Cascade Crest Fuel Break

Transcription

1 DECISION NOTICE And FINDING OF NO SIGNIFICANT IMPACT Cascade Crest Fuel Break USDA FOREST SERVICE MT. HOOD NATIONAL FOREST CLACKAMAS RIVER RANGER DISTRICT CLACKAMAS AND MARION COUNTIES, OREGON An Environmental Assessment (EA) has been prepared for Cascade Crest Fuel Break. This area is located in T.7S., R.8E.; T.8S., R.8E.; T.7S., R.8½ E.; T.9S., R.8E.; Willamette Meridian. All section (s.) number references are to sections of the EA unless specified otherwise. Acres and miles are approximate. This document discusses the creation of a shaded fuel break in the area north of Olallie Lake. A shaded fuel break is a strip of land where woody debris and other fuels have been reduced and trees spaced out so that fire suppression forces can work safely in the event of a wildfire. The project area has high fire hazard due to a continuing mountain pine beetle infestation that is killing lodgepole pine trees. Purpose and Need The purpose of this project is to aid in the suppression of wildfires. The goal is to keep small fires from becoming large. If no action is taken, a large scale wildfire could impact resources on the Forest and tribal historic properties, first foods, medicinal plants and other resources. The proposed fuel break is close to the reservation boundary. The location and design of the proposed fuel break were developed in cooperation with the Tribal Council of the Confederated Tribes of the Warm Springs Reservation. Large wildfires on the Forest/Reservation boundary have happened in past and are likely to happen again. There would be many additional benefits and opportunities: There is a concern for firefighter safety. If no action is taken, a large scale wildfire would put firefighters at risk, more time and forces would be needed to establish effective fire lines, and the fire would grow larger. One goal is to reduce fuels in the fuel break so that flame lengths would be four feet or less. This would permit fire suppression forces to effectively use direct or indirect fire suppression methods, as needed, along roads 4220 and This would help to reduce the risk of small fires becoming large. Currently, fire models indicate that flame lengths would be up to approximately 100 feet. Cascade Crest Fuel Break Decision Notice - Page 1 of 12

2 The suppression of a large wildfire can be extraordinarily expensive. It is more cost effective to reduce fuels and establish potential control lines in advance so that fires can be kept smaller. There is a concern about public safety. Road 4220 (south of the 4690 junction) is a primitive road and is the only access to the Olallie Lake area: a heavily used recreation area. The fuel break would reduce fire intensity along road 4220 and public safety would be enhanced in the event of a wildfire requiring evacuation of the Olallie area. There is a concern about the impacts wildfire would have to spotted owls and their habitat. Reducing wildfire size would result in reduced impacts to the Late- Successional Reserve (LSR) and species dependant on late-successional habitats. The LSR Assessment addresses the need to suppress fire in LSRs. There is a concern about the impacts wildfire would have to scenery and recreation. There is also the opportunity to remove and utilize the biomass as timber, firewood or other products. Section 4.1 contains a detailed discussion of the area s fire hazard and risk and elaborates on how a fuel break would fit on the landscape. Section describes the increasing fire hazard caused by dead and dying trees, by dense vegetation and the accumulation of fuels on the ground. Sections & discuss fire suppression tactics and contrast the scenarios for action and no action. DECISION and RATIONALE I have decided to select Alternative C. (s. 3.2). It is similar to the proposed action but would include only the portion north of the power line. This alternative includes: Cascade Crest Fuel Break A continuous shaded fuel break approximately 500 feet wide would be created adjacent to roads 4230 and Approximately 741 acres would be treated. These roads are a critical element to the success of the fuel break and are generally in the middle of the fuel break except in some areas where the fuel break is shifted somewhat to one side due to topographic and resource issues. The fuel break would be wider in three places to provide safe areas for suppression crews (see maps in Appendix A). Basic Fuel Break Prescription The following measures are designed to achieve the objective of 4-foot flame lengths. Cascade Crest Fuel Break Decision Notice - Page 2 of 12

