REPORT
Elections Code Section 9111 Report
Animal Shelter Initiative
Prepared for:
Napa County
July 8, 2016
Frank J. DeMarco, Esq.
Hanson Bridgett LLP
500 Capitol Mall, Suite 1500
Sacramento, CA 95814
Tel: 916-551-2807
Fax: 916-551-3382
[email protected]
TABLE OF CONTENTS
Page
A.
Introduction .............................................................................................................................1
1.
Scope and Assumptions ..............................................................................................1
2.
Description of Initiative and Alternative Measure......................................................2
3.
a.
Original Initiative ............................................................................................2
b.
Alternative Measure ........................................................................................2
Potential Impacts Broken Down by Each Subsection/Paragraph ...............................3
a.
Areas With No Anticipated Impact.................................................................3
b.
Areas With One-Time Costs. ..........................................................................4
c.
Areas With Likely Cost Increases...................................................................5
d.
Extra Time in the Shelter—Board, Socialization, Exercise &
Enrichment ......................................................................................................5
e.
Extra Time in Shelter- Additional Medical Care ............................................6
f.
Potential Impacts of Reduction in Euthanized Animals .................................8
g.
Areas With Potential Increases in Revenue ....................................................8
h.
Other Impacts ..................................................................................................9
Elections Code Section 9111 Report - Animal Shelter Initiative
Page i
12501112.2
A.
Introduction
This report evaluates the potential impacts of Measure B, an initiative concerning the
handling and disposition of impounded or surrendered dogs, cats and rabbits, which has qualified
for placement on the November 8, 2016 ballot in Napa County, California. On June 14, 2016, the
Napa County Board of Supervisors ordered the preparation of a report analyzing the Initiative's
potential fiscal and operational impacts on Napa County, as authorized by Section 9111 of the
Elections Code. The full text of Section 9111 of the Elections Code is attached as Appendix A.
This report was prepared accordingly, to be presented at the July 12, 2016 meeting of the Board of
Supervisors.
Simultaneously with the actions above and based on direction provided by the Board of
Supervisors, County staff and the initiative proponents developed a potential compromise initiative
("Measure B") that would address many of the concerns raised by County staff over the Animal
Shelter Initiative, and as a result, a second compromise initiative ("Measure A") is to be presented
to the Board at the July 12, 2016 meeting. The compromise initiative is referred to as the
"Alternative Measure" in this report.
The full text of the Original Initiative has been put into ordinance format to be presented to
the Board of Supervisors on July 12, 2016 for placement on the November 8, 2016 ballot. It is
attached to this report as Appendix B. The Alternative Measure will also be presented to the
Board of Supervisors on July 12, 2016 for placement on the ballot and is attached as Appendix A.
1.
Scope and Assumptions
This report is intended to consider the fiscal and operational impacts of the
initiatives. It is anticipated that there will be an overall increase in operating costs as a result. The
cost increases are generally related to the cost of providing medical care, socialization and exercise
to those animals that previously may have been euthanized earlier, such as potentially dangerous or
otherwise unadoptable animals, unweaned animals and seriously ill animals. Some increase in
adoption, dog license, and chipping fees are expected by the Initiative Proponents. However, any
such potential increases in fees would be more than offset by costs associated with longer stays,
new administrative documentation requirements, additional medical care and additional services
provided at the Shelter. Proponents of the Initiative have pointed out a cost saving from reduced
euthanization; however, whether there is a cost reduction or increase from reduced euthanization
is unlikely to offset the associated cost of housing and caring for an animal longer due to medical
or behavioral issues.
The initiative proponents have pointed out that the initiative does not require the
Shelter to maintain animals alive indefinitely. In the event that, after identification of an animal for
euthanization, and notice to the non-profit organizations who have registered to be notified, there
is no assistance or support proffered, there is nothing in the initiative that prevents the destruction
of the animal. Thus, while there is some cost involved in reporting and notice, the initiative does
not require long term cost of care and "warehousing" for an animal. One of the stated goals of the
initiative proponents is to enhance transparency and promote partnerships with interested nonprofit
animal welfare organizations.
