Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 1 of 17 EXHIBIT B

Transcription

1 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 1 of 17 EXHIBIT B

2 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 2 of 17

3 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 3 of 17 TABLE OF CONTENTS I. Objective... 4 II. Responsibility... 4 A. Introduction... 4 B. Alta Ski Area Responsibility... 4 C. Forest Service Responsibility... 4 D. Public Responsibility... 5 E. Vicinity and Area... 5 F. Designated Representative and Liaison... 5 G. Rehabilitation Act of 1973 and A.D.A III. Lift Operations... 7 A. General... 7 B. Chairlifts... 7 C. Surface Tows... 7 D. Maintenance Log... 7 E. Operational Log... 7 F. Lift Operator Training... 7 G. Lift Maintenance Training... 7 H. Lift Evacuation Plan... 7 I. Signs... 8 IV. Ski Patrol... 8 A. Ski Patrol Qualifications... 8 B. Ski Patrol Staffing Levels... 8 C. Ski Patrol Training Program... 8 D. Explosives Magazine Security... 8 E. Patrol Duties F. Opening and Closing Procedures G. First Aid and Rescue Readiness V. Avalanche Control A. Avalanche Control Plans B. Forest Service Responsibility C. Alta Ski Area Responsibility VI. Lodge and Base Facilities A. Buildings B. Employee Courtesy C. Food Handling D. Snow Removal VII. Parking Lot and Related Areas A. Supervision B. Snow Removal C. General VIII. Hill Management A. Signs B. Uphill and Downhill Travel C. Machine Worked Slopes D. Skier Control E. Revocation, Removal and No-Trespass

4 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 4 of 17 IX. Accident Reporting Procedures and Documents X. Alta Ski Area Litter Program A. Education B. Prevention C. Clean-up XI. Nordic Skiing XII. Snowcat Skiing XIII. Commercial Filming XIV. Demo Ski Centers XV. Plans Listed

5 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 5 of 17 I. Objective The objective of this plan is to provide for use of all recreation facilities in the Alta Ski Area (pursuant to the Forest Service special use permit) with minimal risk for employees and the public. II. Responsibility A. Introduction This plan is prepared as required by the Special Use Permit, Clause III c. This plan need not be revised/rewritten annually. Revisions may be made at any time with the concurrence of the Forest Supervisor. The Avalanche Control Plan, Ski Patrol Manual, Lift Evacuation Plan, Search and Rescue Plan and other functional area plans or manuals will be kept current and contained in the master file with this Site Operation Plan in the Alta Ski Area Administrative office. These plans and all other plans mentioned in this Site Operating Plan are subject to Forest Service review and approval. B. Alta Ski Area Responsibility Alta is responsible for the execution of all provisions of this plan and all subordinate plans. A list of subordinate plans is included in this plan. C. Forest Service Responsibility The authorized officer for the ski area permit is the Forest Supervisor. The Forest Supervisor has the authority to suspend ski area operations as necessary to protect public health and safety or the environment (36CFR (f). The Forest Supervisor may delegate responsibilities for routine daily monitoring and day-to-day administration of the ski area to the District Ranger. The Winter Sports Administrator/Specialist (Snow Ranger) is the District Ranger s representative. During the ski season, the Forest Service will provide a Snow Ranger who will periodically monitor all aspects of Ski Area s operation. The Snow Ranger s duties shall be: 1. To monitor the Special Use Permit area and facilities for compliance with the permit terms including this operating plan and its subordinate plans. 2. To provide guidance, as needed, in public safety, rescue work, and avalanche control work. 3. To work as liaison officer between the public and Alta Ski Area and between Alta Ski Area and the Forest Service in matters concerning safety and service. 4. To identify and potentially suspend operations of ski runs or facilities located on the Uinta-Wasatch-Cache National Forest land as necessary to protect public health and safety or the environment. Ski Area management will be consulted, if practical, before any suspension orders are given. The District Ranger may give suspension orders orally. Written confirmation will be forwarded as soon as possible. 4

