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Minutes Transportation 06/10/2002 • TRANSPORTATION ADVISORY BOARD FINAL MINUTES JUNE 10, 2002 BOARD MEMBERS PRESENT John Tayer, Jim Rettew, Brant Liebmann, Jerry Wyss, and Krista Holland STAFF MEMBERS PRESENT Tracy Winfree, Marni Ratzel, Chris Jones, Noreen Walsh, Molly Winter, Dave Bradford, Bill Cowern, Randall Rutsch, Michael Penny, Mike Gardner-Sweeney and Robin Madel, secretary PRE-MEETING DINNER WITH REGIONAL PARTNER Mami Ratzel and Chris Jones from GO Boulder attended the dinner and discussed the plans that have been made for the 2002 Walk and Bike Week. • AGENDA ITEM 1 Call to Order John Tayer, chair, called the meeting to order at 6:02 p.m. AGENDA ITEM 2 Approval of Minutes Minut-s from the May 13, 2002 meeting were not approved because of the following issues. Krista Holland said that a comment made by Premena during Citizen Participation regarding signs on a bike path should have read "...signs installed such that east-west traveling bikes couldn't read them." Krista Holland said that with regards to a bike path on the Bear Canyon Creek flood levee, there should have been a comment about a path from the Foothills bike path to the neighborhood and that this is in the Arapahoe Network Plan. • Transportation Advisory Board Final Minutes June 10, 2002 Page I Krista Holland said that she asked about the 63rd St. bike path that was discussed during the pre-meeting dinner not Jim Rettew. Brant Liebmann said that the TAB comments indicated that he asked about ways to reconcile resident perceptions. Liebmann said that it should read, residents, the mail carrier and myself." Brant Liebmann asked if it would be possible to include his argument for including the north side of Gillaspie Dr. because it is a safety issue. In Liebmann's opinion, if parking on the south side of Gillaspie Dr. if unsafe then the north side should be an NPP. Jim Rettew said that John Tayer's name should be deleted from the TAB member attendance list in the final minutes. Jerry Wyss said that the motion that Jim Rettew made regarding the FHS NPP included the south side of Gillaspie Dr but leave the current parking conditions unchanged. He asked to have the wording on the tape checked. Wyss said that if it was not included then the TAB made a defective motion. Jim Rettew said he thought the motion included Gillaspie Dr.. It was decided that the minutes would be verified and corrected where necessary and re- submitted for approval. • AGENDA ITEM 3 General Citizen Participation Premena, P.O. Box 1038, Boulder 80306, spoke about bike signage. He said that the minutes from the May meeting did not accurately reflect what he is asking for in terms of bike signage. He is asking for a general rule to be put into place that bike signs have to be visible to bikers. He discussed several specific examples during the last meeting and said that he had noticed several more examples on this day as well. He said that since the city is willing to put up signs that work for cars they should be willing to do the same for bikers. He asked to have signs posted on Hawthorne. General Citizen Participation was closed. • Transportation Advisory Board Final Minutes June 10, 2002 Page 2 . AGENDA ITEM 4 Public hearing and reconsideration of a recommendation to City Council on the Longwood Neighborhood Permit Parking (NPP) District. John Tayer said that the agenda reads "reconsideration of a recommendation from TAB." Tayer said that at any time it is the prerogative of any TAB member to move to reconsider a motion they voted for. Tayer said he wanted to get clarification from the staff of the implications of the motion made at the last meeting. He said that after the discussion and the citizen input, there might be somebody on TAB who wants to move to reconsider the motion as an outgrowth of that conversation. Brant Liebmann asked if it has to be moved on and seconded on. Tayer said that it does and by someone who was a member of the party that voted for it previously. Molly Winter and Dave Bradford said that they were coming back to the TAB as a request from the city manager's office that wanted some clarification about the Longwood NPP before going to the city council. Winter said that the staff raised some issues based on the TAB recommendation about Gillaspie Dr.. Winter said that the Longwood portion of the recommendation has received support from both the TAB and the staff. Winter said that it was not clear that Gillaspie could be included in the NPP under the motion made by the TAB in May because it was not part of the original staff proposal and did not receive the full public process with a proper public hearing. Winter said she thought it was important that all issues be put out for a public hearing. Winter said that she had received a memo from a citizen, Joe Mottashed, but she had not had time to read and respond to the memo. Winter said that the staff memo raised the issue about the city's policy for inclusion of a street in a NPP without support from the adjacent property owner. Winter said that in the ordinance, the city manager has the power to set up a NPP but our approach as a city is to work