BOARD OF SUPERVISORS

♪ ¶. Thank you. Good

Thank you. Mr. Allen, I'm on my homestretch. I've got to throw you a couple of curves. I wouldn't want you to fall asleep down there. So what should we be doing? You want to do roll call?

Mr. Lavagnino, Mr. Carbajal, Ms. Wolfe, Ms Farr, Ms Gray.

Present. Thank you. And it's time for the approval of the minutes of October 18th, 2011. Is there a second? Motion and second all in favor say aye. Aye. Opposed? Mr. Allen do we have anything on did I see yeah did we have anything on the administrative agenda?

Madam Chair, members of the board. I have no request to speak on the administrative agenda this morning. I do have one addendum that was published on Friday and I could read those items into the record real quickly if you'd like. First off on item 813 which is on the administrative agenda There's a request that item be continued to November 15th, and that is from the Public Works and to the Board of Directors of Laguna County Sanitation District. Item A-15 was added to the agenda on Friday. That's from Supervisor Gray. It's to approve the appointment of John Lizarraga to the Santa Barbara County Housing Authority Board of Directors And finally, we noted that today there will be a county event that members of the board may be attending. And that's at the Empower launch at 5 p.m.

public comment. Do we have any public comment Mr. Allen?

Madam Chair and members of the board we have one request to speak for public comments Dr. Robert Jones.

Good morning, Dr. Johns.

Good morning, Madam Chair. Thank you for your patience with me approaching the microphone here.

Well we all know it's going to be tennis in six months.

We'll see about that. That was kind of like a guess. Intellectual guess. Now, I'm kind of amazed and taken back by the choice. And this happened October, by the choice of the Hispanic heritage person to represent the Hispanic people and culture. And I'm kind of taken back that that person was presented to this community I mean, there are many, many role models and the mayor of Guadalupe would be an excellent role model. A very excellent person to be that Hispanic Heritage Person of the Month.

And I can think of others. But when you present to us Judge Ochoa, and I'm sure you know his background, Cardinal, When a man cuts the tires of a handicapped person. A man cut the tires of a handicapped person who parked in his spot, and that person I'm talking about is Judge Ochoa. And I'm wondering why in the would you appoint him as representative of the community in this county?

Given that particular background, now I know you're not allowed to answer. But you know, psychologically let me give you an answer for you Supervisor Carvajal. You are an angry man. We don't want to get into this do we?

Let's kind of remember we're going to say something nice. Can't say anything unless you say it kind of nice.

Psychologically this man has no, he has no respect for the people in his community. When you present someone like Judge Ochoa to this community as a role model and we know what his background is I've just spoken about it I'm amazed by this particular appointment. There are plenty of Hispanic Americans, Supervisor Carbajal, that you could have picked from, people who could represent this community.

Dr. Johns,

time's

up.

Oh, okay.

Thank you.

Well, I think I made my point.

I think you probably did. No other public comment, Mr. Allen?

No further

requests to speak.

Madam Chair, usually I don't respond to despite how slanderous and inappropriate things that are said by Robert Johns but I would like to say that What he was saying about Judge Ochoa was completely wrong and false. And I think it's unfortunate that he continues to come here and make these slanderous remarks. The only thing I will say is, I'm glad Dr. Johnson you're out of the hospital and you're back. Thank you.

Thank you, Supervisor. So where are we Mr. Allen? No other public comment. Okay I want to make an announcement. Public comment is closed in case someone from San Yanez is on their way over the hill and they're going to get here late they just missed it come back next week. Mr. Allen?

Madam Chair members of the board were ready to proceed to the departmental agenda.

Okay item number one

Item 1 is from General Services. It's a hearing to consider recommendations regarding an ordinance granting a private pipeline franchise to ERG Resources, LLC.

Mr. Carlantini?

Madam Chair?

Welcome.

Thank you. You

need to get ready. I'm sorry we kind of rushed this.

No, I'm fine.

Okay.

Madam Chair, members of the board. Today in front of you is an application for a franchise within the County of Santa Barbara. The applicant ERG Resources has applied to the county and today's action is the introduction of a first reading of the ordinance to move forward with November 15th adoption. The ordinance will be granting a private pipeline franchise With a term of 20 years, subject to the terms and conditions applicable.

