Coal Creek Canyon Fire Protection District Five Year Plan

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1 Coal Creek Canyon Fire Protection District Five Year Plan Adopted by the Board of Directors October 1, 14 Prepared by Joe Ceurvorst Fire Chief Coal Creek Canyon FPD I. EXECUTIVE SUMMARY Coal Creek Canyon Fire Protection District (CCCFPD) provides fire protection and emergency medical services to the residents, homeowners, commercial properties, and visitors within the District boundaries. CCCFPD has achieved an excellent reputation amongst the local fire

2 districts through an emphasis on training and qualifications resulting in capability. Being recognized as a quality, professionally run organization has also benefited volunteer recruitment. The Fire Chief, Officers and District Board have identified several critical needs to maintain the current level of service. Major facilities repairs and maintenance; Station 1 structural damage during the 1 Flood; Station 1 floor drainage replacement; Station roof leak; Station water damage repair; Station energy efficiency; Station cistern fill line repair; Station exterior; Training classroom soundproofing. Continuation of community cistern water supply improvement project; Aging equipment and apparatus replacement through ; Fire hose replacement; Personal Protective Gear (bunker gear) replacement; Light rescue truck replacement ( year life expectancy); Apparatus replacement through 5; Ambulance replacement ( year life expectancy); Structure engine replacement (5 year life expectancy); Qualifications and administrative demands of the Fire Chief warrant CCCFPD to follow the lead of our comparable neighboring fire districts in hiring a full-time paid Fire Chief. Operating cost escalation has outpaced property valuations and corresponding District revenues. As a result, the District is projected to have a $. million deficiency in cumulative net income through 5 based on the current 8 mill levy property tax and the critical needs identified above. Consequently, the District Board has opted to ask the voters for a mill levy increase. The following points support the mill levy increase ballot initiative. CCCFPD has the lowest mill levy of all neighboring fire districts. A mill levy property tax increase would cover half the projected revenue deficiency. The remaining deficiency will have to be met through successful grants, other funding sources and prudent cost saving initiatives. A mill levy property tax increase on a $5, market value home translates to a $9.8 per year increase in taxes.

3 II: OBJECTIVE OF THE 5-YEAR PLAN The 5-Year Plan documents current capabilities and anticipates the impact of future changes that may affect the ability of the Coal Creek Canyon Fire Protection District (CCCFPD) to provide services to the District. The Plan is not intended to be a rigid blueprint, but is a guide for the Board of Directors, the Fire Chief, and the professional staff of CCCFPD to use in prioritizing the needs of the Department and ensuring that the District is financially prepared to fulfill those needs. Factors the Plan addresses include: Identification of hazards and Values at Risk; Assessment of organizational structure as it relates to capability and objectives; Obsolescence of facilities, apparatus, and equipment; Adoption and implementation of laws, regulations, standards, and codes; Impact of new development; Adjustments to District boundaries; Changes in available revenue; Review of administrative and operating expenses.

4 4 III: BASICS HISTORY1 The greater Coal Creek Canyon area was first settled circa The area at first consisted of a few scattered homesteads and ranches. There were also some mining and logging operations. Transportation in the area was served with a limited number of primitive wagon and logging roads. The situation improved with the completion of the Denver & Salt Lake Railroad in the early 19s. The first colony of summer homes, known as Miramonte, was created in 19. An automobile road through the area was finished in This contributed to the establishment of small communities of mostly summer and weekend cabins such as Wondervu, Crescent, and Shadywood. After World War II, basic utilities such as electricity in 1948, telephones in 195, and a natural gas pipeline in the 196 s, provided a more modern environment for year round living. More subdivisions were established by such developers as Kuhlmann in 1946, followed by Burk, Lyttle, Dowdle, Booth and others. The automobile road was vastly improved over the years and paved in the mid 195 s. The construction of Gross Dam ( ) and the development and building of the Atomic Energy Commission Rocky Flats Plant in 1951 provided the catalyst for many more year round residences in the Coal Creek Canyon area. In the winter of , five men, led by Verne Houlton, formed a fire department which was incorporated as the Coal Creek Canyon Improvement Association (CCCIA) in The first fire truck was donated by the Colorado Forest Service, a converted surplus Army command truck. A dugout fire station was built in 195 into the hillside near present day Crescent Park Drive and Highway, where Station 1 now stands, to house the fire truck. An ambulance was added in 1954, greatly improving emergency medical service to the community. By 1959, the mission of the CCCIA began to include additional goals in area improvements. Consequently, the Coal Creek Canyon Fire Department became a separate legal entity in May of The financial demands of providing fire protection and ambulance service proved to be too great for charitable donations and good will. In August of 1959, the community voted to establish the Coal Creek Canyon Fire Protection District (CCCFPD) for the purpose of providing revenue and guidance for the Fire Department. CCCFPD was formally incorporated on August 1, The first major project of the newly formed CCCFPD was to replace the original dugout fire station. In 196, the first rendition of the present day Station 1 was built on the site of the original dugout fire station on property donated by the Seaver family. Station 1 was expanded in 191, adding a fourth bay to the east and a meeting room and office to the west. 1 Sources: Coal Creek Canyon Colorado, Tales from Times Past by Vicki Moran; Gene Rouse, Retired Volunteer Firefighter and Fire Chief (191-1).