It should also be noted that the initiatives are predicated on the consistent support of
non- profit groups. The live release rates will only improve if the non-profit groups maintain
consistent operation.
Elections Code Section 9111 Report - Animal Shelter Initiative
Page 1
12501112.2
2.
Description of Initiative and Alternative Measure
Both initiatives codify and clarify practices at the Napa County Animal Shelter.
(See CA Food & Agricultural Code section 31108(b)1.)
a.
Original Initiative. The original Initiative amends Napa County Code section
6.04.230 to do all of the following:
(1)
Require, except in limited specified circumstances, that a written
behavioral and medical evaluation be provided to the public and to active, non-profit 501(c)(3)
animal welfare organizations (hereafter "animal welfare organizations") for all impounded and
owner-surrendered dogs, cats and rabbits prior to consideration for destruction. (6.04.230.A.3.a.i)
(2)
Require notification to animal welfare organizations of material
adoption challenges and the completion of a mitigation plan to address those challenges.
(6.04.230.A.3.a.ii, 3.a.iii)
(3)
Require the provision of prompt veterinary care, socialization, and
exercise; require reasonable accommodation of special needs for nursing, unweaned, geriatric, or
extremely frightened animals; and, and require seeking live outcome utilizing all available
resources in partnership with animal welfare organizations. (6.04.230.A.3.b)
(4)
Require 48-hour notice to animal welfare organizations of any
scheduled destruction of an impounded or surrendered animal. (6.04.230.A.3.c)
(5)
Require the shelter to release an animal scheduled for destruction to
non-profit animal welfare organizations, upon their request. (6.04.A.3.d)
(6)
Require that two County employees each sign an acknowledgement
and consent to euthanize the animal prior to their destruction. (6.04.A.3.e)
(7)
Exclude from the above requirements animals suspected of carrying
and showing signs of rabies, animals experiencing irremedial physical suffering, and dogs
determined by court-order to be dangerous. (6.04.230.A.4.a, 4.b, 4.c)
(8)
Require the Shelter to maintain and publish on its website or other
public location, (i) a list of animal welfare organizations requesting notice of scheduled
destructions and (ii) statistical release rates by quarter and annually for the prior three years using
models and formulas developed in the Asilomar Accords of 2004. (6.04.230.C.i, C.ii)
b.
Alternative Measure. The Alternative Measure is nearly verbatim to the
qualified Initiative, with the following exceptions:
1
(b) Except as provided in Section 17006, any stray dog that is impounded pursuant to this division shall, prior to the
euthanasia of that animal, be released to a nonprofit, as defined in Section 501 (c)(3) of the Internal Revenue Code,
animal rescue or adoption organization if requested by the organization prior to the scheduled euthanasia of that
animal. The public or private shelter may enter into cooperative agreements with any animal rescue or adoption
organization. In addition to any required spay or neuter deposit, the public or private shelter, at its discretion, may
assess a fee, not to exceed the standard adoption fee, for animals adopted or released.
Elections Code Section 9111 Report - Animal Shelter Initiative
Page 2
12501112.2
(1)
Paragraph A.3.a.ii. Rather than require notification to non-profit
organizations of the identification of adoption challenged animals within 48 hours, the specific
time frame was omitted and replaced with "upon." It is anticipated that this would be interpreted as
that which is reasonable under the circumstances.
(2)
Paragraph A.3.b.
Struck the words "utilizing all available
resources." See discussion below for more on this item.
(3)
Paragraph A.4.b.
A change was made to the process for
determination of whether a dog is dangerous, after physically attacking a person. Rather than
requiring a court order, the determination is to be made either by qualified shelter staff using what
is known as a "bite scale" or similar industry standard, or by a dog trainer or behaviorist provided
by a non-profit organization (at no cost to the shelter in that case), with a written record to be
prepared in either case.
(4)
Paragraph A.4.c. After the shelter staff having raised the question of
who would make a determination that an animal was irremediably suffering, and therefore
triggering this exception to the protocol instituted by this initiative, the proponents and County
staff have agreed that the determination shall be made by a licensed veterinarian. However, the
shelter staff would not need to wait to have a veterinarian arrive and examine the animal, they will
be able to consult telephonically with the veterinarian. This compromise was reached after
consultation with a local licensed veterinary. It is assumed other veterinarians will be willing to act
in the same manner, though Napa County has no control over this.
