HomeMy WebLinkAboutItem 13 An Ordinance Relating to Police Impact Fees
AGENDA ITEM COVER SHEET
Contact Name:
Contact Number:
s. Goclon
x3027
Meeting Date: March 15, 2005
Item # ) 3
~:~::~~~ir~qOr: '. ". J ~
/
Background Summary:
The Police Impact Fee ordinance was adopted in 1990, and amended in 1991. At that time, a report was
prepared concerning the fee methodology and costs. In 1999, City Planning staff updated the report.
This report was again updated in 2004 and forms the basis for the Police Impact Fee update and
proposed increase.
Issue:
Should the Honorable Mayor and Board of City Commissioners adopt an ordinance to increase the
Police Impact Fee.
Recommendations
Staff recommends that the Honorable Mayor and Board of City Commissioners adopt the
ordinance to increase the Police Impact Fee.
Attachments:
"The City of Ocoee Police Impact Fee Update Final Report 2004"
Police Impact Fee PowerPoint slide presentation
Impact Fee Comparison
Police Impact Fees Ordinance
Financial Impact:
Proposed ordinance would increase police impact fees from the current 8.9 cents per square foot per
residential dwelling unit (an average 2000 square foot dwelling = $172.00) to a flat fee of $501.04 per
residential dwelling unit. It would increase police impact fees from the current 9.7 cents per square foot
nonresidential to 33 cents per square foot nonresidential.
Type of Item: (please mark with an "x')
Public Hearing
~ Ordinance First Reading
Resolution
_ Commission Approval
Discussion & Direction
_ Original Document/Contract Attached for Execution by City Clerk
_ Original Document/Contract Held by Department for Execution
Reviewed by City Attorney
Reviewed by Finance Dept.
Reviewed by ( )
N/A
N/A
N/A
Commissioners
Danny Howell. District 1
Scott Anderson. District 2
Rusty Johnson. District 3
Nancy J. Parker. District 4
Mayor
S. Scott Vandergrift
City Manager
Robert Frank
STAFF REPORT
TO:
The Honorable Mayor and City Commissioners
FROM:
Steven J. Goclon, Chief of Police
DATE:
March 15,2005
RE:
Police Impact Fees
ISSUE
Should the Honorable Mayor and Board of City Commissioners adopt an Ordinance to increase
the Police Impact Fee.
BACKGROUNDIDISCUSSION
The Police Impact Fee was initially adopted February 6, 1990 and amended on May 7, 1991. At that
time, a report was prepared concerning the fee methodology and costs. In 1999, City Planning staff
updated the report, but it was never brought before Commission. This report was again updated in
2004 and forms the basis for the Police Impact Fee update and proposed increase and is known as
the liThe City of Ocoee Police Impact Fee Update Final Report 2004."
The proposed police impact fee ordinance would increase police impact fees from the current 8.9
cents per square foot per residential dwelling unit (an average 2000 square foot dwelling = $172.00) to
a flat fee of $501.04 per residential dwelling unit (or 25 cents per square foot for an average 2000
square foot dwelling). It would increase police impact fees from the current 9.7 cents per square foot
nonresidential to 33 cents per square foot nonresidential. The proposed fees will pay for capitol
equipment for any new officers (approximately $4,364,685) and the portion of new police department
facilities (approximately $5,440,000) added to accommodate the police department's new growth
expected through 2020.
"The City of Ocoee Police Impact Fee Update Final Report 2004" Page 1 of 6
Operational Background
The Ocoee Police Department is located within the 7,816 square foot police headquarters
building, built in 1994. Most operations are based within this building including
administration, communications, records, holding facility, training, arsenal, evidence
storage, locker rooms, booking, and patrol operations. Because of overcrowding, the
Traffic Enforcement,. TJnit and Criminal Investigations Division, as well as training,
storage, and public meeting facilities, have been temporarily moved to separate rented or
City owned properties located elsewhere in the City. In 2000, the police department
commissioned a spatial needs assessment from Architects Design Group of Winter Park.
