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Home My WebLink About2009/11/17 Item 11CITY COUNCIL AGENDA STATEMENT r,. ~ ~ '"~`CHULAVISTA 11/17/09, Item I ~ ITEM TITLE: RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CHULA VISTA AUTHORIZING SUBMITTAL OF FISCAL YEAR 2010/2011 BICYCLE TRANSPORTATION ACCOUNT (BTA) GRANT APPLICATIONS FOR INSTALLATION OF BICYCLE DETECTORS ON TELEGRAPH CANYON/ OTAY LAKES ROAD AND THE INSTALLATION OF BICYCLE RACKS AND BICYCLE LOCKERS IN THE CIVIC CENTER AREA AND CERTIFYING THAT MATCHING F~,JNDS ARE OR WILL BE AVAILABLE THEREFOR SUBMITTED BY: DIRECTOR OF PUBLIC WORKS ~/f^~ ASSISTANT DIRECTOR OF ENG REVIEWED BY: CITY MANAGER ~ ASSISTANT CIT ANAGER ~ f 4/STHS VOTE: YES ^ NO SUMMARY The California Department of Transportation (Caltrans) has announced available grant funding for Fiscal Year 2010/2011 projects through its competitive Bicycle Transportation Account (BTA) grant program. The grant application deadline is December 1, 2009. Staff recommends submitting grant applications for $128,200 for the installation of bicycle detectors on Telegraph Canyon Road/ Otay Lakes Road between I-805 and Wueste Road and $25,000 for the installation of bicycle racks and bicycle lockers in the Civic Center area. ENVIRONMENTAL REVIEW The Environmental Review Coordinator has reviewed the proposed activity for compliance with the California Environmental Quality Act (CEQA) and has determined that the activity is not a "Project" as defined under Section 15378 of the State CEQA Guidelines because the request for grant funds has not been approved and the action approving the project has not yet been approved, adopted or funded by the City of Chula Vista. Therefore, pursuant to Section 15060 (c)(3) of the State CEQA Guidelines the activity is not subject to CEQA. Thus, no environmental review is necessary. RECOMMENDATION Council adopt the resolution. 11-1 11/17/09, Item ~~ Page 2 of 4 BOARDS/COMMISSION RECOMMENDATION Not applicable. DISCUSSION The California Department of Transportation (Caltrans) has announced available grant funding for Fiscal Year 2010/2011 projects through its competitive Bicycle Transportation Account (BTA) grant program. The intent of the program is to improve safety and convenience for bicycle commuters in the region. The BTA grant program is available to local agencies with adopted Bicycle Transportation Plans less than five years old. For Fiscal Year 2010/2011 funding, the plan must be adopted between January 1, 2005 and December 31, 2009. The City of Chula Vista's Bikeway Master Plan was adopted by Council in January 2005 and thus complies with the grant requirements. A total of $7.2 million is anticipated to be available statewide with a maximum award for a single project not to exceed $1.8 million. The grant application deadline is December 1, 2009. Funds must be encumbered the fiscal year that they are awarded. Funds are then available for expenditure during the succeeding two fiscal yeazs. Staff considered submitting applications for various projects recommended in the current Bikeway Master Plan. One project under consideration was construction of the Bayshore Bikeway from E Street to F Street. This project involves constructing approximately %-mile of bike path linking the current northern bike path segment, which ends at E Street, to the bike lanes along Bay Blvd. and the bayfront. It is anticipated that the bike path will eventually extend along the entire Chula Vista bayfront. SANDAG is currently preparing the design for the portion from H Street to Palomar Street, and the Mitigated Negative Declaration has been completed. However, this portion of the Bayshore Bikeway is not currently eligible for funding, according to the Local Assistance Program Guidelines, For the following reasons: • "Cities and counties should submit applications only for those projects where right of way is free and clear of obstructions, encumbrances, disputes, and environmental hazards, and where