(5)
Paragraph D. A new paragraph is added to clarify that any reference
to "animal" in section 6.04.230.A.3 and A.4 of the County Code refers to dogs, cats, and rabbits.
(6)
A redlined version of the Alternative Measure is provided as
Appendix C.
3.
Potential Impacts Broken Down by Each Subsection/Paragraph
a.
Areas With No Anticipated Impact.
All references below are to Section 6.04.230 of the Napa County Code,
which is the section that the Initiative seeks to amend.
(1)
(A)(1) and (A)(2). These sections set forth the time period in which
the Shelter must continue to impound a dog, cat or rabbit. It is not expected that the changes in
paragraphs A.1 and A. 2 will have more than minimal fiscal impact, as they are already a
requirement under State law.
(2)
Section 6.04.230(A)(3)(d). This section is a provision requiring the
Shelter to release any impounded or surrendered animal scheduled for destruction to any active
non-profit animal welfare organizations who have requested such notifications.2 No new costs are
anticipated with A.3.d, as it simply provides that animals must be released under certain
conditions.
2
It should be noted that the Shelter will not release any animal to any non-profit organization, or to anyone for that
matter, if the risk to public safety is deemed too great.
Elections Code Section 9111 Report - Animal Shelter Initiative
Page 3
12501112.2
b.
Areas With One-Time Costs.
(1)
A.3.a.ii. This requires the Shelter to notify a nonprofit organization
within 48 hours of initial identification by staff of material adoption challenges. One- time costs
are anticipated to set up the notification system required under A.3.a.ii:3
Estimated at 5 hours staff time x $66.82/hour average salary = $334.10
(2)
A.3.c. This requires the Shelter to make provision for minimum
48-hour notice of all impounded and surrendered animal scheduled for destruction to any active
non-profit animal welfare organizations who have requested such notification. One-time costs are
anticipated to establish a system for registering non-profit organizations. These costs also include
modifying the Shelter's database system to keep track of when and which organizations were
contacted and maintaining those records for an appropriate period of time in order to provide
transparency to all parties:
Estimated at 3 hours staff time x $66.82/hour average salary = $200.46
(3)
A.3.e. Minimal one-time cost to modify procedures to require dual
sign off under A.3.e:
Estimated at 3.5 hours staff time x $66.82/hour average salary = $233.87
Cost of training for staff- Estimated at 1/Hr/person x $66.82/hr x 8 persons = $534.56
(4)
C.i. Requires the Shelter to maintain and publish on its website, or
other publicly accessible location, a list of active non-profit (501c3) status animal welfare
organization partners who have requested notice of any animals scheduled for destruction.
Minimal one-time costs to set up the publication process called for in C.i:
Estimated at 5 hours staff time x $66.82/hour average salary = $334.10
(5)
C.ii. Requires the Shelter to maintain and publish on its website, or
other publicly accessible location, live release rates for the prior calendar quarter, and the annual
live release rate for the prior three years utilizing methodologies and formulas developed
in the Asilomar Accords of 2004. Set up costs, including training, for methodologies for reporting
the live release rates quarterly and annually online:
Estimated at 5 hours staff time x $66.82/hour average salary = $334.10
Additionally, the County's Information Technology Services (ITS) Department will
likely need to provide support and to modify the way the reports are run, at a one-time cost of
approximately $10,000.
3
The staff cost is calculated using a fully weighted labor rate for an Animal Shelter staff person, which is calculated at
$66.82/hour. See Appendix D, attached. The Initiative Proponents have calculated the cost to be much lower, using a
rate of $27/hr. However, the fully weighted labor rate better captures the real cost to the tax payer:
Elections Code Section 9111 Report - Animal Shelter Initiative
Page 4
12501112.2
c.
