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HomeMy WebLinkAboutHE Determination PP 2022-002 The Dunes CITY OF PASCO HEARING EXAMINER IN THE MATTER OF ) FINDINGS OF FACT, CONCLUSIONS OF LAW, PP 2022-002 ) CONDITIONS OF APPROVAL AND The Dunes—Big Sky Developers ) DECISION THIS MATTER having come on for hearing in front of the City of Pasco Hearing Examiner on September 14, 2022, the Hearing Examiner having taken evidence hereby submits the following Findings of Fact, Conclusions of Law,and Decision and Conditions of Approval as follows: I. FINDINGS OF FACT 1. PROPERTY DESCRIPTION: 1.1 Legal: Parcel 8 of Record Survey#1932653, located in Section 7,Township 9 North, Range 29 East,W.M.Records of Franklin County, Washington(Parcel 115210038). 1.2 General Location: Located south of and adjacent Burns Road approximately 3/4 mile west of Broadmoor Boulevard,Pasco, WA 99301 1.3 Property Size: The site contains approximately 47.36 acres(2,063,001.60 sq.ft.). 1.4 Applicant: Big Sky Developers c/o Caleb Stromstad, 5426 N Road 68,Box D-113, Pasco WA 99301. 2. ACCESS: The parcel has access from Burns Road. 3. UTILITIES: Municipal water is available in Burns Road; a 30' sewer main has recently been brought north from West Court Street to service new development in the area. 4. LAND USE AND ZONING: The site was recently rezoned from RT(Residential Transition) to R-3 (Medium-Density Residential; Ordinance 4578)and is vacant. Surrounding properties are zoned and developed as follows: NORTH: RS-20(County)Single Family Dwellings EAST: RT Vacant SOUTH: RT Vacant WEST: R-1 Vacant/SFDUs 5. COMPREHENSIVE PLAN: The Comprehensive Plan indicates the site is intended for medium-density residential development.According to the Comprehensive Plan,medium- density residential development means 6 to 20 dwelling units per acre.The criteria for allocation under the future land use section of Volume H of the Comprehensive Plan(Vol.II, page 17)encourages development of lands designated for medium-density residential uses PP 2022-002 The Dunes-Big Sky Developers Page 1 of 11 when or where sewer is available,the location is suitable for home sites,and there is a market demand for new home sites. Policy H-1-E encourages the advancement of home ownership, and Goal H-2 suggests the City strive to maintain a variety of housing options for residents of the community. Goal LU-2 encourages the maintenance of established neighborhoods and the creation of new neighborhoods that are safe and enjoyable places to live. 6. ENVIRONMENTAL DETERMINATION: The City of Pasco is the lead agency for this project. Based on the SEPA checklist(SEPA 2020-063),the adopted City Comprehensive Plan, City development regulations, and other information, a Mitigated Determination of Non-Significance(MDNS)was issued for this project on July 7, 2022 (WAC 197-11-355). This MDNS was subsequently withdrawn and replaced with a revised DNS on August 29, 2022. This revised DNS has not been appealed. 7. LOT LAYOUT: The proposed preliminary plat contains 222 single-family lots, all of which would have access from dedicated internal streets,via an access/egress point at Burns Road. Additional access/egress points will be required with the extensions of both Sandifer Parkway and Dent Road to the site.The lots range from 4,948 square feet to 15,048 square feet,the average lot size being 6,186 square feet.The area was recently rezoned from RT (Residential Transition)to R-3 (Medium-Density Residential)zoning(Ordinance 4578). The proposal would be consistent with the development standards of the R-3 zoning district per PMC 25.65.050. 8. RIGHTS-OF-WAY: All lots will have frontage on local access roads to be dedicated as part of the plat.All roads will be fully improved and completed with this subdivision.No lots will have direct access to an arterial street. 9. UTILITIES: Municipal water is available via an 8' line in Burns Road. A 30' sewer main has recently been brought north from West Court Street to service new development in the area. 10. IRRIGATION: This parcel is within the Franklin County Irrigation District service area but has been classified as non-irrigatable under the FCID operational standards and specifications because it is not located near any FCID facilities. As such, it is not being served or assessed by FCID. The owner shall be required to build a system within the plat to deliver irrigation water to each of the new lots with proper irrigation easements for all new lines installed. Prior to building of this system an engineering drawing shall be submitted to FCID for review and comments.The development shall comply with RCW 58.17.310. 11. WATER RIGHTS: The assignment of water rights is a requirement for subdivision approval per Pasco Municipal Code Section 21.05.120(1) and Section 3.35.160. If no water rights are available to transfer to the City, the property owner/developer must pay a water right fee in lieu thereof. 