5 5 Funded by a bond issue, Station was built in 198 on property provided by the Miramonte Group adjacent from Camp Eden Road on Highway. A training classroom was added to the station in 1. Station was constructed in 1989 on property adjacent to the railroad tracks on Blue Mountain Drive donated by the Lacy family to provide fire protection to the Blue Mountain Estates subdivision. A single bay fire station, Station 4, was built in 1994 on land donated by the Gruchy family to house an engine in the southern portion of the District at Gap Road and Dowdle Drive. A three bay station was built adjacent to the original structure in. The CCCFPD and the Coal Creek Canyon Fire Department operated as separate legal entities until. The Coal Creek Canyon Fire Department was a non-profit entity of the fire fighters, whereas the Coal Creek Canyon Fire Protection District was organized as a governmental special district. In, the Coal Creek Canyon Fire Department was dissolved to provide the fire fighters the legal protection afforded as volunteer employees of the special district. Today there is only one legal entity, the Coal Creek Canyon Fire Protection District (CCCFPD), though CCCFPD may also do business as the Coal Creek Canyon Fire Department.

6 6 DISTRICT DESCRIPTION CCCFPD covers 5 square miles centered on the primary geographic feature, Coal Creek Canyon. The District straddles the boundaries of Jefferson, Boulder, and Gilpin counties with the District area split 65% in Jefferson County, % in Boulder County, and 5% in Gilpin County. Land ownership within the District is diverse. Private party land ownership accounts for roughly 5% of the District, the balance held by governmental entities including US Forest Service, Bureau of Land Management, Colorado State Parks, Denver Water Board, Boulder County Open Space and Jefferson County Open Space. The District topography contains flat grasslands on the far eastern boundary, abruptly transitioning to steep mountainous terrain, steep walled canyons, and mountain meadows. Two major drainages flow through the District. South Boulder Creek, including Gross Reservoir, flows through the northern portion of the District and is a major water source for Denver Water Board. Coal Creek, the namesake of the local area, originates within the District and only has nominal flow for much of the year. Two state highways run through the District. Highway 9 is a major artery between Golden and Boulder running near the eastern border of the District. Highway runs through Coal Creek Canyon and is the only east/west access for the residents of the District. There are maintained dirt roads that provide egress to the north and south for the high density residential areas in the District. Gross Dam Road (dirt) connects to Flagstaff Road (paved) on the northern District boundary, which drops down into Boulder via Flagstaff Mountain. To the south, Gap Road ties in with the Peak to Peak Highway (Highway 119), providing alternate access to Golden via Blackhawk and Clear Creek Canyon or Boulder via Nederland and Boulder Canyon. The District has 4 miles of roadway, 1% of which are paved, 5% unpaved dirt, and 1% passable only with high clearance 4x4 vehicles, conditions permitting. The secondary roads are generally narrow, winding, and steep with gradients up to %. Ice and snow are common anytime from September through May, complicating access. A major railway operated by Union Pacific Railroad passes through the District. The railway connecting the major cities of Denver and Salt Lake City was constructed on the steep, heavily forested hillsides in the 188 s and contains 5 tunnels within the District. As many as 8 trains pass through the District daily, including the Amtrak passenger train, coal trains, and freight trains carrying hazardous materials.