Areas With Likely Cost Increases
(1)
A.3.b. is added by the Initiative and requires the Shelter to provide
prompt and necessary veterinary care; appropriate socialization; exercise; reasonable
accommodation of special needs in situations such as nursing mothers, unweaned animals,
geriatric animals, or extremely frightened animals; and to seeks live outcome in partnership with
non-profit animal welfare organizations, including, but not limited to, training, fostering, and
veterinary/medical support.
(2)
Likely cost increases include the cost of veterinary care,
socialization, exercise, and accommodation of special needs animals at a level at which these
services are not presently being provided under 3.b. Depending on each individual circumstance,
the Shelter may be required to provide care above the standards practiced currently.
(3)
Using the euthanasia statistics provided by the Shelter, in 2014 there
were 1,583 live releases of dogs and cats, including those reclaimed by owners, adopted, and
transferred to a rescue or other shelter, and there were 397 dogs and cats euthanized for health or
public safety reasons:
Total animals = 1,980 Live Release Rate = 79.9% (dogs and cats only)
(4)
Based on the assumption that the 1,583 animals released live in 2014
received medical assessment and care, socialization, and exercise, any cost increases would be due
to extending the length of stay, and an appropriate level of care to animals that were previously
considered unadoptable, or otherwise selected for euthanization. By definition, these animals will
be harder to adopt, will require more services, and will remain in the shelter for a longer period of
time than the average shelter animal. It is not possible to truly quantify these costs, but certain
assumptions can be made which can provide a scale of the costs.
(5)
Those animals who were euthanized would still have received a
basic level of care, and these costs remain the same.
Increased costs for these animals is estimated as follows in
Section 3.d.
d.
Extra Time in the Shelter—Board, Socialization, Exercise & Enrichment
(1)
The County charges $20/day in holding costs for dogs, and $10/day
for cats. These charges are found in the County fee schedule and are based on a comprehensive
fee study that determined the Shelter's cost of doing business. (These fees have not been changed
in several years, and as such likely understate Shelter costs.)
(2)
Time in the Shelter varies widely from animal to animal, from just a
few hours to as much as a year. Difficult animals, of course, are on the longer end of that spectrum.
It is not unusual for the Shelter to hold an animal for weeks or even a month or two for a non-profit
organization that has agreed to accept an animal but, often for unstated reasons, cannot do so yet.
Although the proponents organizations, as started by the proponents, do not typically require such
delays this analysis must consider the impact of all partners of the Animal Shelter not just the
proponent’s organizations. To that end, the analysis below (subsection 3-5) outlines the cost under
three scenarios.
Elections Code Section 9111 Report - Animal Shelter Initiative
Page 5
12501112.2
(3)
Under the Alternative Measure, using a blended rate of $15/day, and
an assumed extra stay time of 30 days, and that some of the 397 animals would be known to be
unsavable even early in the process and thus not incur additional costs, the extra costs associated
with the initiative are estimated to be:
$15/day x 30 days x 300 animals = $135,000 estimated additional cost associated with
extended stays and shelter care during that time (basic board, socialization, exercise and
enrichment)
(4)
Under the Original Initiative, because it includes additional
requirements (such as getting a court order), animals are likely to be held for a much longer time.
Using the same blended rate of $15/day, and an assumed extra stay time of 60 days, and that some
of the 397 animals would be known to be unsavable even early in the process and thus not incur
additional costs, the extra costs associated with the initiative are estimated to be:
$15/day x 60 days x 300 animals = $270,000 estimated additional cost associated with
extended stays and shelter care during that time (basic board, socialization, exercise, and
enrichment)
(5)
Under the proponents baseline, assuming the same cost per day and
amount of animals as (3) and (4) but using the proponents respective organizations as a proxy for
the additional time animals are held post an animal rescue partner requesting an animal from the
Animal Shelter the impact is two additional days of extended care. As outlined in subsection (2)
above, it is difficult to assume this baseline as the proponents organizations are only two (2) of
forty (40) Animal Shelter rescue partners:
$15/day x 2 days x 300 = $9,000 estimated cost increase(basic board, socialization,
exercise and enrichment)
e.
Extra Time in Shelter- Additional Medical Care
As stated above, these animals are by definition the more difficult cases and
will require a higher level of veterinary care, in some cases running up towards $10,000.
