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4.10 1 4.10 AGREEMENTS\Lake George Park Commission OCC TAX Agreement-Boat Washing 2022—3-21-2022 RESOLUTION AUTHORIZING AGREEMENT BETWEEN TOWN OF QUEENSBURY AND LAKE GEORGE PARK COMMISSION IN CONNECTION WITH BOAT LAUNCH INSPECTION AND BOAT WASH SYSTEM RESOLUTION NO.: ,2022 INTRODUCED BY: WHO MOVED ITS ADOPTION SECONDED BY: WHEREAS, the Lake George Park Commission (LGPC) implemented a Lake George boat launch inspection and boat wash program as part of its efforts to inspect and wash boats in an effort to kill and contain invasive species, and has requested that the Town of Queensbury partner with LGPC and other municipalities to assist with the procurement and acquisition of essential program equipment and support services and associated administrative expenses by contributing $37,000 for 2021, and WHEREAS, by prior Resolution the Town Board provided for the Town's receipt of occupancy tax revenues from Warren County in accordance with the Local Tourism Promotion and Convention Development Agreement (Agreement) entered into between the Town and Warren County, and WHEREAS, the Agreement provides that specific expenditure of the funds provided under the Agreement are subject to further Resolution of the Queensbury Town Board, and WHEREAS, the Town Board wishes to provide funding in the requested amount of $37,000 for the year 2022 with occupancy tax revenues received from Warren County, and WHEREAS, a proposed Agreement between the Town and LGPC has been presented at this meeting, and NOW, THEREFORE, BE IT RESOLVED, that the Queensbury Town Board hereby approves and authorizes the funding toward the aforedescribed boat launch inspection and boat wash program and the coinciding Agreement between the Town and the Lake George Park Commission (LGPC) substantially in the form presented at this meeting, and authorizes and directs the Town Supervisor to execute the Agreement, with such funding not exceeding the sum of $37,000 for the year 2022 and to be provided by occupancy tax revenues the Town receives from Warren County, to be paid for from Account No.: 050-6410-4412,and BE IT FURTHER, RESOLVED, that such Agreement is expressly contingent upon confirmation by the Town that unallocated occupancy tax funds are available from Warren County, and BE IT FURTHER, RESOLVED, that the Town Board further authorizes an increase of appropriations in Occupancy Tax Account No.: 050-6410-4412 and an increase of revenue coded 050-0000-51113 Occupancy Tax by$37,000 in the 2022 Budget, and BE IT FURTHER, RESOLVED, that the Town Board authorizes and directs the Town Budget Officer to amend the Town Budget, make any adjustments, budget amendments, transfers, prepare any documentation necessary and/or take any actions needed to provide for such payment, and BE IT FURTHER, RESOLVED, that the Town Board authorizes and directs the Town Supervisor and/or Town Budget Officer taking such other and further actions necessary to effectuate the terms of this Resolution. Duly adopted this 21"day of March,2022, by the following vote: AYES NOES ABSENT: AGREEMENTS\Lake George Park Commission—OCC TAX—Boat Washing System for 2022—3-21-22 LOCAL TOURISM PROMOTION AND CONVENTION DEVELOPMENT AGREEMENT This Agreement is made as of the 1ST day of January, 2022 by and between the Town of Queensbury, a municipal corporation with its principal place of business located at 742 Bay Road, Queensbury, New York 12804 (hereinafter referred to as "Municipality") and the Lake George Park Commission, with a principal place of business and mailing address of P. O. Box 749, 75 Fort George Road, Lake George, New York 12845 (hereinafter referred to as "Contractor"). WITNESSETH: WHEREAS, the Municipality has received from Warren County certain funding derived from revenues received by the County as a result of the imposition of the Occupancy Tax authorized by act of the New York State Legislature (Chapter 422 of the Laws of 2003), hereinafter "Occupancy Tax Funds," and WHEREAS, Municipality has agreed to expend the Occupancy Tax Funds for tourism promotion and tourist and convention development and, more specifically, to enhance the general economy of the Municipality through the promotion of tourist activities, conventions, trade shows, special events and other directly related and supported activities for such purposes, and WHEREAS, the Contractor is (1) ready, willing and able to provide services and/or materials consistent with the terms upon which the Municipality must expend the funds and as more specifically described in the attachment annexed hereto as Schedule A and (2) possesses or can make available all necessary qualified personnel, licenses, facilities and expertise to carry out the terms of this Agreement; NOW, THEREFORE, in consideration of the promises, responsibilities, and covenants herein, the Municipality and the Contractor agree as follows: 1. Services/Materials The Contractor shall provide services and /or materials as more specifically described in the attachment annexed hereto as Schedule "A". (Contractor — Please attach a detailed description of services/materials to be provided,the costs and the period for performance of services or supply of materials.) 