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10 1 DEMOGRAPHICS The District is home to approximately, people occupying roughly,8 single family residential homes. Population density is greatest in the central canyon and the upper canyon. The community is primarily a bedroom community, with most residents commuting to the Denver metro area for employment. The population of the District is believed to drop to roughly,5 during week days. Recreational area use, businesses and special event facilities draw up to 1, non-residents into the District daily, particularly on weekends. Recreation at and around Gross Reservoir, Walker Ranch Open Space / Eldorado Canyon State Park, and Golden Gate State Park create unique challenges in search and rescue operations. Highway is a popular route for motorcycles and bicycles from spring through autumn, especially on weekends. Daily traffic counts on Highway can jump from 5, during the week to 1, on weekends. Additionally, Highway 9 carries roughly 1, commuters daily between Golden and Boulder. CCCFPD provides rescue and emergency medical services, usually in response to motor vehicle accidents, to these travelers. Source: Colorado Department of Transportation Traffic Counts for 1.

11 11 VALUES AT RISK Residential homes are the primary value at risk. Home sizes and values vary considerably within the District, from small cabins to large, high-end homes. The District completed a Community Wildfire Protection Plan in 8 rating each subdivision within the District for risk to wildland fire. The subdivisions ranged from Moderate to Extreme, with the majority rated High. Within each subdivision, however, each individual property ranges greatly in defensible space and use of fire resistant construction materials. Progress on improving defensible space around structures has been slow but steady. CCCFPD emphasis has been on awareness, education, and facilitating slash removal. Other community organizations have been active in assisting homeowners with mitigation. Boulder and Jefferson County requirements for residential sprinkler systems in new construction and major remodels have been phased in since The District currently has 1 residences with residential sprinkler systems. Highway 9 has commercial industrial properties, including an aggregate plant, a saw mill, several combination office/warehouse facilities, and a restaurant/bar. Business facilities within the canyon are concentrated in proximity to Highway. These include four restaurants, a convenience store, veterinary clinic, post office, two gasoline stations, auto repair shops, a liquor store, a day care facility, a small motel, and limited retail shops. Industrial properties include an LPG yard, a power company yard/office, and State DOT and County Road and Bridge shops. In addition, there are several home based businesses operated within the District. Community facilities include an elementary (K-8) school, a community hall, and three churches. Other values at risk include the railroad right of way, power transmission lines and transformer stations, natural gas pipelines, the water supply at Gross Reservoir, and the hydropower generation facility at the base of Gross Dam.

12 1 IV: SERVICES PROVIDED Fire Protection CCCFPD provides fire protection within the District and supports our neighboring districts with fire suppression. Fire protection is divided into structure fire and wildland fire. Our objective in structure fire protection is to protect life safety and to preserve property. Wildland fire protection includes the additional objective of containment. During a wildland fire incident, containment may supersede protecting an individual structure or even a group of structures. Wildfire far and away poses the greatest risk to the District. CCCFPD epitomizes wildland urban interface subdivisions combined with large undeveloped tracts of land. Three local ecosystems are represented in the District. In the lower elevations, grasses interspersed with ponderosa pine and mountain mahogany are predominant. In the middle elevations (65-8 feet), Douglas fir, Engelmann spruce, and junipers are added to the mix. The forest transitions to lodgepole pine at the highest elevations in the District. A major wildfire event would quickly exceed the capabilities of the District, both in terms of resources and finances. The incident commander has the option to request a transfer of command with the appropriate Sheriff s office per Colorado statute if the incident exceeds the capability of the local agency. Transferring command of a Type fire significantly expands the pool of resources available to engage the fire, including air resources, and transfers financial liability to the Sheriff. The initial attack incident commander will likely maintain a unified command role after formally transferring command, and CCCFPD resources will continue to be engaged on the incident. A significant component of protecting life safety and preserving property is accomplished before an incident occurs through code adoption and enforcement. CCCFPD has adopted the 1 International Fire Code with amendments and the International Urban-Wildland Interface (WUI) Code with amendments as the fire codes for the District. The District Fire Marshal is responsible for reviewing all building permits for compliance with these codes along with conducting annual inspections of commercial buildings for code compliance. The District Fire Marshal also works in cooperation with the Officer corps to pre-plan incidents at commercial facilities. Wildfire incidents are categorized by type. A Type 5 incident is small in scale and can be handled by a single fire district. Type 4 incidents are larger in scale and utilize mutual aid from neighboring districts. Type 4 incidents are still managed by the local fire district and generally contained within one to two days. Mutual aid agreements between neighboring agencies generally cover the financial obligation of the local fire district. A Type incident is expected to last for multiple days and requires response from multiple agencies from within the county(ies). Aircraft start to make an appearance at the Type incident level. Type incidents generally require that responding agencies be compensated for their services. The operational complexity and financial burden of a Type incident dictate that the county Sheriff s Office assumes responsibility for the incident. Type incidents are large, multi-day incidents that dip into the pool of state resources and finances. Type 1 incidents are the largest, most complex incidents requiring federal assistance, both in terms of resources and finances.

