added to the base contract. The additional design contract can installed after FDOT's portion of the work has been completed and can be handled entirely by Lauderdale-By-The-Sea. Mr. Flynn noted that when his firm performed work on East and West Commercial Boulevard, no MOT plan was necessary: this burden was placed entirely on the contractor for less than $10, 000. He added that if all the additional items can be administered in a single contract after FDOT has completed its work, there may not be a need for MOT. If a secondary construction contract is necessary, however, the MOT plan would be required, with the burden placed on the contractor. Mr. Flynn concluded that he had spoken with a representative of Erdman Anthony to request that they take a second look at their estimate. Commissioner Malkoon noted that the greenway concept would connect Fort Lauderdale with the Town through El Mar Drive, and asked if the estimates include connectivity from Flamingo.Drive. Mr. Flynn confirmed that this is part of the estimate. Commissioner Malkoon also recalled that the Erdman Anthony representative had advised French drains were not required, based upon sea level rise. Mr. Flynn stated that Broward County Surface Water Management has jurisdiction over this issue, and has raised the groundwater elevations to which drainage must be designed. French drains are expected to be adequate for a number of years. Commissioner Malkoon concluded that while he agrees that El Mar Drive is in need of improved infrastructure, such as drainage, sidewalks, and pedestrian lighting, he was not convinced that a walkway in the median is necessary. He suggested the Town look into what basic infrastructural elements might cost outside the walkway to determine if undertaking the project on its own is an alternative. Commissioner Strauss recalled there was discussion of whether or not the project took potential sea level rise into consideration at the previous meeting. The representative from Erdman Anthony had replied that the scope did not address this issue. He recommended that this be clarified upon moving forward. Mayor Vincent proposed that the Town have the project redesigned and then make its own determination regarding the median walkway, based on public input. Mr. Flynn cautioned, however, that a typical cross-section of the project includes widening the median, installation of a multipurpose lane, and a sidewalk and valley gutter with 2 ft. of separation from the travel lane. He added that he would not approve this plan if it were Page 10 of 15

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 submitted for a permit, as it does not comply with FDOT Green Book standards requiring 6 ft. of separation from the travel lane. Town Manager Vance advised that the Commission will need to provide direction to the Broward Metropolitan Planning Organization (MPO) regarding the possibility of proceeding with the lower projected costs not associated with FDOT. Another issue is the proposed greenway trail in the median, which is intended to serve as a connector for greenway areas in Broward County. This would also need to be discussed further with the Broward MPO to determine that agency's position. Vice Mayor Sokolow commented that the MPO is likely to require that FDOT be tasked with building the project in order for it to provide state and/or federal funding. The Commissioners and Town Staff discussed potential aspects of the greenway, including sidewalk distance, the median walkway, and other issues. Town Manager Vance emphasized that the pertinent issue will be to convey to the MPO that the Town does not wish to use FDOT's design engineer to perform supplemental work, and that the median walkway may not be wanted by the Town's residents. It was determined that this Item would be tabled until such time as Staff is prepared to bring it back for the Commission's further consideration. 12. b Guaranteed Maximum Price (GMP) for Fire Station #12 Site Improvements This Item was deferred to the September 26, 2019 meeting. 13.NEW BUSINESS 13. a Neighborhood Free Library Program Development Services Director Linda Connors explained that a resident has proposed constructing a small free library for his/her neighborhood. If the Commission is amenable to this type of use in a public right-of-way, Staff would like to establish some minimum standards for the structure, such as: . A "hold harmless" agreement . Review of the location to ensure it is not within a sight triangle . Does not exceed 4 cubic ft. in size or 5 ft. in height . Property owner will include a statement that s/he will maintain the structure properly, with books in good condition Page 11 of 15

