SOUTHWEST PUBLIC RECYCLING ASSOCIATION: A COOPERATIVE MODEL

Transcription

1 SOUTHWEST PUBLIC RECYCLING ASSOCIATION: A COOPERATIVE MODEL Submitted to: EPA Region 9 March 1993 Submitted by: Southwest Public Recycling Association (SPRA) (602)

2 TABLE OF CONTENTS SECTION1-BACKGROUND... 1 SECTION 2. INITIAL EFFORTS TO CREATE SPRA SOLID WASTE AND RECYCLING SURVEY SOUTHWEST REGIONAL RECYCLING MARKET CONFERENCE PARTICIPATION OF ELECTED AND APPOINTED OFFICIALS MAP OUT FUTURE DIRECTION GAIN COMMITMENTS CONCLUSION... 2 SECTION 3. ADMINISTRATIVE STRUCTURE BOARD OF DIRECTORS. OFFICERS AND COMMITTEE CHAIRS ARTICLES OF INCORPORATION AND BYLAWS CREATE AND ADOPT FIRST YEAR BUDGET HIRE AN EXECUTIVE DIRECTOR SIGN AN AGREEMENT WITH CITY OF TUCSON... 4 SECTION 4. PROGRAM DEVELOPMENT RECYCLING ECONOMIC DEVELOPMENT PROGRAM LocalTeamwork Regional Business Initiatives Compliance with Labelling Standards Legislation "BUY RECYCLED" PROCUREMENT PROGRAM Data Base Management "Buy Recycled" Resource Library "Buy Recycled" Position Paper and Generic Policy Procurement Audit Methodology Procurement Implementation Workshops Analysis of a Cooperative "Buy Recycled Purchasing Program" Policy Development COOPERATIVE MARKETING PROGRAM Developing Material Prospectus, (RFP) Proposal Review, Selection and Contract Negotiation Program Implementation-Sign Up Phase Program Implementation (Day-to-day Management) Program Overview SECTION 5. FINANCIAL RESOURCES

3 SECTION 1 - BACKGROUND Southwest Public Recycling Association (SPRA) was created at a regional meeting held in Tucson, Arizona in January Mayors representing twenty major cities in the southwest held a regional recycling market development conference to discuss and debate what the status of solid waste disposal, recycling, and recycling markets was in the southwest. Consensus was reached at this meeting that the public sector could and should foster the growth of recycling market development in the southwest., Representatives from the major materials groups of paper, glass, metals and plastic communicated that in order for recycling markets to grow and flourish, demand for new products made from recycled materials must meet or exceed the supply of collected materials. Representatives of public sector recycling efforts from other regions of the United States emphasized the value of creating partnerships between government and business. By sharing the responsibility of recycling market growth and development, the public and private Sectors provide recycling with a balanced and strong foundation. SECTION 2 - INITIAL EFFORTS TO CREATE SPRA The strategy to create SPRA had a five part approach that consisted of: + Gathering information on recycling and related solid waste topics in southwest. + Organizing a working conference for the purpose of strakgizing ways that recycling market development issues could be focused on at a regional level. + Inviting key elected and appointed officials from the southwest region to participate. Develop a strategy that would benefit recycling markets in the southwest region. + Gain the commitment of participants to work together to achieve established goals. 2.1 SOLID WASTE AND RECYCLING SURVEY The initial impetus for SPRA was the concern that as recycling collection programs were implemented throughout the region, there might not be enough markets to absorb the additional materials generated from new recycling collection programs. Information was initially gathered via a survey that was developed by the staff of the City of Tucson Mayor s Office in consultation with various local, state and federal solid waste officials. The University of Arizona s Udal1 Public Policy Research Center was involved in performing the survey work, analyzing the results and presenting them at a regional conference. Overall results indicated that almost all cities surveyed in the states of Arizona, Colorado, New Mexico, Nevada, Utah and west Texas were (1) in the early stages of recycling program development (both in the collection of recyclables and purchasing of recycled products), (2) expecting an escalation of solid waste disposal costs and (3) interested in working on common recycling market goals that offered hope for improved market conditions. 1