3 Live trees would be retained at a spacing of approximately 20 feet between the outside edge of the crown. The largest live trees would be retained except in lodgepole pine areas described below. All other trees not needed to make up this leave tree spacing and all snags would be felled. Prune trees to 50% of height or 16 feet whichever is less. Cut shrubs that contribute to ladder fuels. The removal of biomass would be encouraged where feasible. Biomass or fuel that is not removed would be piled and burned. Cleanup and slash piling would be kept current with operations so that increased fire hazard does not occur with untreated slash and debris. Most lodgepole pine stands in this area are dead, dying or may soon die from an ongoing mountain pine beetle infestation. These lodgepole pine trees average 10 inches in diameter. In some of these stands there is an understory of other tree species including mountain hemlock and Douglas-fir that are not susceptible to attack by mountain pine beetle. In these areas, the largest trees of species other than lodgepole pine would be retained where available. Live lodgepole pine would only be retained if they are the only species available. There are areas where most of the lodgepole are dead and where there are insufficient other species to meet the spacing guidelines above. These areas are often quite dense with naturally occurring seedlings or saplings. They would be retained at the spacing listed above. Riparian Apply the basic fuel break prescription in riparian reserves except as described below. These riparian treatments have the objective of minimizing effects to riparian resources while still providing an effective overall fuel break. Three stream courses would have a 50-foot wide buffer on either side of streams. These are Lemiti Creek, South Fork Lemiti Creek and Olallie Creek. These buffers would be wider where appropriate to include adjacent wet areas and meadows. The buffer would have no treatment except within 100 feet of road 4220 or campgrounds where snags would be felled. Adjacent to the no treatment buffers, extending out 50 feet, treatments would be done by hand with no ground-based equipment. Equipment would be allowed on roads. Along other streams (intermittent) there would be a 10-foot wide buffer. The buffer would have no treatment except within 100 feet of road 4220 or campgrounds where snags would be felled. Adjacent to the no treatment buffers, extending out 25 feet, treatments would be done by hand with no ground-based equipment. Equipment would be allowed on roads. Campgrounds In Triangle Lake Horse Campground and Olallie Meadow Campground, treatments have the objective of minimizing effects to campers while still providing an effective overall fuel break. Where feasible, provide visual screening between camp sites. Fall snags. Cascade Crest Fuel Break Decision Notice - Page 3 of 12

4 Equipment would be allowed only on roads. Remove resulting material and existing debris on the ground for disposal elsewhere. Scenic Area Within the Olallie Lake Scenic Area (approximately 115 acres), apply the basic fuel break prescription except as described below. These treatments in the Scenic Area have the objective of minimizing effects to scenery and recreation while still providing an effective overall fuel break. Leave tree spacing would not be uniform with some trees left in clumps. Some trees would be left unpruned. The width of the fuel break boundary would average the distances shown on the project map but the boundary would be irregular to avoid straight sight lines. Mechanical and hand treatment would occur based on topography. Mechanical treatments would be more common in the northern section of the Scenic Area and hand treatments would be more common in the south. Minimize ground disturbance by using techniques such as over-snow biomass removal in sensitive areas and having small landings only within the road prism. Stumps would be cut low. Debris cleanup, piling and burning would be kept current with operations so that only short sections of road 4220 would be visually altered at any one time. If tree marking paint is used on leave trees it would only be used on the portion of the bole not seen from the road. Wildlife Apply the basic fuel break prescription except as described below. These treatments in certain wildlife habitats would minimize effects to wildlife while still providing an effective overall fuel break. Great gray owl: There is potential nesting habitat for great gray owls in the mature stands directly adjacent to Olallie Meadow, however none have been observed there. Because surveys take multiple years to complete, it is presumed at this time that the owls are present. Mature stands that have trees 23 inches or greater in diameter within 200 meters of the meadow would have the following treatments: pruning, the removal of down material, and cutting hazardous snags within 100 feet of road 4220 or Olallie Meadow Campground. A seasonal restriction would be in place from March 1-July 15 for work within ¼ mile of the meadow to reduce the chance of disruption of nesting efforts by owls. This would be waived if the area is eventually surveyed to protocol and found to be unoccupied. Crater Lake tightcoil: This snail is generally found in mid to high elevation habitat adjacent to perennial wet areas. It was found at two locations in the project area. A notreatment buffer approximately 100 feet wide or greater would be applied in these two areas. The buffer would be tailored to site-specific conditions. Cascade Crest Fuel Break Decision Notice - Page 4 of 12

