Fred Banham Hi Karen. To begin I wish to thank you for meeting with

Fred Banham
From:
Sent:
To:
Subject:
Attachments:
Karen Goodings <[email protected]>
Saturday, October 20, 2012 9:30 AM
Fred Banham
FW: Follow up from May 24th meeting with the Ministry of Energy and Mines, and the OGC
Pipeline Abandonment Question.docx; OIL AND GAS TRIBUNAL MEMBERS.docx;
Cumulative Impacts fact sheet.pdf; Setbacks Summary Document.docx
Importance:
High
I believe this was forwarded to you in July. This was an important step in having the communication that we felt, as a
board, was important. Probably didn’t rank very high or maybe not even on the strategic plan. Will you please put this on
the next agenda for follow-up. thanks
From: Nash, Laurel MEM:EX [mailto:[email protected]]
Sent: Wednesday, July 11, 2012 10:32 AM
To: '[email protected]'
Cc: Trachsel, Daymon MEM:EX; Jonsson, Corey OGC:IN
Subject: Follow up from May 24th meeting with the Ministry of Energy and Mines, and the OGC
Importance: High
Hi Karen. To begin I wish to thank you for meeting with Corey and I on May 24, 2012 to discuss community
engagement in northeast British Columbia. We very much appreciated the discussion and look forward to
quarterly meetings. Below I have outlined our understanding of the questions raised at the meeting and a
response.
Question: Can you clarify who is on the Surface Rights Board?
Answer: New Board members will be identified in July. The current members are:
Name
Cheryl Vickers
Robert Fraser
Simmi Sandhu
William Oppen
Viggo Pedersen
Valliammai Chettiar
Position
Chair
Vice Chair
Member
Member
Member
Member
Start date
Expiry
July 22, 2007 Dec. 31, 2013
July 22, 2007 July 31, 2012
July 22, 2007 July 31, 2014
Dec. 8, 2008 Dec. 31, 2013
March 5, 2009 July 31, 2013
June 22, 2012 July 31, 2014
Question: Can you provide more information on pipeline decommissioning and removal of pipelines from
title?
Answer: First attachment provides information on this question.
Question: Who are the members of the Oil and Gas Appeals Tribunal (OGAT) and how are they
chosen? Can there be a landowner rep?
Answer: The Oil and Gas Appeal Tribunal is an independent quasi-judicial agency that was
established under Section 19 of the Oil and Gas Activities Act. The Tribunal hears appeals from
decisions of the Oil and Gas Commission which include certain orders, declarations, findings of
1
contravention, administrative penalties and permitting decisions in relation to an oil and gas activity
such as geophysical exploration, the construction or operation of a pipeline, road construction, and
the production, gathering, processing, storage or disposal of petroleum, natural gas or both. The
Tribunal consists of a shared full-time chair, part-time vice-chair(s) and part-time members. The
Tribunal is jointly administered with the Forest Appeals Commission and the Environmental Appeal
Board in order to take advantage of synergy and keep costs to a minimum. These three agencies are
supported by an administrative office with 11 full-time staff. Members are appointed by the
Lieutenant Governor through Order-in-Council. The membership of the Tribunal is drawn from across
the Province and represents diverse business, legal and technical experience. Members of the
Tribunal are also appointed to the Forest Appeals Commission and the Environmental Appeal
Board. Cabinet appoints the vice-chair(s) and all part-time members for a specified term. The vicechair(s) and all other members serve on a part-time basis. These appointees are not employees of the
public service. The second attachment is a list of OGAT members
Question: Can you provide more information on the fiduciary duty the Crown has with respect to
disclosure/confidentiality of First Nation financial arrangements, and whether agreements with First Nations
address the issue of property rights separately from the rights of private owners?
Answer: I have invited Roger Graham, Chief Negotiator, Northern Regional Negotiations Team, from the
Ministry of Aboriginal Relations and Reconciliation, to our next meeting to address this issue.
Question: Can you provide any information on cumulative impacts?
Answer: The BC Ministry of Forests, Lands and Natural Resource Operations and the Ministry of
Environment are jointly leading a project to explore the development of a Cumulative Effects Assessment
Framework to support natural resource decision-making in BC. The third attachment provides more
information about this new project.
Question: Can you provide a bit more information on Health impacts?