2. Contract Sum A. For the Services performed and/or materials furnished under this agreement the Contractor shall be paid the sum of $37,000 for the year 2022 due under this Contract. The Contractor shall not be entitled to out-of-pocket expenses. Contractor shall not be entitled to partial payment for services rendered or materials furnished at the end of end of each thirty (30) day period as work proceeds. B. Payment of amounts owed by the Municipality by virtue of this contract shall be as set forth above for all services to be performed and all out-of-pocket expenses incurred by reason of this Agreement. There shall be no other amounts due and payable by the Municipality regardless of costs or expenses of the Contractor except for additional services requested by the Municipality which are beyond the Scope of Services and those services customarily performed as a part thereof. 3. Payment A. In order to receive payment under this Contract, the Contractor shall furnish: i) a completed and fully executed Agreement; ii) an invoice or other statement identifying and itemizing the services rendered or materials furnished and charges for the same and if the contract includes or requires payment for services at an hourly rate, that rate shall be specified for each person charged for and employed in the performance of the contract, iii) such other documents as are required by the standard billing procedures of Municipality, iv) a detailed description of how the funds will be used, as well as statistical information describing how the Town's financial investment impacted the program's success, including attendance figures, demographics, etc., v) in the event that Contractor uses subcontractors or material supplier in connection with the services and or materials furnished under this agreement, the Contractor shall obtain from any subcontractors or material suppliers the same documentation required of herein above of Contractor and submit the same to the Municipality to support Contractor's claim for payment, vi) the Contractor shall promote the Municipality in whatever media in which they spend the Town's contribution including, but not limited to, the Town's logo being incorporated into written advertising materials, brochures, radio and/or television ads, etc. B. Payment shall be made thirty(30) days from: i) the furnishing of all materials and completion of required work, or ii) receipt of all documentation required by this section, whichever date is later. 4. Term The initial term of this Agreement shall commence upon execution of this agreement and terminate when the services have been completed or the material furnished as provided for in Schedule "A" or December 31, 2022, whichever date is sooner. On December 31, 2022, in the event that there are any services or materials to be provided under this agreement that the contractor has not provided, all work and services shall immediately cease unless continuation after December 31, 2022 is specifically authorized by Resolution of the Governing Board of Municipality. This Agreement may be terminated at any time upon mutual written consent of the Municipality and Contractor. The Municipality may terminate this Agreement immediately upon written notice of termination to the Contractor, if the Contractor fails to comply with the terms and conditions of this Agreement and/or any laws, rules, regulations, policies or procedures affecting this Agreement. Written notice of termination, where required, shall be sent by personal messenger service or by certified mail, return receipt requested. The termination shall be effective in accordance with the terms of the notice. Upon receipt of the notice of termination, the Contractor agrees to cancel, prior to the effective date of any prospective termination, as many outstanding obligations as possible, and agrees not to incur any new obligations at the receipt of the notice without approval by the Municipality. In no event shall the Municipality be liable for expenses or obligations arising from programs or other expenditures made pursuant to the terms of this Agreement after the termination date. 5. Reports to be Filed Concerning Funds and Expenditures At the end of the contract term or at the end of each calendar year, whichever occurs first, the Contractor shall file with the Municipality a report which shall include: i) the number of persons served by the services or materials provided by Contractor pursuant to this agreement, ii) an outline of plans for continuing the activity or project, and iii) any and all other reasonable information that the Municipality may deem necessary by further Resolution adopted by the Board. 