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HomeMy WebLinkAboutPlanning 10/08/2025Town of Mansfield RECEIVEn YP v [llagfleld, AL14 02048 TOWN CLERKS 0��1��' Board FOASAO�S 10250C1?3 P 2�43 Planning Boa i' Al ,IISF1E I-D Meeting MinWO) S A C' I i1 S F T I` October 8, 2025 Meeting Held in Person in Meeting Roont 3A/B Present: Sharon Friedman, Chair; Ryan Maxwell, Acting Clerk; Ralph Penney; Michael McClanahan; Sreelatha Allam; and Bryan Haworth, Associate Sarah Raposa, Director of Planning & Development Priscilla McGill, Administrative Secretary Absent: Joseph Cerretani and Mark Corsillo, Clerk 1 `Elanuiug Board 11'ieetiug Called„to C?r�ier at'7�t►2 gym....;:' Ms. Friedman called the meeting to order at 7:02 pm. Due to the absence of Clerk, Mark Corsillo, the following motion was made: Motion by Mr. McClanahan and seconded by Mr. Penney to appoint Mr. Maxwell as Acting Clerk for the meeting. Vote: 6-0-0 [Aye 6, Nay 0, Abstain 0] PASSED Ms. Friedman read the introductory statement for audience members who wish to record the meeting. Regarding the application of James Crawford for a Special Permit and Site Plan Approval pursuant to Bylaw Sections 230-5.5, 230-5.3, and 230-3.3E at 40 Pratt Street to demolish the existing structure and construct a new three-story, 5,980 SF 5-unit rowhouse building. The project site is owned by Sandra and Thomas Curtin and is shown on Assessor's Map 022, Lot 112, within the Business 2 (B2) zone. The applicant requested, in writing, that the hearing be continued to October 22, 2025. Motion by Mr. McClanahan and seconded by Mr. Maxwell to continue the public hearing to October 22, 2025, at 7:05 pm. Vote: 6-0-0 [Aye 6, Nay 0, Abstain 0] PASSED Planning Board Meeting Minutes 10-08-25 Page 1 of 11 3. 7:05 pm Public Hearing — Site Plan Approval I West Church Street Regarding the application of Crugnale Properties, LLC for a Site Plan Approval pursuant to Bylaw Section 230-5.3 for the property located at 1 West Church St. to demolish the existing building, parking areas, and associated driveways to construct a new mixed -use building to include seven two-story townhouse units, retail space, and parking. The project site is owned by Washington Realty, Inc. and is shown on Assessor's Plat 021, Lot 064, within the Business 1 (B I) zone. Marco and Sophia Crugnale were present. Mr. Crugnale summarized the plan to demolish and build a new building of mixed retail and condo spaces. There will be 17 parking spots, which meet bylaw requirements. Revised plans had been submitted, including landscaping, lighting plans, trash removal, and snow storage. Most comments from the department meeting have been addressed. The engineering comments will be addressed and submitted for the next hearing date. Mr. Crugnale described the architectural details, which follow the Downtown Guidelines. The building will be sprinklered per the requirements. The North Main Street section of sidewalk will remain, and the new Church Street section will be ADA-compliant. Benches will be added on the sidewalk per Mr. Penney's suggestion. Ms. Raposa said that the application meets the Site Plan bylaw regulations. The hearing should be continued for the applicant to submit the requested renderings and engineering review. Ms. Raposa noted that other departments provided verbal support at the department meeting. Mr. Penney requested the submission of the building renderings and elevations per the Site Plan Approval requirements. The townhouse units will be approximately 1,500 SF to 1,600 SF with two bedrooms and two bathrooms. Mr. Maxwell questioned one of the parking spaces, which appeared difficult to enter and exit. He suggested that a turning radius plan be submitted. He noted that there is one large office and three 12' x 12' office spaces. He asked Mr. Crugnale to consider a redesign of the single stairways to the units, which would make the office spaces larger. He was also concerned with the hedges and entry/exit sight lines being obstructed. Mr. Crugnale said he would address the issues with the engineer. There were no fiirther Board or public comments. Motion by Mr. Maxwell and seconded by Mr. McClanahan to continue the public hearing to October 22, 2025, at 7:00 pm. Vote: 5-0-0 [Aye 5, Nay 0, Abstain 0] PASSED 4. Correspondence and General Business Meeting Minutes — September 24 2025 Motion by Mr. Penney and seconded by Mr. McClanahan to approve the minutes as presented with the minor change to page 3. Vote: 4-0-2 [Aye 4, Nay 0, Abstain 2] PASSED I11<nrning Board Meer ing Minutes "10 08-25 Page 2 of 11 Working Group Alinules,for 1012124101912410130124816125 8113125 and 8120125 Motion by Mr. McClanahan and seconded by Mr. Maxwell to approve the minutes as presented. Vote: 5-0-1 [Aye 5, Nay 0, Abstain 1] PASSED Pursuant to the provisions of MGL Ch. 40A §5, the Mansfield Planning Board will hold a public hearing at 7:30 p.m. on Wednesday, September 10, 2025, to accept public conunents on the following proposed amendments to the Town of Mansfield Zoning Bylaws. Ms. Raposa began the second public hearing with a brief