6 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 6 of To procure military weapons and ammunition, coordinate and facilitate the military weapons used for avalanche control program, and monitor the permit holder s compliance with the acceptable standards and regulations in conducting the program. D. Public Responsibility This plan recognizes that the public user of Alta Ski Area must assume a high degree of personal responsibility for his/her own safety and the safety of others and that the user is the third party in reducing risk at Alta Ski Area. The Inherent Risk Statute, Utah Code 78B-4-402, recognizes that certain risks are an integral part of skiing. These risks include changes in weather conditions; variation or steepness in terrain; snow or ice conditions; surface or sub-surface conditions such as bare spots, forest growth, rocks and stumps; impact with lift towers and other structures and their components; collisions with other skiers; and an individual s failure to ski within his/her own ability. Salt Lake County Ordinance , et al gives authority to Salt Lake county ski areas to close certain areas because of undue avalanche or terrain hazards. It also defines skier responsibilities and liabilities in the event of collision involving two or more skiers. The ordinance requires the skiers involved to render assistance and to present identification to ski area personnel or to the other skiers involved. E. Vicinity and Area The plan covers National Forest lands in all or portions of Sections 4, 5, 8, and 9; Township 3 south, and Range 3 east as specifically described in Exhibit D of the Alta Ski Area s Special Use Permit. F. Designated Representative and Liaison 1. Forest Service: David Whittekiend, the Wasatch-Cache-Uinta Forest Supervisor is the Authorized Officer. Cathy Kahlow, Salt Lake District Ranger is his designated representative for liaison with Alta Ski Area in all activities relating to the administration of the permit, planning and ski area safety. Steve Scheid and Polly Popola, Salt Lake Ranger District Winter Sports Specialists, are her representatives. 2. Alta Ski Area: Onno Wieringa is the President and General Manager of Alta Ski Area and is the designated representative for liaison with the Forest Service in all activities relating to the administration of the permit, planning and ski area safety. Gus Gilman, Ski Patrol Director, and Titus Case, Snow Safety Director, are the designated on-the-ground contacts representing Alta Ski Area. Ski Area Contacts: Name Work # Mobile # President/G.M. Onno Wieringa Ski Patrol Director Gus Gilman Snow Safety Director Titus Case Lifts Manager Van Edgette Grooming Manager Al Tunbridge

7 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 7 of Forest Service Personnel and Emergency Contact Procedure The following will be included in the ski area Operating Plan and posted at Mountain Operations and/or Ski Patrol Headquarters with dispatch. It outlines emergency contact of Forest Service. a. Emergency Contact of Forest Service Forest Service Contacts: Name Work # Mobile # Winter Sports Admin. Steve Scheid Winter Sports Specialist Polly Popola District Ranger Cathy Kahlow Forest Supervisor David Whittekiend District LEO Brandon Robinson b. Forest Service incident notification requirements: 1. Incident Notification. The holder shall be required to contact the authorized officer as soon as practicable after the following incidents that occur on National Forest System (NFS) lands within the authorized area: a. Any incident resulting in death, permanent disability, or personal injuries that are life-threatening or that are likely to cause permanent disability; b. Any failure of a structural, mechanical, electrical component and its primary connection, or operator error, which impairs the operation or function of a passenger ropeway in a way that could affect public safety, or any ropeway incident that requires reporting to State authorities; c. A search and rescue operation to locate a person; d. Any incident that had or has high potential for serious personal injury, significant property damage, or significant environmental or other natural resource damage, including but not limited to avalanches, landslides, flooding, fire, structural failures or release of hazardous substances. 2. Method of Notification. The authorized officer shall determine protocol for how the notification must be made. Notification may be tailored to the unique characteristics of the permitted operation. 3. Contents of Notification. When notifying the authorized officer of an incident, the holder shall be required to specify when, where, and how it occurred, and who was present or affected by the event. G. Rehabilitation Act of 1973 and A.D.A. Alta Ski Area has in the past and will in the future, monitor it s facilities and programs to be in compliance with the Americans with Disabilities Act and the Rehabilitation Act of