Assuming an extra $1,000/animal of medical care, and that only a third of them need additional
care, the extra expense is estimated to be:
100 animals x $1000/animal=$100,000
(1)
A.3.a.iii. This section requires the Shelter to prepare a mitigation
plan for any impounded or surrendered dog, cat or rabbit who are identified as adoption
challenged.
In 2014, 397 dogs and cats were euthanized for health or public
safety reasons. While the breakdown between those that were irremediably suffering and those put
down for other reasons is not readily available, if we assume that 90% of those euthanized were
adoption challenged and would not have fallen into one of the exceptions in Subsection A.4, the
total increased cost for mitigation plans would be the cost of one mitigation plan times 357 animals
(397 x 90%). Assuming that the plan development requires 45 minutes of staff time per animal,
and using an average salary of $66.82/hour, the cost for one mitigation plan would approximate
$50.12:
Elections Code Section 9111 Report - Animal Shelter Initiative
Page 6
12501112.2
357 x $50.12 = $17,892.84/ year estimated increase due to mitigation plan requirement
It is unlikely that this workload could be absorbed by the current
staffing. Additional part-time staffing would be required.
(2)
A.4.b. This section in the Initiative provides that the Shelter destroy
a dog without the need for following the requirements set for in section A.3 (written behavioral
and medical evaluation, non-profit notification, mitigation plan, veterinary care, etc.) if the dog,
after physically attacking a person, has been determined by a court of competent jurisdiction to be
dangerous.
In 2014, 397 dogs and cats were euthanized for health or public
safety reasons. Based on the assumptions made above, we would assume that 10% or 40 of the
animals would have fallen into the exemptions provided for dangerous animals or those with
irremediable physical suffering. Of those 40 we would assume that 10 would fall into this
dangerous animal provision. Assuming that the development of appropriate paperwork would
require the time of Animal Shelter management and County Counsel we can assume 45 minutes
based on an average salary of $82.51 for Animal Shelter staff and an average of 4 hours at an
average hourly rate of $175 for counsel time to prepare the paperwork:
10 x (45 minutes of Supervisor Staff time rate) = $618.83
10 x (County Counsel total time x rate) = $7000
In the Alternative Measure, this section was rewritten to have the
determination made either by a (1) qualified staff pursuant to the American Professional Dog
Trainer's Dog Bite Scale or similar standard; or (2) a dog trainer or behaviorist provided by a nonprofit organization.
Assuming that qualified staff is able to make these determinations in
approximately 30 minutes:
10 x $33.41 = $334.10/ year estimated increase due to determination requirements
(3)
A.4.c. of the original Initiative provides that the Shelter may destroy
a dog, cat or rabbit without the need for following the requirements set for in section A.3 (written
behavioral and medical evaluation, non-profit notification, mitigation plan, veterinary care, etc.) if
the animal is experiencing irremediable physical suffering.
Using the assumptions outlined above, approximately 10% of the
397 animals euthanized in 2014 may have fallen into the exemptions outlined in A.4 of the
initiative, and it is likely that 75% of those were for irremediable physical suffering. In this
scenario, staff would be required to provide veterinarian visits for all of these animals. An onsite
visit by the veterinarian will cost approximately $400 per visit:
30 x $400 = $12,000/ year estimated increase in veterinarian sign-offs for irremediable
suffering.
In the Alternative Measure, "irremediable physical suffering" would
be determined by a licensed veterinarian via telephone consultation.
Elections Code Section 9111 Report - Animal Shelter Initiative
Page 7
12501112.2
Each call to the veterinarian for approval to euthanize will cost
approximately $200. Since many of these decisions to euthanize are currently made by qualified
Shelter personnel, every additional call will be a new expense:
30 x $200 = $6,000/ year estimated increase in telephonic veterinarian sign-offs for
irremediable suffering.
f.
