Travis County Commissioners Court
July 3, 2007
Item 13
Number 13 is consider and take appropriate action on the following: a, variance from section 82.202 l 2 b, standards for construction of streets and drainage in subdivisions in Travis County. 13-b is preliminary plan in precinct 3, rgk ranch preliminary plan, 1508 total lots. And 15-c, phasing agreement between rgk and Travis County.
>> hi, anna bolin, Travis County t.n.r. This plat we originally received on March 14, 2005, and that was prior to the suspension that we had of preliminary plans. And they got a hardship waiver to be able to -- to continue with their development, and one of the reasons why we granted that was some of the things that they agreed to do along with -- while they developed their development. Some things such as they will develop the entire preliminary plan with less than 20% impervious cover. They will adopt the buffer zones for the waterways as required in the interim rules. They will agree to an integrated pest management program and require native vegetation throughout the development and impose night lighting restrictions on the development. Those were some of the things that they voluntarily agreed to. While this has been going through the development -- or the review process, txdot reviewed their preliminary plan and their two proposed access points. They obtained their approval from lcra, lower colorado river authority, on their master plan, and they will be compliant with their alternative performance standards. And they will be getting their water and wastewater from the lazy 9 m.u.d. The variance that they are requesting is for block links. For a block link that exceeds 12,000 linear feet. Due to topography and the fact that we don't really desire to have a lot of cut and fill, staff is recommending this variance for safety reasons and for environmental reasons. So that is the variance that's before you today. There is also a proposed phasing agreement, and basically it lays out when rhymer's peacock road would be built for it's built by the county what their porption would be, or if they get their first, what their obligations are. This is a sensitive area of Travis County. All of Travis County is sensitive, but in this area we have received comments about this is a very urban subdivision and a very rural setting. We have heard concerns over the stream crossings, and we have seen or heard concerns about the fact that we don't have density controls out there, out anywhere. And those are the concerns that we have heard on this development. As far as whether or not it meets -- this is reviewed under chapter 82. Staff feels that it does meet the requirements of chapter 82, that's why it's recommending its approval.
>> how do we address the complaint about the 13 stream crossings?
>> the stream crossings, based on the lay of the land, they made sense. Any crossing will have to be built in an environmentally responsible way. When we look at final plats and site plans, that will be something that we look at very closely along with our environmental people here at the county.
>> I will have four or five legal questions and basically spring from e-mail and fax I got late yesterday. So we will need to discuss that with legal. My recommendation will be that we not take action today on this but take action next week. Will that cause a problem?
>> this is a preliminary plan so ultimately that's a question for legal. I don't think that it will, but it's our attorney's opinion that --.
>> I don't think the applicant is bothered by the fact that that may be the case as well. Is that right?
>> yes. He would like to move forward. I don't want to do this over some long period of time.
>>
>> [inaudible].
>> is she speaking for the hill country? Or is she just speaking for herself?
>> christy is here in the audience. I don't want to put words in her mouth. Let me ask her.
>> I’d like to hear from christy and see exactly because I saw something there that you had brought up in an e-mail, and my question is are you speaking as christy or for the entire organization? If so, it needs to be on the letterhead or something.
>> you bet. I’m speaking as myself as a resident of southwest Travis County.
>> all right. That was my question.
>> there may be some points that I made that could be made on behalf of the hill country alliance. I didn't run -- I can submit comments on behalf of the alliance too. Most of these issues I think were completely together.
>> okay. Thank you.
>> the three or four points I guess I have seen surfacing from the e-mails I received and comments, one would be the streams. The other one would be was there approval of the phasing agreement with its details really requires the county to approve a formal plat that has the same details?
>> the primary concerns are the traffic and the water. We're in an extremely stressful situation in western Travis County. We're having accidents, many of them very serious. The traffic situation I would hope would be looked at more carefully. This is a unique situation because what we understand is the development won't be under construction for many, many years, likely, and the landowner wants to get this entitled or get this locked in under the original subdivision rules before the interim water quality rules were approved. So there's a lot of unknowns. Sweetwater, this -- this was originally -- some of this property, I’m not sure all of it, I don't have a map to show, but much of it was originally where the -- it is part of the lazy 9 m.u.d., but some of these homes were originally in the sweetwater original plans. And we had so much controversy over that and that development hasn't broken ground yet. It's difficult to tell in time what the effects of sweetwater are going to be. So my concern is if this is something that's not going to happen for many, many years, let's hope we look carefully at everything we're going to be entitling or grandfatherring in so we don't have regrets years down the road.