4 2.2 SOUTHWEST REGIONAL RECYCLING MARKET CONFERENCE Information from southwestern cities about solid waste and recycling programs provided the baseline data for a regional conference titled "Southwest Recycling: Creating a Regional Market". Representatives from the paper, glass, metal and plastic industries were invited to provide information on present conditions and future economic trends for their respective industry sectors. In addition, public sector representatives from recycling programs in other parts of the country spoke about their experiences in recycling program implementation. The focus throughout the two day meeting was on recycling markets. The question asked over and over again of the various presenters was, "What can the public sector do to assist in strengthening and expanding recycling markets?" 2.3 PARTICIPATION OF ELECTED AND APPOINTED OFFICIALS The mayors and staff from twenty of the largest cities in the southwest sat down and discussed with recycling industry leaders various approaches for improving recycling markets in the southwest. Participation by key officials sent a strong signal that the region's cities were serious about doing something in both policy and program arenas to improve recycling markets. 2.4 MAP OUT FUTURE DIRECTION Three areas were identified as key for public sector focus: buy-recycled, recycling economic development and cooperative marketing. Participants saw that creating demand for recycled products would spur on growth of industrial sectors that needed recyclable materials. Increased demand for recycled goods would increase the need for expanded collection of recyclable materials. 2.5 GAIN COMMITMENTS After identifying the common recycling market development threads, the mayors decided the best option was to create a non-profit organization that would champion their cause. The two day meeting ended with a press conference announcing the creation of the Southwest Public Recycling Association. The first year workplan included: securing initial funding, hiring an executive director and agreeing on a plan of action for buy recycled, economic development and cooperative marketing efforts. 2.6 CONCLUSION Building an organization requires vision, money and effort. The vision set forth at the January 1991 meeting would not have manifested if there wasn't the additional commitment from the mayors to approach their city councils and ask for a financial commitment. In addition, there was support secured from EPA and recycling industry officials to match the public sector's support. The initial funds were targeted to hire an executive director staff to begin to build SPRA's organization. 2

5 SECTION 3 - ADMINISTRATIVE STRUCTURE The basics of office location and equipment were addressed prior to the executive director officially starting work. The City Council of Tucson under the leadership of Mayor Tom Volgy and Vice Mayor Janet Marcus, offered the fledgling organization office space in the Tucson s Energy and Environment Office. The leadership demonstrated by Tucson s City Council was crucial to maximize the limited resources available, and establish a fertile professional environment from which to grow. There were five steps taken in the early months of SPRA that provided the needed organizational foundation. These steps were: Create SPRA s board of directors and elect its officers. + Prepare and approve articles of incorporation and by-laws to guide SPRA s management. Create and adopt a first year budget. Hire an executive director + Sign a lease agreement with the City of Tucson for office space. 3.1 BOARD OF DIRECTORS, OFFICERS AND COMMITTEE CHAIRS : In March of 1991 representatives of the cities that created SPRA met a second time. At this time and in accordance with a draft set of bylaws the founders of SPRA created a twenty person board of directors to govem the organization. One person was selected by each mayor of the original twenty founding cities to represent that city. Officers were selected for Chairman, Vice Chairman, Secretary and Treasurer. In addition, chairs of standing committees were elected. The committees are buy-recycled, cooperative marketing, economic development, education, and finance. Officers and committee chairs were selected for both their outstanding leadership qualities and their geographical representation from throughout the southwest region. 3.2 ARTICLES OF INCORPORATION AND BYLAWS The City of Tucson s Attomey s Office worked with the mayors office and prepared the drafts the Articles of Incorporation and the Bylaws. These legal documents were approved at the June 1991 meeting of SPRA. In the spring of 1992, the executive director reviewed these documents and recommended adjustments to incorporate requests of the IRS to meet tax exempt requirements, and to meet the expanding membership opportunities of the private sector in the organization. Changes to the bylaws were approved in June 1992 at SPRA s Board of Directors meeting in Provo, Utah. Changes to the articles of incorporation occurred in the Fall of 1992 to meet IRS requests. 3.3 CREATE AND ADOPT FIRST YEAR BUDGET At the March and June 1991 meetings of SPRA, the first year budget was drafted and adopted. This first year budget provided for the hiring of a full-time executive director and an administrative assistant. The City of Tucson offered office space as an in-kind donation. 3

