Agenda 10/13/2015 Item #16D1210/13/2015 16. D.12.
EXECUTIVE SUMMARY
Recommendation to review and accept the Domestic Animal Services Consultation Summary
prepared by Maddie's® Shelter Medicine Program at the University of Florida College of
Veterinary Medicine and endorse the Maddie's Recommendations Imp
entation Plan.
OBJECTIVE: To provide a strategic plan for future Domestic Animal Services (DAS) operational
changes and facility improvements.
CONSIDERATIONS: On December 18, 2011, The Collier County Animal Services Board held their
Two -Year Strategic Goal Workshop. At that time, the Board recommended that Domestic Animal
Services participate in the Maddie's® Shelter Medicine Program at the University of Florida Shelter
Health Assessment. On January 10, 2012, the Advisory Board finalized and approved their Top -Ten List,
which included the Shelter Health Assessment. The cost of the Shelter Health Assessment was approved
and funded during the Board's Budget Workshop held on June 24, 2014.
The Maddie's ® Shelter Medicine Program's Shelter Health Assessment was conducted by a team of five
veterinarians and eight veterinary students during a site visit on March 16 through March 20, 2015.
Results were compiled into the Consultation Summary that was received by DAS on June 10, 2015.
The consultation team examined all aspects of the shelter operations through the framework of the
Association of Shelter Veterinarian's Guidelines for Standards of Care in Animal Shelters; a document
that identifies minimum standards of care and sets forth best practices and unacceptable practices for the
industry. Recommendations on seven primary areas of shelter operations are prioritized into three
categories: immediate, next step and long term goals that are based in part on the availability of resources
to implement these recommendations. DAS can and will be implementing most of the recommendations
over the next 12 months. The balance of the recommended actions will be pursued in FY 17 and FY 18,
some of which will likely require additional resources. The attached Implementation Plan provides a
complete discussion of staffs approach to the recommendations generated by the Consultation Summary.
FISCAL IMPACT: There is no fiscal impact associated with accepting this report at this time. The
adopted FY 16 budget includes $264,900 to implement recommendations made in this report, including
funding of $173,000 in shelter improvements and $60,200 for one additional Veterinary Technician. In
accordance with report recommendations, requests for two additional Animal Care Specialists costing
approximately $94,000 are anticipated for FY 17. Additional funding requests for shelter improvements
in FY 17 and FY 18 are also anticipated, with costs to be determined.
GROWTH MANAGEMENT IMPACT: There is no growth management impact associated with this
item.
LEGAL CONSIDERATIONS: This item has been approved as to form and legality, and requires a
majority vote for Board approval. ERP
RECOMMENDATION: That the Board of County Commissioners accepts the Domestic Animal
Services Consultation Summary and endorses the Maddie's Recommendations Implementation Plan.
Prepared by: Darcy Andrade, Director, Domestic Animal Services
Attachments: Maddie's Fund Shelter Assessment, Maddie's Recommendations Implementation Plan
Packet Page -1360-
10/13/2015 16.D.12.
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.16.D.16.D.12.
Item Summary: Recommendation to review and adopt the Domestic Animal Services
Consultation Summary prepared by Maddie's® Shelter Medicine Program at the University of
Florida College of Veterinary Medicine and endorse the Maddie'so Recommendations
Implementation Plan.
Meeting Date: 10/13/2015
Prepared By
Name: CarrollKellie
Title: Administrative Assistant, Public Services Department
9/29/2015 12:57:28 PM
Submitted by
Title: Division Director - Domestic Animal Svc, Public Services Department
Name: AndradeDarcy
9/29/2015 12:57:29 PM
Approved By
Name: AlonsoHailey
Title: Operations Analyst, Public Services Department
Date: 9/29/2015 4:14:06 PM
Name: TownsendAmanda
Title: Division Director - Operations Support, Public Services Department
Date: 9/30/2015 8:35:47 AM
Name: PepinEmily
Title: Assistant County Attorney, CAO Litigation
Date: 9/30/2015 8:50:27 AM
Name: CarnellSteve
Title: Department Head - Public Services, Public Services Department
Date: 9/30/2015 1:21:17 PM
Packet Page -1361-
10/13/2015 16. D.12.
Name: PepinEmily
Title: Assistant County Attorney, CAO Litigation
Date: 9/30/2015 4:09:39 PM
Name: KlatzkowJeff
Title: County Attorney,
Date: 10 /1/2015 8:17:44 AM
Name: FinnEd
Title: Management/Budget Analyst, Senior, Office of Management & Budget
Date: 10/7/2015 10:08:24 AM
Name: OchsLeo
Title: County Manager, County Managers Office
Date: 10/7/2015 11:25:07 AM
Packet Page -1362-
wUwF UNIVERSITY of
FLORIDA
Maddie'ss Shelter Medicine Program
College of Veterinary Medicine
June 8, 2015
Dear Collier County Domestic Animal Services,
10/13/2015 16. D.12.
2015 SW 161h Avenue
PO Box 100126
Gainesville, FL 32610
352 - 273 -8660
352 - 392 -6125 Fax
The consultation team from Maddie's® Shelter Medicine Program at the University of Florida is very
appreciative of the opportunity to partner with your facility. The consultation process requires
considerable commitment of time and resources by your organization, and we commend you for making
this investment in the future of Collier County.
The recommendations presented in this document were generated from review of the shelter
questionnaire and our site visit on March 16-20, 2015. Our team of five veterinarians and eight
veterinary students focused on seven primary areas of shelter operations: population management,
record keeping, veterinary services, euthanasia, sanitation, housing and facility use, and enrichment and
behavioral welfare.
Contained within this report are the following sections:
• Recommendations: offers specific steps to implement change for each consultation
focus organized into "Immediate Recommendations" that were initiated utilizing
resources at hand while the OF team was on site; "Next Steps" that should be
pursued as soon as the immediate changes are sustainable and require acquisition of
some resources; and, "Long Term Goals" requiring procurement of significant
resources for which planning should begin now.
• Resources: a collection of resources in support of the recommendations are provided,
including sample protocols.
This report is not intended to be viewed as an exhaustive list of current deficiencies for
itemized corrections. Rather, we intend to provide a step -by -step roadmap leading from
immediate action that can be initiated with the resources already available to larger
changes that require future planning and resource acquisition. The recommendations
that follow are based upon the Association of Shelter Veterinarians' Guidelines for
Standards of Care in Animal Shelters as referenced throughout this report.
r 1
i
The Foundation for The Gator NatinN 14-akdkdie's Fund
An Equal opportunity Institution Packet Page -1364-
10/13/2015 16.D.12.
The next steps in the consultation process will involve follow -up site visits by a smaller portion of the OF
consult team to assess progress on the operational topics with each visit primarily targeted to one topic.
We are impressed and inspired by the dedication of Collier County Domestic Animal
Services to strive for best practices. We are here to offer ongoing assistance and support in
any way possible, and we look forward to working with you in the months ahead.
Consultant Team
Cynda Crawford, DVM, PhD
Maddie's Assistant Professor in Shelter Medicine
Program Director
Julie Levy, DVM, PhD, DACVIM
Maddie's Professor in Shelter Medicine
Arnie Burling, DVM
Maddie's Resident in Shelter Medicine
Staci Cannon, DVM, MPH
.-® Maddie's Resident in Shelter Medicine
Chelsea Reinhard, DVM, MPH
Maddie's Resident in Shelter Medicine
Packet Page -1365-
10/13/2015 16.D.12.
Table of Contents
PopulationManagement Recommendations ......................... ..............................2
Recordkeeping Recommendations ................................................. .............................11
Veterinary Services Recommendations ......................................... .............................13
Euthanasia Recommendations ....................................................... .............................21
Sanitation Recommendations ........................................................ .............................23
Facilities and Housing Recommendations .................................... .............................29
Enrichment, Behavior, and Welfare Recommendations ............ .............................36
Packet Page -1366-
10/13/2015 16. D.12.
Population Management Recommendations
The ASV Guidelines for Standards of Care in Animal Shelters states, "Active population management is
one of the foundations of shelter animal health and well- being, and must be based on an appreciation
that capacity to provide humane care has limits for every organization, just as it does in private homes."
In order to increase live release rate while also meeting humane capacity for care, CCDAS must prioritize
proactive population management strategies to shorten the average length of stay and reduce the
number of animals housed in the shelter without compromising each animal's opportunity for a positive
outcome. The consultation recommendations relating to population management are among the
most critical and urgent priorities that CCDAS faces. Their successful implementation underpins the
effectiveness of all other initiatives that CCDAS can make to improve animal behavioral well- being,
husbandry, sanitation, facility improvements, veterinary services, and record keeping.
The ultimate goal of these recommendations is to re- envision CCDAS as the lifesaving hub for Collier
County's homeless animals to protect the community's safety and well- being. As a central resource
center, CCDAS is well positioned to serve animals briefly while determining best outcomes based on
individual animal welfare and public safety. Every animal that leaves CCDAS within days through return
home, transfer to a rescue group, adoption, or neuter - and - release back to field is a success for CCDAS,
and the greatest win of all is preventing animals from ever entering the shelter in the first place.
/�N Achieving the community's desire to reduce euthanasia as a population management tool while also
remaining within the shelter's capacity for care will require collaboration with the non -profit animal
welfare sector and strategic deployment of the shelter's limited resources. CCDAS' ability to meet its
goal for reducing euthanasia while serving the needs of the community is currently hampered by:
• Insufficient staffing for the number of animals held on site
• Inability of staff to complete daily routines and simultaneously provide high - quality customer
service
• Frequent staff turnover due to insufficient training and poor morale resulting in inadequate
workforce capacity
• Supervisors diverting their skilled time to complete essential duties that should be delegated to
others
• Long length of stay leading to shelter crowding and spread of infectious disease
Despite these challenges, CCDAS staff are united in their commitment to saving animals in the shelter
and in providing the best care possible. CCDAS must empower staff to achieve their goals by
implementing a team approach to population management, minimizing length of stay by every means
possible, and leading community coalition formation.
The result of effective population management is reduction in length of stay that in turn will lead to:
• Marked reduction in total number of animals in the shelter
• Adequate staffing capacity to care forthe smaller population
• Reduced spread of infectious diseases
„�s
Maddie's Shelter Medicine Program I University of Florida��,
Packet Page -1367-
10/13/2015 16. D.12.
• Reduced animal stress and behavioral deterioration
• Improved live release rate, staff morale, and public perception
Immediate Recommendations:
Appoint a population manager and establish a population management team with the primary
goal of minimizing length of stay. The team approach is the most efficient and proven method to
facilitate efficient movement of each animal through the shelter system to a positive outcome.
Suggested Population Management Team members include the Shelter Operations Manager, Senior
Animal Care Specialists, Volunteer and Foster Coordinator, and a representative from the veterinary
services team.
The Population Manager should be empowered with the time and responsibility to ensure that
population rounds occur, follow up on decisions made by the team, track length of stay for the
population, and identify long -term stay animals and those needing additional planning to facilitate
their movement through the shelter system. While this would ideally be a full -time dedicated
position, CCDAS can immediately appoint an existing staff member from among the Population
Management Team to fill this role. The staff member should have the time and authority to devote
a portion of each work day to population management activities in addition to rounds, cultivate a
strong rapport with the Humane Society Naples and other rescue groups, and perform a daily
assessment of CCDAS' options for animal placement to remain within capacity including foster care,
medical caseload, adoption floor inventory, and rescue partner saturation.
2. Implement population rounds. The Population Management Team will perform regularly scheduled
walk- through rounds to determine for each animal:
• Current condition
• Immediate needs
• Best options for live release and requirements for rapid movement to disposition with
accountability for completion
Population management rounds are performed by the Population Management Team 3 -5 times per
week. The team spends one hour or less moving through the shelter systematically from cage to
cage to evaluate length of stay, what is required for release, and placement options. The goal is to
identify delays in animal movement through the shelter, to maximize each animal's chances of a live
outcome, to ensure that each animal is on an appropriate pathway from intake to outcome, and to
provide early recognition of the needs of individual animals. This also provides an opportunity to
identify and formulate a plan to address concerns regarding physical and behavioral health. If time
constraints preclude moving through the entire shelter during each rounds session, the team can
visit different sections of the shelter on alternating days while still covering all areas of the shelter at
least twice a week.
Maddie's Shelter Medicine Program ( University of Florida
Packet Page -1368-
10/13/2015 16.D.12.
3. Institute open selection. Allow potential adopters and rescue partners to view and select all
adoption -track animals including those on stray hold. The pre - selected stray animals should be
released to the new adopter following surgery or transferred to the rescue partner the day the hold
period expires if they have not been reclaimed by an owner. By allowing for selection during the
stray hold, open selection can significantly decrease an animal's length of stay and free up space,
staff time, and resources for others.
• To institute open selection, Building 4 should be accessible to the public and volunteers in
addition to Building 3.
• Building 5 can remain restricted to protect the public from access to dangerous dogs, those
involved in legal custody cases, and sick dogs.
• All adoption -track cats should be housed in view of the public.
4. Improve signage for visitors in public areas. Members of the public arriving in the lobby need
further assistance in orienting to the layout of shelter buildings that they can access. A large diagram
of the adoption areas (cats in the lobby, cat rooms off the lobby, and dogs in buildings 3 and 4) as
well as clear signs and arrows to direct visitors to those locations would improve accessibility and
viewing of animals available for adoption.
5. Prioritize fast - tracking of puppies /kittens and highly adoptable dogs /cats. Fast tracking involves
expedited priority movement of highly adoptable animals through the shelter system based on
young age, exceptional personality or appearance, prior training, or compelling history. These
animals should be placed in a highly visible location and can be spayed or neutered as soon as their
stray hold is complete (even if they are not yet selected for adoption). The overall goal is to reduce
animal care days and therefore average length of stay by removing any barriers to rapid live release
for these easiest -to -place animals.
6. Remove barriers to prompt transfer of animals to rescue groups. Animals should be available on a
first -come, first -serve basis. No dog or cat should ever be held in the shelter for specific adopters or
rescue partners if there is another adopter or rescue partner prepared to take them sooner.
Facilitating rapid and seamless transfer of animals to Humane Society Naples ( CCDAS' primary
transfer partner) is a top priority for the Population Manager.
Develop an efficient system to follow up with Interested Parties. Members of the public bringing in
stray animals may express interest in adopting following completion of stray hold. In addition to
recording this information in Chameleon, it is essential to implement a mechanism for staff
members and volunteers to follow up and facilitate an adoption the day the animal becomes
available. These animals can be pre - selected by their finders as part of the open selection process.
8. Obtain a high quality photograph and accurate, complete description of every animal upon intake.
Photos and descriptions posted on the CCDAS website and on cage cards are critical to reunite lost
Maddie's Shelter Medicine Program I University of Florida 4
Packet Page -1369-
10/13/2015 16.D.12.
pets with their owners and to publicize animals for adoption or transfer to rescue partners.
Attractive photographs that fully display the animal accompanied by an accurate description of
appearance, sex, and general age are as essential to live release as appropriate medical care,
husbandry, and vaccination on intake. Staff must be provided with training, equipment, time, and
assistance to obtain high quality photographs at intake. Volunteers can be enlisted to take
additional photographs for adoption promotion.
9. Consider Humane Society Naples to be the equivalent of a highly successful CCDAS offsite
adoption center. This comparison illustrates the urgency of sending highly adoptable animals who
will have a short length of stay at HSN and quickly yield space to bring more animals for display.
Quickly transferring these animals out provides CCDAS more time and space to focus on animals
who needs more individualized placement planning. All staff should consider every animal
transferred to HSN as a success for CCDAS, particularly those sent immediately after intake. Adopting
this philosophy is crucial to increasing the life- saving capacity at CCDAS
10. Update and utilize the "Lost Pet Book" frequently. Lost /found reports represent a key lifesaving
opportunity that is underutilized when kept in a format that is difficult to review and maintain.
Reports should be posted online with permission from the client making the report. Shifting the
lost /found infrastructure online would enhance its efficacy significantly when paired with high
quality intake photos. Volunteers can routinely update postings, follow up on previous reports, and
reconcile reports with the kennel inventory to look for possible matches.
Next Steps:
1. Convene an Executive Rounds Team for long stay animals. Animals remaining in shelter care for
longer than 2 -3 weeks are at increased risk for behavioral deterioration and compromised welfare
and are therefore a top priority for expedient live release. The Executive Rounds Team is tasked with
creatively and proactively developing an individualized plan to find alternate out -of- shelter
placement for these at -risk animals. Sample plans would include marketing strategies, foster -to-
adopt placement, rescue partner appeals, training sessions with a local trainer to improve first -
impression presentation, and changing the animal's display location in the shelter or at off -site
venues.
Members of the Executive Rounds Team include all members of the Population Management Team
with the potential intermittent additions of the Director, local dog trainers, a representative from
Humane Society Naples and other rescue partners, volunteers very familiar with the animals under
discussion, and other parties with relevant expertise as timing and schedules allow. Meetings of the
Executive Rounds Team could initially occur monthly to begin addressing animals with lengths of
stay over 3 weeks. Ultimately, meeting frequency should increase with the goal of defining a specific
placement plan for any animal with a length of stay over 2 weeks.
Maddie's Shelter Medicine Program I University of Florida
Packet Page -1370-
10/13/2015 16.D.12.
n 2. Track average length of stay on a weekly and monthly basis. The Population Manager should
follow trends in the average length of stay for various populations in the shelter to evaluate the
impact of open selection, fast - tracking, and population rounds. Average length of stay should be
tracked for each type of outcome (adoption, rescue, return to owner, and euthanasia) and animal
group (adult dogs, puppies, adult cats, kittens). This tracking will also guide individual animal
decisions.
Display all adoption -track cats in the lobby. Public access to Building 2 for open selection of cats is
not practical due to the current sanitation schedule and multi- purpose use. As an alternative, all cats
considered to be future adoption candidates should be housed in the lobby for public viewing and
pre - selection during stray hold. This will involve installing more individual housing units such as
commercially available cat condos. All adoption condos should prioritize stress reduction for the cats
by providing appropriate space to hide, to stretch out fully, to sleep in a separate area from the
litter box, and to groom /scratch /play.
4. Determine and deploy the most effective promotional activities to increase adoption foot traffic
including special events and off -site adoption options. Tracking the volume of visitors and
adoptions resulting from various marketing strategies will allow CCDAS to evaluate and replicate the
highest yield use of resources and planning time.
5. Empower the CCDAS Director with discretion to reduce or waive adoption fees for promotional
purposes as needed. Adjusting adoption fees for special events and promotions has become a
proven and industry standard marketing technique to increase adoptions at animal shelters.
Minimizing length of stay through promotional events is almost universally of greater fiscal benefit
than the fees generated from adoptions. Empowering the Director with full discretion to reduce or
waive adoption fees on individual animals or for special events will be an important step for CCDAS
in reaching its goals of improved live release and shortened length of stay.
6. Utilize the foster program to leverage short-term and foster -to -adopt homes at the discretion of
the Foster Coordinator and the Population Management Team. While medical treatment and
underage care and socialization are key uses for a foster program, CCDAS' commitment to increasing
live release will demand expanded flexibility in determining eligibility for foster home placement.
Many shelters have experienced great success with empowering foster families to market and place
long -stay shelter animals from their homes through an Adoption Ambassador program. Short-term
foster placements for a weekend or holiday can provide immediate marketing photos, videos, and
information to increase an animal's adoption appeal in the shelter. CCDAS policy should allow
flexible allocation of foster home resources
7. Give the Director discretion to waive reclaim fees when needed to keep animals in good homes.
Holding animals as collateral to obtain payment for fees is counterproductive when the result is
another animal surrendered to CCDAS to care for and place. Returning an animal back to an
adequate home should be considered the desired outcome, and the Director should have authority
Maddie's Shelter Medicine Program I University of Florida t a 6 F
Packet Page -1371-
10/13/2015 16. D.12.
to remove institutional barriers to live release, including the discretion to reduce or waive reclaim
fees.
