By Roberta Millstein

This is just a short update to follow on the Davisite’s earlier articles concerning the Housing Element Update (see here, here, and here).

This past Wednesday (June 9^th), the City of Davis’s Planning Commission met for a second time to discuss the recommendations of the Housing Element Committee (HEC)-- the first meeting was May 26.  At the earlier meeting, most of the comments from the public concerned 10 recommendations that the HEC had passed.  And a good number of the comments came from UC Davis students who were apparently reading from the same script, since their comments were identical or nearly so.

So, one might have expected that the June 9 meeting would be more of the same.  But that was not the case.

June 8, 2021
Mark N. Grote, Secretary
Old East Davis Neighborhood Association

City Council and Planning Commission Members
Planning Staff
Community Members

Re: Future of the Core Transition East

Dear decision-makers and community members: On behalf of the Old East Davis Neighborhood Association Board, I am writing to ask again for collaboration between the city, property owners and neighbors, to address the unique challenges of the Core Transition East as the Downtown Plan moves forward.  

Unique challenges of the Core Transition East parcels

The Core Transition East, located in Old East Davis just to the east of downtown, consists of four large parcels adjacent to the Union Pacific railroad tracks between 3rd and 5th Streets. Current planning provisions designate this area for neighborhood-compatible buildings that make appropriate scale transitions between the downtown core and the traditional, small-scale houses of Old East Davis.

The parcels of the Core Transition East present unique design challenges that are not met by the general building forms of the November 2019 draft Form-Based Code currently under review as part of the Downtown Plan. Some of the unusual features of these parcels are:

The Subversion of the Housing Element Committee (HEC) Deliberation Process by Hidden Development Interests

Note: Several recent articles in the Davisite touch on the subject matter discussed here: For other comments on the Housing Element’s failure to address affordability and the proposals being pushed by development and real estate interests, see Davis Housing Element Fails Affordable Housing (5/27/2021). See also Comments on Draft Housing Element from Legal Services of Northern California (5/25/2021) For comments on problems with the City of Davis’s decision-making process see Good decision-making process involves staff and City Council too (6/3/2021)

By Alan Pryor and Rik Keller

The City of Davis’s Housing Element Committee (HEC), which is supposed to represent a “diversity of interests” in the community, was instead co-opted by development and real estate interests. Two weeks ago, there were a last-minute series of policy recommendations that were sprung on the Committee by these same real estate and development interests in violation of Brown Act open meeting laws. The HEC then further violated these laws in considering and voting to adopt the recommendations. Furthermore, the development and real estate interests on the Committee failed to adequately disclose conflicts of interest in terms of their investments and holdings in the City that would be impacted by the favorable recommendations approved by the HEC.

This subverted process brings up important questions: Why has the City directed a process that has so little public input, especially from genuine affordable housing advocacy groups? How did the City staff allow so many violations of Brown Act laws regarding transparency and open government? Why did the City select HEC members with such a preponderance of real estate interests instead of appointing more representatives from the affordable housing community?

Concerns raised about lack of public participation from all economic segments of the community without adequate time to review, among many other concerns. Additional changes are needed to comply with the law and provide the most effective strategies to address the critical housing needs facing Davis residents with low incomes.

Background: The City of Davis is preparing the 2021 – 2029 Housing Element to evaluate current and future housing conditions and identify housing sites to meet the community’s needs. Updating the Housing Element is a state requirement. The following letter commenting on the Draft Housing Element from Legal Services of Northern California was sent to the Davisite to post.

On 5/26 the City of Davis Planning Commission met to discuss the draft housing element. The Housing Element is a state mandated component to the Cities General Plan since 1969, California has required that all local governments update the Housing Element on regular intervals to meet the housing needs within the community. The City of Davis is receiving comments on the 2021-2029 housing element through July 1st at 5pm. you can learn more about the 2021-2029 Davis Housing Element here Link .

What follows are the comments of Rik Keller to the Davis Planning Commission.

__________

5/26/2021

To: City of Davis Planning Commission

From: Rik Keller

Re: Housing Element Update

I have been a long-term affordable housing consultant and advocate since the mid-1990s. Locally, I have recently advocated for increased affordable housing for various projects in the City review process...

