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HomeMy WebLinkAbout03-30-2015 STUDY SESSION AGENDA PACKETAlityrB URN WASHINGTON City Council Study Session March 30, 2015 - 5:30 PM Council Chambers AGENDA Watch the meeting LIVE! Watch the meeting video M eeti ng videos are not avai I abl e unti 172 hours after the meeting has concluded. I. CALL TO ORDER A. Roll Call 11. ANNOUNCEMENTS, REPORTS, AND PRESENTATIONS A. Use of Force Review and Commendations, Inquiries and Allegations of Misconduct (30 Minutes Presentation)* (Stocker) 111. AGENDA ITEMS FOR COUNCIL DISCUSSION A. Low Impact Development Initial Briefing (15 Minutes Presentation 15 Minute Discussion)* (Carlaw) IV. OTHER DISCUSSION ITEMS V. ADJOURNMENT Agendas and minutes are available to the public at the City Clerk's Office, on the City website (http: / /www.auburnwa.gov), and via e -mail. Complete agenda packets are available for review at the City Clerk's Office. *Denotes attachments included in the agenda packet. Page 1 of 51 AN.3 AuBuRN ITY CAF � \VASHENG`Or, AGENDA BILL APPROVAL FORM Agenda Subject: Date: Use of Force Review and Commendations, Inquiries and March 25, 2015 Allegations of Misconduct (30 Minutes Presentation) Department: Administration Attachments: 2014 Use of Force 2014 CIA Analysis update Administrative Recommendation: Background Summary: Reviewed by Council Committees: Councilmember: Meeting Date: March 30, 2015 Budget Impact: $0 Staff: Stocker Item Number: AN.3 AUBURN * MORE THAN YOU IMAGINED Page 2 of 51 POLICE DEPARTMENT MEMORANDUM CITY OF AUBURI�T WASHINGTON DATE: March 30, 2015 TO: Mayor and Auburn City Council Members FROM: Auburn Police Department SUBJECT: 2014 Annual Response to Resistance Summary The purpose of this annual report is to document and summarize all response to resistance as submitted in the reports furnished by police officers in the Auburn Police Department during the 2014 calendar year. This report illustrates comparable statistics from 2013 and previous years, which will add context and possibly identify trends. The report will compare response to resistance forms vs. use of force allegations; types of injuries sustained by both suspect and officer; and force used when presented with different scenarios (i.e. officer about to be assaulted, property about to be damaged, etc.). In 2014, Auburn Police Officers responded to 89,350 CAD incidents (71,512 in 2013) and completed 18,174 case reports (16,321 in 2013.) Officers made 5,189 arrests (4,414 in 2013) with 2,940 of those arrestees being booked into jail (2,293 in 2013), and issued 9,495 infractions /citations (7,718 in 2013). There were 96 Use of Force Incidents in 2014 compared to 98 in 2013. Of these 96 occasions to use force, 85 suspects were involved. Of the 85 suspects, 35 reported injuries. All injuries were minor scrapes, bruises, small lacerations from going to the ground, K -9 bites, and one broken bone. Auburn Police Officers were compelled to use force once in every 931 CAD incidents, once in every 189 case reports completed, once in every 54 physical arrests, and once in every 31 physical bookings. See below table for ratio comparison from 2013. Only .11% of contacts resulted in a use of force. CAD Cases Arrests Bookings 2013 2013 Ratio (98) 2014 2014 Ratio Force Frequency (96) Change 71,512 1/729 89,350 1/931 -28% 16,321 1/166 18,174 1/189 -14% 4,414 1/45 5,189 1/54 -20% 2,293 1/23 2,940 1/31 -35% AN.3 Page 3 of 51 Th Of the 96 reported use of force incidents, there were zero allegations of inappropriate and /or excessive applications of force. RESPONSE TO RESISTANCE COMPARISON There were 96 Response to Resistance Incidents documented in 2014, which is a decrease from 2013. The Auburn Police Department reports uses of force using a Response to Resistance form. The following chart is a snapshot comparison of total excessive force allegations for each year compared to the amount of force incidents. Force Report Comparison 2007 -2014 Year Use of force Incidents Excessive Force Allegations Sustained Allegations 2009 132 15 0 2010 107 9 1 2011 113 3 0 2012 94 2 0 2013 98 3 1 2014 96 0 0 12.0% - 10.0% - 8.0% - 6.0% - 4.0% - 2.0% - 0.0% r %Total force Resulting in Complaints 2007 -2014 ,11.0% 8.4% 3% 3% 2009 2010 2011 2012 2013 2014 2 AN.3 Page 4 of 51 Types of Force Used The use of force types listed below are techniques that the officers are trained to use depending on the type of resistance they are receiving, among other factors as well. Take Down is by far the most used type of force our officers