>> what is our response to the traffic concerns?
>> well, traffic is a concern for us as well. The county including 71. We did have the developer work with txdot to be sure that those locations, those intersection locations were appropriate, and when -- one of the details of the phasing agreement is when they start to build, they will have to do all the design work with txdot and enter into an advanced funding agreement and indemnification agreement with the county to make the necessary improvements so that you can get in and out of the subdivision safely.
>> but that only applies to 71, correct? It wouldn't apply to reimers peacock.
>> well, in the phasing agreement, depending who gets there first, there are provisions -- I mean they already have access rights off of an access easement that they would get to build on. They would still need to work on being able to have that easement intersect 71 in a safe manner. Whoever makes that intersection is going to have to do that.
>> may I speak? I guess that's a question I’m going to have to ask my board, it seems like. We are stressed by the rate of growth and that's been on the table since '04. The only tool we have really to deal with growth out there is our infrastructure planning. It's really the only thing we have. And I am a little concerned about the fact this project seems to be a major force in reimers peacock road and I’ve seen a plat of the water lines and now their future plans go down the proposed reimers peacock road to the property. And this particular piece of land is right where both of those major pieces of infrastructure will be built. So if the development is not going to be done for many years down the road, seems like we're using this as a tool to get that infrastructure up and running. I propose maybe we take a look at are we ready for that much -- that many new homes in that area and what tools do we have to make a better plan. Highway 71, all the way out to marble falls, is getting ready to be built out at an unbelievable pace. There's a project being proposed in burnet county that could potentially bring 20 new residents along that highway. And I would hope maybe we could take a look at some plans, some progressive plans for highway 71, look at some of the park way ideas, look at some long-range visioning for highway 71 and how we want growth to shape out there rather than moving forward on a new road, new large plats of development before we're ready for it.
>> any other questions, comments? I will have about four legal questions, most of which are in the memo that I gave you a copy of yesterday.
>> good morning, laura grelke, a resident in Travis County and represent the travis settlement homeowners association which is a neighborhood across highway 71 from this proposed development. We are, of course, very concerned about traffic as christy indicated, but I’ve received many e-mails from folks in our homeowners association who couldn't be here today who are really concerned about the way the intersections for this proposed development will match up on 71. One of our neighbors was injured in a car accident this past week right after the one that occurred with the teachers, and it's a very dangerous section. Even the new improvements are dangerous. There's a lot of water flowing over that road. I hydro planed on it just last week. And concerned about exactly how we're going to improve the traffic before we put all the rooftops out there. There's going to be a plan for that piece of property, it's a valuable piece of property, but whether we grandfather in what they are asking versus trying to be progressive in looking at some -- what the county can do to assist us out in Travis County, in the western part of Travis County to maintain our personal state and water quality. Right now it's really flooded out there. I can't imagine getting more rain and more runoff from homes that aren't even built yet. We haven't even seen the effects of what's going to happen with the sweetwater development. I want to be an active part and have been an active part since 2004 in planning for the southwest part of Travis County and I was in part of the dialogue where we came up with the interim rules and I’m a little disappointed this project may skip over the rules and just be another buildout with a lot of runout. I live on bee creek. My kids and family swim in the creek. We've had tons of rain. It's running clear. It's really nice. I can't imagine what's going to happen to it when you start pouring polluted water off developments into that creek.
>> have you received significant flooding in your area?
>> the lake is up 20-something feet. Excuse me?
>> have you received significant flooding?
>> flooding but not --
>> pardon me?