• see: https://www.davisvanguard.org/2018/06/examination-affordability-nishi-projectmeasure-j-expensive-overcrowded/

...and for more equitable and inclusive housing policies in general:

• see my 3-article series here: https://www.davisite.org/2018/10/keeping-davis-white-land-use-policy-is-a-civil-rights-issue.html

I am a strong advocate for addressing exclusionary housing practices. We already have tools in place to counter “snob”/exclusionary zoning. These include inclusionary zoning (IZ) policies that the City of Davis has in place as part of its Affordable Housing Ordinance [AHO] (see Article 18.05 of the Davis Municipal Code: http://qcode.us/codes/davis/view.php?version=beta&view=mobile&topic=18-18_05)

Unfortunately though, the City of Davis has drastically weakened its IZ policies in the past decade. In 2011, in response to pressure from development groups, it suspended its Middle Income Ordinance that was targeted to provide housing affordable to the local workforce. And in early 2018, the 25-35% requirement for inclusionary/affordable housing in the City’s Affordable Housing Ordinance (AHO) was reduced to 15% “temporarily” because of a need to respond to State rules. In the almost 3.5-years since, the City has been promising to update its IZ requirements, but has repeatedly broken its own deadlines, and hasn’t completed the required studies to update it.

Dear Planning Commissioners -

At the upcoming Planning Commission meeting this Wednesday you will be presented with the newly proposed "Davis-Connected Buyers Program" for the Bretton Woods Project. This new proposal has serious flaws and is essentially gutless in terms of ensuring that a large percentage of new homes are sold to existing Davis homeowners thus freeing up current local housing stock for new families as promised by the developer in the actual language on the ballot in the Measure J/R vote in 2018.

I have written a detailed article published in the Davisite about the new program and its shortcomings that are so severe that it renders the program practically non-existent. To see the article click on the following title, Bretton Woods Attempts Another Bait and Switch with Its Davis Based Buyers Program.

In summary, the new Davis-Connected Buyers Program states that it will have prospective buyers sign a disclosure form identifying their link to Davis but that it also allows ANYONE to refuse to sign the disclosure form because they are a member of a protected class based on any race, gender or gender identity, ethnicity, religion, etc. I myself could refuse to sign the disclosure form simply because I am a straight married white agnostic male and the developer's new proposal says that would allow me to buy a new home even if I otherwise had no links at all to Davis. The developer also claims that they will not investigate or demand proof of any "protected status" claims because he does not want to intrude on the prospective buyers privacy. In other words, the developer will take any and all buyers thus opening the floodgates to anyone who wants to buy there and has the wherewithal to engage in bidding wars.

Below is the text of a letter submitted to the Davis Planning Commission for its April 14th meeting expressing issues and concerns with the Bretton Woods Davis-Connected Buyers Program.

Commissioners:

I write to express concerns with the Davis-Connected Buyers Program (DCBP), which is scheduled to be presented at the Planning Commission’s April 14, 2021 meeting. I am disappointed that this agenda item is an informational update only rather than an action item. That suggests that the City Council is not interested in further commission input or recommendations on the DCBP and that its approval by the Council as submitted by the developer is a fait accompli.

I am now retired but have nearly four decades experience with state and federal fair housing laws. I was an attorney with Disability Rights California, California’s designated non-profit disability protection and advocacy organization, for 26 years and subsequently held positions as Chief Consultant for the Assembly Human Services Committee and as legislative director for the California Department of Developmental Services. I am also a former member of the Davis Social Services Commission.

Provisions of the DCBP do not make sense and the program will almost certainly not achieve its purported purpose. Most importantly, as has been alleged—including in a lawsuit challenging the DCBP that was subsequently dismissed without prejudice on procedural grounds—the DCBP is likely to perpetuate, and possibly exacerbate, existing racial disparities in Davis as compared to the region.

Protections Will Weaken for Prospective Davis Senior Buyers

by Alan Pryor

INTRODUCTION

The Bretton Wood developer, David Taormino, is attempting to pull another bait and switch on Davis seniors by completely gutting the campaign promises he made to Davis voters committing to sell 90% of homes in the new project to Davis-based buyers. The long-promised Davis-Based Buyers Program was intended to ensure that 90% of all new homes sold at the new development were to Davis seniors thereby freeing up their existing large homes for new families to come to Davis.