5 Other Some protections are needed for historic and prehistoric resources while still providing an effective overall fuel break. The site-specific treatments are described in detail in s Maintenance After the fuel break is established, it would be expected that only minor work would be needed such as the felling of trees that have since died. However, after approximately 10 to 15 years, regular maintenance is expected. Over time, seedlings and brush would grow up and trees may die or fall into the fuel break. Periodic monitoring would identify when vegetation density or arrangement crosses the threshold of allowable fire behavior (maximum flame length of four feet) and maintenance is needed to allow the fuel break to continue to meet objectives. Some of the work of creating the fuel break and maintaining it over time, may be accomplished by agency firefighting crews when there are no active wildfires. The Forest has a Hotshot crew and an Initial Attack crew (40 people) and two fire engine crews that are fully funded throughout the summer. These crews can accomplish this type of project work before and after the main fire season and when waiting for a fire to occur during the summer. Best Management Practices (BMPs) and Design Criteria in section of the EA are included. No significant impacts were found that would require further mitigation. The selected alternative meets the purpose and need discussed in the EA (s. 2.2). It will result in a shaded fuel break that will aid in the suppression of wild fires. It is not intended to stop a fire by itself, but it will create a safe area to conduct direct or indirect fire suppression operations. Without a fuel break, suppression forces would advance much more slowly because they would have to rely more on heavy equipment to create fire lines. It would also result in greater protection for tribal resources and would facilitate the evacuation of the Olallie Lake area recreation sites. It would also result in the removal of approximately 8,000 tons of biomass in the form of logs, firewood, and other material that could be used to generate electricity or for other uses. Public Involvement A letter describing the proposed project and requesting comments was sent out in May The Forest publishes a schedule of proposed actions (SOPA) quarterly. The project first appeared in July 2007, and in subsequent issues. A field trip for interested publics was conducted on July 31, A 30-day comment period ended on April 23, As a result of comments received and ongoing collaborations with tribes and stakeholders, changes were made including the development of an additional alternative. A second 30- day comment period ended on July 27, Responses to substantive comments are included in Appendix B. Cascade Crest Fuel Break Decision Notice - Page 5 of 12

6 It is my decision to select the Alternative C over the other alternatives considered for the following reasons: It accomplishes the purpose and need. Even though the fuel break is shorter than in the proposed action, it is still viable. The concern raised by the public about the integrity of the resources and scenery in the Olallie Lake area and along the road leading to the Olallie Lake area have been resolved to my satisfaction (s ). I understand that the Olallie Lake area is a backcountry scenic recreation area that is important to many people and that the fuel break is along the road leading to Olallie Lake. I also understand that the fire hazard in the area is high and it is prudent to take reasonable measures to protect not only forests and habitats but scenery and recreational values. I have decided that Alternative C is the best mix for this area because: o Scenery would be protected by measures described in s such as cleaning up slash and low cut stumps. o The fuel break would only be north of the power line which is 2.4 miles away from Olallie Lake. o Leave trees would be variably spaced. o Trees that are dead would be removed. A related issue for some people is that they don t want to see visual alternations in this area because they don t believe that fires are likely to burn or they see fire as natural and the agency should allow them to burn. The analysis in s. 4.1 and my visits to the area have convinced me that fire hazard is high and that action is needed and appropriate for this area. My conclusion is also based on a review of the record that shows a thorough review of relevant scientific information and a consideration of responsible opposing views. The resource and social values that are important in this area would be dramatically harmed by a large stand replacing wild fire and it is appropriate to take actions to minimize the impact and keep wild fires as small as possible. I am sensitive to the concerns about the Olallie Lake area. It is a special place that warrants the extra design features prescribed (in section and included above) to minimize scenic and recreational impacts. Description of Other Alternatives and Reasons for Non Selection: Alternative A is the no-action alternative (s. 3.1). It was not selected because it would not provide any of the benefits described in the purpose and need. If no action is taken a large scale wildfire could impact resources on the Forest and tribal historic properties, first foods, medicinal plants and other resources. If no action is taken, a large scale wildfire would put fire suppression forces at risk, more time and forces would be needed to establish effective fire lines, and the fire would grow larger. Cascade Crest Fuel Break Decision Notice - Page 6 of 12

