6. INTRODUCTION OF AN ORDINANCE TO ADOPT THE 2025 CALIFORNIA BUILDING CODE AND RELATED CALIFORNIA CODES FOR CONSTRUCTION ALONG WITH LOCAL AMENDMENTS AND SETTING A PUBLIC HEARING FOR DEC. 2, 2025 (MCA 2025-0001) – 1) Introduction of an ordinance amending Carlsbad Municipal Code Chapters 18.03 – General Provisions, 18.04 – Building Code, 18.08 – Historical Building Code, 18.09 – Existing Building Code, 18.10 – Mechanical Code, 18.12 – Electrical Code, 18.16 – Plumbing Code, 18.18 – Solar Energy Code, 18.19 – Dangerous Building Code, 18.20 – Residential Code, 18.21 – Green Building Standards Code and 18.30 – Energy Conservation Regulations; and 2) Set a public hearing for Dec. 2, 2025, to consider adoption of the ordinance. (Staff contact: Mike Strong, Community Services)

[6. INTRODUCTION OF AN ORDINANCE TO ADOPT THE 2025 CALIFORNIA BUILDING CODE AND RELATED CALIFORNIA CODES FOR CONSTRUCTION ALONG WITH LOCAL AMENDMENTS AND SETTING A PUBLIC HEARING FOR DEC. 2, 2025 (MCA 2025-0001) – 1) Introduction of an ordinance amending Carlsbad Municipal Code Chapters 18.03 – General Provisions, 18.04 – Building Code, 18.08 – Historical Building Code, 18.09 – Existing Building Code, 18.10 – Mechanical Code, 18.12 – Electrical Code, 18.16 – Plumbing Code, 18.18 – Solar Energy Code, 18.19 – Dangerous Building Code, 18.20 – Residential Code, 18.21 – Green Building Standards Code and 18.30 – Energy Conservation Regulations; and 2) Set a public hearing for Dec. 2, 2025, to consider adoption of the ordinance. (Staff contact: Mike Strong, Community Services)]

ITEM NUMBER 5 IS ORDINANCES FOR INTRODUCTION.

CITY MANAGER. THANK YOU, ITEM NUMBER 6 IS AN INTRODUCTION OF AN ORDINANCE TO ADOPT THE 2025 CALIFORNIA BUILDING CODE AND RELATED CALIFORNIA CODES FOR CONSTRUCTION, ALONG WITH LOCAL AMENDMENTS AND SETTING A PUBLIC HEARING FOR DECEMBER 2ND.

FOR THE BRIEFING OR, EXCUSE ME, PRESENTATION IS ASSISTANT DIRECTOR OF COMMUNITY DEVELOPMENT, MIKE STRONG. THANK YOU. AND GOOD EVENING, MAYOR AND COUNCIL MEMBERS.

FOR THE RECORD, MIKE STRONG, ASSISTANT DIRECTOR OF COMMUNITY DEVELOPMENT. EVERY THREE YEARS, THE CALIFORNIA BUILDING STANDARDS COMMISSION ADOPTS THE RESIDENTIAL CODE, BUILDING CODE, ENERGY CODE, MECHANICAL, PLUMBING, ELECTRICAL, EXISTING BUILDING CODES.

THERE'S ABOUT 13 DIFFERENT PARTS OF WHAT'S COLLECTIVELY KNOWN AS THE CALIFORNIA BUILDING STANDARDS CODE.

I'LL REFER TO THAT IN THE PRESENTATION AS THE STATE MODEL CODES FOR SIMPLICITY.

AND THOSE ARE CODIFIED IN TITLE 24 OF THE CALIFORNIA CODE OF REGULATIONS.

THE LOCAL AGENCIES IN THE STATE OF CALIFORNIA MAY ADOPT BY ORDINANCE AND INCLUDE BY REFERENCE THE CALIFORNIA BUILDING STANDARDS CODE OR STATE MODEL CODE BY REFERENCE IN THEIR LOCAL ORDINANCES.

EVEN IF AN AGENCY DOES NOT ADOPT THE STATE BUILDING CODES BY REFERENCE, IT IS EFFECTIVE THROUGHOUT THE STATE OF CALIFORNIA BY DEFAULT.