But make no mistake about it, this newly proposed watered-down plan has so many loopholes in it that it will open the floodgates to advertising and sales to well-heeled Bay Area expatriates flush with cash from sales of their own inflated homes. Indeed, this will probably drive up prices for new homes at the project so high that it will functionally exclude Davis seniors from participating - much like we saw in the Cannery project where the majority of new sales were to buyers from outside Davis.

By Roberta Millstein, Pam Gunnell, Nancy Price, Alan Pryor, and Colin Walsh

Measure B – the measure that proposed a 200-acre business park and housing development outside of the Mace Curve – failed at the polls.  The defeat comes with official Yolo County returns showing that 16,458 people, or 52% of voters, said “no” to the project.  In Mace Ranch and Wildhorse, 60% of voters opposed the project.

This is a remarkable result considering that the No on B campaign was outspent by over 14 to 1.  As of October 28, Yes on B had spent $258,919 between when B was put on the ballot in July and the election in November, while No on B had spent $18,149.  The No on B campaign, composed solely of volunteer Davis citizens, created its own literature, designed its own sign and other graphics, was active on social media, and, to the extent possible during COVID, pounded the pavement distributing flyers to let Davisites know about the negative impacts that this project would bring.  It was a true grassroots effort.  There were no paid designers, no paid consultants, no multiple glossy mailers, and no push-polls to gather information on what messages would sell.  Opponents also could not table at the Farmers Market due to COVID restrictions, normally the bread and butter of a campaign lacking deep pocket donors to finance getting its message out.

By comparison, Yes on B hired a PR Firm and other consultants more than a year in advance of the vote to help contrive and package its message and run the campaign.

The fact that Measure B was nonetheless defeated in the face of long odds and unusual circumstances shows that DISC was a bad project for Davis from the outset.  It was too big, chewing up prime farmland and habitat.   The promise of on-site housing for DISC employees could not be guaranteed, making the development car-and commuter- oriented with extensive parking areas. Poor public transportation options exacerbated this problem. The DISC development would have massively increased Davis greenhouse gas emissions and made it impossible for Davis to meet its carbon neutrality goals. We are in a climate emergency, as Yolo County and other counties have recognized; Davis needs to shoulder its share of responsibility for climate impacts, including but not limited to wildfire impacts and extreme weather events locally and globally.

(From press release) If you're still undecided about Measure B authorizing the 200-acre DISC Industrial Park on prime farmland and burrowing owl habitat with 2.6 Million sq ft of commercial buildings, following are five very good reasons to vote NO on this massive, sprawling, ill-conceived project that will forever change Davis for the worse.

1. Nightmarish Traffic Gridlock

• The Environmental Impact Report estimated that more than 24,000 in-and-out daily car trips will occur for the DISC project when completed - more than doubling current traffic levels. It will turn Mace Blvd. into a parking lot causing hours of gridlock every day.

• The City and Developer have no plans at all on how they will mitigate this massive influx of new traffic. Instead, a Traffic Demand Management Plan will be prepared by the Developer in the future.

• But "Figuring it all out later" is NOT a plan!

2. Unprecedented Increases in Greenhouse Gas Emissions

• Our world is burning up and melting around us. This year we have seen the largest fires ever in the Pacific Northwest, Colorado, Siberia, the Amazon, and Australia along with record-breaking ice-melts in Greenland and Antarctica.

• Yet according to the project's Environmental Impact Report, "...net emissions in the year 2035 would equal 37,724.31 metric tons of CO2 equivalent per year, the project would NOT meet the City’s target of net carbon neutrality by the year 2040." Instead it will increase the City's carbon footprint by over 8% from this one project.

• Our leaders passed an Emergency Climate Resolution just last year...what are they now thinking?

3. DISC will Cannibalize our Downtown

Thirty different small downtown Davis merchants recently signed a petition opposing the project's 100,000 sq ft of additional retail space (about the size of Davis Target) and the 160,000 sq ft of additional hotel space (more than twice the size of the new Marriott just across the street) because it would present severe economic hardship on the small downtown merchants already reeling from COVID.

• The DISC Environmental Impact Report (EIR) also projected than an additional 313,000 sq ft of commercial space in Davis could become newly vacant due to competition from the DISC project leaving blight in its wake.

• Our Downtown should not be Sacrificed for Developer Profits!