The assessment, completed in March 2001, indicated that the current police building did
not meet the spatial or functional needs of the police department. The 2001 spatial need
was estimated to be 26,584 square feet. The 2010 spatial need was estimated to be 32,507
square feet. The 2020 spatial need was estimated to be 57,551 square feet. This study was
based partially on projected police department growth, which was in turn based on
projected population growth in the city limits and JP A. As previously stated, current
building facilities are being utilized at capacity, accommodating more sworn personnel
and programs than what were envisioned when the building was constructed. Equipment
needs have generally kept pace with the number of personnel added to the force over the
years, although certain large-scale items are showing serious signs of wear due to age and
high use rates.
Currently, the road patrol division operates on three shifts; the day shift from 5:30 AM to
3:30 PM; the evening shift from 2:00 PM to 12:00 AM; and the midnight shift from 8:30
PM to 6:30 AM. Typically, depending on the time of day, five to ten officers are out on
patrol each shift using one squad car per officer.
In addition to typical patrol and administrative activities, the police department maintains
the following: Criminal Investigation unit, NarcoticsNice unit, Traffic Enforcement unit,
School Resource Unit, Evidence/Property unit, Community Affairs unit, K-9 unit, School
Crossing Guard unit, Professional Standards/Training unit, Records section,
Communications/ Dispatch Center, and programs such as Police Explorers, Police
Auxiliary, Citizens' Advisory Counsel, Citizens' Police Academy, and Juvenile
Restorative Justice. The department is highly active in training activities. It generally
handles most police operations needs in-house, unless facilities limitations don't allow it
or equipment or instructor staff is required from an outside source.
Ocoee Police Department Service Activity
General police department activity levels have been increasing over the years as a result
of additional development and population. Crime statistics indicate significant increases
in a variety of areas such as batteries, burglaries, larcenies, auto thefts, drug activities,
and arrests. The total numbers of calls for service (CFS) have steadily increased over the
years. Service requirements are rising faster than the overall population growth rate and
the number of officers added to the police department.
"The City ofOcoee Police Impact Fee Update Final Report 2004" Page 2 of6
Ocoee Police Department Service Activity (continued)
Annual Calls For Service (1998-2003)
OFFENSE 1998 1999 2000 2001 2002 2003
Murders 1 0 1 1 0 0
Rapes 9 13 9 15 22 30
Robberies 27 29 34 30 22 25
Assaults * 532 509 630 586 472 529
Burglaries 292 255 254 283 294 282
Larcenies 1210 1032 1055 1021 1196 1243
Auto Thefts 147 99 113 142 237 189
Criminal Mischief 350 375 331 413 401 467
Drug Offenses 93 150 98 85 118 222
DUI 107 88 141 191 147 339
Vehicle Accidents 1389 1568 1616 1620 1545 1573
Other Criminal Calls 9300 14740 15235 17972 12891 12465
Alarms 2119 1088 1191 1210 2316 2252
Non-Criminal Calls 10692 10551 11713 12537 13877 14575
TOTAL 26268 30497 32421 36106 33538 34280
Source: Ocoee Police Department
*Includes: Assaults, Batteries, Stalking
Annual Calls For Service By Location (1998-2003)
Percent of
1998 1999 2000 2001 2002 2003 Total Total
Residential 17,321 19,464 19,799 23,144 20,411 20,495 120,634 63%
N on-Residential 8,947 11 ,033 12,622 12,962 13,127 13,785 72,476 37%
Total CFS 26,268 30,497 32,421 36,106 33,538 34,280 193,110 100.00%
Source: Ocoee Police Department Records Section
Personnel Levels
The Ocoee Police Department is presently authorized to provide a total of 67 sworn
officers and 27 non-sworn support staff. 36 officers are in Road Patrol division. The
remaining 31 officers make up the previously mentioned specialized units and
administration.