Potential Impacts of Reduction in Euthanized Animals
Initiative Proponents believe that the immediate result of a reduction in
euthanasia will be a reduction in euthanasia related costs. In 2014, 397 cats and dogs were
euthanized by the, excluding owner requested euthanizations. Anticipated cost savings are based
on the charge to the public for euthanization and disposal, which is currently $65 per animal. The
protocol is that each euthanization is staffed by two to three personnel, depending on the
aggressiveness and activity level of the animal involved. Assuming no reduction in owner
requested euthanasia (302 in 2014), and assuming an improvement in the live release rate to 90%
of the remaining animals, this would result in 199 fewer euthanizations per year (1,980 total
animals x 90% = 1,782 total projected live releases, an increase of 199/year). With these figures,
Initiative proponents project a cost savings of $12,935. (199 x $65).
However, the extent of cost saving is not completely clear or easily
predictable, as any savings would need to be offset by any cost increase in housing the animal
longer, particularly if the animal has medical issues.
g.
Areas With Potential Increases in Revenue
Adoption fees are expected to increase as the Shelter, working with its nonprofit partners, is able to market its adoptable animals more effectively. Adoption fees range from
$40 for a rabbit to $175 (plus license) for a puppy. Initiative proponents estimate this revenue
increase to be approximately $1,526.60 (assuming a 10% increase over 2014 levels of 898 dogs
and cats and using an average adoption fee of $117).
However, as with reduction in euthanized animals, any potential increase in
revenues due to increased adoptions is not clear or readily predictable, as increased revenues
would need to be offset by any cost increase associated with longer stays (food, medical, etc.).
It is also likely that these additional animals (because by definition they are
the most difficult cases) will be transferred to adoption partners at no charge, not adopted to the
general public. As such, any significant revenue increase form adoptions is unlikely.
Dog license fees and chipping fees are expected to increase minimally as the
number of animals placed by adoption increases.
Elections Code Section 9111 Report - Animal Shelter Initiative
Page 8
12501112.2
h.
Other Impacts
With broader implementation of a trap, neuter, and release (TNR) program
for feral cats, there will be a reduction in feral cat population over the course of multiple
generations, resulting in reduced costs for trapping, treatment, and transportation. The Shelter is
already a large supporter of TNR. However, for the program to truly have a generational impact in
reducing the feral cat population and associated shelter impact, a large and long term effort by the
non–profit community will be needed to regularly address "hot spot" areas with a concerted
trapping program over a period of years. Previous efforts have been sporadic and have not resulted
in appreciable change.
In some other communities where an aggressive TNR program has been
implemented, the community's level of involvement in the form of volunteers, funding, and
awareness have shown substantial increases. Partnering with non-profit animal welfare
organizations may also provide enhanced resources for dealing with adoption challenged animals.
The hope is that with increased partnering with non-profit organizations, by
utilizing their connections to the community, and non-profit organizations' efforts to encourage
and refer people (via donors, adopters and social media) to adopt from the local county shelter to
ensure higher live release rates, increased adoptions will add adoption fee revenue and will
decrease average lengths of stay for animals, thereby reducing costs.
SUMMARY OF COSTS
Section
Original Initiative Cost
A.3.a.ii
$
A.3.c
$
A.3.e
C.i
$
334
200
$
200
$
769
$
769
$
334
$
334
C.ii
$
10,334
$
10,334
A.3.b
$
270,000
$
135,000
$
100,000
$
100,000
A.3.a.iii
$
17,893
$
17,893
A.4.b
$
7,619
$
335
A.4.c
Reduction in Euthanized
Animals
$
12,000
$
6,000
$
(12,935)
$
(12,935)
Total
$
406,548
$
258,264
Increased medical care
334
Compromise Measure Cost
Appendices
ABCD-
California Elections Code section 9111
Full text of Shelter Initiative
Full text (redline) of Alternative Measure
Labor Cost Estimate
Elections Code Section 9111 Report - Animal Shelter Initiative
Page 9
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix A, Page 1
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix A, Page 2
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix B, Page 1
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix B, Page 2
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix B, Page 3
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix B, Page 4
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix C, Page 1
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix C, Page 2
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix C, Page 3
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix C, Page 4
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix C, Page 5
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix C, Page 6
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix D, Page 1
12501112.2
Elections Code Section 9111 Report - Animal Shelter Initiative
Appendix D, Page 2
12501112.2