with the residents and property owners in developing the NPP by responding to a petition process. This is how the Longwood NPP was instigated. In this case, the property owner, the Boulder Valley School District, has taken a neutral stance on inclusion of the north side of Gillaspie Dr. The school sent a letter to the city in which they said they are neither in support of or opposed to what the neighbors are trying to accomplish. In the letter, the school district says it is not going to initiate or sign a petition to provide an NPP on the north side of Gillaspie Dr. It is not clear whether the south side of Gillaspie Dr. was included in the motion and what it would mean with regards to the existing parking restrictions. If the north side of Gillaspie were included in the zone, the school would be eligible for business permits of an indeterminate number. There is also an issue of displacement of vehicles from the north side of Gillaspie to other neighborhoods therefore creating other NPPs. • Transportation Advisory Board Final Minutes June 10, 2002 Page 3 • The staff put forward several options in terms of addressing access to vehicles. They suggested either creating a loading zone or including the south side of Gillaspie Dr. in the Longwood NPP to give them access to parking on Longwood. TAB Questions Brant Liebmann asked if the blocks of an NPP have to be contiguous. Winter said yes. Jerry Wyss read the section of the ordinance that describes the requirement for blocks to be contiguous. Liebmann asked if a block in the middle of the Goss-Grove neighborhood did not want to be in the NPP if the block would be left out. Winter said that given the city's approach, they would respect the resident's desire and not restrict parking in that area. Brant Liebmann asked if the north side of Gillaspie Dr. would be considered contiguous if the west side of Greenbriar Blvd. were included in the NPP zone. Jerry Wyss said that because the end of Gillaspie Dr. is across the street from the west side of Greenbriar then Gillaspie should be considered contiguous. Winter said it is open to interpretation. Wyss said he didn't think that Greenbriar was included in the NPP. Rettew said he thought he had included it in the motion but because the people on Greenbriar didn't want to be a part of it they didn't have parking restrictions on that block. Jerry Wyss asked whether a decision has ever come back to the TAB after the TAB has • chosen an option that was not proposed by the staff. Tracy Winfree said that she could not think of a time when that had happened. Wyss said that because the TAB created a new option that was not brought by the staff it needed a proper public hearing. Jerry Wyss asked about whom the right-of-way belongs to and whether the purpose of the NPP was to give people control over parking in front of their house. The ordinance says that it belongs to all. Molly Winter said that the purpose of the NPP is to give the neighbors control over parking within a zone and not just in front of their house. Jerry Wyss asked about the definition of business and whether a school is considered a business. Molly Winter said she would have to have an interpretation from the City Attorney's Office about that issue. Wyss said that employee should be interpreted to mean the people who go to an institution every day and are creating the problem. Jerry Wyss asked about the number of commuter permits and the hours of parking available within a specific zone. Winter said that the ordinance could allow for as little as zero permits per block and the parking time could be restricted to no parking within a zone. Jim Rettew asked about the public process involved in creating the zone. He asked what the concern was in not providing Fairview High School an opportunity to respond to the TAB recommendation. Winter said that there was no public hearing held specifically on • Transportation Advisory Board Final Minutes June 10, 2002 Page 4 • Gillaspie and the impacted neighbors didn't have an opportunity to respond to the TAB recommendation, since the original staff recommendation focused on Longwood. Winter said that this was a mayor concern of the city manager before taking the recommendation to the city council. Rettew pointed out that, since the city enlarged the map to determine where the property line between the city and school district is, it looks as though BVSD is the only property owner at stake in this area. Winter concurred. She said that the city made a mistake about defining itself as a property owner. Citizen Participation Linda Nga,1715 Gillaspie Dr., Boulder, 80305, says she is one of the 3 residents that uses the steep driveways at the top of Gillaspie. She said if parking is allowed on the north side of Gillaspie, when driving conditions are bad, it will be dangerous. Bob Kershna, 4410 Hastings Dr., Boulder, lives at the corner of Ludlow and Hastings and said that if the cars are displaced, they will come to his neighborhood. He said he is in favor of a plan to limit parking and the Longwood NPP is not a fair solution that will solve the problem. John Marshall, 1707 Gillaspie Dr., Boulder, 80305, said that the majority