13 1 Two controversial WUI code requirements deserve further mention. Water supply is a challenge in rural fire districts, CCCFPD being no exception. The amended WUI code requires 5, gallon cisterns on private residential structures; however, CCCFPD also allows a contribution to a community cistern fund in lieu of a private cistern. The community cistern is encouraged for several reasons. First, maintenance and inspection of private cisterns is up to the owner. CCCFPD has no legal authority to ensure the private cisterns are filled, that the connections are in good working order, that the cisterns are well marked, and that access is kept clear. Second is the size of the private cisterns. Experience has proven that 5, gallons is often insufficient. A fully involved structure fire typically requires, to, gallons of water through the mop-up stage. Then there is the legal question surrounding use of the water. Can CCCFPD use water from a private cistern on a fire at another private property? What if CCCFPD drains a private cistern and then opts not to defend that structure during a wildland fire because of other factors? The second controversial WUI code requirement involves residential sprinkler systems. Residential sprinkler systems are a critical factor in life safety and property preservation in our wildland urban interface environment. Sprinkler systems compensate for the longer response times of rural volunteer districts, and are by far the most cost effective means of providing fire protection to an individual home, and potentially to a subdivision if the fire were to move into the wildland environment around the involved structure. While there is little controversy regarding the life safety and fire protection residential sprinkler systems provide, there has been strong opposition on the part of builders due to the increased cost. Emergency Medical Services Under Colorado statute, CCCFPD is not required to provide emergency medical services (EMS) within the District, but chooses to do so. EMS constitutes the majority of incidents in the District. CCCFPD maintains a license to operate a basic life support (BLS) ambulance; however, the District is also included in the Boulder County advanced life support (ALS) ambulance contract, currently held by American Medical Response (AMR). CCCFPD is authorized to transport patients to the hospital, but our strong preference is to have AMR transport. Search and Rescue Search and Rescue legally falls under the County Sheriff. CCCFPD does not have any specialized search and rescue teams or equipment. Specialized rescue teams available through Boulder Sheriff include Rocky Mountain Rescue Group (vertical and technical rescue) and Boulder Emergency Squad (dive team, swift water rescue, and rescue dogs). Golden and Clear Creek County also have swift water rescue teams that can be requested as needed. CCCFPD personnel and apparatus are utilized in search and rescue operations in incident command roles, area searches, water transportation, and medical care.

14 14 Hazardous Materials Response CCCFPD is required to provide hazardous materials response in the District. CCCFPD firefighters are trained at the Awareness and Operations level. Incidents requiring Technician level response will require a mutual aid response from one of the metro HazMat teams. All Hazards Response All Hazards is a catch-all phrase for other incident types, the best example being the 1 Flood. Our objective in all hazards incidents is protecting life safety and organizing the incident response using principles of the Incident Command System (ICS). CCCFPD is financially responsible for all outside resources ordered to assist on the incident.

15 15 Annual Incident Summary by Incident Type4 Incident Type Medical a Motor Vehicle Accidents Search and Rescue Wildland Fire b Structure Fire c Vehicle/Other Fire Hazardous Materials All Hazards d Cancelled Total Yr Avg 45% 1% 1% 4% 5% % % % 8% 1% Incidents per Day 15 1 Occurances (Days) Number of Toned Incidents per Daye 9-1 Toned Incidents a) b) c) d) e) Medical includes patient assists and welfare checks. Wildland fire includes unable to locate smoke chases and mutual aid. Structure fire includes alarm investigations. All hazards includes downed power lines and traffic control. Toned incidents result from a 911 emergency call requiring CCCFPD response. 4 Source: District response records provided by JJ Mikulich (Administrative Assistant)