"The City ofOcoee Police Impact Fee Update Final Report 2004" Page 3 of6
Personnel Levels
(continued)
Personnel Utilization: Ocoee Police Department
Current Personnel # 0 Positions
Police Chief 1
Captain 1
Lieutenant 3
Sergeants 10
Officer First Class 1
Police Officer 51
Administrative Assistant III 1
Administrative Assistant II 2
Administrative Aide PIT 1
Chief Communications Supvsr 1
Communications Supervisor 4
Communications Officer 10
Records Supervisor 1
Records Clerks 2
Records Clerks PIT 3
Crime Analyst 1
Evidence & Property Specialist 1
School Crossing Guard PIT 22
Total 116
Source: City of Ocoee Human Resources Department
When compared with the existing lP A population of approx. 39,000, the Ocoee Police
Department has 1.72 sworn officers per 1,000 population. The lPA population has a
significant impact on police calls for service. When compared with the population of city
residents (approx. 29,215), the ratio is 2.3 officers per 1,000. This ratio of sworn officers
per 1,000 population is less than the statewide average of 2.6 officers per 1,000. Based
on this information, it is apparent that sworn staffing is being utilized at maximum
capacity to keep up with the ever-increasing number of CFS. The current Police Impact
Fee Study assumes 3.0 sworn officers per 1,000 population as the target ratio for future
growth. This figure is consistent with the standards set by other states and the Federal
Bureau of Investigation (FBI). Since these personnel levels will form the basis for the
level of service provided to new residents of the community, it is assumed that the City
will, on the average, add three new sworn officers for every 1,000 new residents during
the study period. The City has added one new police officer position since 1999, raising
the number from 66 to 67. Two School Resource Officers are scheduled to be added to
the department in April 2005, however, these officers will primarily service the new high
school (3000 students projected) and will do little to serve the permanent city population.
"The City of Ocoee Police Impact Fee Update Final Report 2004" Page 4 of 6
Personnel Levels (continued)
Year New Population New Houses New Commercial
2000 1645 281 302,594
2001 1602 288 366,280
2002 1253 342 131,618
2003 847 505 95,440
Totals 5347 1416 895,932
Sources: City of Ocoee Community Development! BEBR
On the basis of the population projected to the horizon year, the City would need to add,
on the average, 8 sworn officers per year to maintain current service levels over time. In
other words, the total number of sworn officers would need to increase to at least 183,
requiring 117 more positions than currently provided. In combination, support staff
would need to increase to a minimum of 70 persons, an increase of 43 staff positions.
Facilities and Equipment Inventory
The existing capital investment made by the City of Ocoee to support its police
department includes land, buildings, furnishings, vehicles, and equipment. As with any
asset, the individual items (which make up the total capital goods of the police
department) have varying useful lives and values. Since impact fee rates must be based
upon the current costs of goods necessary to proportionately add to the capital facilities
and equipment of the community, it is necessary to estimate the replacement costs of
existing capital items to provide a common basis from which to project future needs. In
other words, the capital cost to add each new officer can be derived by determining the
capital expenditures for the existing police force divided by the number of sworn
personnel.
To derive the Police Department's capital expenditures, a complete inventory of all
capital items was completed by the Ocoee Police Department. Using this inventory and
cost information provided by the police department, the cost to outfit a new officer was
calculated to be $37,305. The costs included in this calculation are summarized in the
table below.
The total cost for new police headquarters and training facilities (including land and site
development) was estimated at $8.5 million. It is assumed that new growth will account
for 64% of the new building (117 new officers / 183 total officers = 63.34%). It should
be noted that the cost used for the police headquarters building includes only the portion
needed for new growth. Using these figures, the cost of the new police facilities that can
be attributed to new growth is $5,440,000 ($8,500,000 X .64 = $5,440,000).
((The City ofOcoee Police Impact Fee Update Final Report 2004" Page 5 of6
Facilities and Equipment Inventory (continued)
Capital Cost Per Officer: Ocoee Police Department
Item/Catef(orv Cost per Officer Descri]Jtion of Item
Hand Gun $500 Standard issue sidearm
Belt & Misc. Items $500 Includes handcuffs, mace, etc.
Mobile Radio $2,500 Portable 2 way radio
Uniform $500 Set of 5 standard issue
Protective Gear $650 Helmet, baton, bullet proof vest,
shield, riot gear
Lap Top Computer $4,655 Includes modem, software & misc.
equipment
Patrol Vehicle $28,000 Includes Cage, roll bar, light bar, etc.
Facilities $46,496 64% of buildings, structures, land, site
development, furnishing, and equipment
costs through the year 2020
Total cost per officer $83,801 approximation
Police Impact Fee Determination
The police impact fee account has approx. $450,000. The bonds for the current police
headquarters building are through 2028. The amount of existing debt service (paid
exclusively from impact fees) is $71,000 per year. Police Department impact fees have
not been updated since 1990. The existing figures of $.086 per square foot for
residential and $.097 per square foot for non-residential have been inadequate to keep up
with the growth of the city. Annual police impact fee revenues average about $115,000.