introduction and timeline. There will be an informational session at the Council on Aging on October 29"', followed by the 3`d public hearing on November 12, 2025. Fall Town Meeting is scheduled for December 9, 2025. She said that each item presented may not make it to the warrant. Some items are housekeeping and others are substantive. She then reviewed each item with Board and Public comments as noted below. Item 1 - Signs (§230-4.7): Authorizes the Zoning Board of Appeals to grant special permits for sign relief in unique cases where standard regulations are impractical, with detailed plans required. The proposed amendment would allow the ZBA to grant special permits for limited relief on the size and placement of business and industrial signs. Scaled drawings and standard special permit findings would be required. The amendment does not authorize prohibited signs and does not apply in residential districts; residential cases, such as the recent daycare request on School Street, would continue to require a variance. The change is intended as a case -by -case "safety valve" for edge cases where literal standards do not fit a site, while preserving the core rules. No changes have been made to the text since September 10. The ZBA expressed general support after a brief discussion at its September 16d' meeting, though further education and outreach may be needed before presenting at Town Meeting. Mr. Maxwell, drawing on his experience as a former ZBA member, noted that the board had reviewed 12 sign variance cases during his tenure. While not a large number, it was sufficient to demonstrate the need for a special permit option, especially since many of the cases involved commercial businesses where variances were technically not warranted. The special permit process would provide better protection for the ZBA and the Town. Public Comments Dean Boucher of 24 Wayside Drive expressed concern about illuminated signs. Ms. Raposa replied that anything that is currently prohibited would still require a variance, not under the special permit process. The special permit is specifically for size and placement. Planning Board Meeting Minutes 10-08-25 Page 3 of 11 Item 2 - Off -Sheet Parking (§230-4.4): Updates pavement and drainage standards to reflect best engineering practices and 100-year storm design. The proposed amendment modernizes construction and drainage standards for parking areas, applying to commercial, industrial, and multifamily site work (not single-family driveways). The changes clarify pavement thickness requirements and align local standards with federal stormwater regulations and the Town's MS4 permit, including the removal of language allowing direct connections to the Town's drainage system. The draft specifies pavement standards of two inches of top coat and three inches of binder, or as otherwise approved by the Town Engineer using the site plan checklist. This language was intended to provide flexibility on a case -by -case basis, though the word "waiver" does not explicitly appear in the text. Board members expressed concern that the waiver concept may not be sufficiently clear and that older commercial or multifamily properties might have difficulty complying with the new requirements. There was a discussion about the appropriate pavement thickness. While the original bylaw referenced outdated standards of 2.5 inches, updated recommendations suggested 5 inches. Some members felt 5 inches was excessive for parking lots, noting that the standard was more appropriate for highways, while others argued that heavier commercial vehicles, such as 18- wheelers, justify the higher standard. Suggestions included a 4-inch compromise, but no consensus was reached. Given the uncertainty, the Board agreed to table the item and seek further clarification from the Town Engineer before moving forward. Public Comments Bill Clemmey of 55 Fowler Street commented that the proposed pavement thickness requirements in the zoning update seemed excessive. He explained that the current two -and -a - half -inch standard in the bylaw may be outdated, but argued that increasing it to five inches was unnecessary and costly. He cited examples of recently paved commercial lots that have withstood heavy tractor -trailer traffic for 20 years with a total pavement depth of about four inches. He noted that local paving contractors commonly recommend a two -and -a -half -inch base and a one -and -a -half inch top course, totaling four inches, which is the general commercial standard in the area. He cautioned that requiring a five -inch depth would significantly increase project costs, especially for small commercial or multifamily conversions that do not see heavy truck traffic. He suggested the board reconsider the proposed five -inch standard and return to a four -inch requirement. He also expressed concern that while waivers are allowed, it would place an additional burden on the town engineer to review frequent requests. Additionally, he expressed concern with a change to the stormwater design standards from a 25- year to a 100-year