Answer: Phase 1 of the Fraser Basin Council report was released on June 6, 2012. I expect you are in
possession of this, but if not, please let me know and I would be happy to provide it to you. The Province is
now issued the Request For Applications for Phase 2 of the Study, led by the Ministry of Health. The
Ministry expects that the Phase 2 work to begin in September, 2012, so new information will only be
available once Phase Two has been concluded.
Question: Can you provide scientific information on hydraulic fracturing?
Answer: The FracFocus Chemical Disclosure Registry can be found at http://fracfocus.ca/ . This website is
a project of the BC Oil & Gas Commission and is intended to provide objective information on hydraulic
fracturing, fracturing fluids, groundwater and surface water protection and related oil and gas activities in
Canada. The Oil and Gas Commission will follow up with you regarding the dates when they will hold
public presentations in Fort St. John about water and hydraulic fracturing.
Question: Will the Ministry of Energy and Mines be a part of Regional Workforce Tables once this once
the process has unfolded further?
Answer: The Oil and Gas Commission will participate. The Ministry of Energy and Mines will report
out and follow up as required.
2
Question: Will the Ministry be licensing land agents? There is a need to licence agents due to questionable
behaviour of some. Code of conduct and penalties are needed.
Answer: The Ministry is currently exploring a suitable licensing model for land agents in B.C. Ministry
staff met with the Canadian Association of Petroleum Landmen in May 2012, and the next meeting is scheduled
for July.
Question: Where is the Province on the issue of setbacks?
Answer: The fourth attachment provides a summary of where the Province is on setbacks with respect to
the Oil and gas Activities Act, relevant regulations, and the Environmental Protection and Management Guide.
Question: Can BC reserve some blocks (of land) from disposition?
Answer: The request for Petroleum and Natural Gas subsurface rights is industry driven. The Ministry’s
referral process allows the statutory decision maker to make an informed decision about how or if we can
dispose of the subsurface rights. Industry makes a request for subsurface rights to our Crown Sales and GIS
group within the Petroleum and Natural Gas Titles Branch (Branch). The request goes through an internal
review process to ascertain whether the rights are available or not. If we believe that the rights can be made
available we move towards the referral process. Referral packages are distributed to local government, First
Nations and provincial agencies. All referral groups are requested to comment within a 27 day timeline. If
more time is required the Branch is willing to consider the request. We have a number of different
examples in the province where we do not sell subsurface tenure, however, please let me know what the
concerns are that motivate for such a reserve? If surface disturbance is the concern then there are a number
of different things that could occur to reduce the surface disturbance in a particular area.
Question: Can BC improve the maps when you do referrals?
Answer: We are working to improve the maps and look forward to working with you to ensure we capture
the key elements desired on the maps.
Next Steps:
I hope the foregoing information answers the questions posed by you and your Council. Please let me know
if any if you have other questions or if any of the material requires clarification.
Finally, to follow up on the commitment for quarterly meetings with the PRRD, please let me know some
potential dates for our next session, and any topics you wish to discuss.
Respectfully,
Laurel Nash
Executive Lead
Titles and Corporate Relations Division
Ministry of Energy and Mines
(t) 250 356-9569 (c) 250 508 1670
3
From: Karen Goodings [mailto:[email protected]]
Sent: Thursday, June 14, 2012 8:26 PM
To: Trachsel, Daymon MEM:EX
Subject: RE: May 24th meeting in Dawson Creek.
You are most welcome. Thank you for coming and the commitment to bring back the answers.
From: Trachsel, Daymon MEM:EX [mailto:[email protected]]
Sent: Thursday, June 14, 2012 10:09 AM
To: '[email protected]'
Cc: Nash, Laurel MEM:EX
Subject: May 24th meeting in Dawson Creek.
Good morning Director Goodings.
I would like to thank you for the opportunity to meet with you and the PRRD Council on May 24, 2012. We had a great discussion
about our community engagement efforts, and we appreciate the thoughtful comments and feedback received.
Councillors and Directors had a number of questions for us during the meeting. We are presently gathering information and
answers to those questions, and will be providing these to you in the next while.
It was a pleasure to meet with you, and we look forward to continuing dialogue.