They have not kept pace with the Ocoee Fire Department's impact fee (updated in 2000)
rate of $.182 per square foot for residential and $.284 per square foot for non-residential
nor the Ocoee Recreation Department impact fee (updated in 2001) which is a flat rate of
$500 per residential unit. Police impact fees cannot be compared to those of surrounding
law enforcement agencies as they do not have the same growth, number of officers, calls
for service, tax rates, tax base, or capitol needs as the City of Ocoee or the Ocoee Police
Department.
"The City of Ocoee Police Impact Fee Update Final Report 2004" Page 6 of 6
Police Impact Fee Determination (continued)
Having gathered, analyzed, and projected all of the aforementioned data, it is possible to
determine the theoretical proportionate share impact fee rates using the methodology
outlined below.
Existing lP A population: 39,000 ' " ;, " , '
Year 2020 lP A population: 78,000
Proiected population growth: 39,000
New Police Officers needed: 39,000/1,000 X 3.0 = 117
Value of capital items needed for each new $83,801
officer:
Capital investment for new officers: 117 x $ 83,801 = $9,772,685 (approx)
Number of new residential dwelling units Approx. 12,288 DU
to be added in the lP A:
Amount of non-residential building square Approx. 10,982,880
footage to be added in the lP A:
Percentage ratio of residential vs. non- 63% residential vs. 37% non-residential
residential CFS:
Capital investment per residential dwelling unit construction proportionate to CFS:
$9,772,685 x .63 = $6,156,791.5/12,288 DU = $ 501.04 per Dwelling Unit
Capital investment per square foot of non-residential space proportionate to CFS:
$9,772,685 x .37 = $3,615,893.5 /10,982,880 sq. ft. = $0.33 per sq. ft.
Recommended police impact fees:
Residential: $ 501.04 per dwelling unit
Non-residential: $ 0.33 per square foot
CITY OF OCOEE
POLICE IMPACT FEE COMPARISON
Local Government Police Remarks:
Develooment Type Fee/Sa. Ft.
Ocoee.Existing Residential $0,086/sa. ft.
Non-Residential $0.097/sa. ft.
Development Tvpe Fee/SQ, Ft.
Ocoee-Proposed Residential $501.04/unit
Non-Residential $0 .33/sQ. ft.
Land Use Fee Rate Unit of Police impact fee: discounted by 5% of the actual fee.
Classification Measure
IndustriaUManufacturin $0.089 Sq. ft,
olWarehousino
Institutional $0.336 SQ. ft,
Office $0,275 SQ, ft,
Retail $0.493 Sa. ft.
Eating & Drinking $2.21 Sq. ft.
Altamonte Springs Establishment
Lodging & Special
Residential Needs:
Adult Living $58.24 bed
Facilitv/Nursina Home
HoteUMotel $148.51 auest room
Residential:
Sinole Familv $185,54 du
Multiole Familv $168.20 du
Apopka None
Casselberry None
Kissimmee None
Develooment Tvpe Fee
Lake Mary Residential $165/unit
CommerciaUNon- $0.0821sq, ft.
Residential
Land Use Fee Cost
Residential $300.39/du
Non- Per 1000 sq. ft,
Mt. Dora Residential
Commercial $999.51
Institutional $913.06
Industrial $44,38
Orlando None
Type of Fee/Unit of Measure
Construction
Oviedo Residential $214/du
Non-Residential $529/1,000 sq ft-gross
floor area
Winter Type Rate
Springs Residential $111.78/unit
Commercial $0.164/sQ. ft,
Structure Fee/Unit of Measure
Winter Garden Residential $260/U n it
Non-Residential $500/1,000 SQ. ft.
Osceola County None
Seminole County None
C:\Documents and Settings\sgoclon\Local Settings\Temporary Internet Files\OLK1 08\lmpact Fee Comparison_Police_1 0-20041 ,doc
Page 1 of 1
ORDINANCE NO.