8. Limit public hours for intake from 11 am to 5 pm Monday through Saturday to provide staff with
protected time to complete essential duties without interruption. Reduction in "over- the - counter"
intake hours can shift staff focus and empower more efficient time management. Tasks such as
euthanasia, cleaning the cat adoption cages in the lobby, and other necessary daily routines are
most efficiently performed during dedicated time in the morning. Continual interruptions to process
animal admissions before 11am prolong completion of morning tasks. There should also be an
adequate window of time after the last shelter admission for the day to complete intake procedures
without hurrying or taking shortcuts. Uninterrupted completion of these activities will make staff
available to focus on customer service for animal intake, assisting with lost animal walk- throughs,
and adoption counseling during public hours.
9. Schedule owner - requested euthanasia appointments and discontinue private cremation services.
While providing euthanasia services is a valuable community resource, it also requires significant
staff time. To minimize disruption of other staff duties, establish set days and times for the majority
of euthanasia requests to enable planning and availability of assigned staff. Members of the public
calling to inquire about euthanasia services should be directed to come during these windows of
time or be assigned an appointment time to streamline the process. Walk -in and emergency
euthanasia requests would of course still be accommodated immediately, but the frequency of
disruption would be reduced.
Private cremation services require excessive staff time and money, all of which is diverted from the
care of shelter animals. Income from this service does not return the resource investment, and thus
should be discontinued or outsourced.
10. Cultivate enhanced collaboration between Domestic Animal Services and Humane Society Naples
in pursuit of the shared goal of reducing euthanasia. CCDAS is extremely fortunate to have HSN as
a primary transfer partner, and there is opportunity to build upon this relationship for mutual
benefit. Minimizing length of stay at CCDAS prior to transfer to HSN is a top priority for both
organizations to mitigate risk of infectious disease and expedite advanced medical treatment. It
would be ideal if animals identified as destined for HSN could go there immediately upon arrival or
even directly without ever entering CCDAS. Strategies to facilitate immediate diversion include:
• Allow animals to complete their stray holding period at HSN when that best serves the
needs of the animal (i.e. underage, injured, and sick animals). Photos of these animals can
remain listed on the CCDAS website visible to owners looking for lost pets.
• Refer relinquishers of kittens and pregnant cats directly to HSN as an alternative to CCDAS
intake when HSN has space available to take them.
Maddie's Shelter Medicine Program I University of Florida 7
Packet Page -1372-
10/13/2015 16. D.12.
• Hold regularly scheduled meetings in person or by phone between the Population Manager
at CCDAS and key HSN personnel in charge of selecting animals to provide feedback on any
barriers to efficient transfer and to update each other on the current animal inventory and
needs of both organizations.
11. Expand volunteer responsibilities. The dedicated legion of volunteers is one of CCDAS' greatest
assets and represents an unlimited opportunity to improve animal care and customer service. The
volunteers can be leveraged more extensively to assist staff with time- consuming duties such as
laundry, lost pet walk - throughs, behavioral enrichment for dogs and cats, spot cleaning cages of cats
available for adoption in the lobby, obtaining photos of animals for adoption promotion, adoption
counseling, and assisting the public at the front desk. Placing a trained volunteer in the lobby during
peak hours to assist visitors as they arrive and to answer questions could help staff with the
intensive demand to provide high quality customer service while dealing with a high volume of
phone calls and visitors. Volunteers are urgently needed to provide socialization, behavioral
enrichment, and adoption counseling for cats. An open dialogue between CCDAS management,
staff, the Volunteer Coordinator, and volunteer leadership can promote innovative ways to expand
the volunteer presence at CCDAS.
12. Provide innovative positive alternatives to keep cats and dogs in the home when admission to the
shelter is not the best choice (alternatives to intake). CCDAS has established a strong foundation
for this program by offering pet food and vouchers for spay /neuter surgery, and there is enormous
^' potential to expand the provision of alternatives to shelter admission. Behavior and training
support, a veterinary care assistance fund, pet - friendly housing resources, temporary crisis foster
homes, and providing a courtesy listing of pets available for adoption from private homes are all
innovative programs that have provided successful alternatives to intake at municipal shelters in
other communities. Additionally, members of the public surrendering underage kittens should be
encouraged to enroll as foster homes and receive resources, training, and support to keep the
kittens in their home until they are of adequate age to return for immediate adoption at CCDAS or
Humane Society Naples. Finders interested in keeping stray animals with no identification could
also be enlisted as foster homes for the duration of the animal's stray holding period while excellent
photos and an accurate description are posted on the CCDAS website in hopes of owner
reunification.
13. Visit regional shelters with highly successful population management strategies. Hillsborough
County Pet Resource Center has been implementing many of these progressive municipal animal
shelter programs and would serve as an excellent nearby resource and model for CCDAS.
Jacksonville Animal Care and Protective Services also demonstrates successful alternative -to- intake,
return -to -field, and other innovative programs that would be useful to see in action. CCDAS
management, staff, and volunteers would all benefit from visiting these shelters as well as Humane
Society Naples in person to determine what programs and philosophies would be applicable for
CCDAS.
Maddie's Shelter Medicine Program I University of Florida 8'
Packet Page -1373-
10/13/2015 16.D.12.
Lone Term Goals:
1. Redeploy shelter resources including program support and facility upgrades to increase live
release for cats. The striking disparity between canine and feline live release rates at CCDAS
necessitates management -level allocation of attention to the specific needs of cats. The majority of
staff time, physical space, and policy language targets dogs; strengthening the organizational
commitment to cats will be essential to meeting CCDAS' goals for progressive sheltering and
improved overall animal live release. Examples of feline- specific priorities include improved and
increased housing in the adoption area, improved housing in the stray hold building, enhanced
enrichment and marketing activities, and alternative live- release options such as rescue partnerships
and return -to -field programs.
2. Schedule intake of cats and dogs to ensure humane and efficient movement through the shelter
system to an appropriate outcome (managed admission). Deferring admission for owner
surrenders empowers the shelter to remain within the capacity for care while also maximizing each
animal's opportunity for a live release. There is now a strong precedent established by municipal
shelters around the country for admitting owner - surrendered animals by appointment determined
by available space. Many animal owners are willing to keep their pet temporarily knowing that
survival potential in the shelter will be improved by waiting a few days or weeks, particularly when
other resources such as pet food, behavior guidance, low cost veterinary care options, and photo
listing on the internet are offered in the interim. The shelter always has the discretion to offer
immediate admission to animals in imminent risk, and deferment of even a small number of
surrenders at a controlled time increases the flexibility of the shelter to serve emergency admits
more effectively. Communication during the surrender process should strive to elicit a thorough
medical and behavior history while also establishing transparency about the chances of live release
for that specific animal.
3. Revise county code to eliminate mandatory hold times for puppies, kittens, and adult cats without
identification. Redefining these animals to allow immediate adoption or transfer to rescue partners
alleviates the strain on housing capacity, reduces the likelihood of infectious disease outbreaks, and
increases the shelter's life- saving capacity. Hillsborough County has instituted a very progressive
policy to target use of the stray holding period for animals most likely to be reclaimed (i.e. animals
with identification). Their ordinance would be a good model for Collier County to consider.
4. Remove barriers to optimal community cat management. Expanding the role of return -to -field and
community cat management support programs in Collier County is critical to CCDAS' goal of
improving the live release rate for cats. The TNR Memorandum of Understanding established in
support of a pilot program for TNR demonstrated that TNR plays an important role in humane
community cat management in Collier County; however, at this time, the MOU has become an
administrative barrier to maximizing the contribution of TNR to humane community animal control
and nuisance mitigation. Replacing the existing MOU with a policy that enhances use of TNR as an n
alternative to high euthanasia rates of cats will allow the necessary step that CCDAS must take to
Maddie's Shelter Medicine Program I University of Florida
Packet Page -1374-
10/13/2015 16.D.12.
1001**41 move forward with its life- saving goals for cats: redirect healthy thriving stray adult cats to programs
that provide sterilization, vaccination, and return to the location where they were found.
Implement a structured staff training program in customer service that promotes open,
supportive communication with potential adopters and members of the public surrendering
animals. There are many excellent models for basing the adoption process around a structured yet
positive conversation between staff and customers that emphasizes determining and shaping
expectations to maximize the chances of success in each adoption. Trained volunteers can also be
highly effective ambassadors to improve customer service for potential adopters and all shelter
visitors. Resources are available through the Humane Society of the United States and many others,
but ultimately internal dialogue, improved staffing at the front desk, mentorship, and formal
internal training will be critical. Achieving CCDAS' goals for an improved live release rate will require
an organizational commitment to improved customer service by reducing staff stress and supporting
staff with the time and skills necessary to serve the public effectively.
6. Extend adoption hours to increase public access. Many shelters find evenings and both weekend
days to be prime times for adopter foot traffic. Scheduling staff in shifts to accommodate animal
husbandry activities earlier in the day with an emphasis on customer service in the afternoons and
early evenings, particularly on weekends, can be highly effective. CCDAS could consider a trial with
extended hours for adoptions on one weeknight (Wednesdays) and Sundays in addition to existing
Saturday hours during the summer. Closing to the public for one day during the week such as
Mondays could help to balance the increase in staffing demands.
7. Establish a community coalition among key organizations with the overall goal of reducing the
reliance on euthanasia as a population management tool in Collier County. Essential partners
would include CCDAS, Humane Society Naples, Collier Spay & Neuter Clinic, and rescue and Trap -
Neuter- Return (TNR) groups active in the county. This coalition should initiate a formalized process
for community collaboration as the directors of key agencies meet regularly to establish goals,
develop strategies, assess outcomes, coordinate resources, and facilitate communication with the
goal of reducing euthanasia of animals in Collier County. The coalition should compile and share
community -wide animal sheltering statistics on a monthly basis, regularly review progress toward
goals, and adjust strategies frequently based on this feedback. Together, the key agencies would
seize opportunities for novel approaches found to be successful in other communities, such as
mega- adoptathons, foster to adopt, owner retention support, and increased access to spay /neuter
services. There are existing resources for building community collaboration that hold great promise
for Collier County including Target Zero (www.target- zero.org) and Pets for Life
(http: / /www.humanesociety.org/ about /departments /pets- for - life).
8. Cultivate an organizational culture that promotes innovation and embraces opportunities. To
illustrate, the default attitude of all staff and management to suggestions and potential
improvements should be "yes ". Rejecting barriers and valuing problem - solving opens the door to
further discussion, brain- storming, and collaboration.
Maddie's Shelter Medicine Program I University of Florida
Packet Page -1375-
10/13/2015 16.D.12.
Recordkeeping Recommendations
Many of the consultation recommendations for CCDAS necessitate efficient use of staff time and
effective communication throughout the shelter. Utilizing the shelter's management software program
Chameleon to its full potential will be critical as CCDAS implements these initiatives. Chameleon is a
powerful tool and should be used more proactively to ensure consistency in treatments, institute
adequate recordkeeping, and improve deployment of staffing resources. The following
recommendations are necessary to fulfill the potential for enhanced clarity and efficiency that electronic
medical records offer. Complete and accurate information on each animal gathered in one place
through the Chameleon record is essential for CCDAS to fulfill its responsibility to animal welfare and
public safety. The ASV Guidelines state, "Basic elements of a record should include: the identifier,
results of microchip scan, microchip number if present, source of animal, dates of entry and departure,
outcome, species, age, gender, physical description (breed and colors), and available medical and
behavioral information."
1. Ensure that technology access is sufficient to allow convenient access to Chameleon in key areas
of the shelter. Computer terminal access needs to be close and convenient for all animal care
activities, particularly for intake processing, veterinary services, adoption counseling, and kennel
management. Portable computer access in the form of laptops and /or tablets facilitate the
reviewing and updating of records in animal housing areas. Reliable, continuous wireless network
access throughout the entirety of all shelter buildings is necessary in order to conduct efficient
medical records entries and population rounds.
2. Enhance Chameleon utilization as a necessary population management tool. Chameleon offers
significant potential to aid in planning decisions for the population. Computer records should
contain all the relevant information about each animal's history, medical information, behavior
observations, and outcome all in one access point. Breed labeling is a complex and multifaceted
responsibility of sheltering organizations; internal consistency with use of breed designations to
reflect physical appearance will facilitate accurate data collection. The Population Manager and
Team should be able to use Chameleon for a detailed length of stay analysis as well as during rounds
for individual animal planning.
3. Appoint an internal Chameleon Task Force committee to facilitate improved Chameleon use
throughout the shelter. The Task Force should include representatives from throughout shelter
operations (animal care specialists, senior animal care specialists, veterinary services, animal control
officers, front desk staff, and management) and should meet at regularly designated times. The
Task Force can develop a time frame with implementation goals, develop a plan to seek mentorship
(see below), identify and address obstacles to transition, and schedule internal training sessions.
4. Identify local mentors to model effective use of Chameleon. Jacksonville Animal Care and
Protective Services and Hillsborough Pet Resource Center are two examples of high - performing
Maddie's Shelter Medicine Program I University of Florida 1�
Packet Page -1376-
10/13/2015 16.D.12.
shelters that utilize Chameleon as integral to their operations. The internal Chameleon Task Force
should seek out opportunities to send staff members to an organization such as these on a set
schedule to shadow their equivalent job positions on efficient use of Chameleon.
5. Establish Chameleon literacy as a basic job expectation for all staff. The investment in staff training
in comprehensive use of Chameleon will be well returned in increased efficiency and accuracy.
Training options include the annual national Chameleon Software Conference held in each year, in-
house training with a representative from Chameleon, conference calls with Chameleon technical
support, and in- service staff training meetings led by other staff. It would be prudent to designate
one or two staff on the Chameleon Task Force with anticipated longevity in the organization to take
the lead on seeking out ways to maximize Chameleon functions, finding training opportunities, and
training others on new skills.
6. Consider bringing in an outside Chameleon efficiency consultant for intensive staff training and to
provide recommendations for effective program use specific to CCDAS. The cost for this training
could be well justified by the increased efficiency and accuracy yielded from streamlined Chameleon
usage. The Task Force may also identify particularly helpful contacts at local mentor shelters who
could be hired to conduct internal on -site training at CCDAS.
7. Reconcile the kennel inventory with Chameleon records throughout all shelter buildings every
day. Maintaining an accurate location record in Chameleon for each animal in the shelter at all times
is essential. Fortunately, use of the "Quick Kennel" system makes this process rapid and user -
friendly. One staff member should be assigned the task of updating the kennel inventory for dogs,
cats, and all other species each morning. This task does not necessarily need to be completed by a
Senior Animal Care Specialist.
8. Utilize the Basic Data Matrix from the National Federation of Humane Societies to collect and
report data. This minimum data matrix defines the data an animal sheltering organization should
collect, serves as a common language for data collection across the wide spectrum of agencies, and
allows organizations to benchmark their productivity against other organizations. Focusing on this
data reporting strategy would be more useful to CCDAS at this time than using the Asilomar Accords,
which are not currently providing CCDAS with accurate intake and outcome data. [See Resources
folder]
Maddie's Shelter Medicine Program I University of Florida 12
Packet Page -1377-
10/13/2015 16. D.12.
Veterinary Services Recommendations
Shelter medicine is truly a unique blend of both population and individual animal medicine. Complete
veterinary care of shelter animals requires focused expertise combining elements of epidemiology,
infectious disease control, behavioral care, surgery, and shelter management. More specifically the
shelter medicine practitioner must have an expanded understanding in areas including, but not limited,
to: shelter facility design and operation; husbandry (including housing, nutrition, cleaning and
disinfection); vaccination; common shelter infectious disease and behavior problem prevention,
diagnosis and treatment; resource management and risk analysis; strategies for control of companion
animal overpopulation; personnel management; companion animal welfare, public health protection
and disaster response. Shelter medicine practitioners must also be well versed in legal, regulatory,
ethical and emotional aspects of shelter animal care. This is in addition to a solid foundation in
traditional medical and surgical veterinary disciplines.
The primary responsibility of the shelter veterinarian is assurance of the health and welfare of every
animal in the shelter. No other employee has such an advanced level of training and expertise to assess
and manage medical and behavioral issues of sheltered animals. This involves the care of individual
animals, population management, and development of medical protocols. To be effective:
• The veterinarian must have an open and efficient system of seamless communication with the
animal care team and management.
• The veterinarian should have sufficient protected time available for daily contact with every
animal in the shelter, animal examinations, rounds, surgery, and medical procedures.
• The veterinarian should have additional protected time for protocol development, staff training,
systematic reviews, and professional development.
• The veterinarian must have the support of management in creating and implementing protocols
for animal care based on current shelter medicine practice standards.
According to the ASV Guidelines for Standards of Care in Animal Shelters, "Health is not merely the
absence of disease or injury but is also closely tied to an animal's physical and mental well- being. Proper
medical management and health care for shelter animals is an absolute necessity and must include
attention to overall well- being. It is commonly accepted that animal shelters have a responsibility to
provide for the health and welfare of all animals who enter their care... Shelter medical programs must
include veterinary supervision and the participation of trained staff to provide evaluation, preventive
care, diagnosis and treatment... Shelter healthcare protocols should support individual animals regaining
and maintaining a state of physical health and are essential for maintaining an overall healthy
population by reducing the frequency and severity of disease. Individual animal welfare must be
maintained within the balance of decisions and practices that support the overall population.
Comprehensive shelter medical programs that begin on intake and continue throughout each animal's
shelter stay are the foundation of a shelter housing a population of increasingly healthy animals. Decline
of animal health and welfare after intake; sick or injured animals languishing without proper treatment;
Maddie's Shelter Medicine Program I University of Florida; 13
Packet Page -1378-
10/13/2015 16.D.12.
wide scale disease outbreaks; animals dying as a result of shelter- acquired disease or injury; and
frequent zoonotic disease transmission in the shelter are indicators of a poor healthcare program."
Immediate Recommendations:
1. Remove animals with signs of infectious disease from the general population and medical clinic
and house them in a designated isolation space. ASV Guidelines for Standards of Care: "Animals
with a suspected infectious disease must be isolated until diagnosis or subsequent treatment
determines them to be low risk to the general population. It is unacceptable to allow animals with
severe infectious disease to remain in the population." Cats with clinical signs of respiratory
infection should be moved to isolation where staff practices appropriate levels of biosecurity when
providing care. Dogs with respiratory infections should be housed in Building 5. Animals with
respiratory infections that are selected for treatment and placed on an adoption or transfer
pathway are also priority candidates for foster care. Ringworm is a contagious disease of public
health significance; animals with suspected ringworm infections should not be housed in the general
population or medical clinic and must be isolated. Newly arrived animals or animals "reserved" for
special interests should not be housed in Building 5 due to the significant risk of exposure to
infectious disease (see "Facilities" recommendations).
2. Conduct rounds at least once every 24 hours to visually observe and monitor the medical and
behavioral health of every animal. ASV Guidelines for Standards of Care: "Rounds must be
conducted at least once every 24 hours by a trained individual in order to visually observe and
monitor the health and well -being of every animal. Shelter medical staff must regularly monitor the
status of individual animals and the population as a whole. " Daily medical rounds represent the
foundation of an effective animal healthcare program. Uncertainty regarding an animal's medical or
behavioral condition and treatment plan can delay movement of an animal through the shelter
system and contribute to crowding and poor welfare. Visually observe every animal and its
environment prior to cleaning, taking note of food consumption, water consumption, urination,
defecation, attitude, behavior, ambulation, and signs of stress, illness, or injury. All animals in group
housing must be observed daily for warning signs including excessive hiding, agonistic behaviors
(bullying or resource guarding), and loss of appetite. Rounds can be conducted by the veterinarian,
veterinary technician, or a trained staff person. Create a daily action list for the veterinary services
team based on observations from daily rounds. [See the Daily Veterinary Checklist in the Resources
folder]
3. Vaccinate all animals over 4 weeks of age on or before intake, including those who are sick,
injured, lactating, quarantined, and feral. ASV Guidelines for Standards of Care: "Animals must be
vaccinated with core vaccines at or prior to intake..." Follow industry guidelines for vaccine
selection and administration as recommended in the shelter - specific best practices provided in the
2011 American Animal Hospital Association Canine Vaccination Guidelines and 2013 American
Association of Feline Practitioners Feline Vaccination Advisory Panel Report. Discontinue use of
leptospirosis and coronavirus vaccines for dogs. Provide a second DHPP or FVRCP vaccine two
Maddie's Shelter Medicine Program University of Florida SsY'.