6. Records/Audits The Contractor shall establish and maintain complete and accurate books, records, documents, accounts and other evidence directly pertinent to performance under this Agreement (herein collectively "the Records") in accordance with the following requirements: i) the Records must be kept for the balance of the calendar year in which they were made and for six (6) additional years thereafter, and ii) the Municipality Chief Executive Officer, the Chairman of the Warren County Board of Supervisors, the Tourism Committee of the Warren County Board of Supervisors, the Warren County Administrator of Fiscal Services, the County and Municipality Attorney, or any other person or entity authorized to conduct an examination, as well as the Municipality governing board and the Warren County Board of Supervisors, shall have access to the Records during normal business hours at an office of the Contractor, or, if no such office is available, at a mutually agreeable and reasonable venue within the Municipality, for the term specified above for the purposes of inspection, auditing and copying. The Municipality shall take reasonable steps to protect from public disclosure any of the records which are exempt from disclosure under §87 of the Public Officers Law (the "Statute") provided that; a) the Contractor shall timely inform an appropriate Municipality official, in writing, that said records should not be disclosed; and b) said records shall be sufficiently identified and designation of said records as exempt under the statute is reasonable. Nothing contained herein shall diminish, or in any way adversely affect, the Municipality's or County of Warren's right to discovery in any pending or future litigation. 7. Indemnification The Contractor shall defend, indemnify and hold harmless the Municipality and its officers and employees from claims, notices of claims, suits, actions, damages and costs of every kind and nature, including but not limited to reasonable attorney's fees, arising out of activities funded or otherwise carried out pursuant to the terms of this Agreement. 8. Nature of Agreement/Independent Contractor This Agreement is a funding agreement. This Agreement is not intended to create, nor shall it be construed as creating, a joint venture or partnership. The Contractor is an independent contractor and may neither hold itself out nor claim to be an officer, employee or subdivision of the Municipality, nor make any claim, demand or application to or for any right, based on any different status. 9. Discrimination Prohibited The services to be furnished and rendered under this Agreement by the Contractor shall be available to any and all residents of Warren County without regard to race, color, creed, sex, religion, national or ethical origin, handicap or source of payment; and under no circumstances shall a resident's financial ability to pay for the services be provided be considered, unless such consideration is allowed by State and/or Federal law, rule or regulation. 10. Non-Discrimination and Employment The Contractor shall not discriminate against any employee or applicant for employment because of race, creed, color, sex, national origin, age, disability or marital status. Further, the Contractor agrees that neither it nor its subcontractors shall, by reason of race, creed, color, disability, sex or national origin (i) discriminate in the hiring against any citizen who is qualified and available to perform work; or (ii) discriminate against or intimidate any employee hired for the performance of work funded by this Agreement. 11. No Partisan Political Activity Funds provided pursuant to this Agreement shall not be used for any partisan political activity, or for activities that may influence legislation or the election or defeat of any candidate for public office. 12. Non-Assignment/No Sub-Recipients This Agreement may not be assigned by the Contractor or its right, title or interest therein assigned, transferred, conveyed, sublet or otherwise disposed of without the previous consent, in writing, of the Municipality, and any attempts to assign the contract without the Municipality's written consent are null and void, except that contracts entered in to by the Contractor with third parties for commodities and/or services that are part of the services to be performed as identified in Schedule "A" attached hereto shall not be deemed prohibited by this clause. 13. Workers' Compensation/Disability This Agreement shall be void and of no effect unless throughout the life of the Agreement, the Contractor shall secure compensation insurance and disability insurance for the benefit of such employees engaged under this Agreement as are by law required to be insured by provisions of the Workers' Compensation Law and New York State Disability Law. Proof of compensation and disability insurance shall be in the form(s) approved by the Workers' Compensation Board. 