7 Alternative B was the proposed action (s. 2.3). Even though it would best meet the purpose and need, it was not selected because of the concerns expressed by the public about the scenery on the route to Olallie Lake. Alternatives Considered but Eliminated from Detailed Study (s. 3.3) The EA discusses comments that were received suggesting the consideration of other alternatives or ways to modify this project. Details of the suggestions and responses are in the EA at s. 3.3 as well as Appendix B. FINDING OF NO SIGNIFICANT IMPACT (40 CFR ) Based on the site-specific environmental analysis documented in the EA and the comments received from the public, I have determined that this is not a major Federal action that would significantly affect the quality of the human environment; therefore, an Environmental Impact Statement is not needed. This determination is based on the design of the selected alternative and the following factors: 1. My finding of no significant environmental effect is not biased by the beneficial effects of the action. Impacts can be both beneficial and adverse. For this project, there are no know long-term adverse effects or cumulative effects to resources such as water quality, riparian areas, wildlife or heritage resources. These are documented in section 4 of the EA. The project was found to have no effect to listed fish (4.3.13) and it would not likely jeopardize the continued existence of the spotted owl ( ). 2. The project contains design features to protect the public during project implementation including the removal of hazard snags (s. 2.3). After the fuel break is installed there would be important safety advances that would protect the public in the event of a fire related evacuation of the Olallie Lake area (s , s ). 3. There will be no significant effects on unique characteristics of the area. The project is not located in prime farmland or wetlands (s. 4.15), historic and cultural resources have been protected (s. 4.13), it will not impact wild and scenic rivers (s. 3.2). The project will aid in the suppression of wildfires that could threaten the unique character of the Olallie Lake area farther to the south. 4. The effects on the quality of the human environment are not likely to be highly controversial. Public comments suggested that I review certain literature that they claim would discredit the proposal or the analysis of effects. Appendix B of the EA contain responses to this literature. I have concluded that the science is not highly controversial based on a review of the record that shows a thorough review of relevant scientific information. There are some opposing views that I have considered and I recognize that there are certain unknown factors about the future possibility of fire ignition or whether Cascade Crest Fuel Break Decision Notice - Page 7 of 12

8 insect mortality will continue to spread across the landscape. I acknowledge this and I have decided that Alternative C is the best strategy. (Opposing views are addressed in s. 3.3, s , s ). 5. The possible effects on the human environment of the fuel break project are not highly uncertain, nor do they involve unique or unknown risks. The effects analysis discussed in Section 4 of the EA are based on sound scientific research and previous experience. 6. The action is not likely to establish a precedent for future actions with significant effects because this action is not unusual in and of itself, nor does it lead to any further actions that are unique. A similar fuel break has been planned for The Dalles municipal watershed. Fuel breaks have been constructed in many areas across the west (4.1.5). 7. The analysis found no significant cumulative effects. Cumulative effects were assessed in each section of the EA including recreation (s ), fish and water quality (s ), and owls (s ). The analysis considered not only the direct and indirect effects of the fuel break, but also its contribution to cumulative effects. Past, present and foreseeable future projects and recent wildfires have been included in the analysis (s to 4.0.4). The analysis considered the proposed actions with BMPs and design criteria. 8. The action will have no significant adverse effect on districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places and will not cause loss or destruction of significant scientific, cultural, or historical resources. 9. My decision is consistent with the Endangered Species Act. Formal consultation with U.S. Fish & Wildlife Service concerning the northern spotted owl has been completed for this project. The 2008 Biological Opinion from the U.S. Fish & Wildlife Service concurs with the determination that the proposed project may affect, and is likely to adversely affect spotted owls but that it would not jeopardize the owl s continued existence (s ). This project does not occur in Critical Habitat as identified in the May 2008 Recovery Plan. Since this project would have no effect to listed Fish species, consultation is not necessary (s , s ). There will be no significant adverse effects to sensitive species or special status species (s , s , & s. 4.7). The project will not jeopardize the continued existence of any listed species nor will it cause a trend to federal listing or loss of viability for any proposed or sensitive species. 10. My decision will not violate Federal, State, and local laws or requirements for the protection of the environment. Applicable laws and regulations were considered in the EA (s , s. 4.9). The action is consistent with the Mt. Hood Land and Resource Management Plan (each part of section 4). The selected alternative is consistent with the National Forest Management Act regulations for vegetative management. There will be no regulated timber harvest on lands classified as unsuitable for timber production (36 CFR ) and vegetation manipulation is in compliance with 36 CFR (b). The project Cascade Crest Fuel Break Decision Notice - Page 8 of 12

