HomeMy WebLinkAbout2024-02 - Affordable Housing Requirements for New Residential ProjectsORDINANCE NO. 2024-02
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF COSTA
MESA AMENDING TITLE 13 (PLANNING, ZONING, AND
DEVELOPMENT) OF THE COSTA MESA MUNICIPAL CODE TO
ESTABLISH AFFORDABLE HOUSING REQUIREMENTS FOR NEW
RESIDENTIAL PROJECTS
THE CITY COUNCIL OF THE CITY OF COSTA MESA, CALIFORNIA DOES HEREBY
FIND AND DECLAIRE AS FOLLOWS:
SECTION 1: Findings. The City Council finds and declares as follows:
WHEREAS, the City compiled a community housing characteristics report which
found that approximately 47-percent of the Costa Mesa community earns a lower income
and approximately 29-percent of the community qualify for very low or extremely low-
income housing. Based on housing prices, lower income households cannot afford to own
or rent in Costa Mesa without experiencing overpayment;
WHEREAS, on September 27, 2021, the City Council adopted a Strategic Plan
identifying five key goals to address specific community issues and needs which included
to "diversify, stabilize, and increase housing to reflect community needs." To address this
goal, Council identified considering a draft affordable housing ordinance as a priority;
WHEREAS, the City's adopted 2021-2029 Housing Element includes Program 2A
which calls for the City to adopt an affordable housing ordinance;
WHEREAS, the City retained an expert consultant, Keyser Marston Associates
Inc. (KMA), to prepare a Financial Evaluation in order to evaluate supportable affordable
housing requirements and make policy recommendations for a potential affordable
housing ordinance;
WHEREAS, the City Council held two joint study sessions with the Planning
Commission on May 16, 2023 and July 11, 2023 with all persons having the opportunity
to speak for and against the proposal;
WHEREAS, a draft affordable housing ordinance has been prepared based on the
direction of the City Council and Planning Commission, and considering KMA's Financial
Evaluation and feedback received during public comments and during stakeholders
meetings with housing advocates and housing developers;
Ordinance No. 2024-02 Page 1 of 17
WHEREAS, a duly noticed public hearing was held by the Planning Commission
on November 13, 2023 with all persons having the opportunity to speak for and against
the proposal;
WHEREAS, the Planning Commission voted 4-0 (Chair Ereth, Commissioner
Rojas, and Commissioner Klepack absent) to continue the item to December 11, 2023;
WHEREAS, a public hearing was held by Planning Commission on December 11,
2023 with all, persons having the opportunity to speak for and against the proposal;
WHEREAS, the Planning Commission voted 5-2 (Commissioners Zich and
Andrade voting no) to recommend that the City Council give first reading to adopt an
ordinance amending Title 13 of the Costa Mesa Municipal Code to establish minimum
affordable housing requirements;
WHEREAS, a duly noticed public hearing was held by the City Council on January
16, 2024 with all persons having the opportunity to speak for and against the proposal;
WHEREAS, the City Council voted 4-2 (Mayor Pro Tern Harlan and
Councilmember Chavez voting no and Councilmember Harper absent) to give first
reading of Ordinance No. 2024-02 (Affordable Housing Ordinance);
WHEREAS, a duly noticed public hearing was held by the City Council for the
second reading of Ordinance No. 2024-02 and fee resolution to establish the affordable
housing in -lieu fee schedule on April 2, 2024 with all persons having the opportunity to
speak for and against the proposal;
WHEREAS, the City Council made additional revisions to the ordinance for the
threshold project size and affordability requirements for rental projects at 60+ dwelling
units/acre and voted 7-0 to adopt the Affordable Housing Ordinance and give another first
reading of the ordinance as well as continue the fee resolution to a date uncertain;
WHEREAS, a duly noticed public hearing was held by the City Council for the
second reading of Ordinance No. 2024-02 on June 18, 2024 with all persons having the
opportunity to speak for and against the proposal;
WHEREAS, the City Council requested additional information concerning
threshold requirements and potentially modifying the threshold from 50+ units, to 30+
units, and voted 7-0 to continue the Affordable Housing Ordinance and In -Lieu fee
resolution, to the regularly scheduled City Council meeting of July 16, 2024;
Ordinance No. 2024-02 Page 2 of 17
WHEREAS, a duly noticed public hearing was held by the City Council for the
second reading of Ordinance No. 2024-02 on August 6, 2024, with all persons having the
opportunity to speak for and against the proposal; and
WHEREAS, the City Council voted 4-3 (Councilmember Reynolds,
Councilmember Marr, and Councilmember Gameros voting no) to give second reading to
and adopt the Affordable Housing Ordinance and requested the Ordinance and In -Lieu
Fee be reviewed two years after implementation.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF COSTA MESA
HEREBY ORDAINS AS FOLLOWS:
SECTION 2: Code Amendment. Title 13 (Planning, Zoning and Development). Title 13,
Planning, Zoning and Development of the Costa Mesa Municipal Code, as specified in
Exhibit A, attached hereto and incorporated herein by this reference, is hereby amended
as set forth therein.