16 16 V: CURRENT CAPABILITIES STAFFING CCCFPD relies on volunteer employees. The District Fire Marshal is currently the only paid employee and is compensated on an hourly basis. The District also contracts for an Administrative Assistant and a Bookkeeper, both on an hourly basis. All operational positions, including the position of Fire Chief, are currently 1% volunteer. CCCFPD maintains some of the highest training and participation requirements relative to other volunteer and combination agencies in Boulder, Jefferson and Gilpin counties. The high standards are intended to create a highly capable team of firefighters and a professional organization that volunteers want to belong to. Volunteer firefighters are required to maintain minimum certifications. In addition, volunteers are encouraged to pursue advanced certifications including Emergency Medical Technician (EMT), State Firefighter, and NWCG Firefighter Type 1. Advanced training opportunities are offered in auto extrication, incident management, and wildland fire. Minimum Certification Requirements Firefighter CPR Healthcare Provider State Emergency Medical Responder State Firefighter 1 State HazMat Operations Federal NWCG (Wildland) Firefighter Type Wildland Team Member CPR Healthcare Provider Federal NWCG (Wildland) Firefighter Type CCCFPD participates in the Boulder County Fire Fighters Association (BCFFA) training academies for basic wildland firefighting, basic structure firefighting, and hazardous materials certifications. Basic medical training is usually contracted with a paramedic instructor and hosted in District. New applicants generally take two years to complete their certifications. Volunteer firefighters account for 5.4% of national firefighter fatalities, with heart attack being the most frequently cited cause of on the job fatalities. CCCFPD has taken a proactive stance on firefighter health. In 1, the District Board adopted NFPA 158, Standard on Comprehensive Occupational Medical Program for Fire Departments, with amendments. All new applicants receive a physical fitness evaluation by the District Healthcare Provider. In addition, all active firefighters are evaluated periodically starting at age 4. The evaluation includes a treadmill stress test to gauge cardio health under conditions a firefighter is likely to encounter.

17 1 FEMA National Firefighter Fatality Statistics (-1) Firefighter Classification Volunteer Career Wildland Contract Paid On-Call Wildland Full-Time 5.4% 5.% 4.%.% 1.9% Nature of Fatality Heart Attack Trauma Asphyxiation Other Cerebrovascular Accident 4.% 8.% 6.4% 5.% 4.9% The transition to higher standards has not been without pushback. The District did lose some experienced firefighters that chose not to meet the higher certification requirements or were unable to meet the physical fitness requirements. However, the District is now stronger and more diverse than it has ever been. The downside risk of firefighter burnout has not yet been a major issue. Firefighters initially volunteer for various, generally self-serving reasons, be it a sense of belonging to an organization, a sense of good will, networking, peer-pressure, etc. Firefighter retention is based on commitment to a belief that the cause is worthy, the organization excels, and the individual is integral to the success of the organization. The District Board and firefighter leadership must establish an environment that challenges and rewards the volunteer, and that clearly defines a vision and advances the mission of the organization. The optimum number of volunteers to have on the roster must consider the number of firefighters needed to safely run an incident, and the probability of firefighters being able to respond when the incident occurs, while avoiding the dilution of touches when there are too many firefighters. Experience indicates the minimum number of firefighters needed on a fully involved structure fire, without extension into the wildland, is 8-1, with the ideal number being 16-. More than, it becomes difficult to give everyone a meaningful assignment. Factoring 5% to 5% availability, the minimum number of fully trained volunteer firefighters on the roster needs to be -5, and the maximum number should be in the range of -5. The challenge of staffing for a structure fire incident is the resultant dilution of touches on our common EMS incidents where fewer responders are needed. It is imperative that fire leadership involve as many individuals in some aspect of routine incidents as possible. Consideration has been given to forming an EMS team, similar to the Wildland team. The EMS team could be an attractive recruiting option for volunteers not wanting to participate in firefighting. The EMS team concept has not been implemented to date because it would take away touches for our active firefighters. This decision should be reconsidered if our staffing numbers drop under the -5 minimum, including expectations for trainee firefighters. Wildland fire is a whole other animal. We need as many trained, qualified volunteers as we can effectively manage. CCCFPD established a Wildland Team in 5 to attract volunteers that were not able to commit the time or did not have the interest in being active firefighters, but did want to aid the community during a major wildland fire incident. Wildland Team members have the same minimum