cooperative agreements with organizations such as railroads, utility districts, flood control districts, coastal commissions, etc., have been executed " The bike path will need to be constructed along the San Diego Gas and Electric (SDG&E) easement, so an agreement with SDG&E will be necessary. • "BTA projects must be in compliance with the applicable provisions of the California Environmental Quality Act (CEQA) by the BTA application submittal date. " It is anticipated that a Negative Declazation will be needed for this project. An environmental document has not yet been prepared. Staff therefore recommends submitting grant applications for the two projects described below. Both of these projects qualify for a Categorical Exemption. Bicvcle Racks and Lockers A number of Chula Vista City employees at the Civic Center complex have commuted to work for several yeazs. The only current bicycle parking facilities aze the old "comb-style racks". These racks do not provide adequate security for all day parking and can damage bicycles by bending the wheel or by allowing the bicycle to tip over. Employees frequently pazk their bicycles in hallways or offices. Local residents visiting the Civic Center do not have adequate secure short-term bicycle parking facilities. These conditions discourage both residents and 11-2 11/17/09, Item ~~ Page 3 of 4 employees from using their bicycles for transportation to the Civic Center, as well as various recreational facilities in Chula Vista. In order to encourage bicycle transportation, the installation of six new "inverted U" decorative bicycle racks at the Civic Center complex and the Civic Center Library is recommended. The City's Bikeway Master Plan recommends this type of rack, since it allows a bicycle to be supported more securely. Additionally, Che new racks are more attractive and are thus more appropriate to a civic area with high visibility. The six new racks can accommodate up to 12 bicycles. The existing racks will be relocated to City parks that do not currently have any bicycle racks. Photographs and drawings of typical bicycle racks are shown on Attachment 1. City staff considered including bicycle racks at several recreational facilities as part of the application. However, the installation or construction of recreational bicycle facilities is not eligible for BTA grants. Caltrans staff stated that such facilities would probably not be eligible, since they would serve a recreational facility. Additionally, bicycle racks along the downtown Third Ave. business district were not included, since Third Avenue is not currently designated as a bicycle route. The upcoming Bikeway Master Plan Update (awarded by Council on November 3, 2009) will revaluate bikeway designations Citywide, including the Third Ave. downtown area. Staff also proposes to apply for funding for six secure bicycles lockers for City employees. The lockers would be located to the south of the Public Services Building along F Street (see Attachment 1 for proposed layout). They would include four rectangular lockers that hold two bicycles each and two single pie-shaped lockers. The total cost for both locker and racks, including installation, is $28,000. Typical bicycle lockers are shown on Attachment 2. The cost estimate, including installation, for both racks and lockers is shown in Attachment 3. Wireless Bicycle Detection As of September 26, 2009, the California Vehicle Code was amended to require bicycle detection for all new or modified limit line detector installation on public streets. Current bicycle detectors, which generally consist of wire loops installed beneath the surface of the pavement, do not have the sensitivity to detect some new models of bicycles, which have a low metal content. Since they use wires, they are often cut during pavement overlays. Wireless detectors include a box that is cored into the street that transmits radio signals to a controller box generally mounted on a streetlight. This