8 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 8 of 17 III. Lift Operations A. General All Alta Ski Area lifts lie entirely on National Forest Land and will be maintained and operated in accordance with the American National Standards for passenger tramways, aerial tramways and lifts, surface lifts, and tows safety requirements (ANSI B77.1), Utah State Division of Industrial Safety, the Utah Aerial Passenger Tramway Safety Orders, and the Alta Ski Area Winter Sports Site Operating Plan. Lifts will be properly inspected and have a current operating permit prior to public operation. B. Chairlifts Collins Sunnyside Cecret Wildcat Albion Sugarloaf Supreme Rustler (by contract) C. Surface Tows Transfer Rope Tow Big Grizzly Handle Tow Alta Lodge Rope Tow Little Grizzly Conveyor D. Maintenance Log Alta Ski Area will maintain an up-to-date maintenance log in accordance with the current ANSI B77.1 and lift designers recommendation. E. Operational Log Alta Ski Area will maintain daily lift operation log for each lift. Logs will be completed by the operators assigned to each lift. The logs will be turned in to the lift supervisors on a daily basis. Logs will be filed in the Alta Ski Area s administrative office. F. Lift Operator Training Training will be in compliance with current ANSI B77.1. See , , G. Lift Maintenance Training Lift maintenance personnel will be trained in the maintenance of each lift in accordance with the individual manufacturer s specifications book and the current ANSI B77.1 guidelines. Any specialized training will be done by qualified personnel. H. Lift Evacuation Plan The Lift Evacuation plan is part of the Ski Patrol Manual with copies in the ski patrol office, lift operators office, and lift maintenance office. Employees involved in lift evacuation will be properly trained. The ski patrol director and the lift maintenance supervisor or their designee(s) will be responsible for the Lift Evacuation Plan and shall supervise any actual evacuation. 7

9 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 9 of 17 I. Signs All lift signs will be in accordance with the current ANSI B77.1 Standards. The lift supervisor(s) will be responsible for inspection. Signs will be placed, as deemed appropriate, to give information to the public. IV. Ski Patrol A. Ski Patrol Qualifications 1.) Alta Ski Area will provide a ski patrol organization that meets or exceeds the minimum requirements of the National Ski Patrol System. 2.) All patrollers doing first-aid will possess a valid first aid card (American Red Cross Emergency Response Aid, Winter Emergency Care or Emergency Medical Technician.) A copy of all cards will be kept in the ski patrol offices. B. Ski Patrol Staffing Levels 1.) All patrollers will be under the direction of the Alta Ski Area patrol director or designee. 2.) The ski patrol director or designee will frequently monitor daily patrol work and will not be assigned to a daily workstation. 3.) Lift served areas: Specific stationing of each patroller on duty will be directed by the ski patrol director or designee, the Ski Patrol Manual, and this Alta Ski Area Winter Sports Site Operating Plan. When open to the public, a minimum of two radio-equipped pro-patrollers will be on duty in each of the two primary lift served areas (Collins Gulch and Albion Basin), unless an emergency elsewhere necessitates transferring the patrollers. Copies of the Ski Patrol Manual will be filed in the ski patrol office and in the Alta Ski Area administrative office. 4.) Copies of the ski patrol schedules and patrolling pattern shall be furnished to the Forest Service upon request. C. Ski Patrol Training Program Training will be under the direction of the ski patrol leaders or designee. Specialized training in avalanche control, explosives handling, and first aid will be monitored by the ski patrol leaders or designee. Specialized training in military weapons will be conducted by or under the supervision of the Snow Ranger or designee. D. Explosives Magazine Security 1.) To the extent possible, explosives magazines storage facilities located on National Forest System (NFS) lands will be consolidated, or moved to alternate sites. The Forest Service will be notified in advance of any proposed changes in location or consolidations. 2.) The Forest Service authorized officer will be notified after an inspection of 8