use which is also the least forceful type of force. LVNR is Lateral Vascular Neck Restraint, is not considered a "choke hold" and is widely used across the country. PIT is Pursuit Immobilization Technique, is used during pursuits in an attempt to end the pursuit as quickly as possible in order to reduce potential injury and take the suspect into custody. An Intentional Vehicle Strike is authorized by policy in certain situations which entails the officer striking a suspect vehicle with his /her patrol car at slow speed in order to pin the vehicle so that it cannot continue to flee. Force Types Used in 2014 50 45 40 35 30 25 20 15 10 5 0 44 37 20 18 12 10 8 7 4 4 3 4 3 3 2 C� °yzb. C°� C \��� Jar ��P9 ,c• �� � a� yyJ a� <Pe 3 AN.3 Page 5 of 51 Effective vs Not Effective Not every type of force is always effective and at times multiple types of force are used on one person during the same incident. 40 35 30 25 20 15 10 5 0 \(`‘' .4)*(' o � ��` o D4 �t to J ` `�` Q ` � a�aC°J� \�o� \��a`or��P�� •����e`' �a�� Q�e,c' � �e OC \t• • Effective • Not Effective Force Used Resulting in Injuries In 2014, injuries were reported for the suspect in 36% of force incidents and this is down from previous years. Officers received minor injuries in 6% of the incidents, and this too is lower than historical records. Total % of total of Force Suspect Officer suspect Incidents Injuries Injuries injuries 2009 132 63 5 48% 2010 107 47 13 2011 113 51 10 2012 94 38 9 2013 98 39 8 2014 96 35 6 44% 45% 40% 40% 36% 4 AN.3 Page 6 of 51 Suspect Injury By Type 2009 -2014 ▪ 50 45 40 35 30 25 20 15 10 5 0 fl- 2009 2010 2011 2012 2013 2014 • Taser Probe • Pain Complaint • K -9 • Cut /Bruise /Scrape /Bone Time of Day 12 10 8 6 4 2 0 2014 Incidents By Time of Day / \\ -all ( \A ( v , 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 tD N 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N M tD N N M O ▪ N M N CO CO N CO CO 0 00 O r-I r-I r-I r-I r-▪ I r-I r-I r-I r-I r-I N N N N N 0 0 0 00 5 AN.3 Page 7 of 51 Subject Trying to Flee Refusing Commands Other Force Incidents by Time of Day 2009 -2014 The above charts depicts the Auburn Police Department use of force incidents by time of day. As in all previous years documented, the majority of the occasions that officers are compelled to use force occur between the hours of 1800 and 0200. Reason for Use of Force Officer About to be Assau Ited Fighting Stance Other About to be Assaulted Subject With Weapon Muscular Tension /Pulled Away 2009 22 2010 14 2011 2012 2013 2014 25 14 10 22 3 0 15 13 15 19 10 7 3 5 3 1 1 0 1 0 1 0 123 44 99 41 77 52 23 96 29 103 30 109 94 88 53 77 67 35 42 17 7 22 20 The above chart shows the reasons that an officer(s) used force on a subject. Most of the time there are multiple reasons for use of force on one subject. In 2014, there were 238 documented reasons why an officer(s) used force. 6 AN.3 Page 8 of 51 Summary It is clear from the report, that Auburn Officers contact many subjects throughout the year and make many arrests. The most compelling stats in this report are that the calls for service, arrests, and bookings are up considerably and, by percentage, the use of force is down. This is due to the training the officers receive and the quality of personnel we have working for the Auburn Police Department. We, as a department, work hard to train our officers in de- escalation techniques and the officers do a great job influencing behavior. Officers have recently received 40 hours of Crisis Intervention Training and train every year in defensive tactics. 7 AN.3 Page 9 of 51 POLICE DEPARTMENT MEMORANDUM CITY OF AUBU WASHINGTON DATE: March 30, 2015 TO: Mayor and Auburn City Council Members FROM: Auburn Police Department SUBJECT: 2014 Annual Commendations, Inquiries and Allegations of Misconduct Analysis (CIA) This annual analysis of the CIA investigations provides the administration of the agency and the public we serve a review of agency personnel conduct from an analytical perspective and possibly through the eyes of our community. Our Vision Statement calls for us to be a premier agency that is trusted, supported, and respected. Our Mission Statement requires that our department will "provide professional Law Enforcement services to our community." To meet these demands, we must be a disciplined and a well - regulated organization. One method by which to determine our success is to evaluate our CIA process. This report illustrates how well the Auburn Police Department is perceived to be following our Vision and Mission