Regards,
Daymon Trachsel
Manager, Corporate Policy and Planning
Corporate Policy, Planning and Legislation Branch
Ministry of Energy and Mines
Ph. (250) 953-3730
Cell: (250) 589-0042
Fax: 952-0637
4
PIPELINE ABANDONMENT
The BC Oil and Gas Commission (Commission) cannot require a company to abandon
a pipeline unless it is a risk to public or environmental safety, in which case the OGC
may potentially issue an order to abandon the line. As long as the pipeline is
deactivated according to regulation and the required maintenance and monitoring is
maintained the pipeline could remain deactivated indefinitely.
When a pipeline is permanently removed from service, it is considered abandoned. A
pipeline can be abandoned in place if it is properly deactivated, cut and capped below
grade and has identification markers.
In order to abandon the pipeline an amendment application must be made to the
Commission and requires Consultation/Notification. As part of that application to the
Commission, the operator is required to allow the landowner upon whose land the
pipeline is situated the opportunity to request removal of the easement from title. Prior
to processing the application to amend the pipeline for purposes of abandonment on
private land the OGC requires written proof that the landowner was given this
opportunity and that the company has requested the removal from the Land Titles Office
if this was the resolution agreed to by the landowner.
The pipeline must remain registered with BC One Call and the operator remains liable
for the environmental impacts of the pipeline remaining in the ground.
The following sections from the Pipeline & Liquefied Natural Gas Facility Regulation that
are now in effect under OGAA that apply to pipeline deactivation and abandonment.
Deactivation
9 If a pipeline permit holder has not transported fluids through the holder's permitted
pipeline or part of a pipeline for 18 consecutive months, the pipeline permit holder
must
(a) submit a plan for resuming the transportation of fluids through the
pipeline, or
(b) deactivate the pipeline or part of the pipeline in accordance with
CSA Z662 and notify the commission on completion of the deactivation.
Reactivation
10 (1) A pipeline permit holder of a deactivated pipeline system may reactivate the
pipeline, but must do so in accordance with CSA Z662.
(2) Before reactivating a pipeline, the pipeline permit holder must
(a) notify the commission of the intention to carry out the reactivation,
and
(b) if the permit or a permission in a permit relating to the deactivated pipeline has been
suspended, request that the suspension be rescinded.
Obligations on cancellation or cessation of operations
11 The following requirements are prescribed with respect to a pipeline permit and an
LNG facility permit for the purposes of section 40 (e) of the Act:
(a) abandon the pipeline in accordance with CSA Z662;
(b) do everything referred to in section 19 (1) (a) to (g) of the Environmental Protection
and Management Regulation.
Regarding BC One Call - Here is the section from the Pipeline and Liquefied
Natural Gas Facility Regulation that applies:
Integrity management and damage prevention programs
7 (1) A pipeline permit holder must not operate a pipeline approved by the permit unless
(a) the holder has prepared a pipeline integrity management program for
the pipeline that complies with CSA Z662 and Annex N of CSA Z662,
(b) the holder has prepared a damage prevention program for the
purpose of anticipating and preventing damage to the permit holder's pipeline,
(c) the pipeline is operated in accordance with the pipeline integrity management
program and the damage prevention program,
(d) the holder is a member of BC One Call.
This regulation stipulates that a pipeline operator can’t operate pipelines regulated by
the Commission unless they are a member of BC One Call. It is the responsibility of the
pipeline operator to ensure the location of their underground facilities is accurately
identified and any changes or updates are forwarded to BC One Call.
OIL AND GAS TRIBUNAL MEMBERS
Following is a listing of current membership:
Alan Andison (Chair)
R. O’Brian Blackall
Carol Brown
Robert Cameron
Monica Danon-Schaffer
Cindy Derkaz
W.J. Bruce Devitt
Tony Fogarassy
Les Gyug
James Hackett
R.G. (Bob) Holtby
Jagdeep S. Khun-Khun
Gabriella Lang
Blair Lockhart
Ken Long
James Mattison
David Searle (Vice Chair)
Douglas VanDine
Reid White
Robert Wickett
Loreen Williams
Lawyer
Land Surveyor
Lawyer/CGA/Mediator
Professional Engineer
Professional Engineer
Lawyer (Retired)
Professional Forester (Retired)
Geoscientist/Lawyer
Professional Biologist
Professional Forester
Professional Agrologist
Lawyer
Lawyer (Retired)
Lawyer/Geoscientist
Professional Agrologist
Professional Engineer
Lawyer (Retired)
Professional Engineer
Professional Engineer/
Professional Biologist (Retired)
Lawyer
Lawyer/Mediator
Victoria
Charlie Lake
Sooke
North Vancouver
West Vancouver
Salmon Arm
Victoria
Vancouver
Westbank
Nanaimo
Westbank
Vancouver
Campbell River
Vancouver
Prince George
Victoria
North Saanich
Victoria
Telkwa
Vancouver
West Vancouver
Cumulative Effects Assessment
Exploring a Framework for British Columbia
What are cumulative effects?