6 The City of Tucson Mayor s office invoiced the original twenty founding member cities for fiscal year membership dues and completed the grant application to the EPA. The southwest region covered by SPRA encompasses parts of three EPA regions posing challenges in coordinating grant commitments, grant reporting and in general communication. 3.4 HIRE AN EXECUTIVE DIRECTOR The original goal set at the January 1991 meeting was the hiring of an executive director. A search was conducted April through May Interviews occurred in June, and SPRA s first executive director began work at the beginning of September. The key responsibility of the executive director was to coordinate and manage the growth of SPRA. 3.5 SIGN AN AGREEMENT WITH CITY OF TUCSON SPRA entered into a lease agreement with founding member the City of Tucson for office space and administrative assistance. The Tucson City Council s strong commitment to the organization manifested as the donation of office space. The initial one year agreement was recently extended for a second year by the City Council. SECTION 4 - PROGRAM DEVELOPMENT SPRA is typical of any membership organization. Members are SPRA s lifeblood. Members ideas need to be incorporated into the organizational development every step of the way. To accomplish this, a committee structure was created, and regular meetings were scheduled. The first full-fledged organizational meeting of SPRA members occurred in January The purpose of the meeting was to further defmed the goals and objectives of SPRA in the three areas of buy-recycled, cooperative marketing, recycling market development. Participant s ideas served as the basis for the development of the business plan. The April and June SPRA meetings and SPRA s Recycling Market Development Conference in October provided the opportunity to further defme the organization s goals and objectives. The following pages detail the program arm of SPRA. Program areas are at various stages of development as of the writing of this first year summary document. 4.1 RECYCLING ECONOMIC DEVELOPMENT PROGRAM SPRA members are located throughout the southwest. Member access to recycling markets will vary depending on location. For example, members in the Denver metro area have an excellent end-use market for mixed or color-separated container glass (the Coors glass manufacturing facility). There is strong market demand and transportation costs low, therefore glass is not a difficult item to sell. The same scenario applies to SPRA members who recycle newspaper and steel cans in Arizona. Stone Container Company s newsprint papermill in Snowflake, Arizona, and Proler International s detinning facility in Coolidge, Arizona, provide access to end-use recycling markets for old newspapers and used steel cans. When end-use markets are located within a state, access to end-users is high, and transportation costs low. These and other markets are accessible to recycling programs throughout the southwest, but as distances grow between 4

7 seller and buyer, the economics may drop into a costly deficit. SPRA members in Utah and New Mexico pay high transportation costs to transport recyclables out of states. Recyclables such as plastic have to be shipped to California, Texas or sometimes even to the east coast. How then can a recycling market be created closer to the supply of materials? The purpose of SPRA's Recycling Economic Development Program is to encourage all phases in the cycle of recycling within the southwest region. Value should be added to goods locally or at least prior to export from the region. Four areas of focus for attracting new manufacturing capacity to the southwest region are: Local Teamwork Regional Business Initiatives Compliance with Environmental Standards + Legislative Initiatives Loeal Teamwork Within most of the southwest's political jurisdictions there exists staff that focus on three key areas related to SPRA's mission. These areas are (1) solid waste collection and disposal, (2) purchasing of goods and services, and (3) business retention and attraction, or economic development. Y SPRA's objective is to create cross-functional teams or "Green Teams" within member political jurisdiction. These teams will be piloted in six SPRA member communities, then spread by example to all those that wish to participate. The makeup and purpose of the "Greenteams" is to encourage and enable the creation of businesses that run on secondary (recycled) materials, and to encourage the conversion of existing manufacturers to use recyclable materials as feedstock. The greenteam goal will be to identify methods a given community can increase demand and reduce barriers. Examples of increasing demand include: (1) increasing consumption by SPRA members' purchasing departments of products made from recycled materials, (2) encouraging increased purchasing of recycled products by local businesses, and (3) working with retailers to educate and promote recycled products sales. Examples of reducing barriers include: streamlining local and state permitting to be efficient and effective, assisting with zoning and site location, and accessing municipal services Regional Business Initiatives In order for the recycling cycle to grow and flourish, balance is needed among the various players in the cycle. A manufacturer using recycled feedstock must receive enough materials from re-processors. Re-processors must receive enough from collection programs. This part of the cycle is growing both regionally and nationally. However, a problem exists in the demand area for products made from recycled products. If the demand area of the loop does not grow, 5