statements, as well as our Manual of Standards. Summary of 2014 In 2014, Auburn Police Officers responded to 89,350 (71,512 in 2013) CAD incidents and completed 18,174 (16,321 in 2013) case reports. Officers made 5,189 (4,414 in 2013) arrests, with 2,940 (2,293 in 2013) of those arrestees being booked into the SCORE Jail. Officers also issued 9,495 (7,718 in 2013) infractions /citations. All of this activity accounts for only a portion of the personal contacts with our community members that are made by our police officers throughout the year. As outlined in the Auburn Police Department Manual of Standards (MOS), the CIA system provides a standardized means of reporting, investigating, and documenting Commendations, Inquiries, Internal Investigations and Collision Reviews. AN.3 Page 10 of 51 Medal of Valor Commendations A Commendation is used to recognize actions or performance by members of the police department who act or perform in a manner that is outstanding or beyond what is normally expected. The Commendation process recognizes employees for Professionalism, Exemplary Job, Exemplary Actions, Life Saving and Heroism. Total Commendations Involved Employees Letter of Commendation Medal of Distinction 2 209 0 ;IM 1111= 32 48 0 58 0 52 126 Year External Source Internal Source 2010 2011 ■ 34 13 2012 24 8 2013 29 12 2014 42 10 The majority of our commendations come from citizens who took the time to recognize one or more officers due to their exemplary and professional work. These commendations range from officers doing speeches at the schools, to helping someone change a tire, to going above and beyond to investigate someone's case. 2 AN.3 Page 11 of 51 Violations with Misconduct Employee Investigations There are two ways a complaint can be categorized and investigated: Supervisory Inquiry and Internal Investigation. A Supervisory Inquiry involves a complaint made regarding the quality of service delivery. These complaints vary in degree from complaints regarding an employee's demeanor, tardiness, complaints related to customer service, or the nature of a department practice. The employee's immediate supervisor typically handles this type of complaint, but a commander might also take charge of it. An Internal Investigation involves a complaint of a possible violation of department standards, written directives, City policies or applicable Civil Service Rules. These allegations include, but are not limited to, complaints of bias based policing, excessive force, alleged corruption, insubordination, breach of civil rights, false arrest, and other types of allegations of serious misconduct. In the event that an allegation of criminal misconduct is reported and appears to have merit, a simultaneous criminal investigation will be initiated. Internal Investigations Year CAD Incidents Internal Investigations Inv. Wit Misconduct oa Employees mp. With Misconduct Violations Reported • 27 1 2010 73,329 21 1 5 27 1 5 36 1 6 N. IIII 2011 62,488 22 2012 65,750 13 11 24 19 26 22 1 T T 2013 71,512 11 8 15 8 19 12 2014 89,350 5 3 5 3 12 9 Total allegations generated by internal and external sources ternal Sources Internal Sources •tal Combined Total Allegations M Sustained Misconduct 5 7 12 3 6 9 The above table shows that 60% of the allegations received from external sources resulted in a finding of misconduct. 86% of the allegations that were initiated from internal sources resulted in findings of misconduct. 3 AN.3 Page 12 of 51 Employees with Unacceptable Performance Year 2009 2010 2011 2012 2013 2014 21 27 25 21 11 25 Supervisory Inquiries Inquiries with Unacceptable Performance 7 6 9 9 7 5 Violations Initially Re . orted 25 34 32 32 14 45 Involved Em . to ees 33 32 32 20 13 34 9 6 9 9 7 4 Even though inquiries are up this year compared to last, the amount with "unacceptable performance" is considerably down by percentage. Allegations The following table depicts the total combined allegations for all the Supervisory Inquiries and Internal Investigations for 2014. It should be noted that Supervisory Inquiries can result in findings of Acceptable Performance or Unacceptable Performance, and Internal Investigations can result in findings of Misconduct or No Misconduct, among others. For the purpose of this combined report, all findings will be labeled as Misconduct or No Misconduct. Allegation Violation of General Policy Discourtesy Neglect of Duty CORE Values /Professionalism Bias Policing Collision — fail to report Conduct Unbecoming False Arrest Unlawful Search and Seizure RCW Violation Totals 15 8 3 1 1 11 1 7 1 57 No Misconduct • duct 1 11 1 10 1 7 0 43 3 — 1 2 0 0 1 0 0 1 14 Criminal Investigations There were no criminal investigations in 2014. 