Cumulative effects are changes to environmental,
social, and economic values caused by the
combined effect of present, past, and reasonably
foreseeable future actions or events on the
land base.
Why is British Columbia considering a Cumulative
Effects Assessment Framework?
British Columbia’s land base provides a wealth of
economic and social benefits. As both the number
and diversity of land and resource activities
increase, it is important to effectively manage
multiple demands on natural resource systems to
sustain these benefits.
Sustainable management of natural resource
systems requires an understanding of the historical
context of land use, as well as current and
foreseeable future demands. A cumulative effects
assessment framework can help to maximize the
economic and social benefits while improving
environmental outcomes.
BC_CEAMF_Fact Sheet_20120502
How is the framework being developed?
The BC Ministry of Forests, Lands and Natural
Resource Operations and the Ministry of
Environment are jointly leading a project to explore
the development of a Cumulative Effects
Assessment Framework to support natural resource
decision-making in BC. Guidance from all natural
resource agencies is provided through an
interagency steering committee and project
management team.
Three demonstration projects have been initiated
to provide ‘learning labs’ for the development of a
framework and testing of tools to support
cumulative effects assessment. The West
Okanagan-Nicola and North-West demonstration
projects were initiated in 2011, and a NorthEast project has been initiated in Spring 2012.
What is a
Framework?
Cumulative
Effects
Assessment
The proposed framework brings consistency to the
assessment and monitoring of a commonly defined
set of values. The framework will provide more
effective and consistent information to support
decision-making but will not make decisions. The
key elements envisioned for the framework are:
Values
A common set of area-specific
environmental, social and economic
values and associated information to
support natural resource decisionmaking.
Assessment
A consistent approach to assessing
cumulative effects in natural resource
decision-making with the rigour of
assessment scaled proportional to risk.
Decision
Support
Consistent tools for summarizing
assessment results, with consideration
to risks and trade-offs across values.
Monitoring
An integrated monitoring framework
to track and report the condition and
trend of identified values over space
and time.
How will First Nations and Stakeholders be
involved in the development of the framework?
First Nations and key stakeholders identified within
the demonstration project areas have been invited
to participate in a first phase of engagement on the
vision for a cumulative effects framework.
A summary of input received during Phase 1
engagement will be made available to Natural
Resource staff and interested parties.
For more information, please contact us at:
[email protected]
A Joint Project with BC Ministry of Environment and BC Ministry of Forests, Lands and Natural Resource Operations
Setbacks Summary Document
1. Environmental Protection and Management Guide
Section 4 - Wildlife and Wildlife Habitat
Wildlife Habitat Features
Suggested Setbacks
Suggested operating setbacks have been developed to help minimize the impacts to some
important wildlife habitat features and are identified later in this section. Where minimum
construction setbacks are infeasible, applicants may deviate from this Guidebook by submitting
a rationale for infringing on the setbacks and where appropriate, a mitigation strategy with the
application.
Note that in some instances additional setbacks may be required due to lack of topographical
relief, sparse vegetation density, extensive use of habitat, and other special considerations.
The following are the minimum expected construction setbacks for commonly encountered
habitat features:
Trumpeter Swan Nest – 200 meters
Other nesting sites (for example, osprey stick nest, sandhill crane ground nests) – 100
meters
Mineral licks – 100 meters
Bear dens (applies to winter construction only) – 50 meters
In cases where it is not possible to maintain, or where it makes ecological and operational sense
to narrow, these setbacks the applicant should submit a deviation request to the Commission
as part of the application.