Packet Page -1379-
10/13/2015 16. D.12.
weeks later for adults, and vaccinate juveniles every two weeks while housed in the shelter until
they reach 18 -20 weeks of age. Administer intranasal eordetella + Parainfluenza vaccine to dogs
and puppies. Feral or fractious cats can be safely vaccinated in their trap or wire transfer cage by
using a trap comb to confine them to one end. Train staff on recognition of vaccine reactions with a
plan of action if a reaction is suspected. [See the AAHA and AAFP Vaccine Guidelines documents in
the Resources folder.]
4. Provide pain management of appropriate strength and duration to relieve pain. Failure to provide
treatment for pain is unacceptable according to all industry guidelines. ASV Guidelines for
Standards of Care: "Pain must be recognized and treated to alleviate suffering. Analgesia must be an
appropriate strength and duration to alleviate pain. Animals must be reassessed periodically to
provide ongoing pain relief as needed. When adequate pain relief cannot be achieved, transfer to a
facility that can meet the animal's needs must be provided .... It is unacceptable to not provide
treatment for pain." All veterinary care staff must review and embrace the guidance provided in the
2015 AAHA /AAFP Pain Management Guidelines. Staff must combine findings from physical
examination (i.e. suspect recent trauma), individual behavior, and knowledge of the degree of pain
associated with particular surgical procedures, injuries, and /or illnesses to assess pain. Animals
must be reassessed daily or at defined intervals to provide ongoing pain relief as needed. When
adequate relief cannot be achieved, transfer to another facility must be provided. Provide formal
training for staff regarding recognition of pain in animals. Pre- and post- operative analgesia is
required for animals undergoing elective surgery in the shelter, including spaying and neutering.
n
The current analgesia protocols are inadequate, and most animals leave the shelter the day of
surgery with owners /adopters who are not counseled or skilled to recognize pain. Nonsteroidal
anti- inflammatory drugs (NSAIDs) are a widely accepted mainstay for management of perioperative
pain in veterinary medicine. [See the 2015 AAHA /AAFP Pain Management Guidelines document
and the Humane Alliance dog /cat analgesia charts in the Resources folder]
5. Identify shelter animals that are experiencing moderate to severe anxiety, fear, or kennel stress,
and provide treatment. ASV Guidelines for Standards of Care: "Staff must be trained to recognize
body language and other behaviors that indicate animal stress, pain and suffering.....Animals must
be monitored daily to detect trends or changes in well -being and respond to their behavioral
needs." Implement the use of trazodone in dogs exhibiting signs of behavioral deterioration, kennel
stress, anxiety, or fear, including dogs who have only recently entered the shelter. Utilize the
sample dosing sheets provided and identify a mechanism for how veterinary technicians should
identify and begin dogs on trazodone, with veterinary supervision. Train staff to monitor for side
effects and to know when an appropriate dose has been achieved. [See the Canine Trazadone
Protocol in the Resources folder]
6. Adhere to the published Association of Shelter Veterinarians veterinary medical care guidelines
for spay- neuter programs. There are multiple components of the shelter spay- neuter service that
require immediate attention to improve quality, including record keeping, anesthetic management,
and postoperative care. Veterinary care staff should review and embrace recommended procedures
in the 2008 ASV Spay- Neuter Guidelines. Mask or chamber induction with inhalant anesthetic must
0k1 5
Maddie's Shelter Medicine Program ( University of Florida � `$
°� '<n
Packet Page -1380-
10/13/2015 16.D.12.
not be performed routinely and should be avoided whenever possible. Mask maintenance during
surgery should be minimized for patient and staff safety. Continuously monitor animals recovering
from anesthesia. This may be best accomplished by creating a recovery "beach" area in one corner
of the medical clinic space. The medical team should visit other model shelter spay- neuter services
to gain knowledge of current best practices for efficiency and patient care. The best model is
Humane Alliance in Asheville, NC (http: / /humanealliance.org /). This organization offers high- quality-
high volume spay /neuter training for veterinarians (http: / /humanealliance.org /vet- training) and for
entire teams (http: / /humaneaIliance.org /team- training). The use of a permanent tattoo is strongly
recommended to mark cats and dogs at the time of spaying or neutering surgery. [See the 2008
ASV Spay- Neuter Guidelines document in the Resources folder.]
7. Eliminate barriers to discharge from the shelter environment for animals with medical concerns
by embracing foster -to -adopt programs and collaborating with transfer partners. The current
philosophy of housing animals in the shelter in order to medicate them or restricting them. from
adoption /foster /transfer pathways because of medical concerns directly contributes to
overcrowding and poor animal welfare. Members of the community (fosters, adopters, owners) are
capable and willing to provide care to these animals, which will alleviate strain on housing and staff
capacity at the shelter and provide a much better environment for recovery for the animals.
Animals who are adopted but not able to undergo spay- neuter surgery should be enrolled as foster -
to -adopt candidates and not housed in the shelter. Animals should not be housed in the medical
clinic long -term because daily care consumes time that must be focused on meeting the medical
n� needs of the entire shelter population and improving animal flow to live outcomes. With exception
for aggressive animals, legal custody cases, or animals with poor prognosis for recovery, all animals
in the shelter should be actively promoted for adoption or transfer, regardless of medical needs
Develop a written emergency medical treatment protocol to provide appropriate and timely care
for any animal who is injured, in distress, or showing signs of significant illness. ASV Guidelines for
Standards of Care: "An emergency care plan must be in place. Staff should be trained to recognize
conditions that require emergency care." Include provisions for when the veterinarian is on -site but
occupied, when the veterinarian is off -site but available by telephone to give recommendations, and
for when the veterinarian is not available. Include a list of signs and conditions that constitute an
emergency. Note conditions that routinely warrant euthanasia without prior exam by a
veterinarian. Ensure that all officers, animal care staff and foster parents receive training in
recognition of emergency conditions. Include a protocol for euthanasia decisions required during
the legal stray hold period. The shelter can develop a contract with a local emergency clinic for
after -hours care. Officers can transport animals for stabilization or euthanasia if the attending
veterinarian deems it medically necessary. Typically in these relationships, the clinic has standing
approval for a specified amount (i.e. $100 -200 per animal), which allows for examination, pain
management, and fluid therapy. Additional diagnostics and treatment must be approved by a
shelter supervisor.
Maddie's Shelter Medicine Program I University of Florida 16
Packet Page -1381-
10/13/2015 16.D.12.
Next Steps:
1. Develop written protocols for disease prevention and management, to include disease
recognition, communication, decision- making, treatment, and monitoring. Protocols for
administering medications for management of common diseases should be developed in
consultation with the veterinarian and provided to staff. All treatments should be documented in
the patient's medical record. In each protocol, include sufficient detail to allow the medical staff to
provide adequate care in the veterinarian's absence. This includes: indications for treatment,
description of how to monitor the animal, indications to end treatment, and directions for
supportive care. Utilize dosing charts by weight for commonly prescribed medications and confirm
that the dose prescribed is adequate (the calculated dose of doxycycline compounded in the shelter
for administration to cats was 10 -15 times below the recommended therapeutic dose of 10mg /kg).
Use appropriate dosages and duration in accordance with published recommendations to decrease
the occurrence of bacterial resistance. [See the Koret Sample URI Treatment Protocol and ISCAID
Guidelines for Antimicrobial Therapy of Canine Pyoderma in the Resources folder.]
2. Develop comprehensive biosecurity protocols based on a current understanding of principles of
shelter medicine. In animal shelters, frequent animal turnover often leads to movement of animals
that may be incubating diseases. Insufficient housing unit size (especially severe for cats in holding
and isolation), noise, crowding, and unmet needs for enrichment may contribute to stress,
compromised immunity, and increased susceptibility to infectious diseases. Although the threat of
infectious disease entering and spreading within the shelter can be minimized, it can never be
eliminated, and biosecurity protocols and staff training are critically needed. Protocols should
include indications for use of personal protective equipment, such as gloves, boots, and gowns,
instructions for frequent hand sanitation, and step -by -step instructions for monitoring and
medicating infectious animals housed in isolation. Provide dedicated clothing (scrub tops, smocks,
lab coats, gowns, jump suits) that are worn only during "dirty" activities, such as cleaning, treating
sick animals, or euthanasia. Staff must change to clean clothing (especially tops) after these
activities and before proceeding to handle healthy animals, especially new intakes.
3. Develop a detailed written protocol and train staff to perform timely intake processing, including
gathering history, identification, examination (health status and age determination), vaccination,
and parasite treatment. During intake, staff should solicit medical and behavioral information from
owners and finders and any additional history or information about possible ownership. Finders and
owners must be asked if the animal has bitten or scratched any person in the past 10 days (to
pursue required 10 day rabies quarantine prior to final disposition of the animal if necessary).
Reasons for surrender should be obtained, including additional information regarding past
aggression or behavior /medical concerns. Assign two staff members to perform intake processing
within one hour of the animal's arrival before moving to their selected housing area. Train staff to
assess body condition score, determine age and sex, and correctly identify breed at intake. The
protocol should contain step -by -step instructions for physical examination and a clear plan of action
for reporting medical problems at intake and tracking responses in the computerized medical
Maddie's Shelter Medicine Program I University of Florida 17
Packet Page -1382-
10/13/2015 16.D.12.
n record. Record examination findings (both normal and abnormal) and any treatments in the
computerized medical record. Provide computer workstations (even a laptop) in the intake
processing areas to facilitate proper record keeping and improve efficiency. Implement and enforce
biosecurity precautions to reduce the risk of fomite transmission of infectious diseases during intake
processing.
4. Develop and implement a comprehensive microchip identification protocol. Require use of
universal scanners in all areas of the shelter, including front desk, intake processing, euthanasia,
medical clinic, and animal control vehicles. Require scanning at each of the following points: in the
field for immediate reunification with owner, as part of the intake examination upon entry to the
shelter, at the time of medical exam /microchip implantation, at the time of adoption, transfer, or
move to and from foster care, and prior to euthanasia. Train all staff and ACOs on proper microchip
scanning technique and post a scanning technique diagram in all relevant areas of the shelter. To
develop proficiency and confidence with universal scanners which require slow scanning speeds,
train staff by scanning live animals with known microchip identification. [See the Griffin Microchip
Scanning Protocol and the Microchip Scanning Diagram in the Resources folder]
5. Increase medical staffing capacity to allow efficient completion of daily surgeries and provide
support for medical assessment, treatment, and follow -up. Surgical efficiency is maximized with
one veterinarian and 2 to 3 technicians or assistants to provide high - quality and humane anesthesia
and perioperative monitoring. Equivalent surgical caseload can be accomplished in half the current
time required if the veterinarian remains in the surgical suite focused on surgery. Meanwhile, the
technicians and assistants will anesthetize, prep, and recover animals in the clinic space. The
veterinarian must focus on tasks that require a veterinary degree and license - this does not include
animal restraint, surgical prep, cleaning of cages, or evaluating routine fecal flotations. A licensed or
experienced veterinary technician can perform diagnostics, recheck evaluations, and foster care
appointments to expedite animal flow to outcomes. Increased medical staffing or additional staff
training will allow for veterinary services staff coverage on weekends to maintain daily oversight of
the medical health of the population.
6. Revise and streamline the process for submitting vet request paperwork for medical exams. The
veterinarian or technician should examine the animal, initiate a treatment plan (may include
monitoring, dietary recommendations, priority for foster or transfer, isolation, or administration of
medications based on written treatment protocols), and record all findings, recommendations, and
treatments in the Chameleon medical record. This process should occur within 24 hours of a vet
request submission. The ASV Guidelines forStandards of Care state that "Appropriate medical care
must be provided in a timely fashion and documentation must be made of all medical care rendered
to each animal." Staff should use similar laminated vet request signage in dog kennels as is available
in cat housing to alert the medical staff that a vet request is pending for a particular animal. If
volunteers /staff submit frequent or redundant vet requests, consider implementing a
communication strategy such as a vet request binder with log sheets. Once a condition is
addressed, and a treatment /monitoring plan is noted on the log sheet, volunteers and staff can see
Maddie's Shelter Medicine Program I University of Florida. 18
Packet Page -1383-
10/13/2015 16. D.12.
that the veterinary services team is managing the animal's condition and refrain from submission of
redundant requests. [See the Daily Veterinary Check List log sheet in the Resource folder.]
7. Spay and neuter highly adoptable pets as soon as possible. Schedule surgery on the first day
possible prior to adoption. This allows adopters to take their new pet home on the day of adoption
to decrease length of stay and crowding in the shelter as well as operating expenses. Institute
kennel signage for animals who have recently had surgery to alert volunteers and staff regarding
exercise restriction and facilitate monitoring. Spaying or neutering cats and dogs awaiting adoption
for more than a few weeks is strongly recommended as the rapid decline in spraying, marking, and
fighting and the elimination of heat behavior will reduce animal stress.
8. Utilize Chameleon to manage accurate medical records and to schedule re -check examinations,
follow -up vaccinations and parasite treatments. A veterinary technician or assistant can print a
daily to -do list to perform these tasks on schedule. Record all medical treatments in the animal's
Chameleon record. Include detailed reports of history if known, exam findings, diagnostics
performed, diagnosis, and treatment plan (including dose of medications), including monitoring and
recheck evaluation findings. Ensure compliance with the state veterinary practice act and DEA
regulations regarding medical record - keeping.
9. Institute a comprehensive parasite control program with efficacy against intestinal parasites,
heartworms, and fleas. Control of parasites presenting human health risk is essential. Dogs
available for adoption are infected with hookworms and roundworms, which are zoonotic n
pathogens of concern for volunteers, visitors, and adopters, particularly children. These parasites
are shed into the environment, where they contaminate the play yards, walking areas, and kennel
buildings. The ASV Guidelines for Standards of Care state that "All dogs and cats must be dewormed
for roundworms and hookworms before leaving the shelter." Deworm adult dogs and cats with
pyrantel pamoate at admission and 2 weeks later. Deworm puppies and kittens with pyrantel
pamoate at admission and continuing every two weeks until they reach 16 weeks of age. Administer
monthly parasite prevention to adult animals. Develop protocols for recognition, diagnosis, and
treatment of diarrhea to include empiric, broad - spectrum deworming. Basic fecal flotation can be
an insensitive diagnostic test for intestinal parasites, and can be reserved for animals that do not
respond to deworming.
10. Continue to support canine playgroups for enrichment and protection of behavioral well- being.
Dogs with clinical signs of respiratory infection or diarrhea should not attend playgroup.
Asymptomatic heartworm positive dogs should be eligible to attend playgroup and exercise off leash
with monitoring for onset of clinical signs and exercise restriction if signs are noted. Once adulticide
therapy (melarsomine injection) is administered, strict exercise restriction is absolutely required.
Administration of monthly macrocyclic lactone preventive and a course of doxycycline or
minocycline can decrease inflammation and sterilize existing heartworms. [See American
Heartworm Society 2014 Canine Guidelines in the Resources folder]
Maddie's Shelter Medicine Program I University of Florida
Packet Page -1384-
10/13/2015 16.D.12.
11. Provide appropriate husbandry for exotic species. Develop written protocols and train staff to
provide care to all species sheltered. For example, rabbits require unlimited amounts of hay,
opportunities to chew, forage, and exercise, and they require hiding spots. Reptiles require specific
environmental conditions, including attention to lighting, temperature, humidity, and enclosure
substrate and design. Exotic species should be transferred to rescue organizations that are better
equipped to meet their unique needs for humane care.
12. Develop and implement sanitation protocols for the medical clinic that are effective against
common shelter infectious diseases. Equipment, cages and the nebulizer must be disinfected with
a parvocidal disinfectant, such as Accei or Trifectant. Quaternary ammonium compounds, such as
Roccal and Kennel Care, should not be used in the medical clinic because these are inappropriate
products for use in feline areas due to toxicity concerns. Cats and kittens with upper respiratory
infection may be shedding calicivirus, which is an unenveloped virus that requires a parvocidal
disinfectant. Alcohol is not effective against most of the common shelter infectious diseases of
concern, including panleukopenia, parvovirus, and calicivirus.
Long Term Goals:
1. Install intake kennels for dogs in the sally port. Intake vaccination must be performed within one
hour of the animal arriving at the shelter. After vaccination and health status evaluation, adoptable
dogs should be moved to housing in Buildings 3 or 4. Dogs with signs of infectious disease must be
housed in Building 5. Dogs with non - infectious medical concerns requiring close monitoring should
be housed in the small intake room with four runs in the middle of the sally port and next to the
medical clinic. Aggressive dogs or dogs on rabies quarantine should be housed in Building 5.
2. Utilize volunteers in the veterinary services area. Volunteers can help improve overall surgical
efficiency by walking dogs to and from surgery, cleaning instruments and cages, and monitoring
patients in recovery after surgery.
3. Include veterinary services staff members in population rounds. Population rounds are designed
to be a collaborative process, involving staff members from varying departments. Medical staff
members should participate in these rounds as they can provide valuable insight on particular
animals. Furthermore, veterinary technicians can also use this time to identify surgical candidates,
identify animals exhibiting signs of illness, and select candidates for medical foster /transfer.
4. Create protocols regarding foster care. Provide written and oral training to foster parents regarding
their responsibilities, risks of disease transmission, and steps to minimize these risks. Establish
routine recheck appointments at specified intervals to ensure animals are responding to current
treatment, and if not, allow for treatment changes to be made in a timely manner. Establish a
tracking and scheduling system for provision of routine preventive care to foster pets, including
vaccinations and parasite control.
Maddie's Shelter Medicine Program ( University of Florida2ti
ERIE
Packet Page -1385-
10/13/2015 16.D.12.
Euthanasia Recommendations
Euthanasia, by its very name, means a "good death." The goal of euthanasia policies and procedures in
the shelter should be to provide the most humane and caring experience for the animal being
euthanized. The best practice for euthanasia of cats and dogs is known as EBI — Euthanasia by Injection
of sodium pentobarbital. However, euthanasia encompasses more than the injection of the euthanasia
drug. It begins with staff training and oversight and involves all stages of the animal's experience:
identification for euthanasia, room environment, handling and restraint, sedation, administration of the
euthanasia drug, and confirmation of death.
The ASV Guidelines for Standards of Care in Animal Shelters state that, "When performing euthanasia in
a shelter, each individual animal must be treated with respect. A veterinarian with appropriate training
and expertise for the species involved should be consulted to ensure that proper procedures are used.
Any euthanasia method used in a shelter must quickly induce loss of consciousness followed by death,
while ensuring the death is as free from pain, distress, anxiety, or apprehension as possible. The most
humane methods used for euthanasia of shelter animals are intravenous (IV) or intraperitoneal (IP)
injection of a sodium pentobarbital solution... To avoid causing undue stress and anxiety, the least
amount of physical restraint necessary to perform the procedures safely must be used. Pre - euthanasia
drugs should be administered to animals that are aggressive, severely distressed or frightened... Death
r—N
must be verified by multiple methods by trained staff before any animal's body is disposed... A separate
euthanasia room should be designated for euthanasia in a quiet area away from the main pattern of
traffic to minimize distractions and interruptions."
Immediate Recommendations:
1. Train the euthanasia staff in the proper methods for verifying unconsciousness. The shelter
veterinarian must train the staff to conduct and interpret palpebral responses and limb withdrawal
responses. Both responses must be assessed prior to intracardiac injections. Intracardiac injections
are unacceptable unless it has been reliably verified that the animal is unconscious, comatose, or
anesthetized. If the animal still has either a blink or a toe -pinch reflex, either give the animal more
time for the pre- euthanasia anesthetic drugs to take effect or administer additional anesthetic
drugs. [See HSUS Euthanasia Training Manual in the Resource folder.]