9 complies with Executive Order regarding environmental justice (s. 4.14). No disproportionately high adverse human or environmental effects on minorities and/or lowincome populations were identified during the analysis and public information process. CONSISTENCY WITH MT. HOOD FOREST PLAN I find that the selected alternative is consistent with direction found in the Mt. Hood National Forest Land and Resource Management Plan as amended (Forest Plan). It is consistent with standards and guidelines specific to the relevant land allocations and it is consistent with the applicable Forest-wide standards and guidelines (s & s. 4). o Aquatic Conservation Strategy - I find that the selected alternative is consistent with riparian reserve standards and guidelines. It will contribute to maintaining or restoring aquatic conditions and is consistent with the Aquatic Conservation Strategy objectives (s & Biological Evaluation). I have considered the relevant information from the Upper Clackamas Watershed Analysis. This project has adopted the concepts for riparian reserve delineation described in the watershed analyses (s ). The site-potential tree height for this project is 180 feet. I find that the Best Management Practices and project design criteria (s & s ), such as stream protection buffers and operating restrictions on ground based machinery, will minimize impacts and maintain the function of key watershed indicators that make up elements of the Aquatic Conservation Strategy. These key indicators for water quality, habitat, flow, channel condition, and watershed condition, will be maintained or enhanced (s ). I find that the fuel break would provide appropriate protection to riparian reserves and aquatic resources both in the project area and across the landscape (s ). o Management Indicator Species - I have considered the impacts to Forest Management Indicator Species (s ). Management Indicator Species for this portion of the Mt. Hood National Forest include northern spotted owl (s. 4.4), pileated woodpecker, pine marten (s ), deer, elk (s ), salmonid smolts and legal trout (s. 4.3). I find that the selected alternative is consistent with the standards and guidelines pertaining to Management Indicator Species. o Invasive Plants - I find that the selected alternative is consistent with Pacific Northwest Invasive Plant Program Preventing and Managing Invasive Plants Record of Decision issued in 2005 (s. 4.8). Design criteria are included to prevent the spread and establishment of invasive plants (s #2 &5). Cascade Crest Fuel Break Decision Notice - Page 9 of 12

10 o Compliance with the 2001 Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines (2001 ROD). (s , s , s ). I have reviewed the relevant sections in the Environmental Assessment for species listed in the 2001 ROD and I find this decision to be consistent with the 2001 ROD. Specifically: I find that prior to surveys; no known sites existed in the project area. I find that no surveys are needed for aquatic mollusks. The project s prescribed riparian treatments (s ) would not likely cause significant negative effects to species habitat or persistence of the species at the site. I find that no surveys are needed for red tree voles because no suitable habitat is present ( ). I find that no surveys are needed for great gray owls because potential habitat would be avoided (s ). I find that surveys were conducted to protocol for terrestrial mollusks and botanical species (s & s ). I find that known sites that were found during project surveys (two sites of Crater Lake tightcoil, s ), would be managed according to the appropriate management recommendations (s ). I find that sufficient snags exist to meet the needs of black-backed woodpeckers. I find that the construction of a fuel break will provide a degree of protection for rare and uncommon species because it will aid in the suppression of wildfires. Exceptions - The Forest Plan describes the process for documenting an exception to should standards and guidelines (p. Four-45). Action is required; however, case-bycase exceptions are acceptable if identified during interdisciplinary project planning environmental analyses. The Forest Plan contains, at its core, management goals and desired future condition statements that direct how the Mt. Hood National Forest is to be managed (p. Four-1 to Four-44). It also contains a multitude of standards and guidelines that were designed to guide projects to meet management goals and move the landscape toward the desired future condition. These standards and guidelines work as intended when decision makers have the flexibility to determine the size, shape and location of harvest units and can design other implementation details to achieve the Forest Plan s overriding management goals and desired future conditions. Standards and guidelines however were primarily written to address traditional timber sales and they often do not adequately address fuel breaks or high fire hazard situations. This project arose in response to uncontrollable circumstances: the insect infestation and the resulting high fire hazard. There was also no control over the land allocations that insects would move into. Portions of the project are in areas that would not normally have been Cascade Crest Fuel Break Decision Notice - Page 10 of 12