4. DISC will NOT have Affordable Housing

• The DISC Developer falsely claims the amount of affordable housing at the project is "record-breaking" for Davis. That is simply NOT true for either the market-rate OR the subsidized affordable housing.

• The estimated rent for a market-rate 2- bedroom apartment will be $2,500+ per month and the estimated price for a 2,200 sq ft home will be over $800,000+ and will require a $200,000+ annual salary to buy.

• There will be 128 subsidized housing units on-site which is 14.7% of the 850 total housing units. But the West Davis Active Adult Community will have 150 subsidized senior apartments on site which is 31.6% of the 475 total units.

• DISC will neither be "Affordable" or "Record-Breaking"!

5. DISC is using Voodoo Economics to Project a Profit for the City

• Property Tax revenues are based on hopelessly optimistic and unrealistic valuations that are 48% higher compared to the same analysis done by the same financial consultant for the same business park just 5 years ago and 68% higher than current regional averages.

• The City's Finance and Budget Commission voted on a slim 4-3 margin only that the project "is likely to produce a net positive financial benefit to the City"...Not exactly a ringing endorsement.

• And one Commissioner even called the consultant's assumptions a "fairy tale".

• Clearly, a thumb has been put on the scale to make the project seem economically far rosier than reality. _________________________________________________________

The more we hear about DISC, the more it is clear that Davis will get all of the traffic and pollution and the Developers will get all of the profits. It's time to just say "NO"!

__________________________________________________________

Sierra Club Endorses No on Measure B - No on DISC

Photo credit: Nick Buxton

By Juliette Beck

A little over twelve years ago when I was pregnant with my first child and deciding whether to move to Davis to join my sister in raising our families here, I looked at the air quality data and considered the impacts on newborn lungs.

I ultimately made the decision to move here and fight like hell for my children to grow up on a livable planet, in a healthy community. Given the climate emergency that has choked our skies with smoke for weeks on end, I'm not sure I'd make that same decision today.

We are at a critical turning point in human history. For decades, scientists, activists and frontline communities have been telling us we must change course. This summer, it has become undeniable that all of us here in California are now on the frontlines of a rapidly destabilizing climate.

With Measure B (thanks to Measure J/R now on the ballot as Measure D), we as citizens of Davis have the opportunity to vote on how our community will respond to the climate emergency - an emergency caused in large part based on how we as a society develop land and open space.

Located just east of the Mace Blvd curve and north of the Ikeda Market, this swath of farmland borders Davis as a gateway to our city. It could be a showcase for climate positive, regenerative farming that sustains our local food needs. But if Measure B passes, it will instead be a sprawling development comprised mainly of $800,000+ luxury homes and a massive industrial business park.

By the League of Women Voters Davis Area

The Question:  Should residents approve annexing agricultural land to develop the Davis Innovation and Sustainability Campus (DISC)?  Annexation of county land for city-related uses has required citizen approval since voters passed the “Citizens Right to Vote on Future Use of Open Space and Agricultural Lands” ordinance in 2000 (as Measure J) and renewed it in 2010 (as Measure R). 

The Situation:  Davis has studied options for an innovation park with the goals of leveraging UC Davis' international reputation for academic and research advancements in agriculture, biotech, green-tech, and food science research.  As the options were studied, four options initially appeared to be available but these have since been reduced to one (see Appendix for a more detailed history).  The project site is agricultural land that has been productively farmed for many decades.  Moving forward with the project will put an end to farming on the site.

Measure B (DISC) is perhaps the worst development project that has ever come before Davis voters. Above all, it will have major adverse and irreversible environmental effects, and instead of helping to solve the housing problem, it will only aggravate it. Finally, it will do nothing to solve the city’s major fiscal issues, and indeed only exacerbate them.

A year ago, Davis leaders declared a “climate emergency” and declared it would achieve carbon neutrality by 2040. This massive project (over twice the size of the Cannery project) will spew more than 37,000 metric tons of carbon emission every year from the traffic it generates, according to the EIR, a net increase of 8% in Davis’ existing carbon footprint.

The project will generate 24,000 additional car trips daily, and the EIR (Appendix F, p. 123) says that at 14 intersections traffic will deteriorate to Level F. This does not take full account of the cumulative traffic impacts produced by the building of the many many thousands of units completed, under construction and approved in the last few years.

Moreover, the developers are in no way committed to mitigating in any way the inevitable traffic deadlock.