THE DETAILS OF THE REQUEST IS TO ADOPT THE ORDINANCE, SO IT WOULD HAVE AN EFFECTIVE DATE OF JANUARY 1ST, 2026, WHICH ALIGNS WITH THE EFFECTIVE DATE OF THE NEW 2025 EDITION OF THE CALIFORNIA BUILDING STANDARDS CODE.

THERE ARE SOME LOCAL AMENDMENTS THAT ARE BEING CARRIED FORWARD.

THE CITY COUNCIL ADOPTED IN NOVEMBER OF 2022 A COMPREHENSIVE UPDATE TO TITLE 18 OF THE CARLSBAD MUNICIPAL CODE, THAT IS THE CALIFORNIA BUILDING STANDARDS CODE.

COLLECTIVELY ADOPTING ALL OF THE PARTS OF THE MODEL CODES.

SO THERE ALREADY HAS BEEN AN EXTENSIVE EFFORT BY THE CITY TO MAKE SURE THAT THE STATE MODEL CODES ARE APPLICABLE TO CARLSBAD IN SUCH A WAY THAT IT ADDRESSES OUR LOCAL NEEDS.

SO THIS PROPOSAL DOES NOT CHANGE EXISTING POLICY.

[00:20:03]

IT IS JUST MAKING UPDATED SECTION REFERENCES OR MAKING CONSISTENCY CHANGES TO ALIGN WITH THE UPDATED STATE MODEL CODES.

THERE ARE PROPOSED CHANGES IN TRACK CHANGE FORMAT AND ONE OF THE EXHIBITS OF THE STAFF REPORT.

ON JUNE 30TH, 2025, GOVERNOR NEWSOM ADOPTED TWO TRAILER BUDGET BILLS, ASSEMBLY BILL 130 AND SENATE BILL 131, WHICH SIGNIFICANTLY REFORMED HOUSING AND LAND USE LAWS IN THE STATE OF CALIFORNIA.

ONE COMPONENT OF THOSE BILLS IMPACTED THIS PROCESS TO ADOPT AND MODIFY BUILDING STANDARD CODES AND EFFECTIVELY PUT A SIX YEAR FREEZE ON BUILDING CODES, WHICH PROVIDES STABILITY FOR DEVELOPERS.

THERE ARE SOME EXCEPTIONS TO PROPOSED PROVIDING MODIFICATIONS TO BUILDING STANDARD CODE.

READOPTING THE ENABLING ORDINANCES FROM THE 2020 2022 EDITION THAT ARE SUBSTANTIALLY SIMILAR TO THAT PRIOR ORDINANCE IS ONE OF THE EXCEPTIONS.

SO WHAT IS BEING PROVIDED TO YOU IN THE AGENDA PACKET FULLY MEETS THE INTENT OF AB 130 AND SB 131.

BEYOND THAT, PRIOR TO AB 130 AND SB 3131 LOCAL AGENCIES COULD PROPOSE MODIFICATIONS TO THE BUILDING STANDARDS PROVIDED THAT THEY ADDRESSED CLIMATE, GEOLOGIC OR TOPOGRAPHICAL CONDITIONS, EVEN IF THE CITY IS TO READOPT THE SAME BATCH OF AMENDMENTS THAT WERE ADOPTED IN 2022. THE CITY COUNCIL WOULD STILL NEED TO ADOPT THE SAME FINDINGS AND SUBMIT THOSE TO THE STATE.

SO THERE IS AN EXPANSIVE LIST AS INCLUDED AS AN ATTACHMENT TO THE ORDINANCE.

THAT IS THE REQUISITE FINDINGS TO ADOPT AND MODIFY THE BUILDING STANDARDS CODE.

EVEN THOUGH THE CITY COUNCIL HAD ALREADY PREVIOUSLY ADOPTED THEM.

THERE ARE SOME CHANGES IN STATE LAW. SO THIS IS NOT WHAT THE CITY OF CARLSBAD IS PROPOSING AND ITS LOCAL ORDINANCE.

THIS IS SOMETHING THAT THE STATE MODEL CODES ARE IDENTIFYING.

AND IT'S HELPFUL TO GO THROUGH THIS BECAUSE THERE ARE GOING TO BE FUNDAMENTAL CHANGES TO THE DEVELOPMENT COMMUNITY. ONE IS NEW HEAT PUMP TECHNOLOGY, NEW STANDARDS THAT ENCOURAGE THE USE OF HIGH EFFICIENT ELECTRIC HEAT PUMPS FOR SPACE AND WATER HEATING AND NEWLY CONSTRUCTED BUILDINGS.