8 then the cycle falters. Thus market development becomes the key to economic development, and trends in market development will be defined by those who purchase the packaging/products. Consumers, "name brand owners" and retailers are therefore pressure points for increasing recycled material demand. Once a clear demand for recycled materials is established, enabling mechanisms such as financing, zoning specifications and standards must be ready to foster the local manufacturing of recycled content packaging and goods. SPRA can strongly impact market demands by working with consumer product firms and retailers. The level of effort necessary for SPRA to elicit change may be large, however the opportunity exists to influence the entire population by taking this approach. Consumer demand, as evidenced by McDonald's extensive packaging changes, is a powerful motivator for change. The September 1992 announcement of the National Recycling Coalition's Buy Recycled Business Alliance is a further indication of the business community positioning itself for the next market growth area in the economy. SPRA will establish links with consumer products firms andlor retailers to provide the public with recycled goods, information on buying recycled, and methods for verifying environmental claims. Consumer Products Manufacturers mame Brands) are very sensitive to their packaging. They have preferred packaging, but are completely consumer driven. If consumers demand detergent in cast iron tubs, that's how it would be packaged. Consumer refers not only to the general public, but also the retailer. Much of the excess packaging one sees in stores is for the retailer, because the packaging reduces theft, increases stackability, improves the presentation, and moves more product. "Name Brand" owners don't want to give up anything in order to use recycled material or reduce packaging. Owners fear that recycled material will lower the quality of the packaging, and thus negatively impact their image. SPRA will develop programs to work with brand name owners and retailers and help "bring tomorrow to today" by advertising and educating consumers through PSA's, and industry roundtables. Initial implementation will be to have an extensive promotion of the National Recycling Coalition's Buy Recycled Business Alliance through SPRA's own series of presentations. Additional planning will be done as resources permit to develop the details of region-wide industry outreach Compliance with Labelling Standards As with nutritional labelling on food packaging, consumers have the right to have accurate and honest labelling of packaging and products relating to environmental claims. Establishment of an environmental auditing board which can set standards and evaluate manufacturer's claims will diminish inaccurate or dishonest labeling that presently exists. The existing efforts of Greencross, Greenshield and Scientific Certification Systems need to be strengthened or duplicated. 6

9 4.1.4 Legislation SPRA has the opportunity to educate legislatures in the southwestern United States. The goal is to develop an educational effort that can work over the six state region. The southwest's large size and political diversity pose a challenge. SPRA should pick issues that will benefit market development as a whole. Flexible market incentives for industry are preferable to command and control mandates. 4.2 "BUY R ECYO" PROCUREMENT PROGRAM Most communities traditionally focus on collection when developing recycling programs. However, the public sector is beginning to understand their role as consumers of recycled products. SPRA members are discovering they can have tremendous impact on product quality, availability and pricing. As the transition to a recycling economy occurs, problems understandably arise. The most obvious problems are that recycled products too often cost more than virgin, are not as readily available, and are not clearly or accurately labeled. Addressing these issues and encouraging the development and implementation of effective buy-recycled procurement programs within SPRA member jurisdictions, is a key goal of SPRA. '4. There are seven program development areas that comprise SPRA's "Buy Recycled" Procurement Program. They are: + Data base management. "Buy recycled" resource library. "Buy recycled" position paper and generic policy. Procurement audit methodology. Procurement implementation workshops. Analysis of cooperative "buy recycled" purchasing program. + Policy development Data Base Management Staff wil regularly update SPRA's data base on procurement policies and program activities of member jurisdictions "Buy Recycled" Resource Library Staff will develop a resource library on "buy recycled" policy and program development both regionally and nationally. SPRA's office will also be tied into a national "buy recycled" database developed by the publishers of The Official Recycled Products Guide "Buy Recycled" Position Paper and Generic Policy Staff will develop and distribute a buy recycled position paper and policy. This document will contain supporting information for why member jurisdictions should adopt pro-active procurement policies. 7