box controls the traffic signal timing. The sensors collect data such as volume, speed and direction of travel, thus serving as a permanent bicycle count station. The installation should not be damaged during road construction, and it has much greater sensitivity than loop detectors, thereby detecting lightweight bicycles. It is recommended that these detectors be installed in Telegraph Canyon Road/ Otay Lakes Road between I-805 and Wueste Road. L Street/ Telegraph Canyon Road/ Otay Lakes Road is one of the major east -west thoroughfares in Chula Vista, which spans from the bay front to the Otay Lakes. The section east of I-805 has the highest traffic volume in the City, with the average daily trips (ADT) of 72,925 vehicles between Oleander and Paseo del Rey in 2006. Additionally, vehicle sensors, controller boxes and other equipment have already been installed in nine locations between Halecrest Drive and Rutgers Avenue. In these locations, primarily bicycle sensors and contact closure cards, which transmit sensor data to the controller boxes, will need to be installed. 11-3 11/17/09, Item Page 4 of 4 The total estimated cost is $59,550 for Phase I (Halecrest Drive to Rutgers Avenue) and $98,800 for Phase II (St. Claire Drive/ Santa Paula Drive to Wueste Road). This includes the installation of 72 bicycle sensors at 18 locations with 36 stop bar pavement detector zones, 18 contact closure cards, nine controller boxes and other equipment. An additional 19,850 has been included for contingencies and inspection, for a total estimated cost of $178,200. The cost estimate is shown in Attachment 4. DECISION MAKER CONFLICT Staff has reviewed the property holdings of the City Council and has found no property holdings within 500 feet of the boundaries of the property that is the subject of this action. CURRENT FISCAL IMPACT There is no impact to the General Fund from this action. The estimated total cost of $28,000 for the bicycle racks/ lockers and $178,200 for the wireless bicycle detectors will be met, in part, with $153,200 in Bicycle Transportation Account (BTA) Grant funds, if awarded. The remaining required match will be met with funds totaling $53,000 from the City's annual Transnet allocation and Traffic Signal funds. If the grant is awarded, staff will return to Council with a recommendation to accept the funds, create a new Capital Improvement Program (CIP) project, and appropriate the grant funds into the CIP in Fiscal Year 2010/2011 or 2011/2012. ONGOING FISCAL IMPACT If the grant for wireless bicycle detectors is approved, it is proposed that the CIP project for wireless bicycle detectors also include bicycle detectors on Birch Road between La Media Road and Mater Dei High School (estimated cost of $14,350) and additional vehicle detectors on Telegraph Canyon Road/ Otay Lakes Road (estimated cost of $200,000). These funds will be provided from Transnet and Traffic Signal funds where appropriate. This would be the subject of a fixture staff recommendation to Council. After installation of these improvements, there will be expenditures for routine maintenance. Replacement of the battery within the sensor unit is recommended every eight years. These expenditures will be paid out of the City's annual CIP project, Traffic Signal Detection Replacement Program. Funding sources include the Gas Tax, Traffic Signal Fee and Transnet. The .cost of battery replacement is similar to replacing inductive (wired) loops, which are currently used for bicycle detection. ATTACHMENTS 1. Typical bicycle racks 2. Typical bicycle lockers 3. Cost estimate for bicycle racks and lockers 4. Cost estimate for wireless bicycle detection 5. SANDAG Letter of support Prepared by: Elizabeth Chopp, Senior Civil Engineer, Public Works Dept. J. IEngineerlAGENDAICAS200911 l-17-091BTA grant submittal.dac 11-4 A77AGHMENT `~ • ~n~a~e .