THIS SHIFT SUPPORTS CALIFORNIA'S GOAL OF REDUCING THE RELIANCE ON NATURAL GAS AND PROMOTING ELECTRICAL ELECTRIFICATION.

NEW COMMERCIAL KITCHEN SPACES MUST BE BUILT TO BE ELECTRIC READY, FACILITATING FUTURE ELECTRIFICATION.

FOR UPDATED MANDATES TO SOLAR PHOTOVOLTAIC SYSTEMS AND ON-SITE BATTERY TO BE INTRODUCED FOR HIGH RISE RESIDENTIAL AND NONRESIDENTIAL PROJECTS.

THIS AIMS TO STRENGTHEN CALIFORNIA GRID RESILIENCY.

THERE ARE SOME CHANGES FOR ADA COMPLIANCE. THIS WILL PRIMARILY AFFECT COMMERCIAL FACILITIES AND MULTIFAMILY RESIDENTIAL, WHEN IN PARTICULAR IS THAT THERE'S A NEW SECTION CLARIFYING THAT THE CLEAR FLOOR SPACE AT DINING SURFACES SHALL NOT OVERLAP WITH ACCESSIBLE ROUTES, SO THAT MIGHT ACTUALLY IMPACT THE NUMBER OF SEATING CONFIGURATIONS WITHIN EXISTING BUSINESSES.

THERE ARE ADJUSTED GROUND MOTION VALUES AND AMPLIFICATION LEVELS FOR SOILS ANALYSIS THAT WILL INCREASE THE DESIGN FORCES FOR NEW CONSTRUCTION.

SO THAT'S ANOTHER COMPONENT THAT WILL ADDRESS SEISMIC RISK.

AND LASTLY IS THE BICYCLE REQUIREMENTS FOR RESIDENTIAL AND NONRESIDENTIAL.

PREVIOUSLY, VOLUNTARY MEASURES IN THE GREEN BUILDING STANDARDS CODE ARE NOW MANDATORY FOR RESIDENTIAL CONSTRUCTION, AND THE NUMBER OF SHORT-TERM BICYCLE PARKING IN NEW COMMERCIAL DEVELOPMENT IS INCREASING DRAMATICALLY.

THERE'S ALSO A SIGNIFICANT CHANGE WITH THE ELECTRICAL VEHICLE CHARGING AND COMMERCIAL STRUCTURE PRIMARILY REQUIRING ELECTRIC VEHICLE CHARGING STATIONS AND OFFICE AND RETAIL, AND IN OTHER NONRESIDENTIAL USES. AND IT INCREASES THE REQUIREMENT UP TO 50% AND 75%, RESPECTIVELY. THE OTHER CHANGE IN THE GREEN BUILDING STANDARDS CODE RELATED TO EV CAPABLE INFRASTRUCTURE IS THAT THE AMENDED PROVISIONS IN STATE LAW REQUIRE THAT ALL EXISTING EV CAPABLE SPACES IN CONDUIT SITE MUST BE BUILT OUT BEFORE ANY NEW EV CAPABLE SPACES ARE ADDED. SO THERE ARE ADDITIONAL COSTS THAT ARE BEING ADDED TO NEW DEVELOPMENT.

SO ONE THING THAT THE COMMUNITY DEVELOPMENT DEPARTMENT IS DOING IS PROMOTING AWARENESS AND ENCOURAGING APPLICATIONS TO BE RECEIVED PRIOR TO THE EFFECTIVE DATE OF THE NEW STATE MODEL CODES. WHAT THAT MEANS IS THAT ANY APPLICATION THAT'S RECEIVED FOR A BUILDING PERMIT REVIEW NEEDS TO BE FILED BEFORE JANUARY 1ST, 2026, TO BE REVIEWED UNDER THE 2022 EDITION OF THE BUILDING CODE.

ANY APPLICATION RECEIVED AFTER THAT DATE WOULD BE SUBJECT TO THE NEW STATE MODEL CODES.

[00:25:01]

THAT CONCLUDES STAFF'S PRESENTATION, AND I'M AVAILABLE TO ANSWER ANY QUESTIONS.