SECTION 3. Compliance with CEQA. Adoption of this Ordinance is exempt from the
California Environmental Quality Act ("CEQA") pursuant to CEQA Guidelines Section
15061(b)(3) (General Rule). Under Section 15061(b)(3), the activity is covered by the
general rule that CEQA applies only to projects that have the potential for causing a
significant effect on the environment. Where it can be seen with certainty that there is no
possibility that the activity in question may have a significant effect on the environment,
the project is exempt from CEQA. This Ordinance will not affect the physical environment
by permitting a new use or intensifying an existing use. Instead, the Ordinance
establishes affordable housing requirements through a range of means for individual
projects. -There is no potential for the changes to result in significant impact on the
environment. Furthermore, the Ordinance is not considered a project as defined pursuant
to Public Resource Code 21065 because the Ordinance will not cause either direct
physical change in the environment, or a reasonably foreseeable indirect physical change
in the environment.
Ordinance No. 2024-02 Page 3 of 17
SECTION 4. Severability. If any section, subsection, sentence, clause, phrase or portion
of this Ordinance is for any reason held to be invalid or unconstitutional by the decision
of any court of competent jurisdiction, such decision shall not affect the validity of the
remaining portions of this Ordinance. The City Council of the City of Costa Mesa hereby
declares that it would have adopted this Ordinance and each section, subsection,
sentence, clause, phrase, or portion thereof, irrespective of the fact that any one or more
sections, subsections, sentences, clauses, phrases or portions be declared invalid or
unconstitutional.
SECTION 5. Effective Date. This Ordinance shall take effect on the 31st day after
adoption.
SECTION 6. Certification. The Mayor shall sign and the City Clerk shall certify to the
passage and adoption of this Ordinance and shall cause the same to be published or
posted in the manner required by law.
Ordinance No. 2024-02 Page 4 of 17
PASSED AND ADOPTED this 6th day of August, 2
ATTEST:
do- OWK)
Brenda Green, ity Clerk
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss
CITY OF COSTA MESA 1
n Stephens, Mayor
APPROVED AS TO FORM
Kimberly Hall Barlow, City Attorney
I, BRENDA GREEN, City Clerk of the City of Costa Mesa, DO HEREBY CERTIFY
that the above and foregoing Ordinance No. 2024-02 was duly introduced for first reading
at a regular meeting of the City Council held on the 18th day of June 2023, and that
thereafter, said Ordinance was duly passed and adopted at a regular meeting of the City
Council held on the 61h day of August 2024, by the following roll call vote, to wit:
AYES: COUNCIL MEMBERS: CHAVEZ, HARPER, HARLAN, AND STEPHENS.
NOES: COUNCIL MEMBERS: GAMEROS, MARR, REYNOLDS.
ABSENT: COUNCIL MEMBERS: NONE.
IN WITNESS WHEREOF, I have hereby set my hand and affixed the seal of the City of
Costa Mesa this 7th day of August, 2024.
0r_j2_4,0YS&Y0
Brenda Green, ity Clerk
Ordinance No. 2024-02 Page 5 of 17
FY141RIT
ARTICLE 1. RESIDENTIAL DISTRICTS
13-38.1. Affordable housing requirements for new residential developments.
For any proposed residential or mixed -use project with fifty (50) or more dwelling units,
the affordable housing requirements set forth in Chapter XVII (Affordable Housing
Ordinance) shall apply unless otherwise exempted.