Terms and conditions applied to all franchises within the county. The process is described in our local County Code Chapter 2 Article 9 Section 2-82-1. I have, in addition to the application, Good morning, everyone. Thank you for joining us today. The county has issued a land use permit from P and D for their facilities and pipelines and public works is issued a road encroachment County Council for any questions on the code. We have representatives from ERG, North County we have the land use planner and Public Works here for county roads. If you should have any questions please let us know.

The detailed staff report should detail a lot of the several of the general terms that apply to this franchise and it's customary that the code Used for this private franchise is used for private franchises within the county. Should have any questions, please let us know.

Thank you, Madam Chair. I'm pretty satisfied with the staff report. There is one thing that just caught my attention and I really want to make sure I understand it. Upon expiration or earlier termination of the franchise, the applicant shall either remove the pipeline from the roadway or abandon pipeline in accordance with the requirements set forth for such abandonment by the county's Public Works Department.

I'm just, I'm trying to understand that. Why you either remove it or you don't? Or the Public Works Department has the say.

Is that correct Madam Chair, Supervisor Carbrough? It's at the county's option to either leave that pipeline in place. It's been in place for a number of years, and if at the expiration or termination of this thing it would be the assistance of Public Works to help us out to see if it wants to be left in place or removed.

Madam Chair why would we leave debris, corroding debris In the earth, I just don't get it. I'm trying to understand

it. If that condition exists, you're correct. It would probably be removed.

If?

If that condition exists.

And if it doesn't exist are we in a position now to condition it to remove it?

Correct.

But yet we're not conditioning it to remove it.

We have an option to either remove it or leave it

in place. We could ask people to get rid of trash, of course we have that option but I'm just trying to understand why we would leave it so open-ended like that? Isn't it just it'll be removed?

Well, I think it's possibly open ended because within the term of 20 years they could be replacing it too. So in the midst of their maintenance operation, they're going to keep it in good workmanship condition. So those decisions will have to be made upon their application to either abandon it or remove it.

Mr. Carlentini, you might want to circle around this and get the answer if there is such an answer in a different way which is why in the world would you want it? To be left there. There's got to be a reason that it might... Maybe the county wants to run a water line through it or I mean I'm making this up but is there another way that why would you want to let the pipeline stay there?

Well if the future comes where ERG assigns their Their rights entitled to all their oil production equipment and facilities. That's something that we may want to look at that time too.

Madam Chair, if I may add to that and Supervisor Carbajal Again, the primary directive in the franchise is that remove it. And we do retain the option. The question is why in the world... What gives a couple examples? Why in the world would we even want to retain that ability to abandon in place as opposed to remove it? I think the reason you gave is a possible reason. It's certainly a stretch but all we want to do is reserve The ability to do that. The example I would come up with is more along the lines of a determination could be made that it's less impactful to the roadway, less impactful to the environment to leave it in place. Maybe the road just received an overlay is a brand new road And a determination could be made that it has no impact on the environment.

Maybe, you know, CEQA would even be looked at 20 years down the road. There's, you know, a determination could be made no impact to the environment. It's less impact on the road. Let's leave it in place. So we just want to retain the ability to do that. That's the best example I can think of. But the primary directive is to remove it. Secondary is just to retain the ability if we want to. So

that probably makes sense where up the road is,

yeah. I do understand that. I still don't agree with you because that is a line I hear from certain oil companies about certain debris like the shell mounds and what have you but the only thing I would change that would satisfy me is not the Public Works Department but the Board of Supervisors So that the Board of Supervisors would have to take an action to not remove it.

And that wouldn't satisfy me, so it would be done in public? No. That wouldn't be adequate for me. If we could change Public Works Department to the Board of Supervisors, that would be great.

Supervisor Walz?

Thank you Madam Chair. I just wanted to, when I read the resolution and the ordinance it looked like they were in conflict with each other. And what I mean by that is that in the resolution it's the fourth whereas it talks about the existing private line but in the ordinance section one it says the scope of the franchise of facilities to be constructed maintained and operated So we're looking at two different operations. So if you could clarify that for me?

Yes, Madam Chair, Supervisor Wolff. In our county code, we literally pull out the words and terms and conditions from that county code and apply it to the franchise. It's, we would have to amend the county code for every single case to say if it's existing or not. That's why we're saying in the resolution that it's an existing but in the county code it doesn't say that it's a existing.