>> flooding but not to a danger point. Low-water crossings are flooded, but there's other ways to get around, but it's important to improve highway 71, and I would be very open to working with groups. We're working with several developers in the area now to improve and maintain bee creek road. As we get a ritz carlton development out there, those developers are very open minden and cooperative with the community so far because -- seems to be open in the communication. We want to be a part of it. I think the rain water collection example just prior to this issue is very positive stuff. So things are moving in a good direction. I just want to see that continue and the county to support that. I thank you for your efforts with the rain water collection and I would like to see whatever we can do with campo, txdot, whatever it takes. I know some of you are involved with campo. We need to make sure we're looking outside the box and not creating 183 with lots of driveways, traffic lights and heavy development in a part of the county that cannot sustain it very well. I’m committed to be a part of it and hope to continue to work with Commissioner Daugherty when I get back from vacation. I wanted you to look at the issue in a thoughtful way before we pull the trigger and say this is how it's going to be because this is an opportunity. For us
>> [one moment, please, for change in captioners]
>> there are need for roads but how way do that I think we need to look at closely. One of the issues, I haven't seen a map of how the intersections match up, hidden creek and creek meadow and haystack cove, we are concerned. If we are adding intersections, let's combine with one that is already there if we are going to make it safe, if that is indeed the route you go. Thank you for your time in listening.
>> thank you. Yes, sir.
>> I like this. You just come up and sit down and start talking.
>> this is Travis County.
>> you they'd to state your name.
>> my name is craig powell with concept development planning. I represent the rgk ranch and the family. I have a presentation that I was going to do that has a lot of these issues in it and I understand that you want to postpone until next week. I don't have a problem with that but I’m wondering if you would like to see the presentation. Maybe that would help with what other discussions you want to have between now and the next Commissioners court court.
>> let's see it.
>> it's powerpoint. Where do I plug in? Everybody can see that?
>> not yet.
>> ñi. .. . .
>> I’ll true to go through it quickly. You know, I think it will be helpful just based on the discussion that you have already had. This is a map as you can see of western Travis County. The yellow ish green colors are preliminaries that have been filed. You can see west cypress hills and annexation. You see rgk in between those those. The portion that was spoken about that used to belong to annexation, you can see within that r gñcious k black line, that was basically property that the family when they realized that there would probably be homes on that hillside looking at their family compound, went to annexation and bought that property from them so they would not have people looking down on their festivities area. They also purchased some property on the western side to butt up to reimer pee cock knowing they would need additional access at some point in time, especially if they were going to be going through an entitlement process with the county. But you can see a lot of growth and a lot of develop development that is ongoing in west Travis County. So it is definitely an additional pressure on highway 71. The consultant team starting late in 2004 started working with concepts, and one that jumped out of all those processes was the more conservation approach, in other words, the idea that if you just located your development on the uplands and not on the steep slopes, that it would do two things one, obviously, it would be more sensitive to the land out there, which the family time and time again has proven that they care about and are good stewards. But it would also create an exclusivity, setting itself apart from other develop developments in the area that are more typical suburban developments. This uses down to 50-foot lots, which, let me see if I can get the cursor to work, right in this area. That is a hill top that at night you can see the lights of Austin from that location location. The smaller bungalow type houses would still be exclusive with that type of amenity in place. The rest of the lots obviously would have for the most part canyons as their backyard. It's harder to see on this but there is a blue line that is the floodplain that is in the those drainage ways and the red line that is the butter off of that, the lcra buffer, which is more stringent than the Travis County interim ordinance buffer. The other thing we did, and this slide basically demonstrates that if you were to have gone out there and painted all the roofs yellow, orange and blue, this is what it would look like if you flew over the development. The purple is the buildable area of what we are calling mixed use. It kind of demonstrates what it looks like on the land. Again, you know, the idea being that this was our idea of a conservation develop development. It's iranic in a way that later on the county develop development an optional conservation ordinance but this is, this was the direction that we took originally. The chronology of this, we started looking at concepts in late 2004. We submitted the preliminary on the 14th, I think the 15 15th that the county declared that it would no longer accept preliminaries. The interim rules were adopted. I’m in the real sure on the date on that, but the county begins development of the conservation development option in 2006. So we were well ahead of the curve when we tried to come up with our own conservation plan. I think our philosophy, and a lot of that had to do with the fact that we felt like centralized water and wastewater was the safest way do that. In order to pay for it, obviously, you have to have a denser pack of homes around the light where the line would go. This is an instation that shows the lay out of the lights but shows both the floodplain, the county's buffer, and the lcra buffer. As you can see, we kept lots out of all those buffers. In fact, on the western edge it's kind of hard to see at this scale, but you can kind of see the rim rock that runs along the edge of those drainage ways. And we are, I guess in a way respected the discussion at that time about the setback away from that rim rockas being some environmental valuel feature, I think it was called. Just to demonstrate the amount of buffer floodplain setbacks, et cetera, this is just the floodplain. This is with the lcra buffer buffer. And then this is with the open space, the property that is not platted and does not have lots laid out on it it. It's over 55 percent of the property. This shows--
>> 5 percent percent--5 percent is open space ?