2. Train the euthanasia staff on the proper use of a microchip scanner. Microchip scanning is a life-
saving procedure that must be conducted correctly and is not subject to short-cuts or personal
preferences. Every animal must be scanned with the universal scanner immediately prior to
injection of euthanasia solution. Remove all animals from traps or other enclosures prior to
scanning. Feral and fractious animals should be tranquilized, removed from the traps, and
thoroughly scanned with the universal scanner prior to injection of euthanasia solution. Staff
members performing euthanasia must be trained on proper scanning technique with random
Maddie's Shelter Medicine Program University of Florida 21�,
Packet Page -1386-
10/13/2015 16.D.12.
evaluation by a supervisor to ensure compliance. Always verify the universal scanner is in good
working order by scanning a test chip prior to use. [See the Griffin Microchip Scanning Protocol and
the Microchip Scanning Diagram in the Resources folder]
Next Steps:
1. Develop a step -by -step protocol for euthanasia based on best practices and post the protocol in
the euthanasia room. Train all staff members certified to perform euthanasia with this protocol. All
staff must review best practices outlined by the ASV Guidelines for Standards of Care in Animal
Shelters, the AHA Operational Guide for Euthanasia by Injection, and the HSUS Euthanasia Training
Manual. Include an infectious disease control protocol for euthanasia and hold staff accountable for
compliance. Staff must wear PPE when performing euthanasia for animals with signs of infectious
disease due to the potential risk of fomite transmission. [See the AHA Euthanasia Guide and the
HSUS Euthanasia Guide in the Resource folder]
2. Train the euthanasia staff in canine and feline body language and humane restraint techniques. A
minimum of two staff members should conduct euthanasia together to ensure animal and staff
safety. Fearful or fractious cats can be safely injected with pre- euthanasia sedatives intramuscularly
(IM) by using a trap comb or plexiglass shield fitted to the current feral cat dens. Humane low- stress
restraint techniques will permit use of small -gauge needles for IM injection of pre- euthanasia drugs
to induce anesthesia. [See HSUS Euthanasia Training Manual in the Resource folder.]
3. Schedule euthanasia to occur at the beginning of the day prior to increases in activity and foot
traffic throughout the shelter and sally port. Staff assigned to euthanasia must be permitted to
perform this task without interruption. Create "do not disturb" signage to minimize interruptions
during the euthanasia process. Interruptions are stressful for animals and staff and create
distractions that may prevent a smooth, safe and dignified procedure. Animals must not be left
unattended after sedative or euthanasia solution has been administered. Schedule owner
requested euthanasia by appointment.
Long Term Goals:
1. Create a dedicated quiet room for performing euthanasia, such as the room currently housing the
crematory. [See "Facilities Recommendations "] The room should have adequate lighting and
equipment for performing euthanasia humanely. Animals should not be permitted to observe or
hear the euthanasia of another animal.
Maddie's Shelter Medicine Program I University of Florida 22,
Packet Page -1387-
10/13/2015 16.D.12.
Sanitation Recommendations
According to the ASV Guidelines for Standards of Care in Animal Shelters, "Good sanitation is an integral
part of humane animal housing. Proper cleaning and disinfection practices help reduce the transmission
of infectious diseases to both animals and people, and result in a cleaner and healthier environment.
Protocols for proper sanitation are essential for any sheltering program. Providing education and
training as well as ensuring compliance with those protocols is also essential."
Careful and effective cleaning and disinfection by well- trained staff is a key component of infectious
disease control and reducing the dose of infectious agents in the environment. A clean shelter
encourages adoptions and public support as well as protects animals from illness. Cleaning represents
the physical removal of organic material (feces, urine, and food) from surfaces prior to application of a
disinfectant, and practices should be in place to complete the cleaning process humanely, minimizing
stress to the shelter animals. Disinfection is the inactivation of harmful pathogens by application of a
properly selected and diluted product with adequate contact time for the killing process. Sanitation is
the combination of the cleaning and disinfection processes. Standardization of cleaning protocols and
training reduces confusion, improves compliance, and ensures that effective protocols are in place.
Providing staff with sufficient written guidance, training and supplies, and ensuring that the facility is
arranged for easy and effective cleaning and disinfection, can serve as the foundation for a sound
infectious disease control program. n
Immediate Recommendations:
1. Use appropriate disinfectant products with correct dilution and sufficient contact time.
• Quaternary ammonium products should not be used in feline and small mammal housing areas
due to toxicity concerns and they are not effective against common and deadly viruses such as
panleukopenia and calicivirus. Trifectant is a safer and more appropriate product to use in these
areas. Use Trifectant tablets in spray bottles to make preparation less complex and error -free
for staff. Trifectant requires a 10- minute contact time.
• For daily cleaning in the dog kennels, use the Kennel Kare quaternary ammonium product at the
appropriate setting (setting C, not setting B) on the hose -end sprayer to achieve 2 oz. per gallon.
Concentrations exceeding 2 oz /gallon are not warranted because of skin toxicity and no
enhanced killing activity for pathogens. Because Kennel Kare is toxic to skin, it must be rinsed
from all housing surfaces prior to animal contact.
• Incorporate Wysiwash as the disinfectant for all dog housing areas. Unlike Kennel Kare,
Wysiwash kills parvovirus. Wysiwash is an easy -to -use and inexpensive disinfectant for all the
dog runs, walkways, and outside concrete pens. Wysiwash requires a 10- minute contact time.
Maddie's Shelter Medicine Program University of Florida 23
Packet Page -1388-
10/13/2015 16.D.12.
• All spray bottles and hose -end sprayers used for cleaning or disinfecting products should be
clearly labeled with the product name, dilution, date prepared, and instructions on how to
prepare. According to the manufacturer's instructions, Trifectant® 1% solution should be
prepared fresh at least weekly or more often if the solution changes colors or becomes
contaminated with debris. Bleach solutions (4 oz /gallon) must be made fresh each day prior to
use.
Reduce use of resources and time by sanitizing only one food bowl for each dog daily. Use one
food bowl per dog in each run. Bowls can be cleaned daily using a degreasing detergent, such as
Dawn dish detergent, then sanitized in the correct dilution of bleach (4 oz /gallon) or in Wysiwash for
10 minutes before being rinsed and allowed to air dry. This equates to 30 bowls per building instead
of 120. Complete sanitation of all food and water bowls used should be performed between new
occupants of runs.
3. Utilize spot cleaning for all occupied cat cages and communal rooms in Buildings 1 and 2 on a daily
basis. The ASV Guidelines state "Occupied cages can be cleaned using the "spot cleaning" method,
where the animal remains in its cage while the cage is tidied and soiled materials, urine and feces
are removed." The cage does not need to be stripped and disinfected as long as the same cat is
staying in the cage. In most cases, only daily changes of the litterpan, food, and water are necessary.
All other items such as bedding and toys should be left in the cage unless soiled. Soiled surfaces can
be cleaned with Trifectant. Spot cleaning is an excellent way to reduce stress of sheltered cats while
maintaining a sanitary environment. It is easier on staff, takes less time and money to perform
appropriately and can help reduce the incidence of upper respiratory infections. Several staff
members already follow this protocol. Ensure consistency by training all staff and trustees. Provide
supplies in all cat housing areas for staff /trustees to sanitize and furnish cages. [See Spot Cleaning
Protocols for cages and communal rooms in the Resources folder]
4. Thoroughly clean and disinfect all vacated runs, cages, and communal rooms before adding new
occupants.
Dog runs should be cleaned and scrubbed with Kennel Kare to remove organic debris, rinsed,
then Wysiwash applied to all surfaces for at least 10 minutes, followed by rinsing and drying
with a squeegee. All bowls and beds should also be disinfected. [See Sanitation Protocols in the
Resources folder]
• Small dog /puppy and cat cages should be stripped, Trifectant sprayed over all surfaces, allowed
to sit for 10 minutes, then wiped with a wet cloth. All bowls, litterpans, and disinfectable toys
should be cleaned with Dawn dish detergent, soaked in bleach solution (4 oz /gallon) for 10
minutes and rinsed. Non - disinfectable toys should be discarded. [See Sanitation Protocols in
the Resources folder]
• Group rooms for cats /kittens should be stripped, all surfaces sprayed with Trifectant, and the
floor mopped with Trifectant. This is especially important for group rooms housing kittens since
f
Maddie's Shelter Medicine Program I University of Florida 24
Packet Page -1389-
10/13/2015 16. D.12.
they are most susceptible to panleukopenia virus infection. [See Communal Room Disinfection
Protocol in the Resources folder)
5. Incorporate signage into the sanitation routine. Clearly label runs and cages as dirty or clean to
ensure housing units are completely disinfected between occupants. When an animal leaves the
run or cage, label the kennel with the laminated orange dirty sign. This notifies staff to thoroughly
sanitize using a detergent and Wysiwash for dogs and Trifectant for cats, prior to placing a new
animal in the housing unit. Once the run or cage is sanitized, the sign can be flipped to the green
clean side to notify staff that the kennel is ready for a new occupant.
6. Create a daily sanitation protocol for the Building 3 outside pens and train volunteers to follow
the protocol. Volunteers that walk dogs and conduct playgroups with dogs from Building 3 use the
outside concrete pens on a daily basis. These pens must be cleaned and disinfected at the end of the
day so they are ready for use by kennel staff and trustees the next morning.
• Pick up poop and dispose of in a lined trash can
• Spray the concrete surfaces with Kennel Kare and scrub with a brush to remove organic debris
• Rinse with water
• Apply Wysiwash to all surfaces (do not rinse)
• Allow to air dry overnight
Next Steps:
1. Post written sanitation protocols in all animal housing areas and train all staff and trustees to
follow the protocols. The ASV Guidelines state that "Protocols must be developed and
documented.... and updated as needed .... All staff must have access to up -to -date
protocols... Sanitation protocols must include removal of gross organic matter, pre - cleaning of
surfaces with a detergent or degreaser, application of a disinfectant at the correct concentration
and for sufficient time, rinsing, and drying."
• All protocols should be distributed to staff and easily visible throughout staff areas.
• Formal initial training with supervision and ongoing training is necessary for all cleaning and
disinfection protocols.
• Dedicate staff to different housing areas to minimize tracking of potential disease agents
between housing areas: some staff are assigned to healthy animal areas and other staff are
assigned to sick animal areas only. If this is not possible, then staff should move from areas of
healthy and most susceptible animals (puppies and kittens) to areas of isolation and sick
animals.
• Protocols should emphasize safe handling of animals and human health risks.
Maddie's Shelter Medicine Program University of Florida 25
Packet Page -1390-
10/13/2015 16.D.12.
2. Staff should wear fully protective clothing during sanitation, and this clothing should be removed
afterwards. The ASV Guidelines recommend that "Appropriate protective clothing (gloves,
impervious gowns, and boots should be used during sanitation of each area, and removed before
proceeding to care for other animals... ". Clothing can become heavily contaminated during cleaning,
especially since the hosing of runs with water under moderate pressure results in spraying of feces
and urine on staff. Contaminated staff clothing can be a source of infectious disease contact for
animals handled for the remainder of the day. Clothing worn during cleaning should not be worn in
other areas of the shelter.
Rubber boots, clean plastic aprons or coveralls, gloves, and eye protection should be available at
the entrance to each housing area and worn by staff during cleaning and disinfection. This
clothing should not be worn outside of the assigned housing area.
• Gloves must be changed between different housing areas or sections and definitely after
handling a potentially ill animal.
Each housing area should have all necessary equipment and supplies to prevent staff from
leaving the area in search of missing items. The sanitation equipment and supplies should be
inventoried on a regular basis to insure fully stocked areas.
3. Develop and post written step -by -step protocols for cleaning and disinfection of animal control
vehicles and equipment. The ASV Guidelines state that "Transport cages and traps, as well as
vehicle compartments used for animal transport must be thoroughly disinfected after each use."
This includes "all equipment that comes in contact with animals."
• Soiled compartments and equipment should be cleaned with Dawn dish detergent or other
commercial cleanser and rinsed prior to application of the disinfectant.
• Spray bottles containing 1% Trifectant can be used for disinfection of the compartments. The
surfaces should be allowed to air dry.
• Alternatively, the compartments can be sprayed with Wysiwash since a hose is available in the
sallyport and driveway.
• After cleaning to remove organic matter, traps and other capture equipment, control poles, and
muzzles can be submerged in a rubber tub of 1% Trifectant for 10 minutes for effective
disinfection, then rinsed and air- dried. Care must be taken to ensure that all surfaces are
submerged.
4. Develop and post written step -by -step protocols for cleaning and disinfection of dishes and litter
boxes and train all staff, trustees, volunteers, and ACOs on the protocol. This requires a 3 -step
/'**, process of cleaning, rinsing, and disinfection.
Maddie's Shelter Medicine Program I University of Florida; 26t
Packet Page -1391-
10/13/2015 16.D.12.
• The first step is removal of organic matter by washing the items in the sink containing detergent.
• The second step is rinsing to remove the detergent.
• The third step is soaking of the cleaned items in bleach (4 oz /gallon) for at least 10 minutes
followed by rinsing and air - drying.
• Dishes should be cleaned before litter boxes.
• Staff should wear gloves while handling dishes and litter boxes to avoid contamination of their
hands with potential pathogens.
• The sinks must be disinfected with properly diluted bleach after exposure to litter boxes.
5. Empower staff members to participate in monitoring every animal's health and welfare status
during sanitation. The ASV Guidelines state that " "Monitoring of each animal's health status should
be conducted at least once every 24 hours by a trained individual to visually observe the health and
well -being of every animal. Monitoring should include food and water consumption, urination,
defecation, attitude, behavior, ambulation, and signs of illness or other problems." Daily recording
of observations provides a means for prompt identification and intervention for problems crucial to n
protecting individual animals and the shelter population as a whole, and is valuable information for
the veterinary care team.
• Train staff, trustees, and volunteers to recognize changes in basic health and behavioral
parameters including appetite, vomiting or diarrhea, activity level, and behavior.
• Incorporate a standardized system of clearly recording kennel -side observations. The ASV
Guidelines state that daily observations must be written down, not stored in staff memory.
[See Daily Observation Form and Protocols in the Resources folder]
a. The Daily Observations forms can be attached to a clipboard on every run, cage, and
group room.
b. Alternatively, the Daily Observation sheets can be stored in an easily accessible binder in
each housing area.
• The observations should be recorded first thing in the morning before cleaning, and throughout
the day as staff walk through the kennel.
Institute a clear and consistent step -by -step reporting system for health and behavioral concerns
and hold all staff accountable for prompt follow -up actions, including recording the concern in the
Maddie's Shelter Medicine Program I University of Florida 27
Packet Page -1392-
10/13/2015 16.D.12.
/01*N Observation sheets, reporting the concern to a supervisor, transmitting the concern to the
veterinary care team, and recording the concern and remedial actions in the animal's medical
record.
Maddie's Shelter Medicine Program University of Florida $
Packet Page -1393-
10/13/2015 16.D.12.
Facilities and Housing Recommendations
Good housing helps reduce stress and the spread of infectious disease and improves the overall welfare
of the animals in shelter care. The ASV Guidelines state that "Shelters must provide an environment
that is conducive to maintaining animal health. Facilities must be appropriate for the species, the
number of animals receiving care, and the expected length of stay in order to ensure physical and
psychological well -being of the animals."
Immediate Recommendations:
7. Designate a purpose for each housing area and assign a name that reflects the purpose to allow
clear communication between staff, ACOs, and volunteers. Eliminate use of housing areas for
multiple populations and purposes.
House all healthy and adoptable dogs in Buildings 3 and 4. Dogs in these two buildings should be
available for potential adopters and rescue groups to view and select. Adopters can select dogs still
in stray hold but the dogs cannot be released until this period has expired.
0 Owner surrenders and dogs with expired stray hold periods in either building are eligible for
leash walks and playgroups as long as they meet the established safety criteria.
9. House healthy puppies and small dogs in the front 14 runs in Building 4. These highly adoptable
animals should be fast - tracked to this housing area for immediate viewing by the public for adoption
and rescue /transfer.
• Puppies should not participate in playgroups or leash- walking on surfaces that cannot be
effectively disinfected.
• Puppies can be socialized and exercised in the outside concrete pens but only after the surfaces
have been disinfected with Wysiwash.
• Puppies in different runs should not be mixed together for socializing or playing as this increases
risk for infectious disease contact. The outside concrete pens should be disinfected with
Wysiwash between different puppies.
10. Discontinue housing dogs "reserved" for special rescue groups in Building 5. All healthy adoptable
dogs (including heartworm- infected dogs, dogs with demodex mange, etc) should be housed in
Buildings 3 and 4 and made available to the public and all rescue groups on a first come -first serve
basis.
11. Discontinue putting newly admitted dogs in Building S. Create a space in the Sallyport for
temporary housing of new admissions while constructing a more permanent solution.
Maddie's Shelter Medicine Program I University of Florida
Packet Page -1394-
10/13/2015 16. D.12.
• Until a permanent intake housing area in the sallyport is completed, set up large crates and
kennels with tops in the sallyport to house dogs for intake processing conducted immediately
upon admission. Then move the dogs to Building 4 (healthy), Building 5 (legal custody or sick), or
the medical ward off the sallyport (injured, nursing mothers).
• Create an intake processing protocol with instructions on housing selection. Train all staff and
ACOs on this protocol.
12. Consolidate legal custody dogs (rabies /bite quarantine, cruelty cases, etc) in the back section of
Building 5.
13. House dogs suspected to have a contagious disease in the front section of Building 5. The front
door and the partition doors separating this section from the back section must be closed at all
times.
• The entrances to this section should be clearly marked with signage stating that only authorized
personnel are allowed and PPE is required.
• No staff, trustees, or volunteers should enter this section without proper training and full PPE
must always be worn when in this section.
14. House dogs with noncontagious medical conditions requiring frequent monitoring and treatment
in the medical ward off the sallyport.
• This is also the best place for housing mothers with nursing puppies. Mothers can be very
stressed and intimidated by the loud noises and commotion in the kennel buildings, thereby
compromising their welfare.
15. House a litter of kittens in the small group housing room in Building 1. Since kittens are highly
adoptable and have quicker turnover rates than adults, they should be fast - tracked to Building 1 for
display to the public.
• Kittens should not be housed in Building 2 where the public cannot see them. Even kittens in
stray hold period should be housed in Building 1, either in individual cages or in the small group
room with littermates.
• Placement of kittens in the small group room should follow the all -in, all -out policy. This means
that only one litter at a time should be placed in the small group room and no other unrelated
kittens added until all are adopted. This is the best practice to minimize risk for infectious
disease.
Maddie's Shelter Medicine Program I University of Florida 30
Packet Page -1395-
10/13/2015 16. D.12.
If only one kitten is left in the group room, then that kitten can be moved to a cage in the lobby
to open the room up for another litter.
16. House rabbits, guinea pigs, and other small pocket pets in the Conference Room in Building 1.
• These small prey species must not be housed in the same rooms with predator species (dogs
and cats).
• Use species — appropriate housing that provides enough floor space to allow moving around and
stretching out, and assuming comfortable positions for eating, drinking, and elimination.
• Wire mesh bottom cages are unacceptable for any species.
• All species need a hiding box, including rabbits, and enrichment items appropriate for the
species.
Next Steps:
Incorporate more individual housing units for adoptable cats in the front lobby. The goal is to
house all highly adoptable cats and kittens in Building 1 where they are available to the public.
• These housing units should be large adoption condos or cages that provide separate areas for
resting, eating, elimination, and exercise. [Not the 2' X 2' stainless steel cages from Building 2]
7. Install portholes in the 2' X 2' cages for cats in Building 2. This includes the cages in the stray
holding area, the feral cat area, and the isolation room. According to the ASV Guidelines, "Primary
enclosures must provide sufficient space to allow each animal, regardless of species, to make
normal postural adjustments, e.g., turn freely and stand easily, sit, stretch, move their head, without
touching the top of the enclosure, lie in a comfortable position with limbs extended, move about
and assume a comfortable posture for feeding, drinking, urinating and defecating..... and hold their
tails erect when in a normal standing position... Housing must meet the minimum behavioral needs
of animals, providing separate areas for urination /defecation, feeding and resting and sufficient
space to stand and walk several steps, and sit and lie at full body length."