14. Set-Off Rights The Municipality shall have all of its common law, equitable and statutory rights of set-off. These rights shall include, but not be limited to, the Municipality's option to withhold for the purposes of set-off any monies due the Contractor under this Agreement up to the amounts due and owing to the Contractor with regard to this Agreement, any other Agreement with any Municipality department or agency, including any contract for a term commencing prior to the term of this Agreement, plus any amounts due and owing to the Municipality for any other reason, including, without limitation, tax delinquencies, fee delinquencies or monetary penalties relative thereto. 15. Executory Clause The Municipality shall have no liability under this Agreement to the Contractor or to anyone else beyond the funds appropriated and available for this Agreement. 16. International Boycott In accordance with §220-f of the Labor Law, if this contract exceeds $5,000, the Contractor agrees, as a material condition of the contract, that neither the Contractor nor any substantially owned or affiliated person, firm, partnership or corporation, has participated, is participating, or shall participate in an International boycott in violation of the federal Export Administration Act of 1979, or regulations thereunder. If such Contractor, or any of the aforesaid affiliates of Contractor, is convicted, or is otherwise found to have violated said laws or regulations upon the final determination of the United States Commerce Department or any other appropriate agency of the United States subsequent to the Agreement's execution, such contract, amendment or modification thereto shall be rendered forfeit and void. The Contractor shall so notify the Municipality Manager within five (5) business days of such conviction, determination or disposition of appeal. 17. Compliance with Law The Contractor warrants, covenants and represents that: i) it is aware of and familiar with the provisions of General Municipal Law §801, 803 and 805-A, and of the Code of Ethics of Warren Municipality, ii) at no time during the term of this Agreement shall it knowingly permit or allow performance of its services for the Contractor under this Agreement to involve any violation of said statutory provisions or of the Code of Ethics, and iii) it shall fully comply with all other general and special laws and regulations of the State of New York, as well as with all local laws and resolutions of the Municipality, applicable to the services to be performed by the Contractor under this Agreement. 18. Disputes Disputes involving this Agreement, including the breach or alleged breach thereof, may not be submitted to binding arbitration, but must, instead, be heard in a court of competent jurisdiction within the State of New York. 19. Amendment This agreement may not be amended, modified or renewed except by written agreement signed by the Municipality and the Contractor. 20. Severability If any term or provision of this agreement or the application thereof to any person or circumstance shall to any extent be held invalid or unenforceable, the remainder of this agreement or the application of such term or provision to persons or circumstances other than those as to which it is held invalid or unenforceable, shall not be affected thereby and every other term and provision of this agreement shall be valid and be enforced to the fullest extent permitted by law. 21. Entire Agreement This agreement is the entire agreement between the parties and it shall be construed in accordance with the laws of the State of New York. Approved as to form: TOWN OF QUEENSBURY By: John F. Strough, III,Town Supervisor Town Counsel Date: LAKE GEORGE PARK COMMISSION By: David Wick, Executive Director Date: STATE OF NEW YORK ) ss.. COUNTY OF WARREN ) On the day of March, in the year 2022, before me, the undersigned, a Notary Public in and for said state, personally appeared JOHN F. STROUGH, III personally known to me or proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his capacity, and that by his signature on the instrument, the individual, or person upon behalf of which the individual acted, executed the instrument. Notary Public STATE OF NEW YORK ) ss.. COUNTY OF WARREN ) On the day of , in the year 2022, before me, the undersigned, a Notary Public in and for said state, personally appeared DAVID WICK personally known to me or proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed to the within instrument and acknowledged to me that he/she executed the same in his/her capacity, and that by his/her signature on the instrument, the individual, or person upon behalf of which the individual acted, executed the instrument. Notary Public SCHED ULE A Contractor to attach a detailed description of services/materials to be provided, the costs and the period for performance of services or supply of materials. NEW PORK Lake George STATEOF INVOICE OPPORTUNITY. Park Commission Bruce E.Yuun:; I)a%v