10 4.2.4 Procurement Audit Methodology Staff will distribute a procurement audit methodology. This document is being developed by the City of Tucson. Funding for the project is from the Arizona Department of Environmental Quality Recycling Grants Program. This report will help member jurisdictions to accomplish the following: 0 Evaluation of existing procurement practices. Development of long-term purchasing strategies. Review, evaluation and development of product specifications. Development of product testing plans Procurement Implementation Workshops Staff will organize and implement a series of workshops for purchasing officials. These workshops will focus on how to make purchasing decisions and conduct purchasing research for "buy recycled". The document under development by the City of Tucson will serve as the basis for the workshop materials. The workshop will be designed to stand alone, or be incorporated into already existing conferences. Fees will be charged to defray costs when workshops are "stand alone" events. There will be six workshops, one scheduled in each state SPRA serves, within a one year period. Additional workshops will be scheduled based on the success of the first series, and member demand Analysis of a Cooperative "Buy Recycled Purchasing Program" Staff will analyze the feasibility of a cooperative buy recycled purchasing program. The goal of this analysis is to determine the key elements of such a program, the projected participation and economic benefits. Staff will network with existing and developing buy-recycled purchasing efforts to gather the maximum information. Staff will develop a scope of work and budget for the project Policy Development SPRA has a role in shaping and developing policy regionally and nationally. The process for developing a SPRA policy will be as follows: staff will draft position papers on identified issues. The procurement committee will assist in developing the final position paper which the full board of directors will review, comment and approve. Some of the issues are outlined below, others will be identified in the future. procurement issues needing SPRA policy development are: Existing 0 Standards and specifications. Labeling. 0 Legislative incentives at the state level in those states SPRA works in. 8

11 4.3 COOPERATIVE MARKETING PROGRAM The goal of SPRA s cooperative marketing program is to facilitate the movement of recyclable materials from the public sector to the private sector. Of the three goals we have as an organization, cooperative marketing will be the most complex to implement. The four key elements of cooperative marketing are: Developing material prospectus, (RFP). Proposal review, selection and contract negotiation. Program implementation, (sign-up phase). + Program implementation, (day-to-day management) Developing Material The initial phase of the program consists of preparing a request for proposals, RFP, for a specific material (ie: steel cans, newspaper, glass containers, plastic containers, cardboard, scrap metal, etc.). The elements of the RFP are as follows: Background information on SPRA, it s members, and cooperative marketing. 0 Tonnage estimates of secondary material feedstock for a given material from existing SPRA members. Present, and five year projections for a twenty year period. Material specifications from potential buyers. RFP will request multiple specification options. Transportation options available from potential buyers. Pricing of various options. Industry accepted pricing indicator. Buyer qualifications Proposal Review, Selection and Contract Negotiation A proposal review sub-committee will be organized from the marketing committee to review and select the best proposal. Upon selection of the best proposal, a negotiating session will occur between SPRA representatives and the potential buyer to see if both parties can agree on the terms of a purchase agreement. Key issues common to most purchase agreements are material specifications, pricing, transportation, procedures for dealing with off-spec material, procedures for dealing with poor serve on the part of the buyer, the possibility of floor prices, or independent pricing indicators, length of agreement, exclusivity on the part of either party and standardized administrative procedures. When basic terms are agreed upon, a legal review of document occurs by both parties. 0 The negotiating team then presents recommendations to board of directors for approval. 9

12 + Timeline for Steel Can Marketing Program 0 July - August 1992 September October 1992 Steel can prospectus developed. Issuance of RFP for steel cans. Review and selection of proposal. 0 November 1992 Contract negotiation. December 1992 Contract approved. + Timeline for Glass Container Marketing Program October - November 1992 December January - February 1992 March 1993 April 1993 Glass container prospectus developed. Issuance of RFP for glass containers. Review and selection of proposal. Contract negotiation. Contract approved. Timelines for developing marketing agreements for newspaper, cardboard, high and mixed paper grades, plastic containers, scrap metal, tires and aluminum cans will be based on the experience gained from the steel can and glass container efforts Program Implementation-Sign Up Wase Upon completion of a purchase agreement, SPRA staff will prepare a specification package describing the terms of the agreement. This information is then presented to the SPRA membership for consideration. Because each member has its own unique recycling situation, the procedure by which members decide to participate will vary. Further data collection on each member s collection, processing and marketing arrangements must to occur prior to marketing program development. The variables identified so far are: No existing program. If no program is in place, the agreement provides needed assurances that materials can be recycled if collected. * SPRA will suggest language to be included in recycling RFP s and contracts members are developing. This language will allow for a two-step mechanism to occur when SPRA s marketing agreements become the desired route for materials to flow. Existing program. If there is an existing program in place, material is already being marketed by either the jurisdiction directly or by a contractor. In this situation, an analysis has to occur regarding the possibility of shifting materials to SPRA s marketing arrangement. The analysis should include: * Review of the marketing agreement the jurisdiction has with its buyer. 10