12. PREVENT OVERCROWDING: Density requirements of the R-3 zone are designed to address overcrowding concerns. The Comprehensive Plan suggests the property in question be developed with 6 to 20 dwelling units per acre. The proposed plat has a density of approximately 4.7 units per acre, which is well below the Comprehensive Plan density threshold for the area. However, the application for this proposal became vested on January 26, 2022. Ordinance 4575 which codified minimum densities was adopted on January 24, PP 2022-002 The Dunes-Big Sky Developers Page 2 of 11 2022, published on January 27, 2022, and took effect on February 1, 2022. No more than 60 percent of each lot is permitted to be covered with structures per the R-3 standards. 13. PARKS OPEN SPACE/SCHOOLS: There are no City of Pasco parks nearby. Reynolds Middle School and Columbia River Elementary are approximately 1.3 miles to the east of the site along Burns Road; Delta STEM High School is also around 1.3 miles away, traveling east along Burns Road and then south on Broadmoor Road. The City is required by RC W 58.17.110 to make a finding that adequate provisions are being made to mitigate the impacts of the proposed subdivision on the School District. At the request of the School District, the City enacted a school impact fee in 2012. The imposition of this impact fee addresses the requirement to ensure there are adequate provisions for schools. A school impact fee in the amount of $4,700 will be charged for each new single-family dwelling unit at the time of building permit issuance. The Pasco Comprehensive Plan adopted a neighborhood park standard ratio of 2 acres/ 1,000 residents. 14. EFFECTIVE LAND USE/ORDERLY DEVELOPMENT: The density suggested under the Comprehensive Plan is 6 to 20 dwelling units per acre. The developer is proposing a density of 4.7 units per acre, which is well below the target density range for this area. However, the application for this proposal became vested on January 26, 2022; Ordinance 4575 which codified minimum densities was adopted on January 24, 2022, published on January 27, 2022, and took effect on February 1, 2022. Pasco Municipal Code 21.15.010(1) specifies that street patterns shall take into consideration access needed to develop adjacent properties. A revised plat submitted on August 4, 2022, illustrates the extension of Buckingham Drive satisfying this requirement. 15. SAFE TRAVEL & WALKING CONDITIONS: The proposed plat includes adequate streets and sidewalks. Curb, gutter, and sidewalk shall be installed and constructed to current City standards and to the standards of the American's with Disabilities Act (ADA). All lots will have frontage on streets to be dedicated as part of the plat. All roads will be fully improved and completed with this subdivision. As per PMC 21.20.010 Blocks shall not exceed 1,320 feet." Blocks for Lots 14-42 and 56-77 are over 1,320 feet in length.A revised plat submitted on August 4, 2022, confirms the placement of a non-motorized pathway for bicycle or pedestrian use in conformance with PMC 21.15.100 providing access of exceptionally long blocks. 16. ADEQUATE PROVISION OF MUNICIPAL SERVICES: All lots within the plat will be provided with water, sewer, and other utilities. This parcel is within the Franklin County Irrigation District service area but has been classified as non-irrigatable under the FCID operational standards and specifications because it is not located near any FCID facilities. See Findings of Fact No. 10 above. 17. PROVISION OF HOUSING FOR STATE RESIDENTS: The proposed plat contains 222 single-family lots providing the opportunity for the construction of 222 new dwelling units in Pasco. 18. ADEQUATE AIR AND LIGHT: The maximum lot coverage limitations, building height restrictions, and building setbacks will assure that adequate movement of air and light is available to each lot. PP 2022-002 The Dunes-Big Sky Developers Page 3 of 11 19. PROPER ACCESS & TRAVEL: The plat will be developed to City standards to assure proper access is maintained to each lot. A connection will be made to the Burns Road access/egress point. Additional access/egress points will be required with the extensions of both Sandifur Parkway and Dent Road to the site. All lots will have frontage on streets to be dedicated. Pasco Municipal Code 21.15.010(1) specifies that street patterns shall take into consideration access needed to develop adjacent properties. A revised plat submitted on August 4, 2022, illustrates the future extension of Buckingham Drive satisfying this requirement. As per 21.20.020 "The width of the block under normal conditions shall be sufficient to allow for two tiers of lots with easements. One tier of lots shall be provided between a local access street and an arterial." The Future Street Functional Classification System designates both Burns Road and Sandifur Parkway as Arterial Streets. As such, single-tier lots with estate fences would be justified when these are developed as arterial streets as per the Comprehensive Plan. Streets not intended to be Arterials should not have a single tier of lots next to them. Dent Road (Road 115) is designated as a collector Street; blocks for Lots 55-74 should be double-tiered along Dent Road (Road 115). However, the design of one-tier of lots on Dent Road is permitted due to the alignment of the existing sewer trunk main designed and approved by the Pasco Public Works Department, which presents a specific condition in which conformance with PMC 21.20.020 is not feasible. 