>> yes, sir. This shows it with the build buildable portion of the mixed use being in the purple. Now, one piece that doesn't show up on this is down in the very south corner. It's about a 2.6 acre tract that we were going to dedicate for ems and fire, being basically evenly spaced between 71 and hamilton road. We felt maybe that would be a good location for a facility such as that. Here is the aerial underneath that same illustration, showing the green space, mixed use areas and platted lots. You may recognize some of the graphics in this from the booklet that I passed around some two or three months ago , to the Commissioners and you, judge judge. Just as an information piece here is another page from that. And the idea being that it was kind of what I call the fun facts, you know. You talked about the floodplain being approximately 70 acres, the open space being 885 acres, or 55 percent of the property. 13 creek crossings planned. Roughly 1470, 1480 lots ranging from 6500 square feet lots to over 20,000 square foot lots. Sixteen miles of roadway, total property 1596, impervi imperviouk cover. We felt even when they add in the mixed use areas you're still going to be under 15 percent if they try to max that out. The illustration in the bottom corner is basically this. As we were going through our discussions on conservation plan, obviously the devil is in the details. So the kind of the things that you do when you plan it have more to do with how it affects the land than anything else. What we were talking about doing is requiring, let's say, a 12 had00 square foot area could be irrigate--1200 square foot area could be irrigated in one of the rots rots. So the yard would not be a factor. I think as you know we put 7 70 percent of potable water on the yard anyway as a rule rule. Anything we can do to reduce the amount of irrigation that occurs, I think that is a true conservation measure there. We talked about doing the tract driveway. I think you all were recalling my grandparents had two strips of concrete, I’m sure an economical way to do it, but also last impact on the land and less imper viouk cover. This also demonstrates I think the beauty of the area area. Probably the important factor to remember in that, that is why this land is so sought after for development development. It's kind of a chicken and egg scenario that we go through with development on a regular basis. To protect the mere beautiful areas, we try to impose tighter restrictions and regulation on them, which makes them more exclusive, which makes people to spend more money to figure out how to develop on them. Including even going to the legislature because we have seen that occur a few different times. So it really is a situation with where we do need to figure out how to cooperate on these things. We need to figure out how to come up with strategies and incentives, if you will, to do the right thing out there there. Personally, I mostly do urban design. And one of the trends that I think is occurring and will probably occur over the next 8-12 years, especially as my kids start buying houses, what's important to them is how green is this. You know, what is the carbon impact of what is occurring. And those kinds of things are going to start becoming sale factors for homes and businesses over time. This illustration, the two green dots show where it it intersects 71. Both of those in the discussions with tex the dot and the approval with they will, included turn lanes, protected turn lates in the center, and expanded shoulders that could be used for acceleration, deceleration lanes out of the subdivision. This shows an end view of how much wider the pavement section would be in order to do that but it all stays within the current state right-of-way which just gives you an idea of how huge the right-of-way section is out there for 71, and its capability to accept a different cross-section. You know, anything from a boulevard to parkway. Lots of things that could occur. Split level roadways, things that are more scenic and probably safer.
>> is there any way to quantify how much safer these three improvements would make? For accessing 71 ?
>> you could based on the idea that tex dot has includ included those types of safety improvements in their safety manual, and so you can back into how that safety manual, that particular cross-section, was developed, and what their estimates, therefore, were in the less vehicle accidents and so forth by us using that kind of traffic control device. But you can quantify through the manual that this is the way that you control those kinds of intersections. For 71 to be as safe as 360 is, the only thing, you're going to have as many traffic lights as you do on 360. If you recall, when 360 had had very few traffic lights, people drove the same way on that that they drive on 71 right now. I hate to say that. In many ways from transportation standpoint, it just creates problems over time, traffic lights, but that is basically what does it. You start stopping people at intervals and it slows down that overall average speed the. This is a map that shows the congested roadways, and it's accepted by campo. Sorry.
>> have we chatted with the tex dot engineers about increased safety as a result of these improvements ?