CHAPTER XVII. AFFORDABLE HOUSING ORDINANCE
13-326. Purpose.
The purpose of this chapter is to establish an affordable housing program that facilitates
the development and availability of housing affordable to a broad range of households
with varying income levels within the City to meet current and future affordable housing
needs.
13-327. Applicability.
This chapter shall apply to:
(a) properties that are located in areas for which the City completed a Zone Change
and/or General Plan Amendment that allows for residential development after the
effective date of this chapter; and/or
(b) properties that receive City approval of a General Plan Amendment, Zone Change
or other discretionary land use or development approval including but not limited
to Master Plan, Specific Plan, or subdivision after the effective date of this chapter
and which allows for residential development and/or an increase in residential
density as compared to the land uses and density that exists on the site at the time
of the effective date of this chapter; and
(c) provided, however, that this chapter shall not be applied in a manner that conflicts
with applicable State law.
Ordinance No. 2024-02 Page 6 of 17
13-328. Exemptions.
The requirements of this chapter shall not apply to the following:
(a) Residential projects with less than fifty (50) dwelling units;
(b) Any ownership residential projects of any size;
(c) Conversions of existing multi -family residential developments such as apartments to
residential common interest developments (condominiums) for ownership housing
pursuant to section 13-42;
(d) The reconstruction of any residential structures that have been destroyed by fire,
flood, earthquake or other act of nature;
(e) Residential building additions, repairs or remodels;
(f) Residential projects or mixed -use projects having residential units and located within
the boundaries of the Fairview Development Center Specific Plan; and
(g) Any residential project for which the city enters into a development agreement
pursuant to California Government Code Section 65964 that provides affordable
housing obligations comparable to this chapter.
13-328. Fairview Developmental Center Specific Plan.
All residential projects or mixed -use development projects having residential units and
located within the boundaries of the Fairview Development Center Specific Plan shall be
subject to the affordability requirements established by the provisions of the Specific Plan
at the time of its adoption and are not subject to the requirements of this chapter.
13-329. Definitions.
As used in this chapter the following terms shall have the meanings set forth below.
Terms not specifically defined herein shall have the meanings ascribed to them elsewhere
in this code:
Ordinance No. 2024-02 Page 7 of 17
Affordable Housing Agreement. A legally binding recorded agreement and/or deed
restriction in a form satisfactory to the director and the city attorney setting forth those
provisions necessary to ensure that the requirements of the chapter are met, including
but not limited to those specified in section 13-332.
Affordable Housing Plan. A plan containing all of the information specified and submitted
in conformance with this chapter specifying the manner in which affordable units will be
provided.
Affordable Housing Trust Fund. The fund into which all collected in -lieu fees are
deposited for the purposes of furthering affordable housing goals within the City.
Affordable Rent. The maximum affordable housing cost minus any housing costs that
are imposed on the tenant on a mandatory basis. The affordable housing cost is based
on the percentages of AMI identified in the following table, as adjusted for household size
appropriate for the unit (as defined in California Health and Safety Code Section 50052.5),
times 30%:
Affordable Sales Price. The maximum price that can be charged to a moderate income
household based on the calculation methodology defined in California Health and Safety
Code Section 50052.5.
Affordable Unit. A dwelling unit that is required to be rented at the affordable rent or sold
at the affordable sales price to very low, low- and moderate -income households.
Applicant. A person or entity that applies for approval or approvals for a residential project
and/or owns the property or properties on which a residential project is proposed.
Area Median Income (AMI). The median household income of households in Orange
County, adjusted for household size, as determined by the California Housing and
Community Development Department (HCD).
Ordinance No. 2024-02 Page 8 of 17
Director. The Director of Economic and Development Services or his or her designee.
Density Bonus. An increase in the number of units permitted in a proposed Residential
Project provided pursuant to California State Density Bonus Law as set forth in
Government Code Section 65915, et seq.
Extremely Low -Income Household. A household with a gross annual household Income
that does not exceed 30% of AMI for Orange County as defined in California Health and
Safety Code Section 50106.
Gross Annual Household Income. As defined in 25 Cal. Code Regs. Section 6914
including any successor section thereto.
In -lieu Fee. The fee payable as an alternative to the construction of on -site affordable
units.