20. COMPREHENSIVE PLAN POLICIES & MAPS: The Comprehensive Plan designates the plat site for medium-density residential development. Policies of the Comprehensive Plan encourage the advancement of home ownership and the City maintain a broad range of residential land use designations to accommodate a variety of housing opportunities. 21. Housing Goals and Policies of the Comprehensive Plan that pertain to this development include: H-1: Encourage housing for all economic segments of the city's population; H-2: Strive to maintain a variety of housing consistent with the local and regional market; Policy H-2-A: Allow for a full range of residential environments including single family homes, townhomes, condominiums, apartments and manufactured housing. 22. The applicant is proposing to construct 222 single-family lots at a density of 4.7 dwelling units per acre. The proposed density is not within the threshold density for the Medium- Density Area. However, the application for this proposal became vested on January 26, 2022. Ordinance 4575 which codified minimum densities was adopted on January 24, 2022, published on January 27, 2022, and took effect on February 1, 2022. As such, strict compliance with density standards is not required for this plat. See Finding of Fact No. 12, above. 23. The Public Notice was mailed out and published in the Tri-City Herald on August 22, 2022. 24. The site is within the City of Pasco. 25. The State Growth Management Act requires urban growth and urban densities to occur within the Urban Growth Boundaries. 26. The site is zoned R-3 (Medium-Density Residential). 27. A rezone from RT to R-3 was approved in 2022. 28. The minimum lot area in the R-3 zone for single-family dwellings is 4,500 square feet PP 2022-002 The Dunes-Big Sky Developers Page 4 of 11 29. The site is vacant. 30. The site is considered a shrub-steppe habitat. The applicant is required to pay a mitigation for the shrub-steppe habitat, as referenced in the grading permit for this site. 31. The site's Comprehensive Plan designation is for Medium-Density Residential development. 32. Medium-Density Residential development specifies 6 to 20 dwelling units per acre. 33. The developer is proposing 4.7 dwelling units per acre, which is well below the Comprehensive Plan density range for the area. 34. The application for this proposal became vested on January 26, 2022. 35. Ordinance 4575 which codified minimum densities took effect on February 1, 2022, after the present plat application was vested. 36. Lots 34, 35, 36, 55, 56, 73, 74, and 75 are located on street"knuckles." 37. Furthermore, lots over 10,000 square feet are required to have a minimum of 90' of frontage unless located on a cul-de-sac. 38. Lots 34, 35, 36, and 55 exceed the 10,000 sq. ft. lot size threshold and are located on street "knuckles." 39. PMC 21.10.020 defines a cul-de-sac as "a road closed at one end by a circular area of sufficient size for turning vehicles around". 40. Knuckles do not qualify as cul-de-sacs as they are not a closed road/not a road at all. 41. The design and use of"knuckles" are not specifically identified in the Pasco Municipal Code or the City Design and Construction Standards. 42. Because "knuckles" are not cul-de-sacs, the Applicant will have to design the lot sites and/or configurations so that they all comply with the PMC. 43. Development phasing is set up in such a way that Dent Road and Sandifur Parkway would not be improved until the final phase, making secondary accesses unavailable until the final phase of development. This is both a traffic and fire concem. 44. Two separate and approved Apparatus access roads must be provided where the number of dwelling units exceeds 30. 45. Access roads must be placed not less than 1/2 of the length of the maximum overall diagonal dimension of the property or area to be served, measured in a straight line between accesses, as per IFC Section D 106.3 46. Two access roads are required for each phase as outlined. PP 2022-002 The Dunes-Big Sky Developers Page 5 of 11 47. As per IFC Section D 106.3., access roads must be placed not less than 1/2 of the length of the maximum overall diagonal dimension of the property or area to be served, measured in a straight line between accesses. 48. The Housing Element of the Comprehensive Plan encourages the advancement of programs that promote home ownership and development of a variety of residential densities and housing types. 