tl'ick �.:1.1lI'lls.11l f::•:eCUIIP�IJIf'CLG11' Date: 03/14/2022 INVOICE#003-2022 To: Town of Queensbury 742 Bay Road Queensbury, NY 12804 Qty Description Unit Price Line Total Invoice for 2022 Lake George Aquatic Invasive Species Prevention (Boat Inspection) Program, per LGPC memo dated 2/3/22. Thank you for your ongoing $37,000.00 commitment to protecting Lake George. f Subtotal $37,000.00 Sales Tax 0 Total $37,000.00 " �Cil1 G(.,c"7?Qe F'ocd,P,Q.BC'•S 7,!Q �;};e CGr01'Cle,7•JY 128a$ PI1Ci1:?jJ NEW YORK Lake George STATE OF OPPORTUNITY_ park Commission Bruce E.Young Dave Wick Chairman Executive Director February 3,2022 Lake George Boat Inspection Program: Extended Season Results and Wa-ge Update Dear Lake George Boat Inspection Program Partners, I hope this letter finds you well. As shown in our recent 2021 AIS Prevention Program Annual Report,the mandatory boat inspection program continues to provide a great level of protection for Lake George from aquatic invasive species. Our ongoing partnership is the sole reason that this program continues to be a success,and the Commission is very grateful for your continuing support. The purpose of this letter is to highlight required program cost updates and the outcome of our requested extended season inspections. Program Wages To maintain the quality of the Lake George boat inspection and decontamination program,the Commission must be able to hire people qualified to do this important work. Since 2018,the wage rates for the Commission's program have lagged significantly behind partner programs like the DEC/AWI program,as well as local businesses. The result is that the Commission has struggled to fill open positions with appropriate candidates.For the 2022 season,the Adirondack Watershed Institute will pay their new inspection and decontamination stewards$16 per hour. Last season,the Commission paid new inspectors $13.00 per hour,with seasoned,returning staff earning$13.50414.00. The Commission has worked very hard to keep costs down for the eight years of the program.Staffing is by far the largest program expense.The time has come to increase program wages to a level more in line with our partners and local businesses,competing to hire from the same pool. To help minimize these hiring challenges and pay inequities,the Commission will be raising wages for all titles by two dollars for the 2022 season,for a starting wage of$15.00 per hour. Obviously,this will increase the overall program cost. With cost and funding always present in the Commission's calculations,our program managers work on a daily basis to optimize staffing levels at our inspection sites to ensure timely and quality inspections. These efforts have led to the balanced and effective program that we manage to this day. Extended Season Activity As would be expected,extended season activity outside of our regulated dates(April 15th to April 30th and November 15C through December 15th) is significantly lower than peak season(Figures 1-3 in the Appendices).The program averaged only six inspections per day in April,two per day in November,and 75 Fort George Road.P.O.Box 749. Lake George,NY 128451 P17.518.668.9347 ! Fax:518.668.9347 1 email:i7fo@1gpc.state.ny.us one per day in December.The average cost per inspection in the extended season is almost$40,compared to less than$13 for the regulated season. Considering the sparse numbers of inspections,the resultant high cost per inspection and the reduced risk of AIS transport given cold-season conditions,the Commission believes that pre and post-regulated season inspections represent an inefficient use of our collective financial resources.This is consistent with the original determination based on review of data collected during the pilot extended seasons of 2014 and 2015. As you recall,the calculus of risk assessment includes an evaluation of the AIS present in the water column at these times of year,which are very low(plants are senesced and no spawning of small bodies organisms in cold water),very low boating activity,and high cost per inspection. 2022 Program Costs: With and Without Extended Season Specific to revised wage rates,extended season and overall program cost,below is a table that shows an estimate of how these factors would affect the 2022 program. The table is broken down to show the inspection staffing costs of the regulated season May 1st through October 31st,plus the costs of extended season staffing(April 15th through 31st and November 1st through December 15th). Seasonal Staffing 2021 Cost Cost of$2 Raise 2022 Cost May 1-Oct 31 $462,000 $70,000 $532,000 April15-31 $9,880 $2,090 $11,970 Nov 1-30 $19,850 $3,660 $23,510 Dec 1-15 $11,280 $2,250 $13,530 Extended Season Total $41,010 $8,000 $49,010 Staffing Total $503,010 $78,000 $581,010 As shown above,a two-dollar raise increases the cost of regulated season staffing approximately$69,000. This must be considered a minimum permanent increase going forward,and