>> we certainly have chatted with them about what improvements will need to be in place with the subdivision, including the center turn lanes and the widened shoulders. That we've talked to them about.
>> okay. There's another question. The question rale is, if we make these improvants, how much benefit do we get? How much safer are they? And I would think this is what engineers do, isn't it sm.
>> theoretically.
>> I’d get their take on that and then run it by ours and see. Sorry to cut you off there.
>> no, that's fine. As a matter of fact, break in any time as I’m going through this. My wife says I rattle on a lot. These red roads on this map are all what campo and therefore tex dot recognize as highly congested. It's hard to see down here, but 71 is one of those. I think these were 2006 traffic counts. The one to note over here crossing the river, you know shows 10,780 cars, trips per day. You can imagine, then, what it would be back here as you load out into the subdivisions, but obviously they didn't do a traffic count along that section of the roadway. So in the campo plan, in what was adopted as the transportation improvement plan, here is where the safety improvements were. One was basically turn lanes and shoulders, turn lanes and shoulders, turn lane and paved shoulder. The same thing we are doing at the intersections that we are improving. More importantly, how do we raise the issue of how you ultimately improve 71 overall. I think we do that, you know mostly by cooperation of the different groups out in the hill country, the developers developers. I can easily say the family would be happy to engage in those discussions. I think at least two times greg has been on the cell phone with me and told me he almost had a head on on 71. So this is a big concern for him too. So I think it's identifying the issues are important not only to the county and state government, but they are important to the landowners and the residents out there, and figuring out a way to put everybody together to go solve those issues. And you know, obviously, we have been volunteered to help with that. That is the end of the presentation. As you guys go over your issues or what other questions you may have through this next week, I was hoping maybe that would help with some of it. And if it would be helpful, I could always print out this powerpoint and provide it to you if you think that would be helpful as well.
>> it would be helpful to me.
>> okay.
>> have you had a chance to meet with the residents?
>> we had, yeah, we had a great little get-together out at the precinct office and went through a powerpoint of what we were trying to plan, and we have talked a few times. Yeah, we have been trying to at least keep everybody informed. I’m not going to claim that we changed anything big-time as a result of any comments, because again, you know, the issue here was to put en entightmentelments in application. I’m not going to say one way or another what the time frame would be that the family would be interested in ever turning this over to a develop. Nevertheless, you're going to see more and more property , especially where they have the means to do so go to a consultant team and put a plan together and get it entitled because we have all seen over the years things become tougher to do as time goes by. And the only tried and true way to do this is to go through the preliminary plan process, you know, file a plat and lock it in, and then you have something that's been tested and case law in Texasrs land law over time to stand up in court. And that is basically what our mission was. As to when anything ever happens on this or if somebody comes back and changes the plan, you know, I can't say. For something as complicated as this, I have never seen anybody go in and just plat something the way it was without having to do a preliminary plan amendment.
>> if the county were to insist on some sort of timetable, would would we ask?
>> we on would have to, the family would have to take that to their board and discuss it.
>> okay. Questions ?
>> I have one question.
>> all right.
>> it's been partially answered before by mr. Howel howel. But perhaps I need a little more clarification on it. In what ways does this preliminary plat differ from the Travis County conservation development option?
>> let's see. You know, it's probably more stringent. Especially when you include the almost cra--lcra, mps master man improvement that we have, which is more stringent than water quality that were built into the interim Travis County code. You know, I think we probably meet or exceed everything that is within the interim ordinance. But because we didn't follow it exactly, you know, obviously, I can't articulate exactly what those differences were. I didn't really study that ordinance of we were already going down another path.
>> and do you have any bead on what the differences are?
>> one of the differences that comes to mind, the first that that comes up is the archeological assessments. They probably did a component of that with lcra. It's kind of hard to gauge give than they were down a path and probably did some of the same pieces but just since we weren't reviewing that, by we I mean either dropment services or natural resources group, that we will be working heavily with when we do these conservation ordinances, but that is one thing that comes to mind right therethere.
>> since it is aed to be at least in keeping with the conservation approach,, would the family be interested in looking at the possibility of the conservation development option? Since it appears to be close to that in any case.
>> the difference would be that it would require us to go back and modify the plan. Go back basically through a process again. I don't think they are interested in at this point in spending more money on me or engineers or the consult consultant team. Especially since they are at a point where they feel like they have something that's been recommended by staff that meets the requirements. I think they are going to want to move forward. I am 90 percent sure that is probably their position on that, but I would be happy to go back and ask them if they would consider that.