49. The Transportation Element of the Comprehensive Plan encourages the interconnection of neighborhood streets to provide for the disbursement of traffic. 50. The interconnection of neighborhood streets is necessary for utility connections(looping)and the provision of emergency services. 51. Pasco Municipal Code 21.15.01 0(l)specifies that street patterns shall take into consideration access needed to develop adjacent properties. 52. All lots will have frontage on future streets as part of the plat. 53. Per the ITE Trip Generation Manual 9th Edition, the proposed subdivision, when fully developed,will generate approximately 2,113.44 trips per day (9.52 trip/unit * 222 units). 54. The current park impact fee is $1,679 per dwelling unit. 55. RCW 58.17.110 requires the City to make a finding that adequate provisions have been made for schools before any preliminary plat is approved. 56. The City of Pasco has adopted a school impact fee ordinance compelling new housing developments to provide the School District with mitigation fees. The fee was effective April 16,2012. 57. Past correspondence from the Pasco School District indicates impact fees address the requirement to ensure adequate provisions are made for schools. 58. Plat improvements within the City of Pasco are required to comply with the 2020 Standard Drawings and Specification as approved by the City Engineer. These improvements include but are not limited to water, sewer and irrigation lines, streets, streetlights, and storm water retention. 59. Handicapped-accessible pedestrian ramps are to be completed with the street and curb improvements prior to final plat approval. 60. Sidewalks are installed at the time permits are issued for new houses, except sidewalks along major streets,which are installed with the street improvements. 61. The assignment of water rights is a requirement for subdivision approval per Pasco Municipal Code Section 21.05.120(1)and Section 3.35.160. 62. If no water rights are available to transfer to the City the property, owner/developer must pay a water right fee in lieu thereof. PP 2022-002 The Dunes-Big Sky Developers Page 6 of 11 63. The developer is responsible for all costs associated with construction, inspection, and plan review service expenses incurred by the City Engineering Office. 64. The City has nuisance regulations (PMC 9.60) that require property owners (including developers) to maintain their properties in a manner that does not injure, annoy, or endanger the comfort and repose of other property owners. This includes controlling dust, weeds and litter during times of construction for both subdivisions and buildings including houses 65. An open record public hearing after due legal notice was held on September 14, 2022 via Zoom videoconference. 66. Appearing and testifying on behalf of the Applicant at the hearing were Mark Fickes, attorney for the Applicant, and Caleb Stromstad. Mr. Fickes provided legal argument regarding the Plat. He indicated that all Conditions of Approval were acceptable. However, there were some questions. 67. Regarding proposed Condition of Approval No. 1, he asked that language from the September 14, 2022 email from Caleb Stromstad to Rick White be included as a part of proposed Condition of Approval No. 1. 68. Mr. Fickes argued that proposed Conditions of Approval No. 2 and 4 were not really Conditions of Approval. 69. Finally, Mr. Fickes asked that proposed Condition of Approval No. 10 be limited only to those overhead utilities serving this specific plat. 70. Mr. Stromstad testified that he was also an agent authorized to appear and speak on behalf of the Applicant and property owner. He agreed with Mr. Fickes on the revisions to the proposed Conditions of Approval. 71. Mr. Stromstad confirmed that some of the overhead lines to do not serve this specific subdivision. 72. No member of the public testified at the hearing. 73. The staff report, application materials, agency comments and the entire file of record were admitted into the record. 74. Any Conclusion of Law that is more correctly a Finding of Fact is hereby incorporated as such by this reference. II.CONCLUSIONS OF LAW Before recommending approval or denial of the proposed Plat the Hearing Examiner must develop findings of fact from which to draw its conclusion(PMC 21.25.060)therefrom as to whether or not: 1. Adequate provisions are made for the public health,safety and general welfare and for open spaces, drainage ways, streets, alleys, other public ways, water supplies, sanitary wastes, parks, playgrounds, transit stops, schools and school grounds, sidewalks for safe walking conditions for students and other public needs. 