10 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 10 of 17 explosives magazines has taken place by an authorized State agency representative, or the U.S. Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF). 3.) An up-to-date record for each explosives magazine located on NFS lands will be maintained that includes the following information: a) Name and location. b) Type (1-5). c) Name and day and evening telephone numbers of an emergency contact. d) Name and day and evening telephone numbers of a custodian. e) Quantity and type of explosives generally stored. f) Type of military weapon (where applicable). g) Quantity and type of munitions generally stored (where applicable). h) Special security features, such as alarm systems (where applicable). 4.) As required Federal regulations (27 CFR ), each magazine will be inspected at least every seven days. This inspection will be sufficient to determine whether there has been unauthorized entry, or attempted entry, into the magazine, or unauthorized removal of the contents of the magazine. 5.) The loss or theft of any explosives material will be reported to the ATF, local authorities, and the Forest Service within 24 hours of discovery. 6.) A current inventory of explosives will be maintained to ensure prompt detection of discrepancies between the physical inventory and the record inventory as required at 27 CFR and This will include the following: a) Annual report listing all the explosives stored within the permit area b) Daily summary of transactions for each magazine used to store explosives c) Documentation of the total quantity of explosives place in and removed from each magazine during a 24-hour permit and the total amount of explosives remaining at the end of that period. 7.) A policy governing key control and security for magazines has been developed and includes the following provisions: a) An inventory to be maintained of all personnel who have been issued magazine keys and ensures that only those resort staff 9

11 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 11 of 17 who have been authorized to possess explosive material are issued keys. b) Ensure that locks on magazines will be changed immediately if damaged, or if the keys are unaccounted for or stolen. In addition, unregistered locks will be changed at least every year. 8.) As required by the Safe Explosives Act of 2002 and ATF permits issued under the Act, the ski area will request that ATF conduct background checks on all employees authorized to possess explosives. Authorized employees may possess explosives until ATF provides notification otherwise. 9.) All explosives that have deteriorated to the extent they are unstable or dangerous will be removed and destroyed in accordance with manufacturer's instructions (29 CFR (c)(5)(v)). 10.) Explosives magazines and the area surrounding them will be maintained according to the following: a) Magazines will be kept clean, dry, and free of grit, paper, rubbish, and empty packages and containers. b) Except for live trees more than 10 feet tall and vegetation established to stabilize the earthen covering of a magazine, the area within 25 feet of magazines will be clear of all rubbish, brush, dry grass, and small trees. c) No volatile materials, such as paints, solvents, etc., will be kept within 50 feet of magazines (27 CFR ) 11.) Signs will be posted on the outside of buildings which serve as Class I or Class II magazines reading as follows: "Explosives - Keep Off" (29 CFR (c)(2)(iii). E. Patrol Duties Ski patroller s duties will be outlined in the Ski Patrol Manual filed in the Alta Ski Area s administrative office. F. Opening and Closing Procedures The opening and closing procedures and trail closing procedures will be outlined in the Ski Patrol Manual. G. First Aid and Rescue Readiness First Aid and Search and Rescue Plans will be part of the Ski Patrol Manual and will be filed in the ski patrol office, and the Alta Ski Area s administrative office. 10

12 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 12 of 17 V. Avalanche Control A. Avalanche Control Plans The Avalanche Control Plan and Avalauncher Firing Procedure will be filed in the avalanche control office or in the Alta Ski Area s administrative office. B. Forest Service Responsibility The Forest Service will provide general avalanche control monitoring and guidance and will provide military ordinance to be used in the avalanche control program. C. Alta Ski Area Responsibility 1.) Alta Ski Area will provide all supervision, personnel, and equipment and will make decisions concerning necessary and proper control measures and will forecast avalanche potential for Alta Ski Area. 2.) All avalanche control action will be supervised by the Snow Safety Director, or his designee. 3.) Alta Ski Area will carry out all phases of the avalanche control program for the Alta Ski Area, including bearing costs of the program. VI. Lodge and Base Facilities A. Buildings 1.) All Alta Ski Area owned buildings on National Forest Land will meet local building codes and state and county health codes and will be inspected by the appropriate agency or agencies. 2.) All buildings on National Forest land will meet Town of Alta or Salt Lake County fire regulations. 3.) All fire exits will be clearly marked with signs and kept open and clear. 4.) Flammable liquids stored in public buildings must be stored in accordance with the Town of Alta fire regulations. 5.) Trash and litter will be hauled to approved sites on a regular basis. 6.) Icicles and cornices will be routinely removed from the roof areas. If this is not possible, an appropriate area will be roped off to reduce public risk. 7.) Walks, ramps, and stairs will be kept as clear of snow and ice as reasonably as possible, and lighted as necessary. 8.) All building exits will be marked with exit signs. 9.) Good housekeeping practices will be maintained in all buildings including: 11