Several studies have shown that cats stressed due to inappropriate housing in 2' X 2' cages have
lower adoption rates and increased rates of URI compared to cats in cages with more floor space. At
a minimum, there should be at least 2 feet between the feeding, resting, and litter box areas in a
cage - less than 2 feet between these 3 areas is known to adversely impact a cat's food intake and
activity and compound stress, leading to URI and poor welfare.
Maddie's Shelter Medicine Program I University of Florida
Packet Page -1396-
10/13/2015 16.D.12.
• A porthole installed between two adjoining 2' X 2' cages doubles available floor space to 9.2 sq
ft and provides a separate resting and eating area on one side, a separate area for the litterbox
on the opposite side, and room for cats to stand erect, stretch, fully lay down, and walk.
• Cages joined by a porthole are appropriate for housing one adult cat, a bonded pair of adult
cats, or a small litter of kittens.
• Installation of a porthole to adjoin two 30" or 36" wide cages provides best housing for large
litters of kittens. This also facilitates sanitation by confining all the kittens to one side by closing
the porthole door, thereby allowing spot cleaning of the opposite side.
• Porthole installation kits are available for $50 each from the Koret Shelter Medicine Program at
the UC -Davis School of Veterinary Medicine. More information about these kits and directions
for installation is available at this site: http: / /sheltermedicine.com /portals [also see printed
information in the Resources folder]
8. Add a small shed to the parking lot area outside the Sallyport to store crates, emergency water
tank, and other items currently stored in the Sallyport. There is a large amount of usable space in
the Sallyport that is currently taken up with equipment and supplies that are not frequently used.
Storing these items in the shed will free up space dedicated to different operational functions as
detailed below.
9. Install eight T- kennels along one wall in the Sallyport to house newly admitted dogs from the
field. [see diagram below for layout]
• All dogs should be temporarily housed in these kennels for intake processing (vaccines, picture,
kennel cards, etc).
Once processed, the dogs should be moved to the appropriate housing based on a housing
selection protocol based on the recommendations in the previous section above.
• The T- kennels are appropriate for overnight housing of newly admitted dogs brought in by ACOs
after hours. Kennel staff can move the dogs to selected housing the next day.
10. Use the cat housing area off the Sallyport as the new cat and dog intake processing room. [see
diagram below for layout]
• Dog processing should be confined to the front half of the room where the door from the
Sallyport is located.
• Cat processing should be confined to the back half of the room where the cages are located.
• Create a barrier between the front and back halves of the room to separate the functions and
prevent cats from seeing dogs. ,
Maddie's Shelter Medicine Program I University of Florida 32,
Packet Page -1397-
10/13/2015 16. D.12.
• The dog and cat area should each have a weight scale, a refrigerator for vaccines, an exam table, ^
and storage space for supplies and equipment.
• The room should contain a computer for Chameleon access, a camera for pictures for the kennel
cards, and a printer for kennel cards.
11. Install a triple sink in the Sallyport for sanitation of dishes and litterboxes from Buildings 1 and 2.
{see diagram below for suggested location]
12. Research alternatives for having a crematorium on site. The current crematorium on -site is
outdated and takes up a large amount of valuable space. Running the crematorium during the day
creates an unpleasant atmosphere for the animals, staff, volunteers, and visitors. At minimum,
efforts should be made to not operate during the day, when the most traffic is at the shelter.
Lone Term Goals:
1. Create more outdoor holding pens for Buildings 3 and 4
• Split existing pens in half lengthwise using chain link fencing with gates. This creates 16 pens for
each Building.
• Dogs in both rows of runs in each section of Buildings 3 and 4 can be moved to the 16 pens
during sanitation of their runs. This will cut cleaning and disinfection time by nearly 50 %.
• Install an additional permanent concrete pad behind Building 4 to add an additional 8 pens for
this Building.
2. Build an enclosed room in the Sallyport, next to the crematorium, to be utilized as a dedicated
Euthanasia Room. [see diagram below for suggested location]. An alternative is to discontinue use
of the crematorium and convert this space to a dedicated Euthanasia Room.
3. Expand capacity for housing sick cats by converting the current Kennel Supervisor Room in
Building 2 to a second Cat Isolation room. [see diagram below for suggested location].
• Relocate the Supervisor office to Building 1.
• Install portholes in all cages in both Cat Isolation Rooms.
4. Fill drain trenches along the center aisle in Buildings 3, 4, and 5 with cement; cover drain trenches
at the rear of the runs with mesh drain covers.
5. Convert dog runs in Building 5 to double -sided housing with a guillotine door
Maddie's Shelter Medicine Program I University of Florida
Packet Page -1398-
10/13/2015 16.D.12.
• Allows dog to eliminate in area not used for eating and resting.
Permits safe hands -off handling of legal custody dogs and dogs with contagious diseases during
sanitation.
• Enhances biosecurity, staff safety, and the welfare of the dogs.
6. Improve ventilation and lighting to create more humane and comfortable living conditions.
Provide additional, functional ceiling fans in Buildings 3, 4, and 5
0 Install ceiling fans in the cat holding area in Building 2
• Increase lighting in the cat holding area in Building 2.
Maddie's Shelter Medicine Program I University of Florida 34 .,`
Packet Page -1399-
Recommended Repurposing of Building 2 Space
IxFREEZER
9.471— L77 -i 1
Canine
noninfectious
medical cases
Cat lso Cat
(URI) ISO
(URI)
Euthanasia
room
8 T- kennels for dog
intake
10/13/2015 16.D.12.
UMY WRM - nw
LEC
M Gmgzm - nw ixtdt+"I a
YELL= t ITIPA9E Gn MLYC.
Q
Maddie's Shelter Medicine Program I University of Florida'
Packet Page -1400-
10/13/2015 16.D.12.
Enrichment, Behavior, and Welfare
Recommendations
Enrichment refers to a process for improving the environment and behavioral care of confined animals
within the context of their behavioral needs. According to the ASV Guidelines for the Standards of Care
in Animal Shelters, "Enrichment should be given the same significance as other components of animal
care such as nutrition and veterinary care, and should not be considered optional. Enrichment can
prevent development of abnormal behavior in animals by helping them cope with and adjust to the
stress of confinement." The purpose of enrichment is to reduce stress and improve well -being by
providing physical and mental stimulation, encouraging species - typical behaviors, and allowing animals
more control over their environment. A good enrichment program stimulates all of the senses and
provides animals with variety, choice, and control.
It is vital to ensure the safety of staff and volunteers during the implementation of the enrichment
strategies described in this document. All staff members and volunteers should be trained in humane
defensive handling, which are techniques for handling dogs and cats that emphasize human safety while
providing humane control of fearful or potentially aggressive animals. Each animal's history as well as
behavioral observations made in the shelter should be carefully considered to tailor the types of
enrichment will be both safe and stimulating for that animal. Even animals that are not safe to handle
must be provided with some form of daily enrichment to mitigate stress. Some forms of enrichment
that may be safe for one animal, may not be safe for another. For example, some dogs may exhibit food
aggression or resource guarding. In- kennel feeding enrichment for these dogs may pose a risk to staff
members who must distribute the food - dispensing toys and collect them for cleaning. Engaging in
individual and group play activities may lead to high arousal. In some dogs, especially those with a
history of aggression, the high arousal level can create a dangerous situation for staff and volunteers.
The importance of daily enrichment for shelter animals cannot be overstated. Successful enrichment
programs prevent the development and display of abnormal behavior and provide for the psychological
well -being of the animals. Enrichment programs can also be powerful and healing for shelter staff,
reducing compassion fatigue and burnout. Shelter staff, volunteers, and the Collier County community
will be uplifted by seeing physically and behaviorally healthy shelter animals at play.
Immediate Recommendations:
1. Provide every animal with a bed. According to the ASV Guidelines, "soft bedding should be made
available for all animals to provide comfort and prevent pressure sores from developing... Elevated
resting places should be provided whenever possible..." The ability to choose a clean, soft resting
space is a key element in an environmental enrichment program and helps to reduce stress.
• All dogs in runs should have elevated Kuranda beds or plastic pet beds that can be disinfected.
Maddie's Shelter Medicine Program I University of Florida
Packet Page -1401-
10/13/2015 16.D.12.
• All cats and smaller dogs in cages should have soft bedding.
• Soft bedding must be provided to injured, geriatric, or thin animals.
• The fact that some animals may soil their bedding is not a sufficient reason to deny this
important resource to any animal
2. Provide all cats with a hiding space. According to the ASV Guidelines, "Cats must have places to
hide..." Allowing cats to hide gives them some control over their environment and minimizes stress.
• This includes cats in the group housing rooms and individual cages in Building 1 and all cats in
Building 2 (stray holding, feral, and isolation areas).
• Hiding spaces for cats can be shoe boxes, paper bags, feral cat dens, high -sided beds with a
towel draped over the front, or even towels draped over 50% of the cage door.
• When feral cat dens are used, the dens should be positioned so that the clear plastic side is
facing the back cage wall and the opening is on the side.
• The best solution for the small cages in Building 2 is cage door covers. These can be purchased
(http•/ /www.shor - line.com /index.php /products /detai1/871.htm1) or use towels or sheets as a
substitute.
a. The cage door covers are very important to use with feral or frightened cats to alleviate --�
stress!
b. Cage covers must be disinfected between cage occupants.
3. Provide visual barriers or hiding spaces for fearful /anxious dogs. Removing the trigger for the
fear /anxiety or barrier reactivity can make dogs more comfortable and help them to feel more
secure in the kennel environment.
• A visual barrier can be created by fastening a sheet of opaque plastic to the bottom half of the
front run door. These plastic sheets can be cut to fit the door dimensions and attached with
fasteners that allow repeated removal and attachment. Plastic door covers are easily
disinfected.
• An alternative is to put small plastic igloos inside the runs if they fit the dimensions. These are
easily disinfected. Soft bedding can be put inside the igloo in lieu of a Kuranda bed.
3. Provide all dogs and cats with at least one form of in- kennel enrichment daily. Ideally, in- kennel
enrichment would be provided at a consistent time each day. Monitor animals to ensure each form
of in- kennel enrichment is safe and stimulating. M A rotation of toys maintains novelty and can be
mentally stimulating.
• For dogs, this may include a kong or PVC toy filled with peanut butter /treats, an ice treat, or a
bone. Different recipes may be tried for these toys, and success can be judged by the length of
Maddie's Shelter Medicine Program I University of Florida
Packet Page -1402-
10/13/2015 16.D.12.
time dogs spend playing with them and the length of time that the kennel remains quiet. [see 5
easy kennel enrichments for dogs in the Resources folder]
• For cats, in- kennel enrichment may include a stretch -n- scratch toy, toilet paper roll food -
dispensing toys, hanging construction paper /pipe cleaner toys, various balls /mice /wine corks
marinated in cat nip, etc. [see 5 easy kennel enrichments for cats in the Resources folder]
4. Utilize volunteers to implement canine and feline in- kennel enrichment in Buildings 1, 2, 3, and 4.
Stress their vital role in protecting the behavioral health of CCDAS animals. The volunteers are the
best means for insuring that every animal has regular enrichment.
• Ideally, a staff member or lead volunteer should be in charge of the program to keep it
organized and functional.
• Use a log book to mark off which animals received in- kennel enrichment, which type of
enrichment they received, and on what dates it occurred to insure every animal receives regular
enrichment. The information collected can also be shared with potential adopters as part of the
adoption counseling process.
5. Continue to develop Aimee Sadler's Playing for Life playgroups and incorporate eligible dogs in
both Buildings 3 and 4. Playgroups are the most efficient way to ensure all healthy and adoptable
.-N dogs receive daily play sessions. Protocols must be developed to ensure safety during play sessions,
and appropriate equipment for safety must always be readily available.
Sample Layout for a Double Compartment Cat Cage for Enrichment
DOUBLE COMPARTMENT CAGE LAYOUT
PARTIAL CAGE Soft bed should be added to the top of
COVER: for first 24 the shelf for comfort. Draped cloth
hours or with partially over shelf provides a hiding spot
PORTHOLE: open
except wl en
cleanin
IV
(n)
V/
MA
"SCRATCH PAD:
placed high on
door so cats
ctratrh Z crratrh
TOYS: for kitty
FOOD & WATER (mounted on cage fun! PARTIAL IAL CAGE COVER
door)
Maddie's Shelter Medicine Program I University of Florida
Packet Page -1403-
10/13/2015 16.D.12.
Next Steps:
1. Establish a culture at CCDAS where behavioral health is just as important as physical health. Train
all staff members and volunteers to recognize common behavioral concerns in the shelter such as
barrier reactivity, fear /anxiety, aggression, resource guarding, etc. According to the ASV Guidelines,
"Any animal that is observed to be experiencing mental suffering, distress, or behavioral
deterioration must be assessed and appropriately treated in a timely manner..."
• Staff must be trained to recognize behavioral signs of stress and poor welfare:
a. Hiding in the back of the run /cage or continually facing into a corner
b. Cowering or trembling when approached
c. Remaining immobile when touched, usually with the head turned away
d. Constant barking
e. Not eating and weight loss
€. Feigned sleep with eyes open (common in stressed cats)
g. Repetitive patterns of circling or jumping in the run
h. Food or toy guarding
• Kennel staff and volunteers should record behavioral observations on the Daily Monitoring
Sheets for each dog and cat. Alternatively, staff and volunteers can record observations into
Behavior forms in a binder located in each animal housing area. .-.
• Incorporate behavioral observations into Population Rounds and Medical Rounds.
• All behavior concerns must be communicated to kennel supervisors and veterinary staff and the
behaviors promptly addressed.
2. Utilize treat buckets to create a positive association with people walking by the dog runs and to
reward calm behavior. This positive association will improve the kennel presentation for many
dogs, increase their adoptability, and decrease barrier reactivity and barking in the kennel. Train
staff and volunteers to utilize the treat buckets appropriately and to ensure they are properly
stocked and disinfected.
3. Implement auditory enrichment when kennels become quieter. The treat buckets, in- kennel
enrichment, and exercise outside of the kennel will all help to create a quieter kennel environment.
Soft classical music can be played over the speaker system for additional sensory enrichment.
4. Ensure that every animal has an individualized behavioral health and wellness plan catered to
their individual needs. Plans would focus on protecting behavioral health and preventing dogs and
cats from developing shelter- acquired behavior problems. Preventing these problems before they
develop in the shelter will increase adoptability and decrease length of stay.
• Several factors impact the behavioral needs of animals in shelters including their individual
history, age, length of stay, genetic factors and breed characteristics, etc. Based on these ^
Maddie's Shelter Medicine Program I University of Florida
Packet Page -1404-
10/13/2015 16.D.12.
characteristics and response to various forms of enrichment, each animal needs an
individualized plan to help prevent shelter- acquired problems such as frustration, anxiety,
aggression, emotional /behavioral deterioration, etc.
White boards can be used to help keep track of enrichment plans on a weekly basis. Behavioral
observations and responses to various forms of enrichment should also be recorded in
Chameleon after the transition to electronic record - keeping.
Maddie's Shelter Medicine Program I University of Florida 740;x.
Packet Page -1405-
Ln
Lr
O
N
ir
� c
E
E `a
)
� � c
O C
l)
Ln m c
— Y m
f° a
C C C
Q U
`—' E
N m C
a) 1... CJ
E ow E
O o ai
0 d p
+� Cu
C U Ln
C C
O O
U
_ L �
p + a1
U Cu E
L E
N O
U
01 a)
Cr_
m
10/13/2015 16.D.12.
Packet Page -1406-
c-i
Cu (
1.0`
rl
C i =
m
m
m
u.
LL
_.
EM 0
a
a
LL a
V)
o
o
Q
v
�
c
v
E
U
a1
m o
C
a)
C
a
°
o
LL C'
O
O
O
M
p
CD
Ln
v%
ir)-
C
O
U
w
u
a)
U
a)
a
Cu
dcJ
u
�o
Y
to
'Y
to
'Y
u
-C m
w C
O
u
1.4
O
u
m
O
CD
m
0
O
m
m
C
a
a
a
a
N
0-
a
E
LL
>-
c
LL
N
c
c
1-
LL
d'
c
a)
N
c
a1
c
a)
E
-
u
u
u
u
u
u
a C
•v O
C
O
u
m 0i
m
Z
L
o M
�
ro
Y
a m v
n
C
m
= m
Y
3
Q- 3
7
U 11 tz
a1
°
L
wO
C
C
`
on
-0 a
Q
L ._
E
m
3 "m m o°
vi
C
a
>
to ao
to
Y
a
° ECo.Q
c
°
a
o
:3
O m L
m
-6
Cu a) O
o
c E
m
o v
-°
v
Q)
m
C
m
L L II
LF, +) Y
—
- m
�n C
L
m
C C
E
C Q in
U
m
L m C O
C
-a 'C LA
v
N L
O C
m
0
°
v
o
m Q ±'
a,
'+_+
L o
v
a) m
E
-°a
Y
"°
u
E
a) m bn
m
O
�n — a)
C 7
m O
U
"'-
3••'
O
C °
o
a v
a
Q
v .`
c a
m
a, c Cu
Q1 m
o
�'.�
3 N
m CO
°
L.L.
m
m o
a,
a
°'
m
3 a
m
.�
c m
+ o 6
=
a m
O L
C
E p
A
Q
C o
O
CL)
o
a -o
O
a
°
U E
n
H
LE
�
m
a)
L m E
Y C C
a
u
Y
Q
O a) a +-'
Q
>..E
00
m
m
o
m J
Q
() a
c m m
> o
c0 0 v
a
.0
a,
L °)
E a)
O
a 0
c
° y C
a
,
o
E
O
>
o
O 3: C
`v °
a
U
i
to
Y a)
+
m
a) °
O a)
O C
�n -°
a1 n
a)
'n
> C 6
m
O
+' u-
O O
N Y
m
�"' O
C •�
O O
a)
a
a) °j• °
vYi
°
+L—+ 'O O a1
�L a
m
m
-C
Cu a
a, �n
L
O
t.
- C L
m m
Q
3 C
U
C
Q m
a
C L
3 m a Y
O
Y- U
U
L
E O
QJ
m m
O (D
41
`—n a! O
�n -O
Y
C �n o
E •a •�
a �n
Oo m
in .E
�- u
O' °
Y
v
m a, U .`
m
_ C
- m
m .L
u
O C Y O
•N o
a) Cu a
Y
=_ N
a)
C
m
vi
m n O
E a,
c c a a
S a
,n
m
L C
a� .°
O
n 3
a,
3 c
m Y
E "^- c?
N
c a`j
m > !-
- co
c
u *_ ^
O
O�
C —'
() 6 O
L C
a)
L
Y
— N m m
a)
_E
C
Lo L
E m
�� O
-
Q
m
1-
Q a E 3
+m+
LN u
m
5 -�
L C
f—
O
V)
L C 7
E a
O
>
>
m
Ln
h0
C
�
w
O
3
O >
a)
L
�Y•E
a,
m
o
�
o
m C
v c
a
�
m
vi
C
O
w
s O
a
'A
�
v
C
E E
c
a
o
m o
a
a
0
to
°a
},
Y
Y
M M o
a
E
o o
Z a�
o
m
M
o
Q
4- m
O
C
E m O
C
N
O >'
Q
'n in
-C
a1
Cu
ar
C E Co
c
°
>
m s
C
a O
.v
a u
u L u
y
'� CO
Y
O
c
-C
Q
Y
C
�=
O c
N- O
m
Y
O
m
v o
-p
m
v L Y
N
_
O m .E
a
'^
oo
�+ m
N
u '°
O +� Y
C m a
.Y
° Q a
Q
N
C
N `n
C U
N
'C a—
E ° N
'6
UD
'in
m C
` vi
v+•'i
a)
C
O '-'
C
U.
m a Y rYO
C
O
"_
L v
m a`)
L p C
= a)
m m
O
C L
Y
O
E
>
N
CU
>
a a''
C
U a
—
Cy-
L
Y\ Y
O
ai
C
'a .>
a)
a
O .O u
E m
> �•+
"3
m m
C N
a .`
:° oc0
a E
E
c
E v
•L a In
a o0
Cu E
v
s� E
o v Q
a
Y
m
ri a ,ate °J
n
m
di a
or
Lri a -oa
� m
O u.
oo m m
u ar
of u
. o
° mo
A:)uagafl
}o 1an81
aleipawwl
Aaoga ;e:)
juawaSeueW uoi;eIndod
Packet Page -1406-
c-i
N
v
U
•L
a)
Ln
m
E
C
Q
U
^� N
a)
E
O
c
O
O
U
Cu
0
U
Ln
ri
O
N
Ln
i r"I
m O
E N
E a)
Ln Q
C U
O
ate+ m
O O_
� r-
0 O
U 6
E
C
f�4 a)
4D E
O Cu
Cl. E
a E
c -
U L"
� C
O O
it
L
°c
) (:
a, E
E
C
N L
CU a.
m
10/13/2015 16.D.12.