It gives the wording as it states in the franchise, in the ordinance.

I'm going to ask County Council because how do we adopt a resolution that says one thing and adopt an ordinance that says something else?

The franchise you're giving is giving them the right to construct, maintain and operate it there. If they need to do new construction on it, they would come get various permits for that. This gives them the right to construct, maintain or operate. As a matter of fact, it's already in place so they'll just be operating it but if they do need to do construction this franchise will give them the right to do that construction if they get the other permits they need.

All right, then why doesn't it say that in the resolution? The resolution doesn't talk about construct. It just talks about existing private lines. Shouldn't the resolution then reflect that?

It could.

It could or it should?

The purpose of the resolution is to give them the authority overarches that and gives them the authority to also construct.

I would suggest, I think that since we have the authority to modify our resolution and make it to reflect exactly what's going on then we should do that and use the same language. Is there any

Madam Chair, Supervisor Wolf. This resolution was approved by the Board at a previous meeting. The intent of this resolution as stated by County Council was to set the hearing today is a public hearing for an ordinance would go on to second reading so this resolution simply set the dates And the conflict that you're referring to, that the word construct is used in the ordinance and not in the resolution.

I think it's there but the resolution has been approved already. I think as the County Council states, the use of the word construct in the ordinance is for the future if they have to do anything in line with maintaining the pipeline. It was not intended to mean construct a new pipeline.

Okay well you know If we approve this before it was based on the information we had at the time, now we have additional information with the ordinance in front of us. So my suggestion is that we change the resolution because it doesn't... We now have additional information about the possibility to construct

Supervisor, let's see if we have other people that have the same problem. Supervisor Carpenter?

I was just going to say, I can't call a supervisor not to put words in her mouth but what I'm hearing is she just wants to synchronize the two documents and that straightforward irrespective of when we...

So now the issue becomes do we have to go back and redo the resolution so let's just hang on until the attorneys figure out what has to be done here.

The purpose of the resolution Give the county's intent that we're going to do an ordinance in the future. That ordinance in the future was to give them the right to operate their existing facility. The wording in the ordinance is what you're dealing with today. The resolution already existed.

Counsel, the problem is we've got a conflict of don't explain to us what

happened.

We have a conflict of words that one of the supervisors sees she wants to change it. Now, if it's changed because no one doesn't seem like anybody else is real concerned about it. If it's changed as it have to go back and be reread etc., etc., etc..

Madam Chair, I think there's some confusion here.

I

do too. If we could have a chance to-

Let's trail this.

You guys figure it out. And see if it's benign, I don't see why we couldn't change it. All right well let's- If it's operative then the board needs to know that as well. Okay,

we'll trail this one. Mr.

Allen? And also just along those lines because the construct piece, I wonder then about environmental review because right now we're doing an exemption Or negative deck, I'm sorry. So can you at what point then do we revisit this?

Any permits they would need to do the construction, they'd need an encroachment permit, they'd need a land use permit. Any of those would require future CEQA review if there's going to be change right now with Exemption is for the existing facility. If they were going to get some permit, an encroachment permit from Public Works, a land use permit from Planning and Development, they would have to do CEQA at that time.

All right so just... Okay.

Supervisor Farr?

Thank you Madam Chair. You know I think that we just heard that they had an encroachment permit and they had a land use permit. So to me this is an existing line It hasn't been used for some time, according to the staff report. I don't know what that means. I don't know how many years that is and What this was was to say yes You can have the franchise you can go ahead and operate this line and you can maintain it but not really knowing how long it's been since it was used and Whether it's going to need a lot of work in order to bring it up to the point where they can use it again as perhaps part of the discussion here So, you know, if the road encroachment permit which Public Works has already given and a land use permit which P&D has already given for this project encompasses maintenance, which we don't know the extent of because we don't know how bad of shape the pipe is in.

Is that really going to then trigger another round of road encroachment and land use permits? I mean what is the threshold there?

Maintenance of an existing facility is exempt from CEQA. Construction of a new facility would not have to be looked at. Maintenance of an existing facility is a specific exemption from CEQAs.

Okay, but I guess I'm trying to figure out when we cross the line. So we have an existing pipe that maybe is in very bad shape and some segments of it that would have to be totally dug up and replaced. Now that's considered maintenance and would not trigger the need for new permits and any kind of environmental review?