13 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 13 of 17 a. Lodges and eating areas b. Lift shacks and terminals c. Restrooms d. Shops and vehicles 10.) All electric circuit breaker panels will be free and clear of obstructions. B. Employee Courtesy All employees are trained to be friendly and professionally courteous. Employees will receive training in customer service as well as training in their specific job duties. C. Food Handling 1.) The food services at Alta are operated by Alta Ski Area and concessionaires contingent upon Forest Service approval of sublease agreements. Signed concessionaire agreements will be on file in the Alta Ski Area s administrative office. 2.) Food services will operate in compliance with all city, state, county and federal requirements. 3.) Alta Ski Area will monitor the food service operations. D. Snow Removal Alta Ski Area and/or it s concessionaire will be responsible for snow removal from roofs, stairs, porches, and walkways of all Alta Ski Area owned base facilities. VII. Parking Lot and Related Areas A. Supervision 1.) Parking lot personnel will be instructed in basic parking lot traffic control and parking pattern procedures. 2.) The parking lot adjacent to the main office will be maintained to allow adequate ingress and egress to and from the Alta Medical Clinic. B. Snow Removal Snow will be removed, as conditions permit, from all active parking lots to allow adequate egress and ingress. C. General 1.) Parking lot attendants will monitor parking lots. They will report any suspected problems to Alta Ski Area s management. 2.) All gates and posts in vehicle areas will be marked with reflective tape where appropriate. 12

14 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 14 of 17 VIII. Hill Management A. Signs Alta Ski Area will follow the suggested sign placement outlined in the current ANSI B77.1 code and the suggested sign placement outlined in the Ski Patrol Manual. All boundary warning signs are to meet the requirements specified in the Wasatch-Cache National Forest Boundary Policy. Copies of the current ANSI B77.1 code and the Ski Patrol Manual are filed in the Alta Ski Area s administrative office. B. Uphill and Downhill Travel To promote safety of employees and persons on the mountain and to avoid interference with operations, uphill and downhill travel must be accepted and approved by Alta Ski Area C. Groomed Slopes Alta Ski Area uses over the snow vehicles to groom slopes, with emphasis given to the novice, intermediate and instructional areas. Equipment operators will be trained and supervised by the vehicle operations supervisor or his designee. Copies of the daily grooming worksheet will be filed in the vehicle maintenance office. D. Skier Control Skier control includes but is not limited to the following: 1.) Lift lines will be controlled to minimize risk to skiers in line and to skiers skiing in the vicinity. 2.) The ski patrol will attempt to encourage skiers to ski responsibly and to discourage excessive speed or other behavior creating a hazard to other skiers or themselves. 3.) Alta Ski Area may revoke a skier s privileges without compensation and/or call the Alta Town Marshall or Salt Lake County Sheriff either of whom may subject the skier to arrest for violation of skier responsibility codes, State of Utah codes, or any violation of the law. 4.) Alta Ski Area reserves the right to exclude any type of skiing device that they deem creates an unnecessary risk to other skiers and/or the user of the device, or any device they deem causes undue damages to the quality of the snow, or is not consistent with their business management decisions. E. Revocation, Removal and No-Trespass Alta Ski Area, without remuneration to a skier or person, may revoke a skier s pass or ticket, remove a skier or person from the Special Use Permit area and no- 13