Furthermore, the EIR notes that DISC will create a minimum need for 3,760 housing units to accommodate the jobs generated. But it will only provide 850 units, and 83% of them will be at high-end market rates.

Finally, this development, even on its own terms, will not provide the revenues to offset the city’s serious fiscal deficit, quite to the contrary. The city’s Finance and Budget Commission was deeply skeptical of the developers’ claims, three doubted that there would be a net fiscal profit, and one even called the fiscal projections a “fairy tale.” This does not even take into account the major infrastructural spending by the city necessary to try and mitigate the environmental impacts.

What’s not to abhor? Please vote No on B.

Dan Cornford
Davis

DISC for me represents a 20+ year commitment to going down the wrong road.  It represents a reversal of fundamental tenets that have shaped Davis for the better.

DISC is sprawl plain and simple. It circumvents every good planning principle that Davis has stood for. It places retail, office and dense housing on the periphery while destroying 200 acres of farmland. It is the antithesis of what we should be doing in the era of global warming as DISC depends on car commuters and makes a joke of the City’s mandate of carbon neutrality by 2040.

Furthermore, DISC will destabilize existing businesses and compromise our ability to fill existing vacancies. Even before Covid, DISC was a poor plan for a community that values a strong downtown. But, Covid on top of DISC boggles the mind.  The SEIR states that cannibalism from DISC will cause sustained commercial vacancies of up to 313,000 sq. ft.

The good news is that we have an alternative option that would take us down the right road.

We have enough land in Davis to serve our commercial needs. In 2019, the city’s justification for converting 3820 Chiles Rd. from commercial to residential reads “the existing current inventory of vacant land for 0ffice and R&D/Flex uses will meet demand for the next 43 to 69 years”.  We also have a Downtown Plan that is full steam ahead and calls for intensifying residential and commercial in the core. Joe Minicozzi, hosted by Cool Davis in March, was unequivocal that investing in the ground Davis already has, that has existing services and infrastructure, is the best path to economic stability and revitalization.

I want to add that Colin Walsh, candidate for City Council District 2, is the one council candidate who has studied every aspect of DISC and has taken a lead role against the project. In Colin you will find a candidate who will make the tough decisions to do what is right, and not what is politically expedient.  He has the resolve and commitment to go down a better road.

Pam Gunnell
Davis

(From press release) The Developer's promises of economic benefits from DISC want you to believe all you have to do is vote "YES" on Measure B and the City's potholes will be miraculously filled with the gold nuggets tumbling from the DISC bandwagon.

But the DISC project will not be an economic bonanza and may even cost the City money over the long term. This is because extremely optimistic projections of property taxes from the project will probably never materialize.

And with no fiscal guarantees, the Developer will be the only one hauling away wheelbarrels of money!

(From press release)

Our world is burning up and melting around us. This year we have seen the largest fires ever in the Pacific Northwest, Siberia, the Amazon, and Australia along with record-breaking ice-melts in Greenland and Antarctica.

Yet DISC will increase Davis' annual carbon footprint by over 8% - over 83 million pounds per year!...What are they thinking?

Friday, October 2           Davis, CA

 What is Measure B and the DISC Industrial Park 

Measure B is on the November 3 ballot in Davis asking to annex 200 acres of Prime farmland into the City and pave it over to build a sprawling car-centric industrial center and 850 housing units.

This land-use dinosaur would be located on the northeast corner of 2nd St and Mace Blvd just across the street from Ikeda's Market.      

Read more      

___________________________________________            

 DISC will be an Environmental Disaster 

• The Developer claims the project will be carbon neutral. But according to the project's Environmental Impact Report, "...net emissions in the year 2035 would equal 37,724.31 metric tons of CO2 equivalent per year, the project would NOT meet the City’s target of net carbon neutrality by the year 2040." This is unacceptable!
  
  
• There is no way the vast bulk of the project's carbon emissions can be reduced on-site. Instead the Developer will rely on purchase of cheap off-site carbon credits or mitigation elsewhere in the City to supposedly become carbon neutral. But this does nothing to actually reduce the City's total carbon emissions. This is deceitful!
  
  
• The Developer falsely claims if DISC isn't built in Davis, it will just be built elsewhere with more greenhouse gas emissions. But all new commercial buildings anywhere in California must meet ever-increasing energy efficiency standards. This is misleading!
  