Low-income Households. A household with a gross annual household income between
51 % and 80% of AMI for Orange County as defined in California Health and Safety Code
Section 50079.5.
Market -rate Unit. A dwelling unit offered on the open market at the prevailing market -rate
for purchase or rental.
Moderate -income Household. A household with a gross annual household income
between 81 % and 120% of AMI for Orange County as defined in California Health and
Safety Code Section 50093.
Ownership Project. A residential project that is intended to be sold for homeownership.
Rental Project. A residential project that is intended to be rented to tenants.
Residential Project. A project undertaken for the purpose of development of land for
residential purposes that .requires the issuance of a discretionary approval or permit,
including a permit for construction, and that will include fifty (50) or more dwelling units.
Very Low-income Households. A household with a gross annual household income that
does not exceed 50% of AMI for Orange County, as defined in California Health and
Safety Code Section 50105.
Ordinance No. 2024-02 Page 9 of 17
Zone Change. Any proposed change to the official zoning map. The terms rezone and
zoning amendment shall also have the same meaning.
13-330. Affordable Housing Requirements.
The following requirements and standards shall apply to any for rent residential project
subject to this chapter:
(a) Project Threshold. The affordable housing requirement is applicable to any proposed
residential project with fifty (50) dwelling units or more.
(b) Number of Affordable Units. The minimum number of dwelling units required to be set
aside as affordable units and the required affordability level(s) of the units are
specified as follow:
(1) Rental Projects. An applicant of a rental project shall fulfill their obligation with
onsite production of affordable rental units at either low or very -low income levels
and the minimum required number of units shall be calculated based on the
proposed project's base density.
a. For residential projects either rezoned to or located in the areas designated
to be rezoned in the General Plan and/or within the boundaries of Figure
13-200.106 of section 13.200.106 at 60 or more dwelling units per acre: at
least 10% of the total applicable dwelling units proposed shall be affordable
at the low-income level or at least 5% at the very -low income level.
b. For residential projects either rezoned to or located in the areas to be
rezoned in the General Plan and/or within the boundaries of Figure 13-
200.106 of section 13.200.106 at under 60 dwelling units per acre: at least
6% of the total applicable dwelling units proposed shall be affordable at the
low-income level or at least 4% at the very -low income level.
c. For any partial affordable unit calculated, the applicant shall pay a fractional
in -lieu fee payment in accordance with the adopted in -lieu fee schedule or
round up the calculation to the highest whole number.
(2) Residential Projects with Mixed Housing Types. If an applicant proposes a
residential project that includes both ownership and rental units, the provisions of
Ordinance No. 2024-02 Page 10 of 17
this chapter that apply to rental projects shall apply to that portion of the
development that consists of rental units.
(3) Parcel or Lot Merger. An applicant shall not avoid the requirements of this chapter
by submitting piecemeal planning permit applications. At the time of the application
for first approval for the residential project, the applicant shall identify all contiguous
property under common ownership and control. The applicant shall not be required
to construct dwelling units upon the contiguous property at the time of the
application for first approval; however, the applicant shall be required to include
the contiguous property under common ownership or control in its affordable
housing plan. The affordable housing agreement shall be recorded against the
residential project and all contiguous property under common ownership or control
and shall require compliance with this chapter upon development of each
contiguous property at such time as there are planning permit applications that
would authorize residential units for the residential development and the
contiguous property under common ownership or control.
(c) Covenant Period. The affordable units shall remain affordable for not less than fifty-
five (55) years or as stated in the affordable housing agreement or other agreement(s).
After fifty-five (55) years the affordability covenant may be removed only if the property
is redeveloped as a non-residential use.
(d) Timing of Construction. The affordable units shall be constructed concurrently with or
prior to the construction of market rate units. In phased developments, the affordable
units shall be constructed in proportion to the number of dwelling units in each phase
of the market rate project. The applicant shall provide a Construction Phasing Plan as
part of their project plans for review by the director or their designee prior to the
submittal of plans for a building permit.
(e) Unit Size. The size of the affordable units shall be the same size as the market rate
units but the final review authority may consider and approve affordable units no more
than 15% smaller in square footage than the average square footage of the market
rate units.
Ordinance No. 2024-02 Page 11 of 17
(f) Bedroom Mix. The bedroom mix of the affordable units shall be proportional to the
market rate units or as otherwise agreed in the affordable housing agreements or
other approved agreements with the City.