of the property owners on Gillaspie favor inclusion in the NPP zone and that is in keeping with the city's policy. He said that the BVSD and the city are only 2 of the property owners. Dan A. Vowell, 1190 Hartford Dr., Boulder, 80305, says he is a mail carrier in the • potential zone area. He said if the City Council is not clear about the safety concerns he would like to make them clear. He said that if the parking restrictions were changed on the south side of Gillaspie, he would be in danger when delivering mail. He also said he went to a financial advisor whose office is on Greenbriar and he had to park way down on Longwood. Hal Segal, 1765 Gillaspie Dr., Boulder, 80305, is against restricted parking on the north side of Gillaspie but there is a safety issue if parking is allowed on the south side. He said he believes the north side of Gillaspie is the perfect overflow for the parking problems at Fairview, which he said, are caused by the open enrollment that encourages driving. He said he moved into the area knowing that the school lot was there. Scott Ladner, 5436 Illini Way, Boulder, 80303, gave a packet of information to go with his presentation. He concluded that parking on Gillaspie is necessary and not dangerous and he referred to the safety study performed by the city staff. He said without parking on Gillaspie, there will not be adequate parking. He also said that the school couldn't limit driving. If Gillaspie is included, the parking problems will move to other neighborhoods. Brittany Smith, 4565 Darley Ave., Boulder, 80305, discussed the photos that were included in the packet presented by Scott Ladner. She said the cars extend from Greenbriar, down Gillaspie to Kittrell. She said the students counted only 10 more • Transportation Advisory Board Final Minutes June 10, 2002 Page 5 additional spaces. She also said that the students didn't have much of a chance to get • parents and teachers together because of the close timing. Mike Abbousse, 201 Ridge Rd., Boulder, said it is safe and necessary for students to park on the north side of Gillaspie. He said that more neighborhoods would petition to become an NPP zone. The students will use the adopt-a-street program to keep the streets clean and he thanked everyone for their time. Linda Jacobson, 4390 Ludlow St., Boulder, 80305, had work done on her house and had to deal with the parking issues. She doesn't want extra traffic on her street. She asked for no parking zones of 1 or 2 vehicles to increase visibility. She also said that people on Kittrell are talking about initiating an NPP zone. James Bush,1785 Gillaspie Dr., Boulder, 80305, said he is directly impacted by student parking. He said that there shouldn't be parking on the south side of Gillaspie because of safety concerns. He said the parking situation on the north side of Gillaspie would have little bearing on his situation. Noel Clark, 3106 Kittrell, Boulder, 80305, says there will be problems if parking is restricted on the north side of Gillaspie. He said Kittrell would look for inclusion into the zone if that happens. He is in favor of longer-term solutions. He says one option is to put the problem back on the school to build a parking structure that would be paid for through parking fees. Karla Bielanski, 4310 Ludlow St., Boulder, 80305, said she is concerned about the displacement of cars and is opposed to a plan that doesn't more fully solve the problem. The longer-term solution would be to build a parking structure. Hamid Fardi, 3100 Kittrell St., Boulder, 80305, initially thought he wouldn't be affected by the parking issues but says he will eventually be affected. He said the school district must be involved to find a long-term solution. The longer-term solution will affect property values. Citizen Participation was closed. TAB Comments John Tayer said that it was clear that there was some confusion about what happened at the last meeting in terms of what was recorded. It would be appropriate to try to narrow the issues to know where we stand. He asked to have the staff walk the TAB through what is on the table. Then he wanted to clarify the gray areas. Tayer said it seemed that there was a motion but it is not clear what the intent of the TAB was from the minutes. Tayer asked Molly Winter to discuss where she was clear on TAB direction. Winter said that she was clear on inclusion of the 3600 to the 3900 block of Longwood Ave. for the times limits, days, time period, implementation date, etc. Also in the original proposal • Transportation Advisory Board Final Minutes June 10, 2002 Page 6 was the 3900 block of Greenbriar Blvd., which is in the western section of Greenbriar. • Jerry Wyss said that the minutes show that Greenbriar was excluded but his recollection was that it was included. Jim Rettew said that everyone had that same recollection. Winter said that Greenbriar would be included in the zone but there would be no parking restrictions. Everyone agreed on these points. John Tayer summarized what he saw as the issues remaining. He said that it was not clear that the south side of Gillaspie was included in the zone and therefore whether residents can purchase