If it's maintaining the existing facility as it sits, it would be exempt from CEQA. It might need some permit for that. That would be a technical question that the engineers would deal with at the time they were asking to do that.

You know I guess I would have a higher level of comfort if this pipeline had been operated, had been in operation and they were just taking it over and now it was just a matter of maintaining it. But the fact that it hasn't been operated for an extended period of time then we don't really know what the status of it is and how bad it might be so Madam Chair if we're going to trail this item perhaps staff could talk to P&D and Public Works and kind of get an answer to that.

Thank you. Are there any other questions because it sounds like We've got a lot of questions on this that we haven't gotten asked or answered.

Madam Chair, I believe that when you take over an existing pipeline there are regulations dictated by the state through DOGGR of what those requirements are so I'm sure those are all going to be followed. I understand what you're saying but I think we're heaping on another level again at the county that's something the state is supposed to be dictating.

Madam Chair, I think the issue...I just want to go back to the ordinance and I thank Supervisor Lavagnino for his comments. And I would feel much more comfortable if it just talked about the maintenance and use of the existing pipeline. But it's very clear in here that facilities are to be constructed and we really need to get a handle on that. What I heard you say is that this is a routine ordinance that we use all the time. And I really want to know, for this particular franchise, is this routine or was this language specific to this franchise? That they really do intend to construct So because that's the crux for me and the essence of my concern.

Supervisor, is there anything else? Because obviously you found... Okay so do you folks understand what the question is? And do you think you can solve this and we can trail it or do you feel a need to set it over for another couple weeks?

Madam Chair, I feel with the questions I heard that we can trail it. If this goes to the end of the agenda today, I think that gives us enough time to confer with County Council on planning and development to answer the questions I've heard today.

Are there any public speakers Mr. Allen?

Yes, I just want the board to be aware we have eight requests to speak on this item.

Madam Chair, I was just going to suggest. I think Supervisor Lavinino brought up the reference to Dogger that could be a little bit amplified. That would also be great. I think it just gives folks the assurance that there's already state regulations and guidelines that pertain to this

so we have eight speakers that we probably should go ahead and take in case there isn't and then you. You folks will be able to answer whatever the questions may be if we do trail

Madam Chair, our first speaker is Nathan Eady to be followed by Diana Beck.

Good morning Supervisors, Nathan Eady from SES Engineers representing ERG. We have Ben Oakley from ERG who's available to answer any questions I cannot and Diana Beck works for SES Engineers as well and has been one of the project managers working on this. I think we can clarify a lot of the questions that have been asked so far. I think it's really important to note that this is a pipeline that's physically been in place for quite some time And the action today is strictly to give us the 20-year renewal for the franchise, which is really just the right to use, the right of way to pay the lease, to post the bond. All those things that were requirements of the original franchise when it was given in 1970.

Ultimately this is a pipeline that's been in place since about that time. ERG took over ownership of that property when they purchased the rest of the Cat Canyon oil field facilities that used to be owned by Chevron. Chevron had already submitted the application to renew this franchise and ERG is simply trying to complete that action. So if there's a pipeline still physically in place, which it's there, ERG has no immediate plans to do any significant construction on the pipeline. It's not in use right now. They simply want to fulfill that obligation that they renew the franchise agreement, pay all the applicable fees and bonds to the county.

Ultimately to clarify, Chevron who was the previous owner of the field all their operations basically went dark no later than the year 2000. So that's the absolute end date when that pipeline was used so it has not been used for At least 11 years, maybe longer. But any activity to reactivate use of that line would be preceded by a battery of testing to make sure the pipeline can still maintain pressure, has no leaks and it's really intended just to transport water.

So I can answer any other questions, if you like.

Supervisor Wolf? Thank you for being here. You heard my concern about the use of the word constructed and what you said in your statement that there are no immediate plans. Could you expand upon that because we have this 20-year lease. Do you know at this point as you're standing here whether or not there might be plans to construct within that time

frame? The construction would really be more of the repair. I'm sure you can consider that construction if they're physically removing segments of pipe and replacing them. In instances of pipelines like this, there's a significant amount of technology that can be used to sleeve the pipeline in place so that you don't have to disturb the ground And that's an issue that was touched on before in terms of all pipeline agreements like this have a contingency that say it's up to the county or the regulatory agencies to either require removal of the pipeline, or to allow abandonment in place. And Mr. Nesbitt hit the nail on the head and that sometimes it is actually environmentally superior option to leave the pipeline in place so you do not have to disturb the ground over the pipeline.