storm event, stating that while appropriate for large industrial or planned business park sites, the requirement could be prohibitively expensive for smaller downtown or commercial properties. He urged the board to reconsider both the pavement thickness and stonnwater design requirements to avoid deterring redevelopment of smaller lots. Planning Board Meeting Minutes 10-08-25 Page 4 of 11 Item 3 - Special Permit Submissions (§230-5.5): Removes redundant application requirements to streamline permitting and align with Board regulations. This is a housekeeping item that removes redundant checklist language from the bylaw, which has been moved to the technical submittals to the Board's Rules and Regulations. This allows the Board to maintain the submission checklist at a public hearing rather than a town meeting. There have been no changes to this article since September 10"i. Item 4 - Resource Recovery Systems (4230-5.5H): Deletes long -expired moratorium language on trash incinerators to clean up the bylaw. This change removes a moratorium that expired in 1991, eliminating outdated language that no longer applies. There have been no changes to this article since September 101i. Item 5 - Scheduled Rate of Development (§230-4.2Q: Removes the outdated growth management section that expired in 2007. The scheduled rate of development bylaw was adopted in 1997, which capped the number of building permits issued per year. This is being removed as it expired in 2007. There have been no changes to this article since September I Wh. Item 6 - Senior Housing Parldng (§230-3.3J(7)): Reduces parking for 55+ residential facilities from 2 to 1.5 spaces per unit to reflect lower demand. The proposal maintains the change from two spaces per unit to one and a half, reflecting that senior households generally own fewer vehicles, generate fewer trips, and have more off-peak parking patterns than general occupancy developments. The reduction aims to right -size parking areas, reduce unnecessary pavement, improve site design, and support master plan goals for aging in place and sustainable development without compromising safety. Staff reiterated that one and a half spaces per unit is a minimum, not a cap, and applicants anticipating higher demand can demonstrate that during review, with the board able to require visitor or overflow parking if warranted. Since the September 10 discussion, staff added utilization data from five existing local 55-plus developments and obtained input from the Police Department. The Town traffic officer reported no parking issues at the current senior facilities but suggested keeping some flexibility for future applications through a waiver process. Alternative language was suggested, which would allow the planning board, after a public hearing, to reduce the requirement from two spaces to not less than one and a half per unit based on site -specific evidence. The draft criteria included factors such as unit mix, occupancy, proximity to transit, shared parking, and transportation demand measures. Mr. Haworth questioned the need to ease the previously discussed reduction, noting that existing developments meet current standards, but that requiring excessive parking can lead to unnecessary pavement and cost. Ms. Friedman expressed support for maintaining the 1.5-space minimum, observing that senior developments have consistently found it sufficient and that the shift aligns with trends toward less car dependency. The board agreed that the 1.5-space standard remains appropriate for 55-plus housing. Planning Board Meeting Minutes 10-08-25 Page 5 ofII Public Continents Mr. Clemmey noted that the apartment buildings are mostly on one acre of land and have 20, 40, or 50 units with 1.5 parking spaces for each unit. A 55+ community requires a minimum of 6 acres of land per the bylaw, which allows enough room for additional spaces if needed. Item 7 - MSROD Man & Reference (§230-5.12): Updates zoning map references, corrects acreage, and adds a 2025 map revision expanding Subdistrict C to include additional parcels for compliance with the state's MBTA Communities requirements; also corrects site plan review citation. A 2025 map revision will be added to correct a data coding error in the META Communities compliance model. The amendment extends Subdistrict C of the Mansfield Station Revitalization Overlay District (MSROD), updates acreage figures and map references, and corrects a citation to the appropriate section for site plan approval. The expansion addresses a GIS labeling error in which two town -owned parcels were inadvertently included in the district's unit count during the initial compliance submission. The Planning Board's Working Group evaluated several solutions and recommended expanding Subdistrict C to include these parcels, ensuring Mansfield remains in compliance with MBTA Conmmmities zoning requirements. The adjustment does not anticipate new development, as both parcels —comprising the Station Point Apartments —are already built and subject to long-term affordability regulatory agreements, one