Packet Page -1407-
N
C
.a O
0)
C
^.
M
C =
ri
} al
L
m O LL
LL Q
LL
a y
o
Oa
v
c
E
y
L
•v L i
'3
v
_ d y
i�
O
O
N
00
r.4
_
u
U
O
a7 aJ
l 0
w
l0
lD
ri
C0
1.4
V
.�-1
C m
ri
O
ri
O
O
O
O
m
O
O
O
w-
u-
LL
m � �
E
LL
LL
LL
LL
LL
N
LL
o_ a .9 =
r1
Nd
ro
[t
d
�•)')
d
M
E
U
CO
O a)
a)
Cu
s
3 ~
c
�n m on
°c°
Cu
0
pi
o
m Y
U
O
m
O
OL L of
O
C
C C
aj
E (v
Cu
o
`N aa))
v° a
LL,
Cu
m
E
00
T
U m
.- +1 L a)
W m
'O to C
.m c' C
a
i
o
c E
o
Cu o
o o
O
L
° m
o oD
o
*
o
o m
o
(D
"
°
m m
a
o
v a
a,
C
o
+ = a)
a
T o
L a
o a
w
?
m
C
O
E
Cu
.
d
O _
Oo
C7 0
C
C m
a
a
m
z
m
v t Cu
L a a)
N
m
v Ln "-
m O
m
Co 0
aj
L
c 0 m Sk
o
C;
a c
s�
N �
E
E a)
s m
Cu O L
a -o o
w y o
c c
O' T a o
c
-6 7
m.
o
O „- O
Y -O
m c
L X C m
Y -O
E C m
N
0O a) m N
-O
O Y
a m O m
m L
-O
s
in O •Y
a)
OD C
0 O E
O Q C
pD C
m
C
O
C
o = St
> 0 a) -O
O
a. C
O
ti m
U �. -O
C m
•C �n
L
a a O- a)
a
C
'`
a
°o
O
no °o
Cu Cu (D
7 m
a
c C
m
v
4)
L m u
v
m E m
i�a
o m
v O
u v
- ai-
'3
v v
_
+a) a E E
o c v
- 4.
3
v°
c7
v
C�
o
a) E
3
}>u
m a
u
Y
Y,
C) L o u
m�
Ou
m -O
�° O m, N
m N
m
u
m L (D
Q d'
m
Y m
N.. -0
Y
Ln
� a)
D_ a) L:
Y a) :.
In L
..= .. a) . L �
�•.."O a a Ln
Y
N L
a) a
CL �—
u O C
N V1
.O
O
+'
o
Y
pD
C
GD �n O
a)
>
r-I
aj
E
s
=
t •� a)
*' a)
m a) m ra
E v
m
m
6$
c m
m>
m
m
o
a c
3
w c H
v -E
3 a
E +,
-C
o
o o u
°o
o
Cu
° °) o,
E
a
c
o
T
E� c a
O ,u �,
o a o v
: Y
-m
a) to
a)
m
u
N •�, U -O
u a) a)
o U E
o O
O
m a
. R
a
GD O C
u �
`
O o
E
L LL
U
E
; �,
O
-0
T
CO
a O
�. O
Q O —
CL a)
-O a)
LO C EO
m -
C.
.Y
C
�.
0 U C,
L. VY, L C
�. m a
i.
Qj
X
+'
°'
-O C
U O: O
.�
Y O.µ- O
U Cl) L
-O
o
L
2
_E
uJ C
to O
-O
@ ° m
L a).
O -O O
N .0
� O
O. C
�. > Ln
H
C m
m
L. E_
m
a) E O
+ L
E
C C 7
a) m
O
vm
O a)
LL
m >,
Cu m
j -O
m
o o C
C O. "6. a1
L o
a) *' OL
O o_
Y Y O
in b0
a) N
in C
7 E Y N O
C v)
a) C
_
m e
>
m>
c a
a) a
� ai .E
a s �, m +�
c E o
Y m.
m
L �. al N
O L
N N U. Cu
Y !n
E
CL
Y L!') a) Q)
N Y
>
c =>
a
.°u +� LA c
° v o
_ v s
> m
E O O a i
s .o m
v° v
m �c
Cu
T
�
0 (v u a) v
w u
M O v
c) •E
+' o E a)
�' Q ai
�-
3:
2
w a
4 E O
v
to :7- a
C
h +'c.+ m
C
I� m
E O
OO m a U
O1 m u
r4
N
M
V
Awa�a �
}o banal
sdalS IXDN
Aaosajej
Packet Page -1407-
N
Lr)
r-1
O
N
LI)
Lo O
E N
V) QJ
n
a) - o
N M
cv O d
E LO
c C _
O O
Q U '+
U � N
C
V) a) bz E
EO 0O a)
Q
�> C E
C U Ln
C C
O O
U
L C
O - a)
s E
N O
� U
a) a)
0 cc
f6
10/13/2015 16.D.12.
-0 o
LU .(A
LL
LL
w
o L°0
CL
0-
x
0
a)
H
C
E
_D
L
to Cu
�••i
L
i�
M
O
c CA a
w
o
LL C'
O
O O"
O
o O
Ln
V)-
N U1...
O
u
'm E
Ls
u
m
nc
-r
�
4r ++
w
C
O
O.
0
O
O
O
O
C
N
N
B
rq
c�
@ E
a-.�
U-
U-
N
LL
a v
Op
ry)
l}L
LPL.
lU-
CL i=
�
�
ro
E
U
00
aJ
L
Q)
a)
U
a)
u
C.
Cu
U
7
= a) -p
>
3
C
@
C
@
p
>
@
(
-0 V)
0
N
LCO
c a
c
a
c
a
c
@
s
°
o
°'
° v
O`
O
v w
C a)
@ L
C
C
@
O
C
O
O
.O
C
C
E
w
-a @
C
C
�pu . C
@ aJ
�
C
0 V
-� 0
—
u
@ N
Q-0
pO
U
O
U
:
a a)
M
L) 0
u
a N
Ln
@
-0 Y O
3
0
a v
E
�_
_° E
E
a3
°u n
Q
�'an
c
¢
Cu r
Q
N
C
@
+�
C >
Cu
-O
C N
0
E
O
O
a
N
by
vi a..' aJ
@ @
N
L
O @
?'
C
O C
O @
a) C
@.
L
@
0
a)
—
>
> a)
+� h0
@ -p
E C.
@
.--i —
a) N r
U O
0
u O
: U i
> C
N_.p
`)
p
@ @
@
L
to
p. ci
O
@
O.
CL
O LY
-o y-
!n
vi u
`' N
u
L@
L
Clo
..0
ru
O
•B U
@
CL Z
@
+
an
>-
v
Y
@ L
�.
O O
q0
a >-
C Y ti
O
E
O f
�- a)
C
a1 —
@
u @
C
0) 0
u O
� O
p
@- > @ C
Q Cu
O v
-@
u
u
to Fu
> O
E
O
E C O
O
C
Cu
u 0.
C
,�
,�
aJ
O
v
to
tlCD C
'0 .�
Vl '� O
c
O
by j
a) vi
O.
.}'
.-+
ru
O
O �. @
a) -a Ln
>
L Q)
ti O
�. Q1
'O
C .,�
p-
�.- L — i
a•+
@
L a) O
@ to a L
C
>
�, a-+
C @
a..' pp
@
a1 >� cn -
O pp..
C +' @...
C
7
7 p
—
ro
E. C
@
C
O @ C
Q)
p
Q
�,
O
i Y �-+
7..v u
@. C
`^ U N @
aL
aJ �'
'++ Cu
U a): C u
-0 ' j ' >. N .-
u
`^ tl0
-O
`J
p- I — +� Qj
N E
O w i..
m ;,,_ � E
O �
Oa 0)
v v i �O .Q
E
,E
a)
@
4
YO.
Z a
Ln
L
Cu
-C >-
O �c E O
�-
>-
v N
O
C O-0 .L
@
C a
,: L O.. �
,�
� � L: O
�' "CS
0
i .�"'
..@ 0. C C :..0
�+
E 0
a) u_
0
>
c y @ U
—
o O
a
a
C o_
_ @
0@
7 L a
@@
U
0 a o'er
u a i
LY
`� p @
@
"6
Q) O C N
N
bD a
a)
A O >..
O
N E. N y
O A
.Q. >'
a) C_...p @ N
L/) O
C
Q)
>
— N
:. en =
3 � @ C
•c
U L. C, 'Z
@°
a) .0
u -0
.E
�>
Q
> +� 3
,� .v
C E
L L p°
o
•�
a
E a aj
o
v@
v 3
x
w
° c a, .� v@
a
s v o .N
a w
E E
a E E
E
E@
a E Y m>
v m
o
n 0 a E
"O
c 0
dJ
E
E to
O O..
S
-
@ L C .E
rr1 7+
_q
-i a .-
C a
N a ., @ @
-@
m E -2 �
0
.4 u
O...�
Ln a a U @
Aoua2in
10 lanal
sIeog uaaal Buol
Rjosa}e:)
Packet Page -1408-
m
Ln
Q)
U
L
a
LO
m
E
.E
Q
U
Cu
E
O
N
c
7
O
a
O
U
Ln
O
N
aLn
00
E N
E a
Ln O
O u
O
Y ro
C O
C C
O g
U Y
E f°
Y
C
`6 a
t4 E
o a
d Q
a E
C —
U to
C
cCU °
Cu
G @
L
C
a
a E
= E
O
u
a a
m
i
10/13/2015 16.D.12.
Packet Page -1409-
�o
C
U-
N LL
C O
Q
tip
Ca
C .0
N
L
Y L
U
v
C
Q i
C
L=
CD
O O
Ln N
M N
C
Q
U
Cu
++ a
m
O
on
u
D
li
O
tiC
p
y aro+
C C A
O
r
•Q
N
O
a
O
C ca ...
E a
N
,Y '.
tip '.;
}
li
po
C
LL
do
C
m
a a E
)
L.L
C
c
O
O
m
'IT
O
a i=
v
m
o
E
3
z
u
�
c
0
�
U
C
Q
u
(A
N
Cu
O
fu
C
i
E
m
'O
>, a
a s E
a
Y
w C
O
a-
3 L
�,,
C
O
O
U O
C C
u C U
Cu
aj U
aT�
Y
C
��;
a
2
Cu
u��
O
Y�
N
E Q
r
�..`
Cu
C
•�
d
a
U
a O
m a
Q tip C
Q
U U
CU y
a 3: ro
C m
O_
0 Cu
_
— d
C =
O
s
y
a.�„
row.
L °cp
Y
.`�� m
c�L
3 a
Q�
E m
.Q
E E
:
'�
O
E to
= �'
p
�,.. �'
O_ '6
O
a
c L
1, =
D.. -
@ m
YO
m
41 en
-.�
= Y
Q Q
Cu
Y L
,O 01
++ >
ai
—
L m
a
H
a
L
m
m
o v
m
m a Y
Y- m
O
a°
aj
C.
CU
O
U
V1
a C
` u ._
C a
E OD :
Y O
a ca
cl) C Y
O
a
Q
LQ
m +'
M to
Q a� m m
L
_
Q o
w-
Y
_
C
m
E� ._
VI V1
a
tip u a
=
c 0
p
p
'Q
L C +,
a
n M
a C
m
m
E ra Q
m m ,a
+ n
C a
_:.
m
m of :
U
C C
=
C >�
Q of O
C Ln
"6
QU
O
.0 C
In Cep �.
@ O
a
a
C O_ Cu
m
X
-O
c a
�' Q
m Z
a z
3
O_
Y�
a L L
a s Y
y
Q..:.�
U
3
Y
In
Y
Q
Q
C _
CO Y
m
Q
a s C
Y U
w Cu
O O a
C a
a 'p
ra
a.. m C'
O_ -a
E C
vi
a .0
C
`n O E
E •>
m bo
m C
t C ) m
m E �.
_@
"�
CO
a m
`
N a a
U/ a
a qp
++
C
a O i "O
+•..
ii Q L
a.
tip ` Cu
E
.a > L
'in a
-0 cn w
tip C U
ro
'(j
4- m C
u L-
,�
O
w
E C
C C
U
i
Ln
G m G
G
to
to a ro. m
I- C3
Ln tZ
C .0
> u U
Y
Y
cLC C
s
N
O
_
O
V
m
a
U
Y L
m 0
.n a s
U
m
_
C Cu m
Y E
'�
u -C
C
O
C S7.
a
C
u
E
'0 N C C
O
= a-
in r, L f
a
O
>-
u
Q
m Y E
o '3
u C
U C s
m tip
N m
a a Y
E M
c
-u C
c m
m Cu
Q
a
y �..
Y O
to a
= m
U .0 L
C
^-' m
c a
Q
E
L
9 N Q +�
Q
c
CU o
o
api m
Q
C
E N'� C
m 0
m
i
a Y
L Q L
a
a L
u
O
E 'C,Y 0. =
Ln =
v 3 v
E m
°1 a Y
E U
E -
O.
00 m U
=
Y
O.
•C Y
O
p
Omp
,n
C
L
0
ii
m O. -:: m v
.p
m N:: a
L O
U Q_
m E C
t m
u, a
E
Y 0
c E
^
6 ,�
C
s
L m U>
M c
O _.
a
L C
u>
m
a
O O
- a
a
of
ro
4- C
Y
= a a
m to
U a
C
m fl'
E
w
Wo��-
u C
W m
wu
a -m
w�
m
lD : >Q.
r, m '. oo a - .Y
op Y ': Do-
to U
N C
M L.L U
t7 a
Ln
/%:)uagi n
}o lanal
aleipawwl
Ajosa}ej
SuidaaNpjo:)aa
Packet Page -1409-
Ln
Cu
U
Cu
N
m
E
.E
Q
u
N
0)
E
O
c
3
O
u
N
O
u
Ln
0
N
T Lr
L �
rm O
E N
E
Ln O
U
o O
r C
M a
c c
O O
U
F= c,
ro C
L N
ow E
�
a n
v E
c —
u
N O
L
a
CC
C
E
N O
U
OJ N
(E
G
10/13/2015 16.D.12.
Packet Page -1410-
Ln
N
U
v
N
m
E
Q
U
—
v
E
O
A
C:
O
U
a)
O
U
Ln
0
N
C?
C
E
Ln
C
O
m
Y
C
0
U
m
to
O
a
Cu
C
U
16
C)
N
L
Ln
a1
m
C
C
C.
.m
C
CL
E
E
C
CL
Cx
10/13/2015 16. D.12.
�o
c
m 3 LL
n o
m
M 0 Cr
0 4)
c
a)
Q
O
@
O
O
O
C m
N
CL
CL
a aEi E
m
Qj
d
d
d
1-4
d
CL F--
E
d
v
c v
Y
°°
-
a
L --
�
m vi
m
m
Y w '�•�
p C
C
"Q
C
L)1
C m u
a
0
N
O
Vi
C
v o
O°
o Cu
m
m
c a
C C -a
3 c o
C
o w
0 C
o Cu
L �+ C
C N
U
'� N
m
O E O
L
L
cc CL
t
W a) OCa.
E
H
Y Y
�. E
E
p
° E
tmi
o m,
Co axJ
oz
�,.
+, v aom
Q`V)
aIn
E o
�'
m
= m .L °
o v
o v
a°
m
C
i
Y N
�
U a)
01
ra
U
-0
N a) _ a)
F
0i C
+,
m
Y Ln
.m.
�--.
.`'' L `
N '6
m C
6J p
'Q O
O
o
Ln
'.N
a
m C
w
a) .N
m
O
},
4-
Q- Y "O
v
C C
a)
,. C C
Qm
N m
,2 m
a)
O a) m
a O
.�
m
Ln
on E
u 0
Un °
>
Cu —
Q
7
cwt =
Cu -0
°�
v v °'
o v ar
eno
u Cu
U v
Q
C al Ln U
C
m
a U
O
_C -0 v
Y
Cu It) C .-
m O
C __
•C
°
C
C
=>
C Cu
u CL
M m O to
> �+ C Y C
`
m C
GA
m C
o a)
C C N
Ln a)
L a m
@ m
m.
> .0 L Ln °
C a)
C -p
O m `--'
++ E LL
C r+
C Y
C o a
v
m
.3
a) i � c
Ln
� m
y
m e
O y
-o -Q
m a ,•,
v Q
a) Q
O E
>
>
.c
C YO °
6
`
p •C m
u L m c v
rya a
m
rya E'
Ql ++
L a) E
o
N o L C
Y
m L a)
r-+
m L a)
'-" ap c -Q m
LYir O
'C
Y > E
j m a) .0
N. �. a
:: LA L -.°.
and o
Cu a
a) m@
o
i '�
v E
a) Yn E
++ d' m O
U
L a p
-C =
F- m'
>> �+ N
7 N �..
E.. m
0= L s..
L a) Q
I-.. '6 U
..c a) Q
;F- 'D : U
N N>
H m Ln
C —
O E
V E
� .
.3
U
Cu
-0
O LUir
a) is
E
C ry
'
E 1
Ln
m
O
O
O Ln � aj
a) >,
Ln
o
C O
3
_
-O
m
Oo i
L
Y U
O
O l]a
O fL6 Cu
++ a)
Ln m
C w O
m
U ° a1 C
C —
�O m
u -E
+'
O C
++ O. o
m> vi
L a) Ln
Q .0 m
m .L]
-c U m
w
Cu Q)
-
Y
v
° m
C a v
m v n
=> >.
> c E -o
U
E°> E
o o
E
—
aEi
M m o
E +u v
- m
}, a) Q) C
a) o
ono
s... m v m
E
E m�
Y Y
C C
' a
n E A m a1
C Y E a
cL C
O
a)
•C C ti-
C Y
m W a 0
m a) d ,�
O m L
O'
41 C L Ln C
N° � .N
7
C m OC r+
U
7 -O
C C a) d
E
L� Y C
W
z o
.L O Ln E L
++ U r+
w
'` 'D
a) E
CD
w
m a) C
a! .- U C
O s_ a)
a) m
m m
o C O
y !_'
cc
O
Li LU4 N
U) E. O E
.c.
m N °.
L
?r O �.: an Ln
i to Y
'^
N
to m
O N .0
U O. `
C i
m` - C
d O to
3 m Q m
LL
O
U
m L '� C
a a) C O.
a) m •m to
V7 C r0 a1
.0 w
,--� 'L-'
a) a1
N
m aj Q °'
N
C m •�
C U CD
Q E
C
,Ln
a
,� ,�
C
pa
3
pa _
.�.
CO
O a) +p
C
i.
C. i
> a
�-+ . N T aJ
C
a) L .O
•E ai �. a m
O
v a1 d_ C
E
a) C y °.