(g) Design. All exterior and interior improvements including floor plan design,
finishes/materials, etc. for the affordable units shall be comparable, if not same, to the
market rate units. The affordable units shall have same access to and enjoyment of
all community amenities/facilities in the residential project. The final review authority
may consider and approve alternative exterior and/or interior design improvements for
the affordable units as long as it is comparably the same to the market rate units.
(h) Location. Affordable Units shall be dispersed and evenly distributed throughout a
residential project and not clustered in a particular area of the development or as
otherwise agreed at the City's discretion in an affordable housing agreement.
Affordable units within a residential project that share a common entrance or access
shall not have separate entrances or access for market rate and affordable units.
(i) Certificate of Occupancy. No certificate of occupancy will be issued for any
corresponding market rate unit in a new residential project prior to completion of the
required affordable units (including offsite) and/or payment of in -lieu fees.
13-331. Alternative Compliance Procedures.
The following are the alternative options to fulfill the requirements of this chapter if onsite
production of affordable units is determined by the director or their designee to be
economically infeasible.
(a) In -Lieu Fees. The payment of in -lieu fees may be used to fulfill the affordable housing
requirement for rental projects and any fractional number of affordable units required.
(1) In -lieu fees shall be paid prior to the issuance of the first building permit for the
residential project unless specified and/or agreed elsewhere in recorded
agreement(s) with the City. For phased developments, the applicant may pay a
pro rata share of the in -lieu fee concurrently with the issuance of a building permit
for each phase.
Ordinance No. 2024-02 Page 12 of 17
(2) In -lieu fees shall be paid according to a fee schedule adopted by the City Council.
The in -lieu fee schedule shall be adjusted periodically on an annual basis or as
determined by the City Council or their designee and shall be adopted by
resolution.
(3) All in -lieu fees collected shall be deposited into the City's housing trust fund.
(b) OfPsite Construction. Affordable units may be constructed offsite only upon a
determination by the director or their designee that onsite production of affordable
units is economically infeasible. If this alternative compliance option is chosen, then
the offsite affordable units must be constructed prior to or concurrently with
construction of the market rate residential project.
(1) The offsite affordable units shall comply with all applicable requirements
pursuant to this chapter for onsite production of affordable units.
(2) The offsite location shall be located within the City of Costa Mesa boundaries
and shall be located within a reasonable distance from the market rate
residential project that is subject to the affordable housing requirement.
(3) For residential projects for which a master plan is required, the affordable units
may either be provided onsite or offsite on a separate parcel within the
residential project's approved master plan boundaries.
(c) Land Dedication. An applicant may dedicate, without cost to the City, land (single or
multiple parcels) within the City of Costa Mesa boundaries that is sufficient to
accommodate the number of affordable units required by the market rate project. The
following requirements are applicable to any land proposed to be dedicated to the City
to fulfill the affordable housing requirement:
(1) The land to be dedicated to the City shall be located in the City of Costa Mesa;
(2) The General Plan and zoning standards shall allow for residential use at a
density sufficient to allow for the market rate project's required number of
affordable units to be constructed;
(3) The land shall be suitable in terms of size, configuration, and physical
characteristics including existing utilities, streets, and other infrastructure
Ordinance No. 2024-02 Page 13 of 17
improvements necessary to allow for the market rate project's required number
of affordable units to be constructed;
(4) The value of the land shall be equivalent or comparable to the in -lieu fee
payment that would be applicable to the proposed residential project;
(5) The applicant shall provide property related report(s) to demonstrate the
suitability and value of the land to be dedicated including but not limited to title
report, appraisal report, and environmental site assessment(s).
13-332. Affordable Housing Agreement and Affordable Housing Plan.
The applicant shall prepare and submit a draft affordable housing agreement and
affordable housing plan as part of the proposed residential project's planning
application(s). The director shall review and determine if the plan and agreement are
complete and in substantial conformance with the requirements of this chapter. This
section shall not apply to residential projects where the developer fulfills their obligation
with payment of in -lieu fees or land dedication.