AN ORDINANCE OF THE CITY OF OCOEE, FLORIDA
RELATING TO POLICE IMPACT FEES; AMENDING
SECTION 87-40.C OF ARTICLE IV OF CHAPTER 87 OF
THE CODE OF ORDINANCES OF THE CITY OF OCOEE
RELATING TO INTENT, PURPOSE AND BASIS;
AMENDING SECTION 87-42 OF ARTICLE IV OF
CHAPTER 87 OF THE CODE OF ORDINANCES OF THE
CITY OF OCOEE RELATING TO FEE SCHEDULE;
CHANGING THE CALCULATION OF THE POLICE
IMPACT FEE FOR RESIDENTIAL DWELLING UNITS
FROM ONE BASED ON SQUARE FOOTAGE TO A FLAT
RATE PER RESIDENTIAL DWELLING UNIT;
INCREASING THE POLICE IMPACT FEE PER SQUARE
FOOT FOR NONRESIDENTIAL STRUCTURES;
PROVIDING FOR SEVERABILITY; PROVIDING FOR
CODIFICATION; PROVIDING AN EFFECTIVE DATE.
WHEREAS, the City Commission of the City of Ocoee has the authority to adopt this
Ordinance pursuant to Article VIII of the Constitution of the State of Florida and Chapter 166,
Florida Statutes; and
WHEREAS, the City Commission of the City of Ocoee desires to change the
calculation of the police impact fee for residential dwelling units from one based on square
footage to a flat rate per residential dwelling unit and increase the police impact fee per square
foot for nonresidential structures, provided, however, that the existing fees shall apply to any
new buildings for which a building permit application has been submitted to the City on or
prior to the effective date of this Ordinance and for which a building permit is issued within
ninety (90) days from the date of adoption of this Ordinance; and
006.330583.2
WHEREAS, the City has conducted an updated study regarding impact fees and
according to this study has made a determination as to the necessary uniform police impact
fees for new residential dwelling units and new nonresidential structures within the City.
NOW, THEREFORE, BE IT ENACTED BY THE CITY COMMISSION OF THE
CITY OF OCOEE, FLORIDA, AS FOLLOWS:
. d ,d::
SECTION 1. Authority. The City Commission of Ocoee has the authority to adopt
this Ordinance pursuant to Article VIII of the Constitution of the State of Florida and Chapter
166, Florida Statutes.
SECTION 2. Amendment to Section 87-40.C Section 87-40.C of Article IV of
Chapter 87 of the Code of Ordinances of the City of Ocoee, Florida, is hereby amended to read
as follows:
C. This article is based upon a study by the Ocoee Police Department and
Planning Department, as updated in connection with the adoption of this
ordinance, of the anticipated growth in the City of Ocoee and a
projection of the equipment and facilities necessary to serve the
anticipated growth.
SECTION 3. Amendment to Section 87-42 Section 87-42 of Article IV of Chapter 87
of the Code of Ordinances of the City of Ocoee, Florida, is hereby amended to read as follows:
~ 87-42. Fee schedule.
A. The following police impact fees are hereby assessed by the city
and shall be collected by the city prior to the issuance of the building
permit or any other development permit for the construction of any
structure to be used as a residential dwelling or nonresidential structure:
(1) Residential Dwelling Units: $501.04 per Dwelling Unit
(2) Nonresidential Structures: $0.33 per square foot
006.330583.2
-2-
B. The fees imposed for residential and nonresidential construction
are a result of the city's fee calculation study which was designed to
ensure that the impact fees imposed are rationally related to the benefit
received by the applicant.
C. In the event that an applicant believes the impact of the
construction will be less than that set forth above, the applicant may, at
his option, submit evidence to the City Commission in support of an
altetnativ'e'lassessment. Based upon convincing and competent evidence,
the City Commission may adjust the impact fee as appropriate for the
particular property.
SECTION 4. Spvpr9hility If any section, subsection, sentence, clause, phrase or
portion of this Ordinance is for any reason held invalid or unconstitutional by any court of
competent jurisdiction, such portion shall be deemed a separate, distinct and independent
provision and such holding shall not affect the validity of the remaining portion hereto.
SECTION 5. C'ntlifil"9tinn It is the intention of the City Commission of the City that
the provisions of this Ordinance shall become and be made a part of the Code of Ordinances of
the City; and that sections of this Ordinance may be renumbered or relettered and the word
"ordinance" may be changed to "chapter," "section," "article," or such other appropriate word
or phrase in order to accomplish such intentions; and regardless of whether such inclusion in
the Code is accomplished, sections of this Ordinance may be renumbered or relettered and the
correction of typographical errors which do not affect the intent may be authorized by the City
Manager, without need of public hearing, by filing a corrected or recodified copy of same with
the City Clerk.