THANK YOU. DO WE HAVE SPEAKERS? YES, WE HAVE ONE.

PATRICIA LANGAN. PATRICIA, I DIDN'T GIVE THE EXPLANATION AT THE BEGINNING, BUT I'LL JUST TELL YOU NOW.

YOU GET THREE MINUTES TO SPEAK. AT THE END OF THE THREE MINUTES, I'VE ASKED THE CLERK TO TURN OFF THE MICROPHONE. AND AT THE 2.5 MINUTE MARK TO GIVE YOU A NOTICE THAT YOU'RE DOWN TO 30S LEFT, THE ORANGE LIGHT WILL COME ON THE PODIUM, SO PLEASE GO AHEAD.

THANK YOU, MAYOR AND COUNCIL MEMBERS, FOR CONSIDERING MY COMMENTS ON BEHALF OF BUENA VISTA AUDUBON SOCIETY, A 1500 MEMBER HOUSEHOLD ORGANIZATION. I'M REQUESTING THAT THE COUNCIL ALSO ADOPT THE CALIFORNIA GREEN BUILDING STANDARDS CODES.

BIRD FRIENDLY BUILDING DESIGN AMENDMENT A5.107, A VOLUNTARY STANDARD WHICH INCLUDES LIGHT POLLUTION REDUCTION, BIRD FRIENDLY GLAZING AND BUILDING DESIGN GUIDELINES.

NOW I KNOW, I WASN'T, I WAS UNAWARE UNTIL JUST NOW ABOUT AB 130.

BUT THERE IT DOES RELATE TO CLIMATE. AND IF YOU CAN JUST GIVE ME A MOMENT TO EXPLAIN.

SO BEFORE THAT THE NEED FOR ACTION IS URGENT.

BIRDS ARE THE CANARY IN THE ENVIRONMENTAL COAL MINE.

RECENT RESEARCH HAS FOUND THAT BIRD POPULATIONS IN NORTH AMERICA HAVE DECLINED BY MORE THAN 3 BILLION BIRDS OVER THE LAST 50 YEARS.

IT'S HUGE AND UNSUSTAINABLE. SAN DIEGO COUNTY IS ON THE PACIFIC FLYWAY, A MAJOR MIGRATION ROUTE FOR BIRDS.

OVER 100,000 BIRDS MIGRATE ON A GIVEN DAY THROUGH SAN DIEGO COUNTY IN SPRING AND FALL.

BUILDING COLLISION IS A MAJOR CAUSE OF BIRD MORTALITY, AS REPORTED BY THE U.S.

FISH AND WILDLIFE SERVICE. EVERY YEAR, UP TO 1 BILLION BIRDS, 1 BILLION FATALLY COLLIDE WITH GLASS IN THE UNITED STATES.

THE MAJORITY OF COLLISIONS OCCUR DURING THE DAY, WHEN BIRDS CAN SEE THE LANDSCAPE REFLECTIONS IN THE GLASS SO THEY DON'T GET THE CONTEXT CLUES OF A WINDOW, THEY JUST SEE THE REFLECTION AS WHAT'S REAL.

OR BIRDS SEE THROUGH GLASS TO PERCEIVED HABITATS.

THE CITY HAS ALREADY CONSIDERED ADOPTING CALIFORNIA BUILDING CODES, SO IT MAKES SENSE TO INCLUDE THESE BIRD FRIENDLY DESIGN STANDARDS AS WELL.

SO HERE'S WHERE THE EXCEPTION TO AB 130 COMES IN.

IN ADDITION TO SAVING BIRDS, MANY OF THESE DESIGNS ALSO SAVE ENERGY BY REDUCING HEAT GAINS, HEAT GAIN, AND MINIMIZING LIGHTING COSTS. IT'S GOOD PUBLICITY TO BE A BIRD FRIENDLY COMMUNITY.

SAN DIEGO IS A PREMIER BIRD WATCHING DESTINATION AND HOSTS A MAJOR BIRD FESTIVAL EVERY FEBRUARY.

AND THE GOOD NEWS IS THAT WE HAVE THE KNOWLEDGE AND ABILITY TO REDUCE BIRD COLLISIONS, AND EACH OF YOU HAS THE ABILITY TO MAKE A DIFFERENCE IN THIS.