11 targeted for intensive timber management. While the creation of a fuel break would involve some timber removal, the primary goal is to aid in the suppression of wildfires. The Forest Plan directs the suppression of wildfires to protect resources. The EA analyzed the localized impacts of fuel break construction with the landscape-wide benefits of reduced wildfire impacts to determine the achievement of management goals and desired future conditions. Standards and guidelines that were written to shape the development of traditional timber sales may not be applicable especially if they hinder the achievement of key management goals and desired future conditions. Section addresses management goals, desired future conditions and standards and guidelines that relate to fire and fuels. Section addresses standards and guidelines that relate to scenery and recreation. I approve an exception for FW-556 which allows for the flexibility in timing of achieving the prescribed visual quality objectives within one year of implementation. I am recognizing that it would likely take more than one year for the fuel break to become less evident and for visitors to become gradually accustomed to the change. Section addresses riparian standards and guidelines. I find that the project is consistent with these standards and guidelines and would ultimately help minimize the impact of fire on riparian areas across a broad landscape. I approve exceptions for FW-105, FW-107, FW-134, FW-135, and FW-136 as described in s I find that the project is consistent with LSR standards and guidelines (s ). The Regional Ecosystem Office Interagency LSR Working Group has reviewed this project and found it to be consistent with LSR standards and guidelines (s ). Sections address snag and down log standards and guidelines. I approve exceptions for all of the snag and down log standards and guidelines listed in these sections. The fuel break is a relatively narrow strip of land in a larger landscape with abundant snags and down logs. I find that the benefits of the fuel break out weigh the localized impacts. Section addresses soils. I approve exceptions to standards and guidelines FW-031 through FW-038. These standards and guidelines discuss levels of organic matter that should be retained on the ground for soil protection and for long-term productivity. These were designed for traditional timber harvest and are not appropriate in a fuel break. Comments: The legal notice for the 30-day comment period for this project was published in the Oregonian on June 27 th I have considered the substantive comments that were received. The responses to the comments are contained in Appendix B of the EA. Cascade Crest Fuel Break Decision Notice - Page 11 of 12

12 Appeal Rights: This decision is subject to appeal pursuant to Forest Service regulations at 36 CFR 215. Any individual or organization that submitted comments or expressed interest during the comment period may appeal. Any appeal of this decision must be in writing and fully consistent with the content requirements described in 36 CFR The Appeal Deciding Officer is the Regional Forester. An appeal should be addressed to the Regional Forester at any of the following addresses. For postal delivery, mail to: Regional Forester, Appeal Deciding Officer, USDA Forest Service, PO Box 3623, Portland, OR The street location for those submitting hand-delivered appeals is 333 SW First Ave., Portland, OR. The office hours are 8-4:30 M-F, excluding holidays. For fax, send to Electronic appeals must be submitted as part of the actual message, or as an attachment in Microsoft Word (.doc), rich text format (.rtf), or portable document format (.pdf) only. s submitted to addresses other than the one listed above, or in formats other than those listed, or containing viruses, will be rejected. It is the responsibility of the appellant to confirm receipt of appeals submitted by electronic mail. The Appeal, including attachments, must be postmarked or received by the Appeal Deciding Officer within 45 days of the date legal notice of this decision was published in the Oregonian. For further information regarding these appeal procedures, contact the Forest Environmental Coordinator Michelle Lombardo at Project Implementation: Implementation of this decision may occur on, but not before, 5 business days from the close of the 45-day appeal filing period described above. If an appeal is filed, implementation may not occur for 15 business days following the date of appeal disposition (36 CFR ). The EA can be downloaded from the Forest web site at in the Projects & Plans section. For further information contact Jim Roden, Estacada Ranger Station, 595 NW Industrial Way, Estacada, OR Phone: (503) jroden@fs.fed.us Recommended By: Responsible Official: /S/ Andrei Rykoff September 16, 2010 /S/ Gary L. Larsen ANDREI RYKOFF Date Published GARY L. LARSEN District Ranger Forest Supervisor Cascade Crest Fuel Break Decision Notice - Page 12 of 12