permits. Tayer also said that it was not clear how many business permits the property owner (BVSD) on the north side of Gillaspie would receive. Finally Tayer said that Winter pointed out that the lack of a position from the school district is an issue. Jerry Wyss said that he was willing to reconsider the motion to correct the misunderstandings and to clarify the issues. He said that the TAB might have stepped beyond the boundary by picking an option other than those proposed by the staff. Wyss said that the staff should have been able to evaluate the option the TAB advocated. He said he thought that staff should take the issue back to the neighbors and have them help shape the staff recommendation. Wyss recommended creating a NPP on the south side of Gillaspie with 0 commuter permits and 0 hours for non-resident parking. That would allow only residents, guests and vendors to park on that side of the street and would allow the neighbors to self-regulate parking. He also advocated leaving the north side the way it is or adding resident only parking from 8-4 on school days. Jim Rettew said he would not support a motion to reconsider the motion because he thought that the TAB made the right decision in May. Rettew said that if IBM moved in and didn't have enough parking for all of their employees, then the situation would change for sure. Jerry Wyss felt that the current recommendation doesn't address the issue of how many business permits the school could receive and this could be problematic. Brant Liebmann said that the most liberal interpretation is that employees include students. Liebmann also pointed out that the City Manager doesn't have to issue any permits if he chooses. Jerry Wyss motioned to reconsider the TAB motion regarding the Longwood NPP. There was no second for the motion. John Tayer said that one of the key issues is the treatment of the school as a business. Molly Winter said that she believed that an institution is not considered a business but she asked to have an interpretation about the issue from the City Attorney's Office. Tayer also said that he wanted clarification about whether the south side of Gillaspie was included in the motion made during the May meeting so residents could purchase permits. Molly Winter said that based on her conversations with one of the city's Transportation Advisory Board Final Minutes June 10, 2002 Page 7 attorneys, the north and south side of the streets are considered to be within the NPP • zone. Jerry Wyss said that he thought it made sense for the board to reconsider and re-do the motion the way that the TAB intended it. John Tayer said that he thought that we already had a motion that was adopted and approved and the staff needed some clarification on one element of it. John Tayer said that since it was clear that most people wanted to have an NPP that includes the south part of Gillaspie he would entertain a motion to add that to the previous motion. Jim Rettew made a motion that stipulates that the south side of Gillaspie is included in the Longwood Neighborhood Permit Parking program but will maintain the existing parking restrictions on the south side. Brant Liebmann seconded the motion. The vote was 4-1 in favor of the motion. Jerry Wyss opposed the motion. Molly Winter asked for guidance about the fact that the property owner on the north side of Gillaspie did not ask to be in the zone. John Tayer repeated Molly winter in saying that the policy (which is not a rule but is a guideline) is to get the majority of the property owners to petition for the zone. The issue of whether that is an appropriate approach is a topic for another discussion. Brant Liebmann said that the residents on the east side of Greenbriar opted out and he . asked if they were included in the zone without their support. Winter said that those residents were taken out once they made their feelings known to the staff. Jim Rettew said that the school district should stop being coy and tell the city what it wants. John Tayer said that they would have a chance to do that with the city council and the city manager. Jim Rettew told the neighbors of the surrounding, streets that the TAB understands that this is not a perfect solution and all will have to see how it works. Rettew advocated a combination of carpooling, parking on Greenbriar and using commuter permits as possible accommodating the parking requirements. He said the other neighbors will need to follow the public process of they have the same parking problems. AGENDA ITEM 5 Public hearing and consideration of a recommendation to City Council on changes to City Code regarding the issue of Sidewalk Vegetation Removal. Noreen Walsh said that the city is in Phase II of the sidewalk vegetation removal program. Walt Fricke said that the issue fits into a set of rules that govern public right of way. • Transportation Advisory Board Final Minutes June 10, 2002 Page 8 • TAB Questions Krista Holland asked about the recommended configuration of gutters. Walt Fricke said that the intent is to standardize the way gutters are constructed and to provide a basis for maintenance to charge for removal of obstructions. Also, the gutters