4 AN.3 Page 13 of 51 Collisions 35 30 25 20 15 10 5 0 2008 -2014 Collisions 2008 2009 2010 2011 2012 2013 2014 ■ Collisions ■ Preventable In 2014, there were 32 collisions involving APD employees. 22 of the 32 collisions were determined to be preventable on the part of the officer. The average years of service of the officers involved in collisions is 6.5 and the average age of the officer was 37. 20 of the collisions that occurred were officers who have 4 years or less of service with Auburn PD. The preventable collisions were attributed to officers with an average of 5.2 years of service. In reviewing the 22 collisions, which were determined through a Collision Review Board to be preventable, "driver inattention" was apparent in most cases, by either watching for suspects or looking at vehicle equipment inside the car. If the drivers had been more attentive, they would not have collided with another vehicle, curb, tree, etc. All 2014 collisions (preventable and non - preventable) are categorized as follows: • 9 - Driver Inattention • 1 - Fail to clear intersection • 6 - Improper Backing • 6 - Poor Tactics • 10- Other driver at fault 5 AN.3 Page 14 of 51 32 26 22 22 22 17 15 14 16 15 — — 11 — — 2008 2009 2010 2011 2012 2013 2014 ■ Collisions ■ Preventable In 2014, there were 32 collisions involving APD employees. 22 of the 32 collisions were determined to be preventable on the part of the officer. The average years of service of the officers involved in collisions is 6.5 and the average age of the officer was 37. 20 of the collisions that occurred were officers who have 4 years or less of service with Auburn PD. The preventable collisions were attributed to officers with an average of 5.2 years of service. In reviewing the 22 collisions, which were determined through a Collision Review Board to be preventable, "driver inattention" was apparent in most cases, by either watching for suspects or looking at vehicle equipment inside the car. If the drivers had been more attentive, they would not have collided with another vehicle, curb, tree, etc. All 2014 collisions (preventable and non - preventable) are categorized as follows: • 9 - Driver Inattention • 1 - Fail to clear intersection • 6 - Improper Backing • 6 - Poor Tactics • 10- Other driver at fault 5 AN.3 Page 14 of 51 18 - 16 14 12 10 8 6 4 2 0 17 Corrective Action - 2014 10 2 Coaching Written Non - Preventable Suspension Reprimand This chart depicts the corrective action dispensed to the employees in preventable collisions. Some officers also received additional training where it was appropriate. Actions Taken The following chart depicts action taken for misconduct, whether from an Internal Investigation, Supervisory Inquiry, or Preventable Collision. Combined Discipline ( Internals /Inquiries /Collisions) 24 Counseling 2 3 1 Verbal Written Suspension Resigned (not in Reprimand Reprimand lieu of termination) 6 AN.3 Page 15 of 51 Outside Agency Investigations To ensure that our investigations are unbiased, there are times when an outside agency may be asked to investigate serious allegations of misconduct made against agency staff, especially those that may be of a criminal nature. In the years 2007- 2010, there were no investigations assigned to an outside agency. Between 2011 and 2012, three criminal investigations were investigated by outside agencies. In 2013, outside agencies investigated three officers under two incidents. Those agencies presented the information to the respective prosecutors without influence from the Auburn Police Department or the City of Auburn. The King County Prosecutor's Office filed Assault charges on one incident and the employee resigned in lieu of termination. In the second incident of alleged excessive use of force, the prosecutors determined that no crime was committed. In 2014, there were no outside investigations. It is the practice of the Auburn Police Department to err on the side of caution and allow outside agencies to objectively investigate serious allegations of misconduct. In our view, this provides Auburn citizens with confidence and allows for unbiased transparency into actions, activities, and decisions made by the Auburn Police Department. There were no grievances in 2014. Grievances Conclusion A review of the frequency of incidents for 2014 regarding alleged misconduct by employees of the Auburn Police Department does not appear to raise any specific concerns. The data revealed in this analysis shows a decline in some areas and an increase in others. The most notable positive mark is the percentage of misconduct totals to the total allegations is very low. In addition to that, the number of allegations and found misconduct when compared to the actual number of contacts Auburn Police Officers encounter each year is extremely low. The data revealed for 2014 illustrates that the Auburn Police Department is successful in striving to perform by the standards of our CORE values and provide professional police services to the City of Auburn. 