2. Environmental Protection and Management Regulation
Part 2 - Permit Considerations and Directions
Division 1 – Government’s Environmental Objectives
Water
4 The following objectives with respect to water quality, quantity and timing of flow are
prescribed for the purposes of the definition of "government's environmental objectives" in
section 1 (2) of the Act:
(a) that wellsites, facility areas and pipeline corridors not be located within
(i) 100 m of where water is diverted by a waterworks or stored in a water
storage reservoir, or
(ii) 100 m of where water is diverted by a water supply well or the ground water
capture zone for the water supply well, whichever is greater,
unless
(iii) any adverse affects on the waterworks, water supply well, water storage
reservoir or ground water capture zone can be effectively mitigated, or
(iv) the person proposing to locate the operating area is the holder of the
authorization for the waterworks, water supply well or water storage reservoir;
(b) that operating areas not be located
(i) within an identified ground water recharge area,
(ii) within a designated watershed, or
(iii) on top of an identified aquifer
unless the operating area will not have a material adverse effect on the quality and
quantity of water and the natural timing of water flow.
Riparian values
5 The following objectives with respect to riparian values are prescribed for the purposes of the
definition of "government's environmental objectives" in section 1 (2) of the Act:
(a) that operating areas not be located within any of the following:
(i) a stream, except to facilitate the crossing of the stream;
(ii) a lake, except to facilitate
(A) the crossing of the lake, or
(B) geophysical exploration on lakes that are frozen to the bottom;
(iii) a wetland with a riparian class of W2, except to facilitate the crossing of the
wetland;
(iv) an enclosed upland within a wetland, unless
(A) the wetland has a riparian class of W1 or W3,
(B) the enclosed upland is greater than 5 ha, and
(C) it is not practicable to locate the operating area elsewhere;
(v) a riparian reserve zone except to facilitate a crossing of the applicable stream,
wetland or lake;
(vi) except to facilitate a crossing, a riparian management zone, unless an
operating area will not have a material adverse effect on the ability of the
riparian management zone to
(A) conserve the fish habitat, wildlife habitat, biodiversity and the water
values of the riparian management zone, and
(B) protect the riparian reserve zone, if any, and
(b) that sufficient streamside trees and understory vegetation be retained to prevent
the temperature of a temperature sensitive stream from increasing or decreasing to an
extent that would have a material adverse impact on the fish in the stream.
Part 4 – Classification, Identification and Establishment
Division 1 – Riparian Classification
Stream riparian classes
22 (4) Subject to subsection (5), for each riparian class of stream, the minimum riparian
management area width, riparian reserve zone width and riparian management zone width, on
each side of the stream, are as follows:
Item
Riparian Class
1
2
3
4
5
6
7
S1-A
S1-B
S2
S3
S4
S5
S6
Riparian Management
Riparian Reserve
Riparian Management
Area (metres)
100
70
50
40
30
30
20
Zone (metres)
50
50
30
20
0
0
0
Zone (metres)
50
20
20
20
30
30
20
Wetland riparian classes
23 (2) For each riparian class of wetland, the minimum riparian management area width,
riparian reserve zone width and riparian management zone width for the wetland are as
follows:
Item
Riparian Class
1
2
3
W1
W2
W3
Riparian Management
Riparian Reserve
Riparian Management
Area (metres)
50
30
0
Zone (metres)
10
10
0
Zone (metres)
40
20
0
Lake riparian classes
24 (2) For each riparian class of lake, the minimum riparian management area width, riparian
reserve zone width and riparian management zone width are as follows:
Item
Riparian Class
1
2
3
L1-A
L1-B
L2
Riparian Management
Riparian Reserve
Riparian Management
Area (metres)
70
40
30
Zone (metres)
50
20
10
Zone (metres)
20
20
20
4
5
L3
L4
30
30
0
0
30
30
3. Drilling and Production Regulation
Part 3 — Well Position, Spacing and Target Areas
Position of wells
5
(1) If a well or facility is
(a) closer than 100 m to the natural boundary of a water body, or
(b) 100 m or more from the natural boundary of a water body, but situated so
that, given the topography or other relevant factors, it is likely that an
uncontrolled flow of oil, gas, brine or another fluid may reach the water body,
the permit holder must ensure surface-control features are in place, or surface-control
measures have been taken, to contain escaping fluids.
(2) A permit holder must not drill a well within
(a) 40 m of the right of way or easement of any road allowance or public utility,
(b) 100 m of a permanent building, installation or works,
(c) 100 m of a place of public concourse, or
(d) 100 m of a reservation for national defence.