Well, I'm sure you can probably understand some of the confusion with the wording because now construct as you're looking at it means to repair. And I think of repair as being part of maintained. So we really, as we look to council to really clarify that for us please. Thank

you.

Supervisor Farr.

Thank you, Madam Chair. Thank you Mr. Eadie for that but if the pipeline hasn't been used in 11 years, you haven't done any inspection of it yet? You haven't run a smart peek through or any of the stuff that you can do to have any idea what the issues might be with the pipeline as far as the level of repair needed? Not yet.

Chair and Supervisor Farr, that is correct. This is one of many pieces of equipment the ERG inherited from Chevron when they purchased their entire facility. This pipeline is so small, four inches, that you don't necessarily run an actual pig which is a monitor through it. You pressure test it. You actually fill it with water and see if it can hold pressure. If it does not then you know there's a leak in the pipeline somewhere.

Ultimately, all that would have to be completed before ERG tried to reactivate use of the line. But what's important to note right now is ERG is obligated because the pipeline is still there to renew the franchise agreement with the county which is just giving them permission to keep the pipeline in place. Before they did any significant work on a pipeline, they'd first test it and then if there was any serious repair work that needed to be done, they'd have to go to the county and get the necessary permits to do that.

Okay,

so when would you anticipate that they would start testing the line?

I think the use of the pipeline is a fairly low priority for ERG. First they need to ascertain whether or not they even still want to continue use of the line. ERG's not to that point yet. They just simply at this point in time, because Chevron had started this application process to renew the franchise agreement. They need to complete it otherwise technically they don't have a legal right to have the pipeline in place anymore.

Okay thank

you.

Supervisor

Wolfe? Thank you. This is to County Council. Thank you for your presentation So we heard from the speaker that they're going to use a pipeline to transport water In the resolution that we already adopted it says that were it's going to be used to transmit produced water and related oil and gas products And in the ordinance, and again now, you know, we're looking at different wording so we need to be consistent The ordinance says that the franchise will operate and maintain the pipeline for transportation of hydrocarbon substances.

So that sounds like a little bit more than water, so if you could when you all meet, if you can get some of the language consistent and we know exactly what's being transported in the pipeline.

Other questions? Next speaker.

Our next speaker is Diana Beck followed by Ben Oakley.

I don't think you're.

Diana Beck works for us as well, she's just here to answer additional questions and Ben Oakley is from ERG so unless there's any specific questions, I don't think they feel the need to

speak. Okay got it thank you.

Then we'll go with Sonia Stevens to be followed by Kathy Deputy.

Sonia Stevens?

Welcome.

Hi,

I've never done this before. Do I push anything? Nope. Okay. You're on. I live out in Cat Canyon. My name is Sonia Stevens and I have a husband and three children. I don't know all that's going on. All I can tell you is from my experience, I'm constantly smelling rotten smells out there and I'm just concerned about what's gonna happen around my home. We built our home about five years ago. We did everything properly We had to pay for permits and the environmental agency was very concerned about our water, and we had to do everything right. Now I'm concerned about if you let these people do certain things right next to my home is it going to affect my water?

What can happen? What's it going to do to us? On the way here I smelled a bad leaking Gas smell coming over Goddard Ridge and I do also have an incident that I reported back on October 3rd, Incident number 10168. It's going to be faxed to you. My children and I were driving home at about 730 at night and there's a big flame that they've fired up recently over near Palmer and Cat Canyon Road and it burns really high in the early morning and late night at times when Call to check if that's safe or not. But anyways, I was driving by it and went around a corner and all of the sudden we were overcome with horrendous fumes. Not the normal fumes that I get with stuff here and there but we had to gasp. It took our breath away. My kids were all screaming in the car.

It was really, really, really bad smell. And when I got home, we don't have cell service so I had to get all the way home called the fire department They went to find what the smell was. They couldn't smell anything, but when they were going back to Sisquok, they noticed the flame was off and there was all kinds of activity there and apparently the flame had, I don't know the proper wording, but it had blown up and burnt stuff all around it and that's the stuff we got a whiff of. And I don't know what that's gonna do to us in the future and I'm just concerned. What kind of things are they gonna dig up right next to our home and put in there and run through those pipes?