become unsafe when they are modified because they allow ice to build up in the winter. Krista Holland asked about the requirement to use only grass as a landscaping material in alleyways. Fricke said that because the alleyways are narrow, the entire width is needed for vehicles to pass through. The intent is to keep people from planting trees and shrubs that reduce the width. Holland suggested basing the restrictions on height and width. Holland said her concern was that only grass is specified and she wanted to see other suitable material added to the list. Krista Holland asked about the use of sprinklers in areas that bikers and pedestrians frequent. When sprinklers shoot into the areas used by bikers and peds, they deter people from traveling through those areas. Fricke said that that is an unrelated issue to the topic. Tracy Winfree said she would forward the issue to the Parks and Recreation staff as maintenance issue. Brant Liebmann asked about maintenance of the strip between the sidewalk and the street. Fricke said that all that the city requires is for residents to keep weeds down to 12 inches but he said most people landscape the area. • Brant Liebmann asked if a resident would be charged for removal of materials that are in the right of way if the city has to remove them. Fricke said that the resident will be charged if the resident has planted the materials themselves. The process usually happens through citizen complaints. The staff evaluated the complaint to see how the landscaping fits into the area. Citizen Participation Premena, P.O. Box 1038, Boulder 80306, said he was concerned about objects in curbs and alleys. He said he frequently observes people walking in alleys. He said unless there is an obstruction in an alleyway, why bother asking someone to move landscaping. He said that the city has been opposed to the Hollywood curb but he said it is a great way for bikers to get out of the way of cars. Citizen Participation was closed. TAB Comments Jerry Wyss said that he supported the proposed ban on dangerous curb cuts. Brant Liebmann asked how you go about installing a curb cut. Fricke said that there are standards established by the city that residents must follow. • Transportation Advisory Board Final Minutes June 10, 2002 Page 9 i Brant Liebmann asked about obstructions on unimproved property. Fricke said that a citizen who wants to address this issue would either deal directly with the property owner or go through the city. Jerry Wyss requested installation of a new utility bill insert outlining the details of the new ordinance when it is passed. He also asked that the graphics on the brochure be very clear. Jerry Wyss motioned to recommend approval to the City Council. Krista Holland asked about the issue of using only grass and whether she needed to make a motion. Fricke said the city does not want property owners to make the alleyways look like private property. Jerry Wyss motioned to recommend approval of the staff recommendation to City Council on changes to the City code regarding the issue of Sidewalk Vegetation Removal with a further recommendation that the staff broaden the definition of grass in the alleyway to include other non-obstructing vegetation materials. Krista Holland seconded. Krista Holland proposed and amendment to the motion to say that if a curb obstruction does not pool water then it is not a problem. Walt Fricke said that the issue is governed . by city standards. Holland withdrew the amendment. The vote was 5-0 in favor of the motion. AGENDA ITEM 6 Public hearing and consideration of a recommendation to City Council on the Year 2003-2008 Transportation Capital Improvement Program (CIP). Tracy Winfree said that the CIP is designed to maintain the integrity of transportation prioritization while slowing expansion of the multi-modal system due to reduced sales tax revenues, sustainability of the Transportation Fund and includes Transportation Improvement Project funding. Winfree said that changes to the statement from the last meeting were highlighted in the packet. TAB Questions TAB questions covered specific project funding for the Broadway Bridge Replacement project, the utility undergrounding program, the NTMP program, the Transit Village, the • Transportation Advisory Board Final Minutes June 10, 2002 Page 10 Greenways program, pedestrian systems, the center portion of 281h St. and the Eco-pass is program. Jim Rettew asked why the allocation of certain funding isn't consistent with the stated priorities. Winfree said that in a lot of cases there is more funding available than is directly reported within a certain category because the funding is either leveraged in other projects or is spread out amongst several projects. Jerry Wyss suggested indicating external dollars spent on city projects. Jerry Wyss asked about the regional breakdown. Mike Sweeney said that the 2002 breakdown would be provided at a later point. Citizen Participation There was none. Citizen Participation was closed. TAB Comments Krista Holland discussed the Greenways Advisory Committee meeting that was held on June 5, 2002. She said that the GAC discussed potential cuts to the program. The