THE EFFORT IS UNDERWAY. OCEANSIDE HAS ALREADY INCLUDED IT IN THE OLIVE APARTMENT, OLIVE PARK APARTMENTS, EIR, AND THESE STANDARDS WILL BE INCLUDED IN THE NEW NCTD OFFICE BUILDING IN OCEANSIDE.

AS WAS MENTIONED EARLIER, CARLSBAD SHOULD LEAD BY EXAMPLE TO PROTECT AND PRESERVE THE ENVIRONMENT, JUST LIKE FOR RECYCLING. WITH NUMEROUS HIGH DENSITY PROJECTS ON THE HORIZON, IT IS CRITICAL TO ADOPT BIRD FRIENDLY BUILDING DESIGN STANDARDS NOW.

PLEASE INCLUDE AMENDMENT A5.107 IN THIS ORDINANCE, AND I CAN PROVIDE MORE INFORMATION IF YOU WOULD LIKE.

THANK YOU. THANK YOU. QUESTIONS FROM COUNCIL.

MISS ACOSTA, THANK YOU. THANKS SO MUCH FOR THE PRESENTATION.

I DON'T KNOW. I DON'T WANT TO PUT YOU ON THE SPOT, BUT DO YOU KNOW, AND DID STAFF RESEARCH THIS? THE BIRD FRIENDLY TOPIC THAT WAS PRESENTED BY THE PUBLIC SPEAKER? I BELIEVE THE PUBLIC SPEAKER MADE A COMMENT ON A LAND USE DEVELOPMENT APPLICATION EARLIER THIS YEAR THAT WAS PRESENTED TO THE CITY COUNCIL.

SO I'M AWARE OF THE CONCEPT. STAFF HAD NOT BEEN PRESENTED A REQUEST AS PART OF THE PUBLICATION OF THE STAFF REPORT, SO IT WAS NOT ANALYZED PRIOR TO THIS EVENING FOR INCLUSION IN THIS AGENDA PACKET.

THE MEASURE THAT IS REFERRED TO IN CHAPTER A5 OF THE GREEN BUILDING STANDARD CODE IS A SET OF VOLUNTARY MEASURES THAT HAVE BEEN PROMULGATED BY THE STATE TO IDENTIFY OPPORTUNITIES FOR CITIES TO GO BEYOND THE MANDATE TO GO BEYOND.

AND IN SOME CASES, THE REACH CODES ARE A GOOD EXAMPLE OF SOMETHING GOING BEYOND WHAT'S MINIMALLY REQUIRED AS A STANDARD FOR ENERGY EFFICIENCY OR CLIMATE ACTION PLANNING. THIS IS ONE OF THOSE MEASURES THAT FALLS WITHIN TO THOSE VOLUNTARY CATEGORIES.

SO IF THE CITY COUNCIL WAS INTERESTED IN REVIEWING OR CONSIDERING THAT, IT WOULD HAVE TO BE LIKELY EVALUATED AND RETURNED AS A SEPARATE AGENDA ITEM, AND WE CAN EVALUATE WHETHER OR NOT IT MEETS THE ELIGIBILITY CRITERIA FOR UNDER THE AB 130 FOR BUILDING STANDARDS MODIFICATIONS.

THANK YOU. I WAS JUST ABOUT TO ASK A FOLLOW UP QUESTION OF WHETHER WE BELIEVED THAT THAT WOULD BE AFFECTED BY AB 130,

[00:30:02]

BUT I SUPPOSE WE CAN WE CAN TAKE A LOOK AT THAT LATER.

THANK YOU. ANY OTHER QUESTIONS OR COMMENTS? MOTION.

PLEASE MOVE INTRODUCTION OF THE ORDINANCE AND SET THE PUBLIC HEARING FOR DECEMBER 2ND, 2025.

SECOND. PLEASE VOTE. PASSES UNANIMOUSLY. THANK YOU.