>> it's my an understanding, and correct me if I’m wrong, but generally speaking, I’m not leveling an accusation, I’m saying if you're looking for the most conservative approach to an entitlement you're looking to get the greatest latitude in your platting possible. In your preliminary platting so that you will have the greatest amount of flexibility for the future. Of course, our, of course, I as a Commissioner have some difficulty with that in knowing, and I think we all in this room know, that we are going to become more stringent in development guidelines in western Travis County because of water quality, traffic, quality of life issues. So am I hearing that, I seem to be hearing two different messages here. One that this is it, and then another that we are willing to negotiate. On some aspects of it. Is the negotiation only available after the preliminary plat is approved approved? And therefore we are working from an entitlement position position?
>> again, I’m 90 percent sure that that is, that would be the position. If you want to propose something different, like I say, I would be happy to take it back to the family.
>> okay.
>> you know, and rick was just pointing out, as we went through this, the concepts on this, obviously, one of our choices would have been to do, to take the lots that had already been laid out by sweet water on the pork of the property they bought and do something similar but the family opted not to to that approach. I guess in a way when you say, we want the most flexibility, I don't know that anybody feels like they have, when they get an entitlement, they have locked themselves into any real flexibility. They feel like they have locked themselves in for at least a known quantity. They realize, in this ever- ever-changing regulatory environment, and we have only seen it go one direction, and probably rightfully so, over time, that to go back and change their plan will bring them in under a new set of rules. Does that make sense ?
>> uh-huh.
>> in a way it's not is much that you are getting this great flexibility out of this approval. It's just you are getting something that is a known quantity. You know, so you are satisfying the fiduciary responsibility you have to the trustees and at least being able to lock it into that value.
>> what is your response to the concern that if you have about 13 stream crossings, the likelihood of polluting some of these streams is much greater than say you had a smaller number?
>> I suppose that would be true if we were talking about a lot of commercial traffic, benzene trucks or fuel tankers. From the standpoint of a residential development, I don't know that 13 versus five or six or whatever it may be makes that much difference. I think it's probably inconsequential, would probably be my opinion.
>> have you given any thought to--
>> it's much more expensive to build 13 crossings than it is to billed six.
>> have you given any thought to safeguards that will be talk to prevent another hit creek type situation? I think everybody learns lessons, I guess I won't call them bad actors, but un unfortunate events. We all see the fallout. Obviously, the changes in regulatory requirements that the county is going through, a lot of that was spurred by that event. You know, I was a project manager for developments for quite a few years. Personally, I wouldn't try to do the clearing, the road grading and everything at the same time that could cause a blow-out like that if you had a rain event. They were just, got in a hurry and they blew it. But I think given that one little slide I showed that showed, talked about how you could possibly reduce the amount of irrigated drain on somebody's yard, there have been some discussions about that. But again, those kinds of details are probably what are included in the subdivision process. When somebody actually wants to come develop, that is when you get into those kinds of details. But I guess I’m saying that the family is concerned about those kind of the things but they are not something that gets considered in a preliminary plat typically.
>> my last question, if you give us a copy of your presentation today, it will have the total acreage set aside for open space, buffer the other things us mentioned.
>> yes, sir.
>> okay. Any other questions from the court ?
>> let me ask. When you say 20 percent or less than 20 percent of im imper viouk cover, is that grows or knit? What do you calculate ?
>> a gross percentage for the acreage.
>> okay.
>> you think it's actually around 11.
>> it's 11 percent based on the plan bee--plan we have today for the residential. In the purple areas you see on the map, if they were to max those out, build out, it would probably be closer to 15 percent.
>> anybody else? We'll have this back on the court's agenda next week.
>> all right. Thank you.
>> thank you very much.
>> judge, item number 12, the previous.
>> show Commissioner Davis voted for that.
>> item 1.
>> instead of being off the dias.
>> thank you very much. Mike, still in the courthouse? I saw you and was thinking of a 1 instead of this other item that you are here on.
>> that's okay.
>> we didn't know you were here until I looked up and saw you.
>> it's raining again.
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Last Modified:
Wednesday, July 3, 2007, 8:00 AM