(a) Affordable Housing Plan Requirements. The applicant shall submit a plan detailing
how the requirements of this chapter will be implemented. The plan shall include the
following information but not limited to:
(1) The location, structure, proposed tenure and size of the proposed market rate
and affordable units;
(2) The total number of affordable units to be provided and the calculations used
to determine the number of required affordable units;
(3) A floor plan and site plan depicting the location of the affordable units;
(4) The income level targets for each affordable unit;
(5) The mechanisms that will be used to assure that the affordable units remain
affordable for the required term as specified in section 13-330(b);
(6) A marketing plan for the process by which qualified households will be reviewed
and selected to rent affordable units; and
Ordinance No. 2024-02 Page 14 of 17
(7) Construction phasing plan schedule with the anticipated completion and
opening date and as applicable for phased residential projects.
(b) Affordable Housing Agreement Requirements. Upon final project approval, the
developer shall execute and record an affordable housing agreement in a form
approved by the City Attorney, prior to approval of any final or parcel map or issuance
of any building permit, whichever occurs first, and that at a minimum specifies the
number, type, location, size, and phasing of all affordable units, provisions for income
certification and screening of potential renters of the affordable units, consistent with
the approved affordable housing plan and any administrative procedures adopted
pursuant to section 13-338.
(1) An affordable housing agreement will not be required for projects which will be
satisfying their affordable housing requirement through payment to the City of
an in -lieu fee.
(2) The City Council, by resolution, may establish fees for the ongoing
administration and monitoring of the affordable units, which fees may be
updated periodically, as required.
13-333. Affordable Housing Trust Fund.
All in -lieu fees, promissory note repayments, shared appreciation payments and other
funds collected under this chapter shall be deposited into a separate account to be
designated as the City of Costa Mesa Affordable Housing Trust Fund. The City may elect
to deposit funds from other sources into this affordable housing trust fund. The moneys
and all earnings from investments of the moneys in the affordable housing trust fund shall
be expended exclusively to provide or assure continued provision of affordable housing
in the City through, including but not limited to, acquisition, construction, development
assistance, rent subsidies, or first-time homebuyer programs, and for the associated
costs of administering and monitoring these programs.
Ordinance No. 2024-02 Page 15 of 17
13-334. Density Bonus.
Pursuant to the California State Density Bonus Law (Government Code Section 65915,
et seq.), if the applicant is proposing to provide affordable units in exchange for an
increase in density, concessions, incentives, or waivers/modifications of development
standards, the affordable units required to fulfill the density bonus may also count as
affordable units required in this chapter provided they also meet, or exceed, the
requirements outlined in section 13-330.
13-335. Parking Requirements.
An applicant that provides affordable units pursuant to this chapter is not required to
comply with the parking requirements set forth in section 13-85. A lower parking
requirement may be allowed if supported by a parking study prepared by a traffic
engineering firm with expertise in parking trends and demands, unless otherwise
prohibited by state law. The parking study shall be reviewed and approved by the director
or their designee.
13-336. Concurrent Processing.
Concurrent processing of planning application(s) and plan check application(s) may be
allowed at the discretion of the director or their designee when the planning application(s)
have been deemed complete. The applicant shall be required to enter into a hold
harmless agreement with the City prior to any concurrent review.
13-337. Compliance Monitoring.
To ensure that affordable units constructed pursuant to this chapter are properly
maintained and continue to comply with the applicable provisions of this chapter, the
applicant or responsible party at the time shall submit annual compliance reports to the
City for review. In addition, the City shall conduct periodic onsite audits to ensure
compliance with all applicable laws, policies, and agreements. The City Council may
adopt fees for the costs of monitoring and compliance review, which shall be deposited
into the affordable housing trust fund for that purpose.
Ordinance No. 2024-02 Page 16 of 17
13-338. Administrative Procedures.
The City Manager is authorized to adopt administrative rules, regulations, policies,
guidelines, standards, and/or procedures necessary to implement the provisions of this
chapter including but not limited to eligibility requirements and/or preference standards
that may be applied in the selection of homebuyers and tenants.
13-339. Enforcement.
(a) Violations of this chapter may be enforced by all available remedies at law or in equity,
including, but not limited to those set forth in section 1-33 of this code.
(b) Failure of any city official, employee, or agent to fulfill and/or enforce the requirements
of this chapter shall not excuse any person or property from the requirements of this
chapter.
Ordinance No. 2024-02 Page 17 of 17