GAC decided that if cuts are to happen they would prefer to cut trail-building projects versus • the maintenance program but they would prefer to keep the program in tact. Holland asked the TAB to support a motion to recommend that the Greenways budget not be reduced. Jim Rettew said that he thought there were some projects in the Greenways program that could be reduced in spite of the match and he wanted to give the staff the ability to cut those projects along with the rest of the transportation budget. John Tayer said that they don't want to cut Greenways funding, then he wondered what else they would have to give the same consideration. He said he thinks the staff has taken a very balanced approach to managing the budget. He also said that by supporting the CIP, the TAB is showing its support for the Greenways budget at its current level. Jim Rettew motioned to recommend to the City Council the 2003-2008 Transportation Capital Improvement Program. Jerry Wvss seconded the motion. The vote was 5-0 in favor of the motion. Krista Holland made a motion to make a statement that, given the current budget forecast, the TAB recommendation is that the Greenways budget not be reduced. There was discussion about this item and Holland decided to go back to the GAC and voice the TAB support through passing the CIP and she withdrew her motion. • Transportation Advisory Board Final Minutes June 10, 2002 Page 11 • AGENDA ITEM 7 Matters From Staff: • Michael Penny is the Development Review Coordinator for Planning and Development Services. He reviewed the reviewed the rules regarding public right of way and private development. He discussed the city's philosophy for closure of bike/ped/traffic lanes. Penny said that the purpose of traffic control is to protect the safety of (in order) pedestrians, bikers and drivers. Penney said he is working with Bill Cowern to ensure appropriate and accurate signage within the city. He said that the impacts depend on the location and the type of project and the on-site manager will make the final call. Penney said that there is no policy for bikeway signage in the Manual of Uniform Traffic Control Devices and there is no written policy or legal requirement to follow. • Randall Rutsch gave an update on Phase 2 of the Transportation Master Plan update, which covers policy refinement. Rutsch reviewed the schedule and timeline; funding sources, multi-modal pathways, travel-demand-management, and the Jobs-to- Population Balance Project. Rutsch said he would be returning to the TAB in July to discuss the public process and the materials and would be taking the issue to the City Council on the following evening. Rutsch reviewed the activities that have been completed so far and those that are on going. Phase 3 will include plan development and Phase 4 will be plan adoption. • Jim Rettew motioned to suspend the rules at allow the meeting past 10:00 p.m. Jerry Wyss seconded the motion. The vote was 5-0 in favor of the motion. • Tracy Winfree provided an update on U.S. 36. She said that CDOT maintains that they can fund their portion of the Environmental Impact Statement. The coalition is facilitating the process to advance the project. • Tracy Winfree said that RTD released the new version of Fasttracks last week. It will be presented at the RTD board on June 18 with an attempt to get it in place before the November 2002 vote. The U.S. 36 coalition is concerned that the new version is significantly different from the Locally Preferred Alternative from the U.S. 36 Major Investment Study. Matters From the Board: Brant Liebmann asked to have a discussion about providing Eco-passes to fiscally challenged bus riders added to the To-Do list. • John Tam asked for an update on the Forest Glen General Improvement District with respect to their Eco-pass program. • Jim Rettew asked about putting together a TDM site review plan per Jerry Wyss' request at the TAB retreat. Jerry Wyss said that after looking through the TDM material in the packet he realized that the staff has been doing more on this issue than . Transportation Advisory Board Final Minutes June 10, 2002 Page 12 • he originally thought. • Krista Holland asked to have a discussion about rules regarding sprinklers that spray over sidewalks, bike paths and multi-use paths. • Jim Rettew asked about the TAB retreat summary. Tracy Winfree responded that it was not yet available and would be forwarded to the TAB in the next packet, assuming it will have been drafted. Discussion of Future Meeting Agenda Tracy Winfree said that there would be no speaker at the next meeting because there would be an Open House for Phase II of the TMP in the hour preceding the TAB meeting. The meeting will primarily cover the TMP and there may be a briefing on the next NTMP situation. AGENDA ITEM 8 Adjournment Jim Rettew motioned to adjourn the meeting. Jerry Wyss seconded. The vote was 5-0 in favor of the motion. • The meeting was adjourned at 10:50 p.m. Next Meeting July 8, 2002, 6:00 p.m., Transportation Advisory Board regular meeting, at the City Council Chambers. ~79 d~ Minutes approved on By • Transportation Advisory Board Final Minutes June 10, 2002 Page 13