Part 7 — Safety, Security and Pollution Prevention
Fire Prevention
47
A permit holder must ensure all of the following:
(c) flares and incinerators are located at least 80 m from any public road, public utility,
building, installation, works, place of public concourse or reservation for national
defence;
Position of tanks and production equipment
48
A permit holder must ensure that any petroleum storage tanks and production
equipment for a well or facility for which the permit holder is responsible are located
not less than 60 m from any right of way, easement, road allowance, public utility,
building, installation, works, place of public concourse or reservation for national
defence.
4. OGAA General Regulations
Part 1 – Miscellaneous
Pipeline crossing distances
11
(1) In this section, “ground activity” means any work, operation or activity that results in
a disturbance of the earth, including a mining activity as defined in section 1 of the
Mines Act, but not including
(a) cultivation to a depth of less than 45 cm below the surface of the ground,
and
(b) a disturbance, other than cultivation referred to in paragraph (a), of the earth
to a depth of less than 30 cm.
(2) A ground activity is a prescribed activity for the purposes of section 76(1)(b) of the
Act.
(3) The following distances are prescribed for the purposes of section 76(1) of the Act:
(a) 40 m, for any activity other than the prescribed activity referred to in
subsection (2);
(b) 40 m, for the prescribed activity referred to in subsection (2)
5. Geophysical Exploration Regulation
Geophysical exploration near pipeline, utility, residence, etc.
4
(1) Subject to subsections (2) and (3), if a geophysical permit holder conducts
geophysical exploration in the vicinity of any gas, oil or water pipeline or well, electric
cable, transmission line, utility, residence or other improvement, the geophysical permit
holder must not damage or interrupt the use of the pipeline, well, electric cable,
transmission line, utility, residence or other improvement.
(2) Subject to subsection (3), the use of an explosive or non-explosive energy source to
carry out geophysical exploration in relation to a structure described in column 1 of
Schedule 1 must not be conducted at a distance less than the minimum distance shown
in column 2 or 3.
(3) An explosive or non-explosive energy source may be used to carry out geophysical
exploration in relation to a structure described in column 1 of Schedule 2 at a distance
not less than the minimum distance shown in column 2 or 3 if the geophysical permit
holder has the prior written consent of the owner of the structure
Schedule 1
Minimum Buffer Distances
[section 4 (2)]
1
Structure
Building or structure with a concrete base, residence, barn, concrete
irrigation structure, concrete lined irrigation canal and concrete water
pipeline
Artificial water hole, developed spring or piezometer
Driveway, gateway or buried water pipeline (other than a concretelined pipeline)
Buried telephone or telecommunication line
Survey monument
Petroleum or natural gas pipeline (measured from the centre line of
the pipeline) and a petroleum or natural gas well
Piping used to transmit, at less than 700 kPa, natural gas to
consumers by a gas utility as defined in the Gas Utility Act
Dugout or other earthen excavation designed to collect runoff and
store water for later use, measured from the inside edge of the high
water mark
Irrigation canal (other than a concrete-lined canal)
Dam having a storage reservoir capacity of 30 000 cubic meters or
more and that is 2.5 meters high or more when measured to the top
of the barrier
2
Non-explosive
energy source
(metres)
3
Explosive energy source
Charge
weight
(kg)
Distance
(metres)
50
all
180
100 (Vibroseis)
50 (other than
vibroseis)
all
180
5
all
10
2
all
all
>0 2
>2 4
>4 6
>6 8
> 8 10
> 10 20
> 20 40
>40
100
2
2
15
2
32
45
55
64
72
101
143
226
3
all
3
25
all
50
10
all
10
50
all
180
Cemetery, measured to its surveyed boundary
Domestic septic tank below ground or septic storage device above
ground
50
all
100
15
all
15
Schedule 2
Reduced Buffer Distances
[section 4 (3)]
1
2
3
Structure
Non-explosive
energy source
(metres)
Explosive energy source
Residence, barn, building or structure with a concrete base, concrete
irrigation structure, concrete lined irrigation canal, concrete water
pipeline, artificial water hole, developed spring or piezometer
50
Charge
weight
(kg)
Distance
(metres)
>0 2
64
>2 4
90
>4 6
110
>6 8
128
>8 10
142
>10 12
156