[7. INTRODUCTION OF ORDINANCES TO ADOPT THE 2025 CALIFORNIA FIRE CODE AND CALIFORNIA WILDLAND-URBAN INTERFACE CODE, ALONG WITH AMENDMENTS AND SETTING A PUBLIC HEARING FOR DEC. 2, 2025 – 1) Introduction of an ordinance repealing the existing Carlsbad Municipal Code Chapter 17.04 (Fire Prevention Code) and adopting a new Chapter 17.04 (Fire Prevention Code) based on the 2025 edition of the California Fire Code; and 2) Introduction of an ordinance adopting a new Carlsbad Municipal Code Chapter 17.06 (WildlandUrban Interface Code) based on the 2025 edition of the California Wildland-Urban Interface Code; and 3) Set a public hearing for Dec. 2, 2025, to consider adoption of the ordinances. (Staff contact: Darcy Davidson, Fire)]

ITEM NUMBER 7 CITY MANAGER. THANK YOU. ITEM NUMBER 7 IS THE INTRODUCTION OF ORDINANCES TO ADOPT THE 2025 CALIFORNIA FIRE CODE AND CALIFORNIA WILDLAND URBAN INTERFACE CODE, ALONG WITH AMENDMENTS AND SETTING A PUBLIC HEARING FOR DECEMBER 2ND, 2025. FOR THE PRESENTATION WE HAVE FIRE DIVISION CHIEF DARCY DAVIDSON.

CHIEF. GOOD EVENING, MAYOR, MAYOR PRO TEM AND MEMBERS OF CITY COUNCIL.

I'M DARCY DAVIDSON, AS MENTIONED, FIRE CHIEF, DIVISION CHIEF, FIRE MARSHAL.

TONIGHT I AM INTRODUCING TWO ORDINANCES. ONE IS TO ADOPT THE UPDATED CALIFORNIA FIRE CODE WITH LOCAL AMENDMENTS, AND THE OTHER IS TO ADOPT THE WILDLAND URBAN INTERFACE CODE WITH LOCAL AMENDMENTS.

THIS IS THE STATE'S FIRST PUBLICATION OF THIS SECOND DOCUMENT.

SOME OF THIS IS GOING TO BE A REPEAT, SO I WILL GO THROUGH IT VERY QUICKLY.

AS NOTED PREVIOUSLY, EVERY THREE YEARS, THE BUILDING STANDARDS COMMISSION UPDATES THE STATE'S MODEL BUILDING CODES WITH LOCAL JURISDICTIONS ENFORCED TO PROTECT HEALTH AND PUBLIC SAFETY. THE COMMISSION HAS RELEASED THE 2025 SET OF BUILDING CODES, WHICH BECOME EFFECTIVE JANUARY 1ST, 2026. LOCAL JURISDICTIONS ARE REQUIRED TO ENFORCE STATE ADOPTED CODES AS THE MINIMUM BUILDING STANDARDS FOR CONSTRUCTION.

EVERY CITY IN THE COUNTY, EVERY CITY AND COUNTY IN THE STATE CAN EITHER ACCEPT THE MODEL CODES AS WRITTEN, OR CAN ADD AMENDMENTS TO ADOPT THEIR OWN VERSIONS, PROVIDING CERTAIN CONDITIONS ARE MET.

THE FIRST CONDITION IS THAT STATE LAW ALLOWS LOCAL AMENDMENTS TO THE STATE CODE, WHEN THE FINDINGS CAN BE MADE, THAT THESE CHANGES ARE NECESSARY DUE TO ADDRESS LOCALLY UNIQUE TOPOGRAPHICAL, GEOGRAPHIC, OR CLIMACTIC CONDITIONS. THESE CAN ALL BE LISTED CAN BE FOUND LISTED IN ATTACHMENT A, AND SECOND, STATE LAW AUTHORIZES THE LOCAL FIRE PROTECTION AGENCIES TO ADOPT A BUILDING STANDARDS THAT ARE MORE STRINGENT TO THOSE ADOPTED BY THE STATE FIRE MARSHAL.

AMENDMENTS CANNOT BE LESS RESTRICTIVE, AND THEN JURISDICTIONS ARE REQUIRED TO ADOPT THE LOCAL AMENDMENTS BY ORDINANCE TO BE ENFORCEABLE.

AS PREVIOUSLY MENTIONED, THERE IS A NEW STATE LAW, AB 130, THAT AFFECTS RESIDENTIAL UNITS THAT PUT A MORATORIUM ON ENACTING CODES THAT AFFECT RESIDENTIAL UNITS EFFECTIVE OCTOBER 1ST, 2025 THROUGH JUNE 1ST, 2031.

WE DID CONSIDER THIS LEGISLATIVE REQUIREMENT DURING OUR PROCESS AND WE ARE IN FULL COMPLIANCE.