SECTION 6. Rffpl"tivp n9tp This Ordinance shall become effective immediately upon
passage and adoption, provided, however, that the existing fees shall apply to any new
buildings for which a building permit application has been submitted to the City on or prior to
006.330583.2
-3-
the effective date of this Ordinance and for which a building permit is issued within ninety (90)
days from the date of adoption of this Ordinance.
PASSED AND ADOPTED this _ day of
,2005.
ATTEST:
APPROVED:
CITY OF OCOEE, FLORIDA
Beth Eikenberry, City Clerk
(SEAL)
S. Scott Vandergrift, Mayor
FOR USE AND RELIANCE ONLY BY
THE CITY OF OCOEE, FLORIDA;
APPROVED AS TO FORM AND
LEGALITY this _ day of , 2005.
, 2005 AND
ADVERTISED
, 2005
READ FIRST TIME , 2005
READ SECOND TIME AND ADOPTED
, 2005
UNDER AGENDA ITEM NO.
FOLEY & LARDNER LLP
By:
City Attorney
006.330583.2
-4-
Copy of Public Hearing Advertisement
Orlando Sentinel
Date Published
-rhw~~ ~, 'ZOOS-
Advertisement
.." :CITY OF"OOOEE:",
NOTICE OF PUBLIC HEARING,
FOR AN AMENDMENT"
TO THE CODE OF ORDINANCES
:;.~~71
NOTICE IS HEREBY GIVEN, pursuant to Subsection
l66.04l(3)(c) 2., Florida Statues, that on Tuesday,
MARCH 15, 2005 at 7:15 p.m. or as soon thereafter as
practical, the CITY OF OCOEE CITY COMMISSION
will hold the SECOND READING & PUBLIC HEAR-
ING at. the City of. Ocoee Commission Chambers, 150
North Lak.eshore Drive, Ocoee, Florida, to consider the
adoption of the following Ordinance concerning police
. impact fees:
AN ORDINANCE OF THE CITY OF OCOEE,
FLORIDA RELATING TO POLICE IMPACT FEES;
AMENDING SECTION 87-40.C OF ARTICLE IV OF
CHAPTER 87 OF THE CODE OF ORDINANCES OF
THE CITY OF OCOEE RELATING TO INTENT,
PURPOSE AND BASIS; AMENDING SECTION 87.
42 OF ARTICLE IV OF CHAPTER 87 OF THE
CODE OF ORDINANCES OF.THE CITY OF
OCOEE RELATING TO FEE SCHEDULE; CHANG-
ING THE CALCULATION OF THE POLICE
IMPACT FEE FOR RESIDENTIAL DWELLING
UNITS FROM ONE BASED ON SQUARE FOOTAGE
, TO A FLAT RATE PER RESIDENTlAL DWELLING
UNIT; INCREASING THE POLiCE IMPACT FEE
PER SQUARE FOOT FOR NONRESIDENTIAL
STRUCTURES; PROVIDING FOR SEVERABn..ITY;
PROVIDING FOR CODIFICATION; PROVIDING
AN EFFECTIVE DATE.
Interested parties may appear at the public hearing and be
heard with respect to the proposed actions.
The complete case file may be inspected at the Ocoee
Community Development Department/Planning Division
located at 150 North Lakeshore Drive, Ocoee, Florida
between the hours of 8:00 a.m. and 5:00 p.m., Monday
through Friday, except legal holidays.
The City Commission may continue the public hearings to
. other dates and times, as it deems necessary. Any inter-
ested party shall be advised of the dates, times, and places
of any continuation of these or continued public hearings.
Any .centinuances shall be announc~d during these hear-
ings and no further notices regarding these matters will be
published.
You are advised that any person who desires to appeal any
decision made at the public hearings will need a record of
the proceedings and for this purpose may need to ensure
thilt a verbatim record of the proceedings is made which
includes the testimony and evidence upon which the
appeal is based.
Persons with disabilities needing assistance to participate
in any of these proceedings should contact the City Clerk's
Office 48 hours in advance of the meeting at 407-905-
3105. .
Beth Eikenberry, City Clerok:
Run Dater March 3,2005
O:\Office Procedures\Copy ofPuuu" H<;<U lug f\Qvemsement.doc
\:
I
!