U CO m m
. O },
O O > m n
.L Y 'm
a N
L. Q) w
Y
L U . �,,,
n 0
> Q m
Cu s�
> a! an Y.
a) m Ln
- °
>
n` fl °
-° Q 'X o
Q v
w v v f0 Y
a •� o
0, v o
Cu
3 a
•°—)
CL
°
it v a
u
ri E° 3
v m
0o
a o E
m
v M
L6 Ln
Y raa
r
A3uasjn
Sda ;S IxaN
}o jan81
Packet Page -1411-
0
LO
0
N
l--i
� o
N
N E QJ
U N
> 0 U
v O
N Y
m
._ = C
O O
Q U +�
U C Y
C C
E bD E
p aJ
o a a
Cu E
C U VI
U a) O
O N
U aJ E
-= E
N O
U
v a)
.O
fa
10/13/2015 16. D.12.
o
-T
0
a
(D
m °c°
v
E
•u y
c
+�
L L
aJ U
CJ
U
m O
O v.
°
Cr
uc--.
o o
No 0
0
LO
Ln
-L4
c
O
-0 m E
ri
.--I
.--1.
e-1 -:
to
aj m
C
0
Q
Q
0
Q
C
4C! w
O
m aJ
C
U-
U-
Lj-
LL
U-
LL
a
mU
CC:
a F=
U
�
E
3 —
—
�
CU
L
c
Y
_
Y
�n
oca, �.
-D
U H
p
•�
aL�.,a
to
aJ
O
_ O
O. L
3
M "O
°1
Cu . �.
` v tE
c v
O
m
O
n
'
5
a o'
c
c
Cu
m
c
p O
L
OU
L
i
>.�
aJ
CU
m
O C
O O
YO L
U
m a
O 6>
'L
O
a�
UD
`
__
—
— v
a�
M c
4--
v, E
`
u'
n
v
°� a aJ,
L
'�' E
o m
a
c c
v a E
a�
c v c
w o`
aJ
Z1
Q
'A
�.
�. EO
N .
j
j
ate.+
CU
�..
Q
-0
-0—
F- L
O
U N O
m m
Q
Cu
3:
7H
°
-i v
v a c
6
v "
E o 0
a
Q
v v v
a
m m
E LA a
v m .c
m y
m
u
E
O L '�
v ;c
Q
N
u
vYi Y ,�-
u
Ln O C
v a
X a)
O. 'u. m
u
°
m. � O
uui
E
aJ o
Cu p
F- �' a
w CL
0. U
p v >
a� o
L aJ p
-° u
z L
c E
O. x
m� 0)
m o¢
F-- � E
oj
0
L
O_..
±+ D
C
T O
Cu
L
°
o
° ° °' °D .�
c
a
m ° o c
3
0
@
+-+ O c P _
�... C U
Y
m—
u �- aJ
O
E
CC_D
a1 N.
'O
C
> . CO.: >
�.
CL
Y
m.
v=
.a Z' z
v c
.� N
a
O� °
�^ Q 06
Cz
E
'C
L 'C
LO
O_
+Y
N
t
OU
v` O �- !� •ra a. "O C
•�
u E >. N
m �
aJ aJ
E w u v E E
°
u a
c
to
v cn
O �n C '+`'�- C C.. CJ i.+
C •>
N
�,. C -° to
E
-6
"o O E..
C O
LL
u m +m+ O Y
m C '.
aJ C N
'
aJ
C > m:
V. m:
O
fp w N
ro
— U Cu . Cu
> ..� � •u j. Ln "- OA. '.
j.. iJ Ou.
V-.. aJ
QLJ ._.. U
C..,
•> v
.
a O Cu aJ Y a �., m �n
O Q O
U a1
"�
O
..�_.,
O
O. O
'C. -O UO: .� t`
Q E �.
C 6 4a O
u
N o_ E m m a � n
v: ° CL
Lr m o:. E o
Ln
o f
r�
ADuasan
10 1anaI
AaoSale:)
Packet Page -1412-
N
u
U
v
ul
f6
E
.E
En
Q
U
E+
W
E
O
Q
c
C
O
U
U
0
U
Ln
`--1
O
N
Ln
roL
O
E
E a)
C -0
ur) O
C u
O
ru
Y Q
Y (�
C d
C C
U O
E
Y
C
a)
4D E
O �
d Q
a, E
C
v rn
C
cQ O
G �
C
v
s E
E
o
U
Q) QJ
Q
.%
Packet Page -1413-
10/13/2015 16.D.12.
i
T I
r9
C
N
m
t
C
N
u
C �
O �
N In
N �
1
3UO1
W
-a o
v
c u a
C L c
a N
LM
U U d
o
rco a
c LA
d
Cu
O
CD
C)
Y
C C rLC
U
_
Q
N
N
rN
@ C
ro
d a) E
v
LL
M
CI
O
rN
d.
C H
E
o
Z
L
U
rm"
m
,
L)
a) (1) o
O
�'..
ro
u C .
0=
rfl .. O
u+
O N
u. C _c9 T
a
C ,�_ N ::
in +'
N Q�1
CL Q)
4 O_
'LS
Cu
L
(D O N LL
O J E
C. � O_ .
OCD E
fu6
L:
a - v
L
Ln
M C
(C
CL
c6 N..
a X
CL u CU
�
L
O
U. �'' . (1)
r0
.� C
ra 7• rD
Cu C.
a al
>
m L10
rn
u Y C
-O ro
O Y..L
'O O
a).. C
O
C` U
T v O 6
+� Cu
a) �
U1 OL
>, -a
M;
CL
C.
O v s
*'' >
u
CO
v
E L "O
Y' CL aJ
a E
++ a)
C C
O'
pD
Q
ro Cu 3
a a)
a,
E v c
a)'
L p�
v
a =
n
tlQ E
C O- O C
O UD =
O-0 R
N o
QJ
L
Y
� Co
Ln
Q1
G)Y
N C
M?: - n.3
Y:
u L
a) Ln 0
, U
vt
O
u)
w v
p
ra
E 4--. T
.N p f4.
__ C
a) >
T v m�
_
.�
—_
Y
Q)
p.. IYl1 L
p O- vi
E a*
ra O
ra..
in u
a).
CL E
O :�..
+ o
Y:
'Q m Ln
L>
C
N a
°= u )
Q CL
to . r o
a)
c c
•i
ra �-
c
'i
vi
Y u ra
C O_
Q) E Ln
O C C •Y.
Y CL a) �
•Y
� M N
N
Cu —_
tn.
e
= �.@
E Y a,
o o E
CU 0) v
�i Q
m
E:
M C >.. I9
: E. T �. rII C
C O U a
> a
> N
a
a n v
zz
a) @ F F
E -8a w E
° •3
Ln�
y a
C) m u
E a
v c
a
E
LL
L' Q)
ou E a
_
H ca Q H
o u
E CL
a� o
H 3
a�'
H- uu
n
N
Cu
C
C
6f
T
rp
C
O
Q) ...E
hD... 0. a y''
�- to vi..
p_. m.. E
'Cu
N -O -0
"O
rCD
m..0 ±�
nD
.Y
m _O
+,
u O
C r0 Cu
-a
c
L 3
u
>
�°
v 3
=c
m
01
p m
v
L F
Cu
O
u
N
E
0,
O O n
v v
Q)
aEi E
E
C
E
c-a L°
a)s�
au•�
av
C
O
O C C C_
p
° M
a
E E O
._ u
a)
aui
° o -O
a)
E *�_
E
Gi a)
p
p a)
O'
E -a
ro
u m
o
a,,, O
a
O O
m hD ra
4-
O O
m Cu
ro
a O
a
+--
U N. N CO
O a
C. C. p
"0O Q.:.
N =.
N
a
Y C
_
C O 'Y
>O N
>. OU >
m O
u •U
v
U
Cl-
_O
u
-0
, v
v
,°1
v
c
06 E u>
rn u
r 1 a s
a)
a Q)
-
/ouasin
SICOD
uaaai,
}o lana1
Ajosajej
Packet Page -1413-
10/13/2015 16.D.12.
i
T I
r9
C
N
m
t
C
N
u
C �
O �
N In
N �
1
3UO1
W
U-)
e•i
O
N
Ln
� O
N
E N
:3 -0
U Ln
O v
'— Q
Ln Y C ru
E a
.E 0 c
0 0
Q U
E
C
Ln ru QJ
E E
0 o a)
D o a
E
C
� U Ln
O
U O 0
L L
O CJ
U v E
L E
u7 O
� U
a C)
c
ra
G
10/13/2015 16. D.12.
•a p
c '
A
C
011
Do -
o LL
LL CL
R 4)
c ° Cr
H
a as
O
'a f6
d C
�
��.,
. 4 :�,
U
U
r�
a
U
U
ra
O
O
a
U
m
i-I
O
000
C a,
f0 E
?'N
�- = LL
CL
is
c-
C
N
N
Q
C
N
LL
O
N
. . "'.
l}L
IrL
CL E=
C
E
U
U
U
a ,,
�
s
a
Y
r9
m
a
Y Cu
O
a
CU
4d
3
a
a m
to
a ra
°D
V)
a°
a Cr
_
E
E
E
N
'II
+L+
c
of
t
c a)
,ax;,
C 9
.^�
C
U W
C (9
yr-
U
ru O m Q
a 4) ��
u �
an a -O
c) rn 'p
C..
3
"6
-A
E O �.
o
x'.19
a s
t 'O C
o ._ a
` N
E a p
-6
y �.
a
O ..6
C— a
L) >y C r9 -6
a
> +n
OL a _. 1 -_
u 7 vi
a U O
-Q Cu r6
U C
u 7
U U a
Y
O 7
N
} r9
W
L
0: '.N C) C
a-C o
C ,°
m
C .�
3 a)
�O
�'
In
E
O
__
a m v
I�
c� °
v
`-
C c
+
3 a
c
0 °C
LE
—
'°
Cu
Q
a-! � J. �,
a O
u O '>
00 T
X
"O w4-. p
7 W C
C
E o
•z
V1
�:
�_
L ..:�
�O
W Ln --
-O 00
a
Z
C f9
C a)
W .�
-O O
C
a 00 ro
U 0.
Q
-C , LL a. a
C C-
-
r0 C
a >
V
Q— C
M
a) U
O
+''
a N
o c c
a c
oNO o
`a)
Q Q �
� 00 cco
C
o n
i)
>�
�
a o
o Cu
v v 3
L
" ate) v
a) n o
o
a E
U
o c
t'3 C CO
Cr V N
+* m
�'
o
yr- S
a
t)')
_C
—
a C
L1 E.
4— a .
L O c
U
O0 d0
_�
L
ON
a)
a .�
C
o o
Y.
O LL
L ? U
(�
C
i
N
O
i-•
f6 tiO
O to C
O u. OL.
a
c 3�
O
a) °
c
C
E s c
o
v
° o
a Cu E L
c a°
E
a)
w
E
U a)
c ti
m ro
ra
o a E c
1n
o a- p
Y
- v
Y
a
o N u
u
v L
Cu E
a c
S
'6C
'C
L/)
Cp
' C :�. Ql
.L rEo` iv p
— a)
N
a
— v
-C Q)
—
f— ro L> L,
H ci u
Q L C
rn
a ro
c
I— Q a
Ln u a)
a'
E
E
L.
L1
o
m L
° a
a Ln a
Y
°
L L
_
yr-
a1
_ ar ra
°
C
— m
E
y lan
a-� r0 ++ .
C
0 a
C
O
: N
Cl
+�..
'-' a
C C
u o
Uu
C Y C
u
C
-C
L U O
7 C -C
O L'
f6
a
C
C
U b0
O
C m 0
C
C
Ln
a
O -O
u
a
N a
E
`C
ca
o a
v
L
o Q u
6
E
'.i-'
L
r9
N L
—
T C
In
m w vi
r0 T
m
a r0p : LY . ..
...
O u
fl O
C C
C
— C
a
C:,
9
Q -° o
o ro °
-M-
o
o
-C c
b� o
0
L
C
C
O
—
j
4.
o
m .°
u
C
GJ
o
Cl)
-a
c9 to L..
C
-0
Cu
}
r9 a
c r
.-
c ,E
.-
a c
—
Y ..
M E
— a
O U
F— o
O +� rn
f— "O
t/). Oa �, a
U L L...
M E- I
�
L c
r-I a 7
L
N a
7 o
rr a s
c a
N m L
a) u
M-0 um N
a c
e-I a u
A:)uaBin
sleog
}o lanai
ajelpawwl
sdajS IxaN
uaaal Ou01
Aao�a }e�
elseueyjn3
Packet Page -1414-
v
U
L
a)
N
m
E
c
Q
U
U,
a)
E
O
O
C
0
U
G)
O
U
Ln
O
N
T LAY
m O
E N
E (`,
cn o
C Y
O u
C
Q.
c =
0 0
U 'Y
E m
Y
m a)
E
ow v
a a
a) E
C
U N
C
m °-
� m
L
C
a0+ a!
a) E
.c E
N 0
U
a, a)
O
m
R
10/13/2015 16. D.12.
Packet Page -1415-
O
t" q
bD
v 3
m 3 LL
} y
LL
LrL Cy
c
a
o
0
aco
E
E
C 'C
0 Cr
p
LL C=
O
C) : O
O Ln
O
++
u
U
�
al cC
O
o
m
a
N
N
N
N ,
E_
m E
d p! E
LL
m
LL
m
C
v
LL
M
LL
: N
LL
fA
CY
LL
M
Cf
LL
-4
C7,
o H
E
U
a
o Qj
C
L
m
to
0
a) m
.0
L
O
t`�A `1
v m
Ln
Y
v
C
+
61
0 0
m f0
U' U Y
O- a
o a
`-'
c
E
o
°=
'�oQ
E
o.cco
cs
3
O
0
CL
'-
p 3
o
o—
C a •3
a�
m
a c
Cu
c
o
a) o
m
U
W
C
Y
Y
Y v Y
> N
L. po
0�
C C.
O
a E
O '? 6
Cu
Cu
C
U O
U
m
to
o
�
�-
,
'
U
c
:+3_
o 0N
Cu
s
-o
`L°'?
m
0
o -a E
v a
C o
0 0
0
M> v
r
E
C.
CL
OL E
v o
U ..
@>
c
m o
..o L
a
Y
c
N Y m a
pp m *' E
N
to ? ��"
(U [a
to
Q
a.
U
Y aJ
'�
+) c
v E
v
c v
O
A
c v� o
Y
c ;°_
Cu
CA
c t_
v O
N E
O
m o
,L, n
Cu
m 0- L
O N v
m <. O) to aYi
d
m
E
Q
> t)
_
u
A C.
v
rYO
L
o N
n u Y L
p _a
to a) ` E
N �.
H
D
v
CL) E
3 a1
a
Y
L
a) o
p
°
c Y c 3
o o
o
c u v ou
o
c a
E a
c
cca
CL
a�
°> E
Y *'
c
o
-o E
O^ Y
L
v
Cu n)
o ,�,
uu
m 3
m p 0
m
a
O
O
O 3
0:,'
�:.
-0 m o
"YO. -p.
cY0
-O +�+
Q -.w
0 .�..
3 c o
m
°'
Cu Y o
a'`*� -0 M
Cu o 3
w N m
a
w p0
L N
ai 'a
w�.. .0
N
41 C U
N a p_
N.: •� H
N m .` Cu
4J p
N Cu
n
N
Y E
Y Y
m
a) C
U U
CL
V)
to m
N u
`� C
C
a) O 'O
N a) to Y
a) lJJ to
'G. O
— �. @
— v y
= u
— m
: Op
L O to
-C : O_ a) ; C
-a
.0
'0- Y.`..
Q a) t_
Q u 7
N o
Q N
Lr)
U m Y
F- vi - O
F-
C a)
Ln
v
O
O
m
p
C
to
6
-O
N u
O_
= Y
'^'
N
�.- C
O
stn v+'i
v m..
`�...�
O Y
E N
C
m m C
M
C C
(D p
m_
+-'
o.. _ —. O:
>
C
O
a N
' u
,� L
0 0
U to
O n
U 7 a
w E o
en m C
Q) U S N
O p
0 C o
U m O.
o c Y
Y O
C
C
m ?�
E
O
U
E
L 'O N
Y
3
L �,,
a p
p O
L --
m
C m
O m o
,m,
a N
o>
0
m=
0
c
C�
a= >
C
v
L
o 3
c c n
o a
Cu
o
v
a
c- C
u
m o
o
6 a v
m -0
_ a
o c
m
—> o
E
E
do c@
c m C
v
m a, Y
'_' 3
A R Cl)
E
=a C
° °
c
ao
cpoo v � u
'E -a
;a m o
L"
O
a1. O
Cu O)
C
m E. O
N
m N
N C
C O C Cu
m
: ,m, N p
C
C O
N m r-
Cu m a) :.
to
aa))
m =
"-
O O
O
U u O
u U. m-
- C
T o •N
T o
0 w
'(p
:.0 to O.'.
3
N
0
>-
YO O.. m
?' vi Ll
p) L
— m C '0
M
.a O
Y •N to
:.L o
N
U
a a) E
C
o
C
a m
L
pp L°
m m
o v a) T
to
`° c L
o °;
C N
CL
u A
a) M
a
L
a
3 t
4D pp
ro
oU
C
N..m
N
._. to C
0 O
v a) �
pU c p
�
m
�'
N. Y.
-0
'N V..-a
�. Y C
Si a
Co
Y
o
E
M :� i-
yL•, C
p_' C pp
�.+ -
F-. U O
U E u
U a) o
O
d
M 0 0
r4 .3 Ou .
O
N trait .
m.. 3
M u m
m
> 0-
_ u
� OL O. uu o
10.. x-+. O>
C C':
a-i m m.
N U U
kwasa n
10 banal
aleipawwl
sda�S IxaN
tiogale:)
UOIle4lUes
Packet Page -1415-
O
t" q
Ln
r-I
O
N
Ln
E N
Ln N
U � G
c *'
O
a)
N N (6
� C
Q U O
U E u
Ln O C
L
E °D
p v
p a n
+> C E
C
M U
O O
U
y m
O L v
U E
N O
U
aJ Cu
0
cm
G
6 p
C N
a)
C E
N
ar u a
c
Y C
v)
N
c E
`
C L i
� O
�
` }
V
LL
U
CL
O
a O
N
Y �
2
4) O
-O 'O
by
_ Ln
f6 V a)
7:5
CL
bA
O �
N
c LA Cr
E m
LL
-
T _0
a)
'J ) r
C
N
0
a)
u
-0 O
C
O
.L
L Q
1-I
tio
r-I
U
a) C fL6
vii
C)
N
@
CU _
®
> h
a
E
E
E
a a
m
C
b
b0 C
n
m
O
Q
bo O
L
>
s (1)
c
U
N
Cu
C
L C
C �
a, O
.
U
C) a)
C.
(O
O
C
m
C
d'
O O
U N
O Cu
N
m
Cu
i7n
=3
v o
a=
b
v
ai
J
Cu
O
3
a v
o
N v
L,- 0 -0
a)
E C
`C
ba
a). —_
a)
bA C
LS
O
a).. >
O Y
Y
.0
.L. -0
L
a) -O
E
C
m
O
Ul)
a u
m
v
O
b.0
L
CL
ns �' vu-..
L_
�O
.O Cu
C
" s
.�
Q
O .?
C in
01
O
N
L
U
c
Q
v a
O
O
a
O
0
O U
a) E
'Ct
:3 v
OU
O
_
3
Q
4D
O Y: E U
CL
C
O C C
C)
L
Cu
C
a) M
Q
>�
�^
o
O
O
U
OQ
a)
0
a)
`� �
- a) N -C
N 0 0
�,-. —
cab
d. a)
v
Ln L
u
bo oj
c
C:
u .0
ai C
w o
a)
d
—
c c
o
Cu o
t�-0
— ¢'E
z
C)
o 3
as
v o
a o
°+'
W a
Y
V
9
Q..
•in N
O
N
O L
T
[C4
L
v Q
-0 U
a) �O C
rn
s a) N O
CO
a) C C
v C .0 O
rb
CL a) C
_u �n
L 4-- C "--
c O
m
_
N N to p..
O O
7 O Q
a
Y
C -O O
-C
U
+�
O
a) �.+ E O a) C
O
.N. ns
+� �. 'O
O E C
4 +� O 'o ba -6
E
L ra
L iD c
to fC '..