expiring in 2063 and the other in perpetuity. Since the September 10 discussion, the mapped area was refined, reducing Subdistrict C's acreage from 105 acres to 95 acres after narrowing the scope from three parcels to two. Staff noted that state feedback on the revision is still pending and that minor technical adjustments may be needed before final adoption at the November 12 meeting. Item 8 - Host Community Agreements (4230-3.4N(9)): Removes outdated impact fee language to comply with updated Cannabis Control Commission regulations. This amendment removes the bylaw provision allowing general impact fees and host community agreements for marijuana facilities. Recent state law changes require that any impact fee be tied to documented, actual costs incurred by the Town. The amendment ensures compliance with state regulations and reduces the risk of legal challenges. There have been no changes since September 10"'. Item 9 - Floodplain District (✓Z230-5.4): Updates maps, standards, and definitions to maintain National Flood Insurance Program compliance. The proposed updates to the floodplain bylaw are to comply with the latest FEMA and National Flood Insurance Program (NFIP) requirements. The changes include updated map references, clarified development standards, new definitions, and refined permitting procedures. This protects public safety, reduces property damage, and keeps Mansfield eligible for federal flood insurance and disaster relief. Planning Board Meeting Minutes 10-08-25 Page 6 of 11 The bylaw was reviewed and changes proposed for consistency with state standards by the director of the Flood Hazard Management Program for the Department of Conservation and Recreation, and there have been no changes to this bylaw since September 10"i. Item 10 - School Bus Parking (§230-3.5N): Adds school bus parking as a special permit use in multiple districts to allow relocation of facilities. The zoning amendment is intended to address school bus parking within the town. The original draft created a new special permit process allowing the planning board to consider school bus parking facilities in any district, with findings on neighborhood compatibility, traffic circulation, public health and welfare, and engineering standards. Applications would require detailed site plans prepared by a professional engineer, showing bus and employee parking, circulation, drainage, and pedestrian safety measures. Additional provisions addressed screening, landscaping, and stormwater compliance with state standards. The proposal also incorporated existing DEP limits on idling and noise and allowed the board to cap the number of buses and issue renewable special permits for up to five years. Based on feedback from the September 10 meeting and research on how other towns regulate school bus facilities, staff found little relevant precedent but identified that Mansfield's bylaw already defines "municipal use" as land or facilities used by the Town of Mansfield. Because many municipal services are now provided through contracts of leases, this definition leaves ambiguity for privately owned facilities used on the town's behalf —such as a bus yard operated by a private contractor under the school transportation contract. The revised amendment would clarify that "municipal use" includes "facilities or operations undertaken through contracts or leases on behalf of the Town," ensuring that such facilities are treated as niu nicipal for zoning purposes and remain subject to plarming board site plan review and the town's clearinghouse process. This clarification would close the regulatory gap without creating new special permit procedures. Board members expressed support for the simpler approach, noting that it provides flexibility and addresses the issue without conflicting with the Dover Amendment, which complicates the regulation of private facilities serving public schools. Ms. Raposa confirmed that town counsel reviewed and approved the language as an appropriate solution. Item 11 - New B5 Limited Business District: Establishes a new B5 zone to allow low -impact neighborhood commercial uses in West Mansfield. This proposed zoning amendment would be to create a new Limited Business District in West Mansfield. The new district would allow low -impact, neighborhood -scale commercial uses consistent with the town's master plan goals to promote economic development and provide local services in the western part of town. Uses would be more limited than in other business zones, and all projects would remain subject to planning board review. The article first appeared at the May Annual Town Meeting as a citizen petition for a four -acre parcel at 465-500 School Street, proposed for a gas station and convenience store with four pumps (eight fueling positions), a canopy, and approximately 28 parking spaces. The article received about 60% support but did not achieve the required two-thirds supermajority. Planning Board Meeting Minutes 10-08-25 Page 7 of 11 The Board is revisiting the article to address community feedback and refine the proposal. While