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 . If the library does not meet these standards, its removal will be required Mayor Vincent asked if the free libraries would have to be regulated if they were on a homeowner's private property instead of in the right-of-way. Development Services Director Connors advised that the Town would still have an interest in regulating the structure's size and ensuring it does not lie within a sight triangle. The intent is for the free library to be easily accessible to pedestrian traffic. The Commissioners agreed by consensus for Staff to recognize and "grandfather" existing free library structures. 14.COMMISSIONERCOMMENTS Commissioner Strauss extended his condolences on the recent death of resident June Lassel, as well as on the recent hurricane affecting the Bahamas. Commissioner Oldaker thanked Town Manager Vance and Town Staff for addressing a recent garbage issue on his street. He noted that the Town is experiencing service issues with Waste Pro, Inc., and recommended that meetings be scheduled with that provider to address these difficulties. Commissioner Malkoon recognized Staff for their recent hurricane preparation efforts. He also thanked the VFD for their work fighting a fire in the Bel Air neighborhood, and concluded that construction has begun on an apiary near the Municipal Public Works garage. 15.ORDINANCES1ST READING None. 16. ORDINANCES 2ND READING 16. a Ordinance 2019-07 - AN ORDINANCE OF THE TOWN OF LAUDERDALE-BY-THE-SEA, FLORIDA, AMENDING CHAPTER 30 "UNIFIED LAND DEVELOPMENT REGULATIONS" ARTICLE V "ZONING, " DIVISION 2 "DISTRICTS, " SUBDIVISION M "B-1 DISTRICT REGULATIONS, " SECTION 30-271 "B-1 DISTRICT - BUSINESS, " OF THE CODE OF ORDINANCES TO PERMIT WATERFRONT HOTELS AS A CONDITIONAL USE, MODIFYING DISTRICT REGULATIONS AND ESTABLISHING SPECIFIC CONDITIONAL Page 12 of 15

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 USE REQUIREMENTS FOR WATERFRONT HOTEL USES AND FURTHER AMENDING SUBDIVISION Q "SUPPLEMENTAL REGULATIONS"; PROVIDING FOR CODIFICATION, SEVERABILIT^, CONFLICTS, AND AN EFFECTIVE DATE At this time Mayor Vincent opened public comment. Barbara Cole, resident, stated that she was in favor of the proposed Ordinance, as boutique hotels could attract business to the Town's west side. With no other individuals wishing to speak at this time, Mayor Vincent closed public comment. Development Services Director Connors advised that first reading of this proposed Ordinance was approved at the July 19, 2019 Commission meeting. It is being tested on a limited basis, which is why the Ordinance is currently limited to waterfront properties in the B-1 zoning district. There has been one change since first reading: line 101 now refers to 200 sq. ft. rather than 120 sq. ft. This is to maintain consistency with existing Code. Commissioner Oldaker emphasized that the proposed Ordinance is not a zoning change, but a change of use within a zoning district. Development Services Director Connors added that Staff and the Planning and Zoning Board discussed permission of waterfront hotels and decided to introduce them on a small scale. Commissioner Malkoon noted that this may spur interest in redevelopment of waterfront properties in other districts as well. Commissioner Strauss noted that while there has been concern regarding waterfront hotel development in the marina area, any such developments must still comply with Code and be approved by the Town. The nature of conditional use means it would be reviewed by Staff, followed by a public hearing before the Planning and Zoning Board, and ultimately heard by the Town Commission for final approval. Public notice would be posted for each step of the process. Mayor Vincent commented that he was no longer certain this conditional use should be limited to a few properties on the west side, as they can help make the west a more vibrant community. He suggested that zoning may be changed in the future to support additional developments. Town Attorney Susan Trevarthen cautioned that while there is Page 13 of 15

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 no way to broaden this concept as part of tonight's vote, the Commission may take additional action in the future. Vice Mayor Sokolow made a motion, seconded by Commissioner Oldaker, to adopt the Ordinance on second reading. Motion carried 5-0. 17. RESOLUTIONS - PUBLIC COMMENTS 17. a Resolution 2019-29 - A RESOLUTION OF THE TOWN OF LAUDERDALE-BY-THE-SEA, FLORIDA, WAIVING THE TOWN PURCHASING MANUAL; APPROVING AN AGREEMENT WITH AT&T FOR FIBER-OPTIC INTERNET SERVICE; AUTHORIZING THE TOWN MANAGER TO EXECUTE AND IMPLEMENT THE AGREEMENT; PROVIDING FOR AN EFFECTIVE DATE At this time Mayor Vincent opened public comment, which he closed upon receiving no input. Vice Mayor Sokolow made a motion, seconded by Commissioner Oldaker, to authorize the Town Manager to execute and implement an agreement with AT&T for fiber optic services. Motion carried 5-0. 18.QUASI JUDICIALPUBLIC HEARINGS None. Page 14 of 15

Lauderdale-By-The-Sea Regular Town Commission Meeting September 12, 2019 19. ADJOURNMENT With no other business to come before the Commission at this time, the meeting was adjourned at 10:11 p. m. Mayor Chris Vincent ATTEST f ^ x Town Clerk Tedra Alien Y Date Page 15 of 15