~acksTM by:,;cycle-safe - Froth the leader nz secure bic'~cie parkin. v,, _ - ;,,.,w. For more than 20 years, Cycle-Safe has revolutionized bicycle parking wlfh breakthrough ' tlesigns, materials and technologies. Cycle-Safe installations are Iodated wgrldwide, on .. city streetsand university campuses; Ih office parks and shopping cenfers, at park 8 ride lots, and more. For variety, longevity and dependabtllty, Cycle-Saft*,has nri'equal - } " , ~,'~ ,; ~ i ~afperior~desi~la fvr ,", ~ , ~~~,, ~ ~ .IMI~~`' better safet~_ ~, . The inverted U js the most ~I; ypG.. ,S. anlversallYacknowledged ;~, rne~~""_• , tlesign for efficient bidycle >r'` f r ~~ racks. Cycle-Safe Vintage `"'-''` Q Racks offeCSUperior cycle frame support and stablhty characteristic of this design The smoatfi lines of Cycle-.. i ~~ alsfo saferefd~n destria s are "- p ntraffic ~ ~ ~.'£~ ~ around bike parking.:' ~ --~ x. '''THE PLYMOUTH s " ~~ ~ _ ~ surf~ce=Moum # 121405 Dr~rabte and r~taintetzane~=free. Cycle-Safe Vtntage Racks are cdmpletelycdvered with TGIC Potyestel''powder;ceat :.with E-clot primer over Schedule 40 steel pressure'plpe Thls ensures maximum . corro`siotrreslstance, Impact-resistance, and UV stability to provide' a maintenance free firiish: - - In-ground Installation This is the standard for new construction and the most severe type of inverted-U installation. Can easily ba installed in ' existlng Iecatlons by drilling a 3"~" core and grouting. Material: SCHD 40 pipe Coating: TGIC Radius: 12" Tube: 2" wdm: 23° Installed Height: 36" 48' -- - _ ~~ ae ~ T 12" ade ~ 1 $„ 9" O 2008 cycle-safe®, Inc. U.S. Design Patent Pending. 11-5 THE PEARL ' ln-ground Rack # 1218DG Surface-Mount #121805 D c 8 6 5 4 3 2 D DIVIDER LLOW ? BIKES . . 102.69 B a b 44.00 I 25.95 I -"1 OPENING-- MODEL: DL106-2-F-P Z 6 c 6 -' "' """' HANNAN SPECIAlTIES INC. °SeeS l3 F S '~/ 544 \ A. Kb :E bJ. U~+ '..' SY.'tl °~' ~~' <:.~ DL100-2 F-P SAS DRAWN) D < ~ -, ~ ' ~ DURA LOCKER '*"""""""' "'° """"'" RECTANGULAR SHAPED BIKE '~-~"~'- °F- LOCKER ASSEMBLY n c~ ~ ~ ccune~as. i w+ ~~ ~ ~^~ ~~ SIZE DWG. NO. REV rrm" """xc~:u W` therwise see U l . "'r,~.~.rt ieewxmin ~~wssr.^viuiae SEE CUSTOMER NOTES n ess o eosiomer dlawings B DL100-MAIN A$$Y ~ s cV""Y1O SCALE: EIGHT: SHEEi20F2 m>w .* ww~scu_wnw.;, I` 5 d 3 z I I ,~V< \ ~- 39.00 -~ HANNAH SPECIALTIES, iNC. 4019 LEOS LANE, WILT tt3 CARMICHAEL, CA 95608 P(BOOj 722-2453, P(916)488-7026,((516)488-725b 51MM1N DURALOCKER.COM, E-MAUL: HANNANSP(dPACBELL.NE7 27 48" 2' I r DOOR CLEARANCE BOTH ENDS OF LOCKER. ALLOW FOR LOADING CF EIRE. SDGGESTED CLEARANCE OF 6G' (MINIMUM OF 48`j -_ 44- 48 4T :: I ~~ ze• -CHECK LOCKING STYLE OTHER A'JAILASLE OPTIONS: STAINLESSST°EL PgOLOCK STYLE HANDLE •PERFOMTED WALLS AND DOORS PRODUCT'. DLP1C0-i (PFOLOCK NOTINrLUDED', •GEAR HOOKS DESCRIPTION. PIE SHAPED DURA LOCKERO 31KE LOCKER • NUMBER PLATES HEAVY DUTY 0263 FOP.OUT'T'HANDLE •GRAFFITI3ESISTANTADDITIONAL COATING 1UNIT-1 DOOR.181KE CAPACITY 'KITH 2 USER KEYS (KEYED DIFFERENIlYI DATE. ~t I-0' ENG: TLrZ CONFIDENTIALDW+WINGAHD INFORMATION IS NOT TO B'e COPIED OR NOTES' DISCLOSED TO OTHERS WITHOUT THE CONSEN70F HANNaN SPECIALTIES.ING 1. INSTALL BIKE LOCKERS ACCORDING TO MANUFACTURER'S SPECIE (CATIONS. SPECIFICATIONS ARE SU&IECT TO CHANGE WITHOUT NOTICE. ?. CONSULTANT TO SELECT CULOR(FINISHj, SEE MANUFACTURERS SPECIFICATIONS. 3. SEE SITE PLAN FOR LOCATION OR CONSULT ONMER. X2007 HANNAH SPECIALTIES, INC. ALL PROPRIETARY RIGHTS RESER'JED. ~1~7 ~~~/i City of Chula Vista ~. PUBLIC WORKS ~ ENGINEERING DEPARTMENT CHULAVISfA Infrastructure Planning AT7ACHM'EN7 3 Date Prepared By: 20-Oct-09 R Solorzano MIIC4I~GU ect Number: ect Title: Installation of Birycle Lockers and Bicycle Racks This project will provide for six new decorative racks to secure twelve bicycles, and six bicycle lockers to secure ten bicycles, to be installed in the Chula Vista Civic Center area, and at the Central Public Library. ~ " TOTALCOST 1;Cleanng & grubbing 1i LS $500.00 $500 . 2 tRemoval of exlsting racks ~-~ 1 LS X00.00 _ 200 3~ - -- - Removal/relocation of existing irrigation i 1 LS -- - --- -----L ------^ 2 000.00 ---~~ 2,000 ----.. 