  
• The Developer claims the project's jobs will be "Green" jobs. But because almost 80% of the greenhouse gases generated from DISC come from the projected 24,000+ daily car trips, DISC would actually have a smaller carbon footprint if built in other locations with superior public transportation access and much shorter commutes for workers. Commuter jobs are NOT "Green"!

The more we hear about DISC, the more it is clear that Davis will get all of the adverse environmental impacts and the Developers will get all of the profits. It's time to just say "NO"!

___________________________________________  

Sierra Club Endorses No on Measure B - No on DISC

____________________________________

For more information, order a lawn sign, or make a donation -  www.VoteNoOnDISC.com

(From press release)

Citing grounds of “excessive traffic, greenhouse gas emissions, and poor land-use and planning”, the Sierra Club announces its opposition to Measure B in Davis CA on the November 2020 municipal ballot.

Measure B is a vote to allow the annexation of approximately 200-acres of Prime farmland on the northeast periphery of the City and the development of a business park along with a 850-unit housing development. The project site is now farmed and serves as foraging habitat for numerous Special Status Species including Burrowing Owls, Swainson’s Hawks, and White-Tailed Kites.

The endorsement of the opposition to this ballot measure follows an extensive evaluation process by the local Sierra Club Yolano Group, the Sierra Club Mother Lode Chapter Political and Executive Committees, and the Sierra Club California Local Measure Review Committee.

The Sierra Club has long-standing official policies designed to minimize urban sprawl onto farmland and habitat and maximize intensive infill development. These include planning policies that further conservation of open space and preservation of natural areas and agricultural lands. The Sierra Club opposes sprawl as a pattern of increasingly inefficient and wasteful land use with devastating environmental and social outcomes.

The following email was sent to the City Council on late Tuesday evening and is reprinted here with the permission of the author.

Hello Mayor Partida, Council Members Lee, Frerichs, Carson, and Arnold, City Manager Webb and Assistant City Manager Feeney,

My comment to the City Council regarding Pacifico didn't make it through tonight. Nevertheless, I briefly want to remind all of you of the situation in our South Davis neighborhood.

The acts of crime and intimidation are continuous and not getting better. In fact, random hostile acts of intimidation have increased in number and the act of crime itself has increased in severity.

The most recent incidents that have compromise safety and well-being include:

• attempted rape
• prostitution in the parking lot
• theft and intimidation to Pacifico residents by Pacifico residents
• loitering combined with heavy consumption of alcohol on the bike path and near homes
• drug deals and coercion in the parking lot
• bb rifle shooting on the green belt by a known violent and dangerous criminal who frequents Pacifico
• a dumpster fire that was suffocating and threatened my family and home.

Those who currently have their safety and well being compromised due to the Use at Pacifico include:

• my family and visiting family and friends
• neighbors, families, and friends in homes (Oakshade West Neighborhood Association and beyond)
• neighbors, families, and students in apartments/duplexes (Octave and Sharp and Flats, Avalon, Brisa)
• neighbors and Pacifico residents, including disadvantaged women, children and elders - some of our most vulnerable.

These dangers affect everyone in this neighborhood. Many horrible things have happened and continue to happen.

I respectfully request that a plan for Pacifico be of top priority and the subject be put on the long range calendar. Thank you.

Gratefully yours,

Tracy De Wit

Community input to the Council majority of Partida, Lee and Carson is needed now

By Eileen M. Samitz

Many thanks to the Davis religious leaders for the excellent article published August 22 in the Davisite.

This incredible and sincere outreach by so many local religious leaders to the City Council majority is impressive and their recommended action is so needed to be taken by Council majority now.  So everyone’s input to the Council is needed now, to support the recommendation to reconsider approval of the University Commons project, before this Tuesday’s August 25^th meeting when the Council is scheduled to finalize approval of the project.

The Davis religious leaders group recommendation for the Council majority is to “take a pause and reconsider their approval votes” and to reject it. This terrible project does not offer any housing that is affordable. So, urging the Council to reconsider its approval is clearly the right thing to do for the sake of the UCD students, as well as the rest of the community needing housing that is affordable. The University Commons “affordable units” are affordable in name only, and it is an insult to even classify them as “affordable” with the rental prices they are projecting.