7 AN.3 Page 16 of 51 DI.B C=ITY or AUBURN WASH I NCTO AGENDA BILL APPROVAL FORM Agenda Subject: Date: Low Impact Development Initial Briefing (15 Minutes March 23, 2015 Presentation 15 Minute Discussion) Department: CD & PW Attachments: Land mpact Development PowerPoint Presentation Administrative Recommendation: Budget Impact: $0 For discussion only. Background Summary: The City has been issued a municipal stormwater permit by the Washington State Department of Ecology (modified permit effective January 16, 2014). A requirement of that permit is to control runoff from new development, redevelopment and construction sites. An element of controlling runoff from development sites will include making Low Impact Development (LID) techniques the preferred and commonly -used approach for stormwater management. The staff briefing will cover the regulatory background bringing us to this point, how Low Impact Development compares to traditional stormwater management methods, our plan for assessing and amending City stormwater requirements (including City Council and public involvement), and the proposed schedule for implementation. This is an initial briefing, beginning a process that will culminate with Council adoption of new policy, code, and standards, making Low Impact Development the preferred stormwater management technique in Auburn. Pursuant to the City Council request on March 16, 2015 for additional information about the City of Auburn's National Pollutant Discharge Elimination System (NPDES) Phase II Municipal Stormwater Permit, the presentation will include an overview of the NPDES permit requirements. The presentation will also include the new permit requirements that went into effect following the Pollution Control Hearings Board decision and settlement agreement with Ecology on the 2012 appeal by the Coalition of Government Entities (13 municipalities including Auburn). Reviewed by Council Committees: AUBURN * MORE THAN YOU IMAGINED Page 17 of 51 DI.B Councilmember: Meeting Date: March 30, 2015 Staff: Carlaw Item Number: DI.B AUBURN * MORE THAN YOU IMAGINED Page 18 of 51 Low Impact Development City Council Study Session Presentation March 30, 2015 Page 19 of 51 Presentation Overview +Review of National Pollutant Discharge Elimination System Municipal Stormwater Permit +What is Low Impact Development? DI.B • What are our regulatory requirements? • Plan for compliance • Council and Public Involvement Process • Schedule National Pollutant Discharge Elimination System (NPDES) ❖Authorized by the Federal Clean Water Act (CWA) ❖Intended to protect and restore waters for "fishable, swimmable" uses ❖Controls water pollution by regulating point sources ❖Authority to oversee the program in WA was delegated to the Department of Ecology ❖Phase I Permits — municipalities with population > 100,000 ❖Phase II Permits — municipalities < 100,000 Auburn has a Phase II Permit DI.B Page 21 of 51 The Federal Municipal NPDES Permit requires: ❖Public Education and Outreach ❖Public Participation / Involvement ❖Illicit Discharge Detection and Elimination ❖Construction Site Runoff Control ❖Post Construction Runoff Control ❖Pollution Prevention / Good Housekeeping The Washington Permit adds: ❖Total Maximum Daily Load (TMDL) Compliance (another CWA program) ❖Monitoring Failure to comply with the Phase II requirements puts the City at risk for fines and 3rd party lawsuits, and jeopardizes our ability to secure grants and loans DI.B Page 22 of 51 Appeal of New NPDES Requirements +In 2012, 13 municipalities (including Auburn) and other entities appealed new requirements proposed by the Washington Department of Ecology for Phase II Municipal Stormwater Permits. +In 2013, the Pollution Control Hearings Board decision on the appeal, and a subsequent settlement agreement between Ecology and the plaintiffs, resulted in the following additional permit