15 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 15 of 17 trespass them for any of the following acts and behaviors: 1.) Violations of local, state or federal laws, ordinances or regulations. 2.) Threats of violence or communications or actions likely to incite imminent violence or other imminent lawless behavior in others. 3.) Use of lifts without a valid lift ticket or pass. 4.) Unauthorized resale or purchase of any lift pass or ticket or any other fraudulent use or alteration of any lift pass or ticket. 5.) Providing unauthorized ski instruction. 6.) Actions likely to cause harm to self or others such as violation of closed areas, reckless or hazardous behavior in lift lines, on the lifts or on the slopes, including but not limited to reckless jumping, out-of-control skiing, excessive speed for conditions, and unauthorized construction of jumps or obstacles. 7.) Sledding, tubing or snowshoeing in unauthorized areas. 8.) Unauthorized use of snowmobiles or other over-the-snow vehicles. 9.) Unauthorized removal, destruction, defacing or relocation of any signs, barricades, rope lines, cones, or other warning or marking devices. 10.) Reckless or hazardous behavior on lifts that may endanger self or others or that may cause damage to the equipment such as jumping from a lift; swinging chairs, rope tows or handle tows that is deliberate and excessive; climbing towers; or interfering with the operation of equipment. 11.) Interfering with mountain operations or avalanche mitigation work, including but not limited to failing to respect avalanche closures or posted hazards. 12.) Unauthorized overnight parking or camping. 13.) Unauthorized use of equipment or downhill devices. 14.) Uphill or downhill travel that is not approved by Alta Ski Area. IX. Accident Reporting Procedures and Documentation A. Alta Ski Area has a formal accident reporting plan which is part of the Ski Patrol Manual. Copies are filed in the Alta Ski Area s administrative office. B. The Forest Service will be notified immediately of all deaths. The Winter Sports Specialist and Ski Patrol Director shall communicate regularly about accidents on the mountain. All accident reports will be available to the Forest Service. 14

16 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 16 of 17 X. Alta Ski Area Litter Program Alta Ski Area will maintain and improve it s program of litter prevention and clean-up. Components of the effort will include: A. Education 1). Alta Ski Area will continue using signs in the ski area reminding visitors to keep their National Forest clean. Season pass holder hand-outs will emphasize the same message. Hopefully, the Forest Service will use the Public Information programs for the same purpose. B. Prevention and Containment C. Clean-up 1.) Alta Ski Area will continue to purchase, distribute, and maintain garbage and recycling cans throughout the area. 2.) The spent-round containment fence at the Peruvian Ridge Rifle site will continue to be kept up and emptied as conditions warrant. 1.) Alta Ski Area will work with the Town of Alta on the annual Canyon Clean- Up Day. 2.) A primary function of Alta Ski Area parkers will be picking up litter as it is generated. 3.) Litter pick-up is a budgeted activity for summer crews. 4.) Alta Ski Area will continue distributing signs that encourage summer hikers to collect litter and take it to the nearest road for pick-up by Alta crews. XI. Nordic Skiing Alta Ski Area will groom and offer a 3k Nordic track originating at the Wildcat Base/Alta Ski Shop and winding around both sides of the base to base tow. During occasional periods of high pressure we will experiment with a loop starting at the top of Sunnyside Lift. XII. Snowcat Skiing Alta Ski Area will be offering snowcat skiing, primarily on private property in the Grizzly Gulch area, with the tours being booked by the Ski School and meeting at the Albion Day Lodge. XIII. Commercial Filming Filming at Alta will continue as per the Forest Service policy and Onno Wieringa will serve as the contact person and can be contacted at

17 Case 2:14-cv DB Document 25-2 Filed 03/31/14 Page 17 of 17 XIV. Demo Ski Center As an extension to the Alta Ski Shop located in the Wildcat Ticket office, there will be one portable 10 x12 building moved into Alf s mid-mountain restaurant to serve as ski demo, waxing and accessory sales areas. The building will be moved in and out on the snow to comply with Town of Alta building requirements. XV. Plans Listed The following documents and plans are subject to Forest Service review and approval and are at the Alta Ski Area s administrative office. Avalanche Control Plan Avalauncher Firing Procedure Ski Patrol Manual (Which includes Lift Evacuation, First Aid, Signs, and Search and Rescue plans.) Daily Grooming Worksheet Daily Lift Operation Log Boundary Policy No Discrimination Harassment Policy Commercial Filming Policy 16