many residents supported the project for its potential tax benefits and reuse of a vacant site, others voiced concerns over traffic safety, scale, and the precedent of "spot zoning." Residents also urged a more comprehensive approach to planning for the School Street corridor rather than parcel -by -parcel changes. A 2021 SRPEDD traffic study of the School Street Plymouth Street intersection confirmed that the intersection currently operates at a failing level of service (LOS F) during peak hours and already meets the warrants for a fall traffic signal under federal and state criteria. Modeling showed that a signal alone would not be sufficient, but a signal combined with new turn lanes could improve perforinance. It was emphasized that intersection upgrades are essential and development could help fund those improvements, while inaction would leave the town responsible for the full cost. Public Comments Sammy Kanan of Kanan Fuels LLC/owner of 464 School St., described plans for a modern convenience store with electric vehicle charging. He expressed willingness to contribute financially toward traffic improvements but noted that the specific scope would depend on engineering recommendations and overall project costs. He confirmed he would be open to entering a legally binding agreement regarding mitigation contributions before town meeting. The board agreed that the revised proposal represents an opportunity to address both redevelopment goals and traffic safety needs while responding to prior community concerns. Item 12 - Pre-1989 Residential Lots (§230-4.1 G): Technical correction to remove restrictive language and ensure older lots can meet prior dimensional standards without variances. There have been no changes to this bylaw since September 10al. Item 13 - 40Y Multi -Generational Housing Overlay (§230-5.13): Establishes a new overlay district under the state's Chapter 40Y legislation to create more flexible housing options for all stages of life. Ms. Raposa reviewed the presentation from the September 10°i public hearing. She noted that there have been no changes to this bylaw since that meeting. This bylaw creates a new multi -generational overlay district under the state's 40-wide legislation. The goal is to provide housing options that work for residents of all stages of life, from first-time homebuyers to families with children, and seniors who want to age in place, not purely as a starter home district. This aligns the law's limits, home size cap, small design, sidewalks, open space, and an affordability trigger while waiting for final state guidance, which would be reconciled before town meeting. The goal is to create more housing choices in an overlay district without replacing underlying zoning. These dimensional standards are intentionally smaller than the underlying zoning to make homes more attainable. At the same time, we've built in requirements for open space and setbacks to ensure projects still fit traditional neighborhood character. Sustainability features such as pervious pavement and energy -efficient design are encouraged with clustered homes to help Planning Board Meeting Minutes 10-08-25 Page 8 of 11 protect open space. Infrastructure requirements include sidewalks and open space. Larger developments must provide at least 10% affordable homes. This is not age -restricted. It promotes modest, attainable homes, helps residents stay in town as they age, and allows us to guide development locally rather than having state mandates dictate outcomes. Ms. Raposa noted that a new 40Y web page has been created and can be viewed on the Town's website. Public Comments Multiple residents raised significant concerns regarding a proposed Chapter 40Y overlay district on Gilbert Street, particularly about the appropriateness of high -density housing on this land. Questions focused on maintenance responsibilities for private infrastructure, such as septic systems, roads, and lawns, which would largely fall to homeowners' associations rather than the town. Several attendees highlighted environmental and safety issues, noting that the property is a floodplain, contains wetlands, and is poorly suited for high -density development. They emphasized potential impacts on water management, stormwater runoff, and existing town infrastructure, including water mains. Concerns were also voiced about the density and scale of the proposed development, shared septic systems, and minimal lot sizes, cautioning that approving the overlay could set a precedent for future developments that might degrade the town's character. Residents questioned the timing of the proposal relative to the state's final guidance on 40Y, stressing that the Town may be moving forward before clear regulatory guidelines are established. Several speakers noted perceived conflicts of interest and urged the planning board to prioritize the long -tern safety, environmental health, and quality of life of Mansfield residents over developer interests. Some attendees supported the 40Y concept in theory for affordable housing, but argued that this specific