requirements for Auburn: • Changes to the Watershed -scale stormwater planning condition • New or revised definitions for Conveyance system, Discharge point, Outfall, Receiving waterbody or receiving waters Conclusion: the new regulations had little impact on Auburn's stormwater management program because it had already incorporated these requirements Page 23 of 51 Low Impact Development (LID) DI.B Stormwater Management Methods Traditional urban stormwater management practices ❖Construct centralized storm facilities that collect & remove runoff quickly ❖Clear & grade the site to facilitate development, not stormwater management Low impact development practices ❖smaller scale storm facilities ❖Decentralized and distributed ❖Integrated within the landscape Page 25 of 51 Low - Impact Development (LID) "A stormwater and land use management strategy that strives to mimic pre- disturbance hydrologic processes of infiltration, filtration, storage, evaporation, and transpiration by emphasizing conservation, use of on -site natural features, site planning, and distributed stormwater management practices that are integrated into a project design." Low Impact Development Technical Guidance Manual for Puget Sound, WSU Extension and the Puget Sound Partnership Page 26 of 51 LID Stormwater Facilities +Reduce volume thereby minimizing high flows •:•Remove pollutants from stormwater +Replenish streams and wetlands through shallow groundwater +Reduce the size of conventional stormwater facilities Increase open space +Visua I ly attractive +Can result in construction and maintenance cost savings +Can increase densities DI.B Bioretention Required Best Management Practice (BMP), unless infeasible Page 28 of 51 Permeable Pavement DI Required BMP (unless infeasible) Rain Gardens (small projects only) Page 30 of 51 Dispersion Required BMP (unless infeasible) DI.B Page 31 of 51 Downspout Dispersion Required BMP (unless infeasible) Page 32 of 51 Sheet Flow Required BMP (unless infeasible) Page 33 of 51 Vegetated Roofs BMP - City may opt to allow or require •I :I :M DI.B Page 34 of 51 Rainwater Harvesting BMPs — City may opt to allow or require DI.B Page 35 of 51 Minimal Excavation BMP - City may opt to allow or require DI.B Page 36 of 51 Western WA Phase 1 & Phase II NPDES Permit Overview +LID will be required, where feasible +Review & amend local codes & standards +Site & subdivision scale requirements +Small, medium and large projects Page 37 of 51 Development Code Review & Amendment Goals DI.B +Reduce impervious surface Protect native vegetation +Reduce stormwater runoff +Make LID the preferred and commonly used approach Code Amendments Related to Site Design Principles Key principles to be considered during code changes +Reduced road width +Changes in road layout and orientation +Clustering +Higher building & smaller footprints Parking regulations +Landscaping using bioretention Page 39 of 51 Narrow Roads Changes in Road Layout & Orientation DI.B of 51 Clustering Conventional Design DI.B Low - Impact Design Page 42 of 51 Taller Buildings with Smaller Footprints One story building, built right up to setback lines. Impervious surfacing 65% of the site. DI.B Three story building with vegetated roofs, equalling less than 30% impervious surfacing, Existing vegetation can be retained or new vegetation can be installed to provide usable open space and stormwater treatment/infiltration opportunities. Page 43 of 51 Parking Regulations Required Landscaping Used as Bioretention DI.B Page 45 of 51 DI.B Development Code Review & Amendment Page 46 of 51 Steps ❖Assemble Team ❖Understand LID topics to Address ❖Review Existing Codes & Standards ❖Fill in the Gaps ❖Engage elected officials and public to review and revise proposed codes and standards ❖City Council adopts new codes and standards ❖Implement LID DI.B Page 47 of 51 Core Team Community Development and Public Works +Storm Drainage •:•Development •:•Permitting +Planning +Transportation +Building Schedule 2015 Review City code and documents Internal stakeholder input Propose updates 2016 Meetings with external stakeholders Draft updates Technical, legal, external review Council and public input Adopt revisions, prepare tools & guidance, train staff 2017 Implement updated requirements beginning 1/1/17 Page 49 of 51 Implementation The change to LID will represent a paradigm shift that will affect the way we do business DI.B +Education and Training +Inspection +Maintenance +Cost (short & long term) Page 50 of 51 Comments and/or Questions? DI.B Page 51 of 51