programmatic funding will have to take this into account to remain viable and effective for the future. A permanent extension of the regulated season would require additional long-term commitments of funding on top of the wage adjustments.The total cost of extended season operations adds an additional $49,000. Together,the increased wages and extended season add approximately$118,000 to the program cost versus year 2020. The total annual cost of the inspection program includes the seasonal wages plus equipment,fuel, materials,etc. The 2021 total program cost was$642,000 (including extended season). Adding the $78,000 for wage increases (including extended season) brings the projected 2022 total cost up to $720,000. However,subtracting the extended season cost reduces the total program cost to approximately $670,000 annually. A compromise option would be to have limited operations in April and November at the Million Dollar Beach.During those months in 2021,the MDB performed 65%of all inspections and accounted for only 26%of the staffing cost,roughly$10,000. In this scenario,the DEC gates would be left open since the 75 Fort George Road,P.O.Box 749,Lake George;NY 128451 P17.518.668.9347 I Fax:518.668.9347 I email:info@Igpc.state.ny.us regulated season is limited to May 15t through October 315t.The Commission would prefer not to go through a regulation amendment process at this time,because it is currently working to enact wastewater regulations. To keep the program viable,all involved program partners are requested to consider increasing their contributions commensurate with the wage realities. The 2022 funding requests to address just the wage increases would reflect as follows: 2022 Total Program Costs-Not Including Extended Season ($670,000) • Warren County:$111,500 • Village,Town LG, Queensbury,Bolton:$36,500 each • LGA/Fund: $77,500 • Total Local Contributions$335,000 plus LGPC NYS EPF($335,000) =$670,000 2022 Total Program Cost-Adding Limited Extended Season($680,000) • Warren County:$113,000 • Village,Town LG, Queensbury,Bolton:$37,000 each • LGA/Fund: $79,000 • Total Local Contributions ($340,000) plus LGPC NYS EPF ($340,000) = $680,000 2022 Total Program Cost-Adding Full Extended Season($720,000) • Warren County$118,000 • Village,Town LG,Queensbury,Bolton: $40,000 each • LGA/Fund: $82,000 • Total Local Contributions ($360,000) plus LGPC NYS EPF ($360,000) = $720,000 Conclusion By all metrics,the Lake George Aquatic Invasive Species Prevention Program has been highly successful in keeping invasive species out of Lake George without disrupting or impacting the thousands of boaters who enjoy Lake George every year,contributing massively to the region's economy. The Commission strives to keep program costs as low as possible while maintaining an effective program. Due to ongoing challenges with maintaining staffing,the Commission needs to increase wages for the program to remain viable. These increases will align much more closely with the current labor market and the Adirondack AIS program. With these costs comes the need for increased funding,spread among our state and local partners. The Commission believes that the proposed funding levels for the program partners are reasonable and equitable,and we sincerely hope that you will continue to support this important program at the level it needs to adequately function. 75 Fort George Road,P.O.Box 749,Lake George,NY 12845 1 P17.518.668.9347 I Fax:518.668.9347 1 email:info@lgpc.state.ny.us F The Commission believes that the limited approach to extended season operations offers the best balance of protection and cost effectiveness.This approach provides the added benefit of not requiring any regulation amendments and allows for additional data collection. The Commission has sincere gratitude and appreciation for all your efforts and foresight in the creation and implementation of this initiative. I hope to speak with all of you soon regarding the program and our 2022 funding request. Best Regards, Dame Dave Wick Executive Director Appendices: (MDB=Million Dollar Beach, NIP=Mossy Point, RR=Rogers Rock, NM=Norowal Marina Fig. 1: April 2021 Entry Inspections 50 45 40 35 r, 30 I 25 20 15 10 0 '° 'Iv NV ti�P V ti�,P yP ,1,P V ti ti ti ti ti ti ti ti M MDB U MP > RR 75 Fort George Road,P.O.Box 749.Lake George,NY 12845 I Pli.598.668.9347 I Fax:598.668.9347 I email:info@Igpc.state.ny.us r O N N W A In Ol V 00 l0 O Cn N O 1 p O N N W A In M V w to O � e -Nov-21 m `�1 2-Nov-21 0 m �pP 3-Nov-21 o cad 4-Nov-21 m b ape 5-Nov-21 �1 Gl 6-Nov-21 o gO 7-Nov-Z1 x e0 TI �Z T! 8-Nov-21 Qq m �� 9 Nov-21 Iv W 1 10-Nov-21 Z GpPc NC7 11 Nov 21 z �1 [nD 12-Nov-21 o pPc� 3- m 13 Nov-21 1 ( ffi 14-Nov-21 o Pc� Q 15-Nov-21 CD Z iV fv 16-Nov-21 m Pc�1 ® 17-Nov-21 w z Ip p � z 18-Nov-21 F ;z ec", — 19-Nov-21 T 11,p n 20-Nov-21 rD k Pc� n 21-Nov-21 n d J�?p 22-Nov-21 a 23-Nov-21 24-Nov-21 P Cad 25-Nov-21 - 1Qp 26-Nov-21 27-Nov-21 S ' 28-Nov-21 c,2 29-Nov-21 y 30-Nov-21 m m �c