site is unsuitable. They recommended careful consideration of environmental constraints, infrastructure capacity, and multi -generational accessibility before any approval. The development team will hold a 40Y informational session on November 10'l' at the Council on Aging. The Board suggested that the development team could respond to the public questions and conuients for the next hearing. The Board also clarified to the public that the bylaw is only for a 40Y overlay district and that this is not for discussion of a specific project. Lynn Sweet with LDS Consulting Group (virtual) appreciated the deliberation and consideration of the public and the Board. She clarified that there are new site plans and a traffic study had been conducted, and that information could be provided. She reiterated that at the time of application submission, all required information would be submitted, including wetland submissions to the Conservation Commission. Attorney Jonathan Silverstein, applicant's counsel, confirmed that there is no application before the Board. This is a proposed bylaw that they have worked with the Town to create, which would allow for future application filing. If this bylaw is passed at Town meeting, then an application could be submitted, followed by a significant review of the detailed engineering plans, of the septic design, and of the stornwater management system. Planning Board Meeting Minutes 10-08-25 Page 9 of 11 Motion by Mr. McClanahan and seconded by Mr. Maxwell to continue the public hearing to November 12, 2025, at 7:05 pm and to move the draft zoning bylaw amendments to the Select Board for inclusion on the December 9, 2025, Special Town Meeting warrant as placeholder articles. The Board will finalize the text of each article for town meeting consideration at its November 12th, 2025, meeting and transmit the final anguage thereafter. Vote: 5-0-0 [Aye 5, Nay 0, Abstain 0] PASSED The Board reviewed the plan entitled "Plan of Land 91 Otis Street' by Hutchins Trowbridge Associates, Inc., dated September 15, 2025. The lots are labeled non -conforming, non -buildable, and are to be added to existing lots. The plan depicts two existing lots, lot one and lot two, each retaining frontage on Otis Street. No new building lots are being created. The non -buildable parcels, lot one A and lot two A, are being added to existing lots, and both lot one and two retain their frontage along Otis Street, the public way. Parcels 1 A and 2A are clearly labeled, non -conforming, non -buildable, and are being conveyed to adjoining lots, avoiding the creation of undersized or buildable lots. This plan meets the statutory criteria for A &R endorsement because it does not create a subdivision. The applicant is requesting that the plan endorse the plan dated September 15th, Pursuant to Massachusetts General Law, Chapter 41, Section 81-P. Motion by Mr. McClanahan and seconded by Mr. Maxwell to approve the plan. Vote: 5-0-0 [Aye 5, Nay 0, Abstain 0] PASSED Surety release and plan signing as the final action items to conclude Board approval, which was granted on August 27, 2025. The motion would be to approve that the Planning Board acknowledges receipt of the required $50,000 affordable housing trust contribution, which was condition one of the special permit modification, and to endorse the modified subdivision plan for lot 16A at 23 McKenzie Lane, and to execute form J to release lot 16 from the subdivision covenant. Town Counsel had also reviewed this. Motion by Mr. Maxwell and seconded by Ms. Friedman to Acknowledge receipt of the required $50,000 Affordable Housing Trust contribution for Rolling Fields (Condition 1 of the 8/27/25 Special Permit Modification); endorse the modified subdivision plan for Lot 16A at 23 McKenzi Lane; and execute Form J to release Lot 16 from the subdivision covenant recorded at Bristol County North District Registry of Deeds, Book 20392, Page 300. Vote: 5-0-0 [Aye 5, Nay 0, Abstain 0] PASSED Planning Board Meeting Minutes 10-08-25 Page 10 of 11 8. OngoingPiam►i�gBoardDiscussions *placeholder, Parks-vayM-ansit OrientedDevelopmen Zoning Bylatn Amendments Planning board Policies & Procedures of the Planning Board with Site Plan Approval and Special Permit rules and Regulations and Planning Board Fees No items No items Motion by Mr. McClanahan and seconded by Mr. Maxwell M to adjourn at 9:52 pm Vote: 6-0-0 [Aye 6, Nay 0, Abstain 0] PASSED The date of the Next Planning Board Meeting is October 22, 2025, at 7: 00 p. m. — ) 0 I 22 2s Clerk �� 11L �f ��jyi� �� Date of Approval Documents Presented for the Meeting 1. Meeting Notice Agenda for October 8, 2025 2. Draft Meeting Minutes for September 24, 2025 3. 2024 and 2025 Working Group Minutes 4. 40 Pratt Street application and supporting documents 5. 1 West Church Street application and supporting documents 6. Proposed Zoning Bylaw Amendments draft as prepared for this meeting 7. 91 Otis Street Form A (Approval Not Required) 8. Rolling Fields Form J Lot Release and final plans for endorsement Planning Board Meeting Minutes 10-08-25 Page 11 of 11