18 18 wildland training certification requirements as active firefighters and receive the same advanced wildland fire training opportunities as active firefighters. Wildland Team members, however, are not eligible for volunteer pension benefits. The Wildland Team leadership challenge is maintaining morale between incidents, as the frequency of large scale incidents is relatively low. Options to keep volunteers involved include participation in prescribed fire and mutual aid response. CCCFPD generally runs a recruitment drive starting in January and concluding by end of February. Recruitment efforts typically generate 5 viable candidates. The new recruits must pass a records check and be interviewed by the station officers. Acceptable candidates undergo a pre-employment physical before being offered a position on the Department. The recruitment class generally starts their CPR and basic wildland training in April. Annual recruitment has proven to be the most effective as we are able to manage the basic training opportunities as a group rather than trying to fit individuals into classes here and there. Training is key to keeping volunteers motivated. The training needs to be challenging and applicable. Regular, but not overly demanding on the volunteer s time. Fresh and not repetitive (which can be particularly challenging given the broad range of experience on the team). Recruiting, Periodic Physicals and Training Expenses Recruiting $,6 $4,18 $6,899 $,419 Periodic $,19 $5,9 $5,89 $,84 Physicals Training $,55 $16,1 $16,58 $5,66 9 $8,594 5 $,446 $,491 $,59 $9,81 $4,1 5 Source: Profit and loss statements from audited accounting records.

19 19 STAFFING STATISTICS (1-December Data)6 Number of CCCFPD Volunteer Firefighters Total Station Station Station 8 Station Wildland Team EMT s State FF1 s State FF s + State Certified FF s NWCG Qualified Wildland FF s Wildland FFT1 s % 44 86% 5 8% 4 8% 6 68% 41 8% 6 59% 4 % 55% 4 8% 6 1% 9 6% 9% 8 % Years of Service for CCCFPD Volunteers Years Age of CCCFPD Volunteers Gender Mix of CCCFPD Volunteers 1 1 Male 4 4 Female Source: District records provided by JJ Mikulich (Administrative Assistant).

20 VOLUNTEER PENSION BENEFIT CCCFPD participates in the Statewide Volunteer Firefighter Defined Benefit program administered by FPPA, providing a nominal pension incentive for firefighters who achieve 1+ years of eligible service. Active firefighters receive credit for a year of service if they meet the minimum District training and incident response requirements. The pension benefit is vested after 5 years of eligible service and can be carried over to another participating fire district within the state. The current pension benefit pays $ per month to retired firefighters with years of eligible service, known as full retirement, starting at age 5. Partial retirement benefits are prorated for years of service ranging from 1 years of service to years of service at $15 per month per year of service. The pension benefit is being phased out by several volunteer fire agencies. The decision by other agencies to drop the pension benefit is driven by a combination of factors including underfunding of plans, budget constraints, and the perceived effectiveness of the benefit on retaining qualified firefighters. The CCCFPD pension is audited bi-annually. As of 1, the CCCFPD plan is slightly underfunded, having not recovered from the market downturn in 8. The CCCFPD Pension Board has elected to ride out the market downturn rather than increase the pension funding or decrease the current pension benefit. At present, the CCCFPD Pension Board has not had any serious discussions about changing the pension benefit, believing the benefit contributes to qualified firefighter retention. CCCFPD Pension Expenses 1 CCCFPD $8,469 Contribution State Contribution $4,9 Total Contribution $5,548 1 $,8 11 $,51 1 $,5 9 $5,69 5 $4,689 $18,5 $4,61 $5,548 $4,615 $5,1 $,19 $5,54 $4,68 $5,45 $,55 $4,444 $18,5 $6, $81,91 $6,86 $4, $69,65 N/A Select CCCFPD Pension Plan Statistics (1-December Values) $96,46 $86,65 $819,65 $84,5 $,5 Plan $64,41 $885, $6,8 Retired Firefighters Collecting Pension8 1 1 Individuals 9 Collecting Total Payments $86,85 $86,84 Source: Profit and loss statements from audited accounting records 8 Source: Personnel records provided by JJ Mikulich (Administrative Assistant) and FPPA Statements for Twelve Months Ending December 1 9 Source: FPPA Statements for Twelve Months Ending December 1

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