4} 4" PCC slabwork for bicycle lockers area 300 ! SF 15.00 4 500 __ Si ! 6 Decorative'"vintage" bicycle racks, installed _ _ 6_ ___ EA_ Pie shaped single bicycle lockers (each locker 4prore<onP hikpl insta I 2 EA __ __00_00 $2,500.00 $4 800 5,000 ------? I -- Rectangular dual bicycle lockers (each locker secures 4 i EA }twnhikeslinstalled-_-. --~ -T $2 500.00 10,000 $ r I All assembly and installation done by contractor ' ~~ ___---- ~--'-'--- ---~-----.- i -- i i --- ------ __'_--- -----r-...- ----' -- __.___1 __.-___--.__ _ ~- ' _ __- _ . _ I , _- Subtotal 27 000 Contin encies '% Construction & Contingencies $27 000 Engineering Design & Inspection I '% ~ Surve ! % ~ Other Costs Installation ins ection ~ 3.7'% 1 000 TOTAL COST OF PROJECT $28 000 R Solorzano BTA Bike lockers-racks COST-EST.nIS 10/26/2009 11-8 ~yl// City of Chula Vista ~. PUBLIC WORKS ENGINEERING DEPARTMENT ATTACHMENT CHULAVISfA Infrastructure Planning Date 5-Nov-09 Prepared By: Checked By: R. Solorzano Project Number: Project Title: Description: Road/Otay Lakes Road from I-805 to Lake Crest Drive Purchase and installation of in-pavement wireless detectors at 18 intersections. This includes the installation of 72 bicycle sensors at 18 locations with 36 stop bar pavement detector zones, 38 contact closure cards. nine controller boxes and other eauioment. w ~... TOTAL.COST le Wireless Detection for 9 ~ g I EA $4,966.67 $441700 _----.-...Inkers24ti2ns.---- B l 1 I d nc u Equ pmen t l1 r3-6_e-a VSN240T ____~____ _ _ _ ! -_._ --------- -._.-__ 1. ---- 9 ea CC-170 __~~ ~ ~ ___ ____ 18 ea RP_240-B _ _ _^ F _____ i _ +1 ea Epoxy, acts., box ! 1- -__._ _ !Labor 1 LS ! ~~ $14,850.00 ~ $14,850 (Phase II Bicycle Wireless Detection for 9 I i 9 i EA __?- Inter-sections.---------------~---------y-- Equipment includes: ~ ~ $8,577.78 ------ 77,200 - ---~- _ _ _ ~, ~~ '9 eea AP-240E5G i9 EA CC Card ! ._.._. X18 ea RP240-B --?-----i - , - - - - ---r- ------- --- - ------ ----------- - i ~36 ea VSN240T .._-...----------- -- ~--- -- _~1 ea Epoxy, acts:, box ----! ~ --__-- _ labor 1 ~-LS ____ _ _ y 21 600.00 i $21,600 I i i I Subtotal 158 350 Contin encies 10':% ~ $15,850 Construction & Contingencies 174 200 Engineering Design & Inspection i% Survey Other Costs Installation ins ection I 2.31% ~ $4,000 TOTAL COST OF PROJECT $178,200 R Solorzano 8TA Bike VYreless Detection COST-EST.xIS 11/6/2009 11-9 SANDAG aTra~t~nrr -~ a01 B Street Suite 800 November 9, 2009 Fife Number 3300200 San Diego, C4 92701-4237 (679) 699-7900 Erwin Gojuangco Fax (619) 699-7905 District Local Assistance Engineer wwwsandag.org Caltrans Local Assistance District 11 4050 Taylor Street, MS-132 San Diego, CA 92110 MEMBER AGENdES Dear Mr. Gojuangco: cities of cadsbad SUBJECT: City of Chula Vista Bicycle Transportation Account (BTA) Application Chula /sta Coronado Please accept this letter of support for the City of Chula Vista to submit a BTA Del Mar application for the 2010-2011 BTA funding cycle. As you may be aware, over many Eicajon years, both the City of Chula Vista and the San Diego Association of Governments Encinitas (SANDAG) have worked collaboratively on numerous projects of regional significance. Exondido To that end, the City of Chula Vista is submitting a BTA grant application to install Imperial Reach wireless bicycle detection at 18 signalized intersections along Telegraph Canyon Road tamlesa and Otay Lakes Road in Chula Vista. The goal of this project is to be able to detect lemon Grove bicycles at 18 signalized intersections over a 7-mile, 6-lane major arterial that carries National city a roximatel 50,000-70,000 vehicles er da This se ment of roadwa PP y P Y~ 9 y is part of the Oceanside Chula Vista Bicycle Master Plan and also is part of the adapted Regional Bikeway Foway Network featured in the San Diego Regional Bicycle Plan. As part of this project, work son Diego San Marcos efforts will also include assessing and evaluating the detection technology, providing Santee order