13 * Review of the processing and marketing agreement the jurisdiction has with it's private contractor and review of the marketing agreement the private contractor has with the end-use market Program Implementation (Day-to-day Management) The model proposed for program implementation is based on SPRA's "hub and spoke" approach recently funded by New Mexico. This approach establishes a satellite office in New Mexico staffed by one professional, with clerical support provided by the host SPRA member city. Once a jurisdiction signs up with SPRA to market a specific material, SPRA staff then meets with the appropriate people to work out the logistics of program management so that both parties understand each other's responsibilities. The responsibilities are divided as follows: The jurisdiction is responsible for making sure all materials meet the material specifications SPRA has negotiated, and for maintaining an accurate and updated inventory. The jurisdiction also should have the ability to load or make ready to load materials for shipment. SPRA is responsible for scheduling pick-up, transportation and sale of material. SPRA is responsible for billings, collection and payments. SPRA is responsible for troubleshooting problems that arise between seller and buyer. To implement cooperative marketing throughout the region satellite offices will be established in each state SPRA has members and as funding permits. Initial work to be accomplished in each state will be to: 0 Establish office and collect all data on all recycling programs, processing facilities, and existing intermediate and end-use markets. Data gathering will be accomplished by utilizing existing materials, telephone contact, and inspection of facilities. Develop materials processing procedures and specifications. Upon compiling program information, consistent procedures and specifications will be developed to facilitate the preparation of materials for market. Provide technical assistance and monitor material inventory. SPRA staff will travel to each community to present the procedures and specifications for materials processing, and to meet with local officials and recycling program operators to offer technical assistance. Materials inventory will be maintained, and continued on an ongoing basis, in anticipation of the cooperative marketing program. 0 Develop a statewide marketing network, including transportation arrangements and program administration. Begin cooperative marketing program. As appropriate marketing and transportation arrangements are made, marketing of materials will begin. SPRA will manage material revenues and incur all transportation and handling costs, and will disburse payment to all participating programs on a monthly basis. 11

14 4.3.5 Program Overview The cooperative marketing program that SPRA is developing is based on a "hub and spoke" approach to program implementation. At the end of the second year SPRA has established a satellite office in Santa Fe, New Mexico with funding assistance from the State of New Mexico. Also SPRA recently received notification from the State of Arizona of their decision to fund SPRA to develop the Same approach in Arizona which will occur in early Furthermore, discussions are underway with the States of Colorado and Utah to establish state-wide offices. 12

15 SECTION 5 - FINANCIAL RESOURCES The financing of programs that SPRA is developing necessitates a bold, diversified approach. To date infrastructure investment has come from federal, state and local governments, recycling industry groups. Grant sources are viewed as seed money for SPRA s first five years. Programs that are being implemented have a self funding mechanism to assure their longterm financial viability after grants end. As of the preparation of this summary document in December 1992 the finances of SPRA stand at the following: FY Budget FY Actual FY Budget Membership1 Public Agencies Foundations3 Earned Income4 $44, 000 $42,000 $55,000 75,000 60, , ,000 17,000 8,000 58,000 TOTALREVENUES $136,000 $1 10,000 $369,000 I EXPENSES by Budget hr Actual IFY Budget 11. Salary & Fringe I $ I $ I $224, II - Association/Projects6 46,000 50, ,000 - TOTAL EXPENSES $136,000 $1 10,000 $369,000 II I Membership consists of cities, counties, Native American Nations, businesses, institutions, non-profits, and individuals. Public agencies consists of EPA regional offices VI, VIII, and IX and state agencies in Arizona, Colorado, New Mexico, Nevada, Utah, and Texas. Foundations - applications have been made. Earned Income - conferences, workshops, donations and cooperative marketing program. Salary and Fringe - FY staff, 1.0 full time equivalent (FTE) for 6 months; 2.5 FTE for 6 months. FY staff, 5.5 FTE for 12 months. AssociationlProjects - telephone, postage, travel, printing, supplies, equipment, legal, accounting, workshops, annual conference. City of Tucson provides in-kind office space. 13