E C
E
�. b.0 N
r-
b0 41
(9 bA
7 V1
f0
U
X
fED vi
O C
> v
y
a m a)
a) >
-0
v
>
d c
a
c
a �,
a u Cl)
�Gi
'
o o n
cv c m
C o
L
In to
—
in m CL
L M
46
O O u
N. CO
M O_
"O > :
j: C r.+
LO
a) M
td O a) Q
f6 bn
Oa
OC- L
>
@
> U
> U .. to . u
CL. C
.� r-
CL
C
a O
p
�
U O O +) O
O v
E O m
E
a)
C
O C
a) Q
_
O
2
0
L C
O O
L N L
w
a)
O
L
m
m Q m
o- "O +`+ CL
Ln 3:
C
r-I @ CL .0 w E
N .E
kmas.in
sleoE)
}o lanai
wj;)i Suol
@Jelpawwl
SulsnoH pue
Packet Page -1416-
10/13/2015 16.D.12.
Cu
bo
LL Q)
0
m
a)
bo u
CL
C
c
L aJ
U
a)
C N
a)
C E
U
Y C
v)
N
c E
`
� O
�
` }
V
U
CL
O
L
Y �
2
4) O
-O 'O
by
bn v
7:5
CL
bA
O �
N
E m
o ()
-
T _0
a)
'J ) r
C
a)
-0 O
C
O
.L
L Q
c
O a) a,
7
m 0
°
vii
V) W
N
O
_0 U)
(1)
®
> h
E
W
C
m
C
b
b0 C
n
m
O
Q
bo O
>
s (1)
a) y
C
L C
C �
a, O
.
U
C) a)
o °-
Cri .E
d'
a)
U
N
N
E
Q
U
�\ Ln
a)
E
O
O
.1
a-+
C
O
U
O
U
Ln
C)
N
Ln
C)
E N
E a)
O
Ln O
C U
O
M
= a-
� C
u O
E f°
Y
C
q0 E
O N
CL
o —
ai E
C —
•V N
C
O O
Y
m
L
C
Cu
E
N O
U
N a
0
m
L
10/13/2015 16.D.12.
Packet Page -1417-
N
rl
_Cu�
_u_
m ° LL
a °
N
H
U
aJ
° Cr
_
_
O
u
Cu
v
v
0
v E
41
p
O
O
00
m ..
c`o
O
0i
= C
4!
N
N
N
O
d
CL
N
w
m E d
LL
u
L.LL
d w E
N
N
d
N
d
cl
E
v
v
N
i
In
Ln
Gi
Ln 0
m
ono
N o
o m
— c
a °�' Cu o
v'
6
Q a.
o
to CL
Y C
m •` Y
E
0 '_
y....
`o
`o
a O °
a)
+' > 0o
`
CL
Co O
'� O
o Y m
v�
v u L°m
_
a 'E
O O Cu
o
N a
-p Y
w ^
m r.
Y C �..
L,
Y: a) m f0
Y L
ai Y .a
y
CL
U_ "o �
C Y
a) to ° v
C a'
m +'
O. v
Y C O
:N N
O C O
Y N N
-:. "O u •m
_ a1
O -a Y
U
Q. r- Cu v
Y
X z
fro
-° �-
= LL
C O >..
O =. LL
++
W C N LL
�.
Cu .
u >. > O.
C
—
— Cu m-0
bn
C; N
a)
p
m. ` O
fl. E M-
m w vOi Y O
U
L: Z
0
c=i
C
m
Cu .'in
aL.+
C a, u
a)
L a/ u
7 N .N�..
O �.+ N
°
•m a)
C> O
O C d
Y
N
D.
m O
Y
Y 41�
`p c E
+T+ �O
C m
'C L
CL
00 =
N
oA �- O
C
"- O
Y °. o O
a H p
m 00 •'= in..
Q
O_"Q
p. O Q
-°
of O Q
00
C ],. u.0 N
L.0
j Y a)
�i m m E
tio.
19 m
C
O
C
° O Cu
O_
U m M
U N +��+
C C
N
m
a) N
>. Cu
-a '+� C
Y C
Y .�
w
Cu U ,G L
N a C
L L of C m
O mm
Q
Y a)
O al C
-a
a) C
o L C. a
m O Y
In CU
LIO
u a F-
m a �-
o Q E
v E c
0,-o Y o
m o
U
C U L
..a a1 N
*' ° m aJ
m �n C "a _— a1
Lm @.
L
Co C +�
p C Y
cn L Y I--
Y OL. E O
C 7 i1 m v
'�.
m: 0
Cu a
a. -a
�O
U O. -a
0 3 w 41
o_
p on p
'3 m a. v
v :: p
m y
a C
I
p C
m
o 7 C
6 O
`�O
.0 aJ Y
n L
to aJ >, N m N
7 2
E �^-I -I
Y C lD
Y C tD
U ° m '�
G) Q Y L
+N., m L O
Cu
O
N a1
a
to -O Y p pp
tN L 'a LO
L ,n +-� "a Ou
_
3}
O
E c N
O
E C N
c °' o" .�
CL �'
f° v `O v
>.
LL
O E. E. E 7
Cu Y
on 0. C
.s
L. E N U
-
w :L
`
C
u. C LL
O.
O d1 ° O
0
O
` -a °
H. �,
— .E C N :3
Ln —O
d..O .c
n. c
. O _
S.L.
on m w=
C
Q. m aJ u d
C
Y -a
Y
Ls
N
Y
E
LA
M bn
of
m U
In
a a E
s
E
c c
o C
_
U C
a Vf
0 aJ
tCC al
+=
Q
a
m
o > a
> Y
m
ao v L
a) on
C
v
m 'a)
T
L O
bn
t
pp
N
> Co
u �0
O
Y
C
OU C
O
m U
C
C
E
m
0
c
v
Y
.�
ai
o Cr E Y
N m
v C
C L
•�
a m
�.
U
C Cu O
N.
�••�
C U
E
Y
.�
Ln
a
E
00
on C
°
V
w
7 Ln
to L �
aJ
�.
Q m
y C ��,
O =
3
p L
+�+ N CD
c
L
E m
° on
C
m
0 U
�+ v
Ln
�, a m
N
t o.
n°
Q
Cu fl
N
3
a)
Y O" m
N
do
of C N
CO _a m
41 C
L
m Y_
Y O
C. Co
O
3 111
U .0
L
O>
�n U
O C
Q.
O.E
Y
C
•°
C
�
U°
� L
3
i 0
Ou
N C
O�
7.
O Y 'a
0
0 i3 C "O
�. II.
7
_ E
m p
N >�
C ,Y
O o
v m
_ a •�
_ a� o m
_
o
O E Q
c
Ln -0
� a,
u m
oo E E 3
6 on
r-I V)
4 a 2
sdaIS
A:)Uagan
}xaN
}o Janal
(il osa;e:)
Packet Page -1417-
N
rl
Ln
t--I
O
N
Ln
T �
m O
C N
N E a
u Ln Q
> O U
a - O
ro
E
.E C C
0 0
d u ',�
u C a
Ln c
v - a
E to E
o ° v
o 0 0_
C
C
� U Ln
o O
U N +,
N � �
L
O a
U L E
N E
O
u
a v
cro
G
10/13/2015 16.D.12.
a) °
OA
tln
bD
to
GD
bn
rn
a
C U C
�.
m.
C`
m 3 3
LLLL a
w a
LL a
LL Q
W
}L
LL � a.
a o�
Ln
a
o
a
a
X
a
Cl
a
X
0
o
a
o
0
o
a
v
Cj
Ln
L.,
Qj
C 7 •p
to
m o a
o
o
o
1
kA
o
00
0
00
0
z
o
,�
o
O
0
0
O
�.
N
O
O
C
O
m
00
1-1
W m
as
N
O
O
,
O
,
O
O
N
O
Nm
O
C a'
Y
N
Y•
N
N
N`
N
m E
LL
}..
LL
}
}
LL
LL
d Gc
:.
Ll.:
LL
LL
LL
`.
lJ
lJ
�
C
a
3
on
0 c
oo
a
aco @
c
n
o C
t o
-
_
c m
0
3
a
o
a
C v
.-
.�.`j
*' x
c�4..� O �.�
O
c
m
*v �'
E a
fu
L
'
c
E
O
a a
C
m
o
C
a
O
a o
0)
a
N
ID
E
n
CL L
- 3=
r
o c
a Ln
a@
},m
v
u E
0 o
o
_0
LL o
o
o c E
m a o2S
a
a
3 @ c
o
a E,�
m
C
L �; c
- m c
= m Ln
p u
m
a
c
o 0
n
a
(O E
c
m N
:'+''
a u Cu
m
.0 a..
y
—
.�
a
d
U
U N
on
a
7 f�D >
ar
o0
CL m
(E
w
Co �
c a
_
O O
a L
a L
m Y. a
i
7 u0
O
on
E o 00
•�
V1
a
a 3 L
L. -Q 4'- LL
o
`'
a
_
-Q +m+ L'
eo c.
�' p
a Y a
fl-
Qa) C.: o
, a "-
.-{-
u O
o
a o o
— c a a
c a
c c a a
.� a s
a
on
o
Cu E N
m —}
m
m o a
c
a
= c o o
a a Y
�
.6
c L c
u a
E �-'
vi
am+ z a C �.
m
V7 _
m °
U LL
c- c
' C L4
0 m
I4 a a
c a a
v cn°
L an
C
o c C
.
II. U C
L
�-+
.a✓ a tC
N. on M Y, a
L C
a-+ O
m
U
C �.
O -0
.ti. a
C - E ..
p. o. 7 C
a
C i m 4n
a "O O
'+- +�
a
,...O �- O:.
E u
� u �=
E
Cu fl o, a
E o
o
au w
-C
a n -a
L m c
.3
— ro 9 n
— a
•3' ;,_,.
u
c i
a
m d'.
a m
c..
C m m a
L a a
c p—
a�
u �.. L..
a
m
z __
o o
m
a a a
C. a m
u E a
a u E°
m
E a E°
a s
E 'u
m
� N
v: c v
c
m c'
a -aa °u rco
c° .5
c i
iL- a cco
m
i s
c
O LL
m-
fL- cry o
U) u ai
`�
a
—
— +a+
O O
O
E
—A
_
_
on
° ° a
z' E
n
m
c
a o
a
U
C T
C m
L Y
X ...
C.
CL
OX
"Y ll7.
CCn
4�.- C :
'Q
L
m
f0. O
a C a:
Cu
° bn
Ln a
°
C O m
C
C_
m
W 'O
L_
''
v-
L
E o O
a
E
Q a
n n
nJ C
(9 0
a
C.
n
Cu
i
O
p LU
m
�'
O -°
0
on C`
C.
o
E
E
c
Y? 3 Cu
c
c m
Y m
a
a OJ
N
O
O
C
7
U
a
a N
L U y
a c
Y. N
U
° E
In L
to
U
o:s
3
p0
a a
"p.
°' o
°�
of
+�+ C
°
_ +•a do Z
L c
.1- O a
tin a L
+� a
m e
Q C
_- M
E
C
O m
C +�
a o
a •�
E v
E
a pn
L
m -i
v .�
E
vm
[O
m '"'.. a C
U
'..'a:. p.
= M O
N::
c
Y" .� :.
`n
Ln
— O to
*'
i
a
a n
[6
B x o
'O
-'. C
_
vi
.ti
L VI
an
a m
Vi .. U
am+ C
ro
i_2
M
a E
_O:
—
.0
N
—: Y
E
d:a E
O
y bA
++
D L o
O
— C. _
U —
�i
CO i-
'Z
r.4 u
ni m u �'
rf .S °o
ui a s
° m
r� u
4 co
rj a
touasin
}o JaA81
SICOD waal Suol
Aaosaje:)
Packet Page -1418-
m
v
U
L
v
N
f=
c
Q
U
v
E
0
T
C
O
U
v
O
U
/1
Ln
0
N
Ln
L t�
ro O
C� N
C
�'1 O
C O u 'U
M (p
O 4_
C O
U
E 4-1
C
4D E
O
CL a
v
C —
U �
C
N O
C
Fu E
� E
Ln o
U
CU a)
f6
10
10/13/2015 16.D.12.
w
o O
-D
v
13D
10
w
1
to
in
w 'Y
Co
Cu
m w
U-a
a
>
a
a
a
d 0
C)
Cr
CD
CD 0
u. D)
CD
Q
CD
Q
0
C) CD
.V).
O
I
0
Y
00
u
O
�.
C)
Q
Q
Q
N
N
N
LL
LL
C
d a E
't ` LL
a
a-+
lri
M
C7
LL
LrL
N
Cl
N
CJ
t}l
M
Cl
M
d
E
D
z
u
;n
oCn
v v E
CD
"�
.ca
..0 E
m D
u
E
O O_
'D Y O
N
s
Y a p
m
C
�.
>
a p *'
^
w
N
>..
bCA.,.
C
•C)
m -0
vYi
Cu
�n v O
U In
,.�.+ : LL
v .�
in
�n
~S O
C C U
m >
Y
In
tw
'O
ro
CC
@ C
O
M "O
u 9 u
L
C' o
v
a
o •3 v
a
o +
A.
n
�
v
> °° -D a)
o
vi
a
4- >
'�
.Q >
In
O
�n m'-
-O a)
a -o
a
v
—
-0
In
LA
> a
O O
VI
C
C
m
}v,,
Y
41
cE In
C m
Y
O
�i C
-6. a)
.ate
m m CO
++ m '�''
v C
U ,�
O U
u.
_
'c
a;, -p
m
Q +�
c
v
Y �..
O v,.
c
p
cw O
m >
v
O
.y,. �.
_
c �O
m
O m v
U u
m
:C
N
_u O `:
u
N v O
u U O -p
C a)
0.++ ,O
p O c,
O �.
O. Q
O
Y v Y.
Cu •X �.
O
In bD
*'
C 0 v
E
C
O
�n a)
m
a
C @ C
C L C O
Y
c6 ++
C O am,.
In : �n
_
C
- Cu
_
—
a1 — -p Q1
fl-
C m Y-0
O
m C
u0
v
U... v
fO '�
N
CO
QJ
� C
C v C
m @
a) -
Y D
U
v
�v o
Q.
u.
a �n
O
tw O
C
v0- m
a+- - Fu C
C)
C
•�
"' C
, C
a
a
a
u C
- O
C
n
v
a'�
h0 Q)
O_
.N m
N c
a) X
a v a
m
w .- w m
Co a
m
C
u
In >`
,n
CJ CD
E,
C
O y
D
v
U
Q.
N .F
Ts
u
.._ m
v
C. U Q
_
O
+
ru
by
Ci
O.
C
C
'�n aJ D
u -C i
Ln =
' =.
`n
-6
L v
+-�
O
C r-+
C N
Y
�....3. v
w O
C M
�O.
L ..
04
C
L
•� L
m
_.. v tlp
�
.N L N
Lf1 v
m
"O
_ O
U.
N
'6
i
p
In U
},
p E
°�° s j
,�
0
3
In
c
C)
0
Cu
0
Co
CU M
E
`O m
m
c7' In
C
-
C Q
O
�
C Q)
m C
E
O
4.-. C C..
> U c p-
: I"
v -
C ,
_
_ C..
@ In
in C
O
W
m p
a. �
tiDS
.
-o C.
: 0
CL p
—
�n C
ro
_
.a D
.m :3
72
'L
> O :. C
'p.
'6 -
'6_ E
..v
aJ
�:..
a)
: Ou
.
Q. C� 'O
'O C
C
11
v
>
p
>.
O
> m
O
> O
o
w a 0
u_ N> c
1 U O
� m bD
-0 ''.
. —N.
Ou. i
O,. O
"6 "D
V ?
..
N
M.
C
a. p
flr to In
Cr m
N
lD
.--I
v0-
kmasi
aleipawwl
}o jan91
lC�ona }e�
aae }IaM pue 'Joineyag 'JuawyDiau3
Packet Page -1419-
r-I
Ln
O
N
Ln
ro O
C� N
N E aj
U ✓� G
o
i O U
N aro ro
E r/)
.E G p
O O
Q U +�
U E
C
v " Cl)
E E
o Cu
E
Ln
U
0
G C O
L m
4J L 0
_ CU C
O ±' N
U v E
=V) N O
U
_N N
ro
f6
G
10/13/2015 16. D.12.
-0 o
tw
n
b
a�_
L+
o_
" Q-
LL n
o
0
0
a�
E
v
Cu
m
m
C
o
o
Co
E-
asi
LZ
o°
m
M
�
N
C
O
DO
00
N
O
�N
ON.
O
ON:.
E
LL
U-
LL
>-
LL
>-
i
d
E
�--� 4'
O ✓.
o
L
a
i
}' U �. 6 L C
Yt a �
'a �'-
�n ro
fJ
o
� `� ++
'O O
_ O Y C
N'
O — va•'i
C C...
C. *'
a
E Q a m c a
3'A
c cm
0 'E
Gi
-6 > rl
i6 C
�C9
(9
a f6
p to
C
~
'6 SZ
'`''
"O a .m O
U C
�^ C
U E r6
C
a
U... O
U E Q� -O
0
U a
a
C Cu :. a; Cu
'"
Cu
p
-GC E
N �.� .. .
C V ate+ p +� •�
O Cu
N
'.ice L. a
C~
�f CL
� •� �..
L
C N O L C" CU
Y— 07 C a�
n�
= ?�
Q C
OU
E r0
N M
C E
C U
O L
o a C
u p a
- C
- `° v a E�:
c CU �
�--..
s M O a
v a
O
O U
CL
Q
0
Q ti
UE
C
a
yr
� +
co
c
o
a
L m
Q
O
U
- Cu
Q
a a
a "
-5
-
-6
Q a m U
E
O
m
C-0
'c
_0
C
pp '
U a
>
aT
_ o
Dx
a
C T O C
C N
3
.L 7 C
C C C6 Cu
T
U=
i
=_ a U
O
E
a m to
rC vai
� aM f° en p E
C
p N
U L
M OA ro
p `:. rn
C a en c
O. i
�-
3— o
"-.
Cu U
m 'o
a
— L C o L
� cLo o p a."1 ,_;
a >-
cn
O
L
E
— i
a= 5
O O a
C
° °
o
r
>-
Q
2
"O
o O
o C
u C Q
p
n
a
m
E
_0
> .
Q Q
Ln
C)
r6 I
U
y
6L1 C
�. -p
.E
a;
i
E,
3
>
E
�°
E
a
U E
a° p
a
o f
ro Q o
Cu M
u
ra � 'L .
te
'G
Q
E .E
U rn
C)
U. a
'L.
— a
ra.
a
Q
U
o f
O
tin
Q O O
�,
a L
aE
_E o
E
o
a
a
m a
QL1.
u
a C
a T a
L rn
Y C
C
i M'
a C m
> m
c
3 0 C
_o p7
a) -C a
�'
C yai M
'6 a .pD
U CQ.
.a •rD
ro E
a U
s
c
o .E -i
Cu a
+ m
O
ra
s— a
n
a o
a m
_a M
N
a C n
0 n
C
E L
a m O i
E-o
v o n
+, o
- o
M>
N a-0 o
a
n�
a
a
•� `� 'f3.
C _c Q
p L :.a
U
ro 'cn
=> a>
.� •.F+.' L. ra
E C...
C >.._C 'p
�—
U T o—
U
W S >.
tn.. +"' L
_ C
W a
'C a
C 7
off M Co
7
lD CL .0 m
a L
14 M Q
O T a
N Q - -0
a
Y
s
4 .0 �
kmAin
I
}o lanai
sdajS jxaN
Ajosa;e:)
Packet Page -1420-
L7
r-I
"\
/'14S
N
0
N
A N
t0 O
E N
N E o
4J 7
U N O
L O O
N
N C
— 4� to
f6 5 a
c C
Q 0 O
U C
�,. Ln m N
O
O L Cu
c E
C V Ln
� C
U v O
.y
L
a) C:
O ! N
U N E
L E
N O
U
N d
c�
G
/ 1
Packet Page -1421-
10/13/2015 16.D.12.
LO
r4