of magnitude operations and maintenance costs estimates and other related Solana beach information to determine possible future regional application effort, and supporting usta the implementation of the California Department of Transportation Directive 09-06. and county of San Diego In November 2008, through a collaborative effort, the City of Chula Vista and SANDAG partnered to implement a wireless vehicle detection pilot system for nine signalized intersections on the west half of this corridor. This technology provides the ability to ADVISORY MEMBERS monitor remotely real-time traffic conditions and is currently planned to be extended Imperial county to other local agencies. By expanding the technology application to detect bicycles, the California Deparbnenr~ project objective is to move toward amulti-modal monitoring system while also of r2nsportarion providing local agency partners with proof of concept documentation for bicycle Metropolitan deteCtlOn. Transit System As you can see, this grant application has many merits and can serve as a model for North county transit DisMa im rovin re Tonal erformance monitorin efforts throw h a multi-modal s stem P 9 9 P 9 9 Y while ensuring bicyclists' needs are met. United Stites Department of Defense Sincerely, San Diego. Unified Port DisiriR ~ - C. --~ ~ ` '~-^ "v , im.. \ ,..~ ~__ _ San Diego County water Authority CHRIS KLUTH Transportation/Land Use Planner Southern California Tnhal Chairmen's ASOCiafion ckl/aes/ama Mexico ~~-~Q RESOLUTION NO.2009- RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CHULA VISTA AUTHORIZING SUBMITTAL OF FISCAL YEAR 2010/2011 BICYCLE TRANSPORTATION ACCOUNT (BTA) GRANT APPLICATIONS FOR INSTALLATION OF BICYCLE DETECTORS ON TELEGRAPH CANYON/ OTAY LAKES ROAD AND THE INSTALLATION OF BICYCLE RACKS AND BICYCLE LOCKERS IN THE CIVIC CENTER AREA AND CERTIFYING THAT MATCHING FUNDS ARE OR WILL BE AVAILABLE THEREFOR WHEREAS, the City Council adopted a comprehensive update of the City of Chula Vista Bikeway Master Plan (Plan) in January 2005; and WHEREAS, installation of bicycle racks and lockers and bicycle detection equipment is recommended by the Plan; and WHEREAS, the California Department of Transportation (Caltrans) has announced available grant funding for Fiscal Year 2010/2011 projects through its competitive Bicycle Transportation Account (BTA) grant program, with a grant application deadline of December I, 2009; and WHEREAS, staff recommends the installation of bicycle racks and lockers at the Civic Center area to encourage the use of bicycles at an estimated cost of $28,000; and WHEREAS, staff also recommends the installation of wireless bicycle detectors and associated equipment on Telegraph Canyon/ Otay Lakes Road between I-805 and Wueste Road at an estimated cost of $136,750 in order to provide more accurate bicycle detection on one of the city's busiest streets; and WHEREAS, the City is required to provide a minimum ten percent match of local funds. It is proposed that the City apply for a grant of $86,750 and matching funds of $50,000 from the City's Transnet allocation and Traffic Signal funds for the installation of bicycle detectors and a grant of $25,000 and matching funds of $3,000 for the installation of bicycle lockers and racks; and WHEREAS, the City will have sufficient funds in the Fiscal Year 2010/2011 Transnet allocation and in Traffic Signal funds to commit these funds. NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Chula Vista authorizes submittal of Fiscal Year 2010/2011 Bicycle Transportation Account (BTA) grant applications for installation of bicycle detectors on Telegraph Canyon Road/ Otay Lakes 11-11 Road and the installation of bicycle racks and bicycle lockers in the Civic Center azea and certifies matching funds aze or will be available therefor. Presented by R.A. Hopkins Director of Public Works Approved as to form by w. J r "" a~-^ ~ ~ ~.L ~j/(B ~ Mies ~ I' ' , ty Attorney ~~~ Y~+'t w !`~ 1 CC.~2~ 11-12