1.1 The proposed plat will be required to develop under the standards of the Pasco Municipal Code and the standard specifications of the City Engineering Division. These standards for streets, sidewalks, and other infrastructure improvements were PP 2022-002 The Dunes-Big Sky Developers Page 7 of 11 designed to ensure the public health, safety, and general welfare of the community. These standards include provisions for streets, drainage, water and sewer service and the provision for dedication of right-of-way. The preliminary plat was forwarded to the PUD, the Pasco School District, Cascade Gas, Charter Cable, Franklin County Irrigation District, and Ben-Franklin Transit Authority for review and comment. As per International fire Code (IFC) Section D107, no more than 30 lots will be allowed without the dedication of ROW and development of secondary access into the subdivision. 1.2 Based on the School District's Capital Facilities Plan the City collects school mitigation fees for each new dwelling unit. The fee is paid at the time of building permit issuance. The school impact fee addresses the requirements of RCW 58.17.110. All new developments participate in establishing parks through the payment of park fees at the time of permitting. 2. The proposed subdivision contributes to the orderly development and land use patterns in the area. The proposed Plat makes efficient use of vacant land. 2.1 The proposed subdivision will provide street improvements within the plat as per City standards. A connection will be made to Burns Road to the west. The applicant is proposing to construct 222 single-family lots at a density of 4.7 dwelling units per acre; the proposed density is not within the threshold density for the Medium-Density Area. However,the application for this proposal became vested on January 26, 2022; Ordinance 4575 which codified minimum densities was adopted on January 24,2022, published on January 27, 2022, and took effect on February 1, 2022. As such, strict compliance with density standards is not required for this plat. 3. The proposed subdivision conforms to the policies, maps, and narrative text of the Comprehensive Plan. 3.1 The Comprehensive Plan land use map designates the site and all surrounding properties for Medium-Density Residential development and may be developed with single family homes, townhomes, condominiums, apartments and manufactured housings. 3.2 Medium-Density Residential specifies development at a density of 6 to 20 dwelling units per acre_ Policies of the Comprehensive Plan encourage the advancement of home ownership and suggest the City strive to maintain a variety of housing for residents. 3.3 The plat indicates a density of 4.7 dwelling units per acre, which does not meet the density range established by the Comprehensive Plan. However, the application for this proposal became vested on January 26, 2022; Ordinance 4575 which codified minimum densities was adopted on January 24, 2022,published on January 27, 2022, and took effect on February 1, 2022. As such, strict compliance with density standards is not required for this plat. 3.4 The Housing Element of the Plan encourages the promotion of a variety of residential densities and suggests the community should support the advancement of programs encouraging home ownership. The Plan also encourages the interconnection of local streets for inter-neighborhood travel for public safety as well as providing for traffic disbursement. PP 2022-002 The Dunes-Big Sky Developers Page 8 of 11 4. The proposed subdivision conforms to the general purposes of any applicable policies or plans which have been adopted by the City Council. 4.1 Development plans and policies have been adopted by the City Council in the form of the Comprehensive Plan. The proposed subdivision conforms to the policies, maps, and narrative text of the Comprehensive Plan as noted in number three above. 5. The proposed subdivision conforms to the general purposes of the subdivision regulations. 5.1 The general purposes of the subdivision regulations have been enumerated and discussed in the staff analysis and Findings of Fact. Housing Goals and Policies of the Comprehensive Plan that pertain to this development include Housing Goal H-1: Encourage housing for all economic segments of the city's population;Housing Goal H-2: Strive to maintain a variety of housing consistent with the local and regional market; Housing Policy H-2-A: Allow for a full range of residential environments including single family homes, townhomes, condominiums, apartments and manufactured housing. 5.2 The applicant is proposing to construct 222 single-family lots at a density of 4.7 dwelling units per acre. The proposed density is not within the threshold density for the Medium-Density Area. However, the application for this proposal became vested on January 26, 2022; Ordinance 4575 which codified minimum densities was adopted on January 24, 2022, published on January 27, 2022, and took effect on February 1, 2022. As such, strict compliance with density standards is not required for this plat. 5.3 The Findings of Fact indicate the subdivision is in conformance with the general purposes of the subdivision regulations provided certain mitigation measures (i.e., school impact fees are paid). 6. The public use and interest will be served by approval of the proposed subdivision. 