We have Going to be dorm, you know it's been dormant for so long. I didn't realize I was moving into a oil field that was going to be kicked up again and everything is, you know, the workers that come every day. One almost ran me off the road. There's a lot of activity now and I'm just concerned. I want people to go out there and not just grant permits without really knowing what you're allowing them to do. Check it out thoroughly.

Thank you

and thank

you

for being here, and I'm not being rude. I'm just curious where did you live before you lived in Cat Canyon?

Lompoc. And we wanted to live in the country. So you took Cat Canyon huh? Yes. It

all filled for a long, long time yeah.

Well right where we are you don't see all of that stuff. You know people don't jump out and tell you what you're moving into they just ask you know you get permits people don't warn you about things We don't know. We just did everything we thought we were doing right, and it looked like everything was abandoned, and now it's all firing up again. Thank you. Good luck. Thank you.

Next speaker?

Ms. Kathy Deputy to be followed by John Stevens.

Welcome. I'm the same as her. I am not used to doing this kind of stuff. My name is Kathy Deputy. I live in Cat Canyon and Long Canyon area. I'm actually a property owner out there, and we raise cattle and hay. I myself at the age of 18 worked for Texaco Oil. Okay? I pumped the Hammond Lease, and the line that you are talking about was not being used at the time that I worked there. I worked for Texco Oil from 1978 to 1981. There's two injection wells on the Hammond Lease, both of those were used for wastewater and lease water is what they're trying to say they use this line for.

Okay, they could have had this line franchise but it was not in use the time that I worked there. The only lines that were used was production lines that basically Union Oil had all the pipeline to that. are set up right at the Hammond tank battery and that is where the oil went through the LAC unit. The LAC unit is actually a line that used to reject the oil back out of the pipeline if it didn't have the right consistency of water in it, the right gravity, the right temperature and the right viscosity of oil.

Those are the only oil lines that basically came out of the tank battery at Hammond. The Hammond tank battery was shut in 1982 Okay. Nothing's been coming out of that tank battery. That's what, 32 years ago? Okay. So I know for a fact that line hasn't been used for 32 years. Another thing on this paper that you guys have it says that this company, excuse me, I'm nervous. It says his company is exempt from all environmental impact report. I would like to know why that is and Cat Canyon is a blue line Creek Okay, and it's a flood zone river. And all the tributaries that come out of the mountains go into this tributary. The Palmer, you're saying that this franchise will go through the Cat Canyon and the Palmer areas? The Palmer is a tributary of Blue Line Creek.

All these go to the Sisquauk River which then goes into the Santa Maria groundwater basin. So the water that's coming out of there is supplying water for the drinking water for Santa Maria. This company To me, I don't know this company. They don't have a track record here. Their new company what I have seen of them there's a bunch of different franchises together all limited liability is what they have on there.

I read some of their paperwork and it shows that they only have 10% of the mineral rights in the Hammond Lease So and what they're going to use for water, water never came to that lease through a line like that. We got the water from over the top of Gatto Ridge so it came from way over the southern homes now where the water used to come from. I have big concerns about the air quality

I'm sorry that your time is up. Ms. Deputy, thank you for coming down here and giving us this testimony. And I would assume that some of these – this is going to be happening more and more because the oil fields were basically shut down since 1970 And we're dealing with this. So here is a person that obviously knows a bit about it, and some might

not. I worked for the oil fields for nine years after I quit Texas Oil. I contract pumped from myself for Gulf Oil.

So you might want to take her number and address because you could be helpful. Supervisor

Carvajal? Madam Chair, unless there's some real urgent time constraint, I would encourage us to put this over a week in light of what's been said. I'm inclined to be supportive how we can move this franchise forward But you've raised some really important issues that I want to at least clarify in my mind and hear from staff, make sure they're covered.

Well the question

is... Let me finish Madam Chair because it sounds to me that, and I'm not going there, I'm just working out some thoughts here. As we look, one do we have to franchise? And certainly I would want to encourage that to move forward so that they could continue that but a lot of the fact This is next to a blue line waterway. Why wouldn't we look to the company to make sure this is an operable line within the best environmental standards before we franchise or as part of franchising? And maybe we don't have that right from council's perspective, maybe we do but all these issues now are coming up that I hadn't quite I