6.1 The proposed plat, if approved, will be developed in accordance with all City standards designed to ensure the health,safety and general welfare of the community are met. The Comprehensive Plan will be implemented through development of this plat.These factors will ensure the public use and interest are served. 7. Any Finding of Fact that is more correctly a Conclusion of Law is hereby incorporated as such by this reference. III. CONDITIONS OF APPROVAL All conditions imposed by this decision shall be binding on the applicant,which includes the owner or owners of the properties,heirs, assigns,and successors. 1. Project must participate in a proportional share of the improvements for the intersection improvements at Broadmoor Boulevard and Burns Road, the cost of which shall be not less than $846/trip and not to exceed $1,753/trip. This shall be implemented through a voluntary agreement under RCW 82.02.020 to be prepared by the City and reviewed and reasonably approved by the Applicant prior to final plat approval, with the Applicant's final proportionate share based upon the City's adopted traffic improvement plans for the intersection, commercially reasonable cost estimates for the project, and past email communications between staff and the Applicant. PP 2022-002 The Dunes-Big Sky Developers Page 9 of 11 2. Street patterns shall take into consideration access needed to develop adjacent properties, as per Pasco Municipal Code 21.15.010. 3. All improvements shall be in accordance with the Pasco Municipal Code. The Pasco Municipal Code adopts the most recent versions of the City of Pasco Standard Specifications, the Washington State Department of Transportation Standard Specifications for Road, Bridges, and Municipal Construction, the International Building Code, and the International Fire Code. If there are any conflicting regulations in any of these documents, the more stringent regulation shall apply. 4. Two separate and approved Apparatus access roads shall be provided where the number of dwelling units exceeds 30. 5. Access roads shall be placed not less than 1/2 of the length of the maximum overall diagonal dimension of the property or area to be served, measured in a straight line between accesses, as per IFC Section D106.3. 6. The face of the final plat shall include this statement: "As a condition of approval of this final plat the owner waives the right to protest the formation of a Local Improvement District for sewer/water/road/sidewalk improvements to the full extent as permitted by RCW 35.43.182. 7. The face of the final plat shall include this statement: "The individual or company making improvements on a lot or lots of this plat is responsible for providing and installing all trench, conduit, primary vaults, secondary junction boxes, and backfill for the PUD's primary and secondary distribution system in accordance with PUD specifications; said individual or company will make full advance payment of line extension fees and will provide all necessary utility easements prior to PUD construction and/or connection of any electrical service to or within the plat." 8. Any existing water rights associated with the subject property shall be transferred to the City as a condition of approval. If no water rights are available then the property owner, in accordance with PMC 21.05.120, shall pay to the City, in lieu thereof, a water rights acquisition fee as established in the City Fee Summary Ordinance as identified in PMC 3.35. 9. Only City and other utilities with franchise agreements are allowed in the public right of way. 10. Overhead utilities serving this specific plat are required to be re-routed below ground. 11. It shall be the responsibility of the property owner/developer to contact all utility owners to determine their system improvement requirements. Prior to subdivision construction plan submittal and/or review the property owner/developer shall provide to the City of Pasco written support/approval of the proposed development from all outside utilities, public and private. 12. All fee payments for bonding of ROW improvements and Water Rights must be paid at the time of Final Plat being submitted for signatures. 13. Because "knuckles" are not cul-de-sacs as defined by the PMC, the Applicant shall redesign the lot sizes and/or configurations so that all lots comply with all provisions of the PMC. IV. DECISION Based on the above Findings of Fact and Conclusions of Law, the Hearing Examiner APPROVES the application for a Preliminary Plat subject to the Conditions of Approval. PP 2022-002 The Dunes-Big Sky Developers Page 10 of 11 Dated this_;�day of September, 2022. CITY PA :)?BARING EXAMINER 1 rew L.Ko6k-amp Absent a timely appeal,this Decision is final' 1 See Ch. 36.70C RCW(establishing a 21 day appeal period to superior court,and setting forth necessary review contents,along with filing and service requirements). PP 2022-002 The Dunes-Big Sky Developers Page 11 of 11