Three years into legalization, the globally renowned mecca for cannabis cultivation and culture, Humboldt County, CA has more notices to abate and warnings for the alleged nuisance of cannabis cultivation as it has in parcels lawfully allowed to cultivate.
Before legalization, an estimated 10,000-30,000 marijuana farms were scattered over the hills and in the backyards and garages of homes countywide. Since late 2015, about 2,500 applicants began the process to get cannabis related permits but few of the original growers have made it through the process.
According to Executive Secretary Suzanne Lippre of the Humboldt County Planning and Building Department, as of February 2020, there are only about 450 cannabis cultivation related permits on file for Humboldt County (this includes RRR’s-moving cultivation sq. ftg. to another parcel essentially, often those who have permits already). A number of permits belong to the same owner. For instance, one person and their related business holds at least eleven of the cannabis cultivation and other related permits. (Note: there are more applicants who have yet to finish the process and even some who finished the process since we filed our freedom of information request but, for this story, we’re using the numbers of fully permitted as of February of this year.)
Most of the 2500 permit applicants have abandoned their applications, some have since been abated, and others have fled the area leaving behind empty homesteads and forcing many small non-cannabis businesses to close or cut back as the money from those farms no longer feed the economic engine of Humboldt County.
The stated plan of the County for the cannabis abatement program was to remove growers who caused environmental damage. District Two Supervisor Estelle Fennel states, “I want the maximum number of people, especially the people who care about this land, the water, the trees, I want those people to feel like they can stay here and continue, I don’t care a whip about someone who came here to make money on a big farm.” (M.M. 19) However, the cost and complexity of the permit process inherently favors larger farmers over smaller cultivators, and, as many former growers have claimed, the process favors those who are not afraid of damaging the environment to make a profit over those who grew small, environmentally sound gardens.
Even Humboldt County’s Planning and Building Department’s Director John Ford appeared to acknowledge this when he stated at a Civil Liberties Monitoring Project Town Hall meeting at the Mateel Community Center on August 23, 2018, “A lot of the things that would appear to be egregious violations also have permits on them.” (M.M 50)
Some permit applicants are still in process so the final number of cannabis cultivation permits is still unknown. Though notably, many of the smallest growers in Humboldt County have not finished the permit process. The majority of permitted farms are 10,000 sq. ft. and greater, only 86 permits are for cultivation sites that are 5,000 sq. ft. and less.
It is sometimes assumed that farmers who are not in compliance could get a permit, and they just choose to go without one. However, the prohibitive costs and complexity of the cannabis cultivation permit process is rarely considered. Cannabis is more regulated, enforced and taxed than any other agricultural industry in the State of California. The physical environmental site requirements for permitting and licensing by various state, regional and local agencies are unparalleled, often costing hundreds of thousands of dollars. Furthermore the costs are often unknown until you pay for permit applications and hire various experts. These site requirements can include restoration of prior logging and other non-cannabis industry legacies, new sensitive habitat research, as well as water related issues that the property owners sometimes did not personally cause and are unable to afford to fix (such as replacing culverts).
What many didn’t realize is that the cultivator going through the permitting process has become a means of upgrading rural infrastructure, including roads for neighboring parcels. According to the Humboldt County Cannabis Equity Assessment, “[Cultivators] are the victims of a regulatory cannabis framework with extraordinarily high economic and regulatory barriers to entry. Those barriers are directly financial, in terms of taxes and licensing, but also reflect the high cost of becoming compliant with county codes. Those codes are not just environmental, but for upgrading rural infrastructure that has not seen public investment since the logging boom.”
The complexities and immense costs involved are reportedly the primary inhibitors to undertaking the permitting process, not a lack of desire to comply on behalf of property owners. This is also indicated in the number of property owners who paid for a permit and fell out of compliance
In addition, a history of conflict between the cannabis (and rural) community and the Planning and Building Department doesn’t help the situation. It wasn’t long ago that the Planning and Building Department brought guns to code enforcement actions.
A North Coast Journal article from April 24, 2008 described the mood of the times. “People were furious, and scared. And it was happening in all the rural areas of the county — everybody had heard, by now, the report from the hippie-communal property near Trinidad, called Yee Haw, where a Sheriff’s deputy on a code enforcement inspection was said to have pointed a gun at a woman and her babies,” the piece stated.
The conflict between the Department and cultivators has historically led to growers (and rural residents) opting out of the system entirely. In 1988, during a Humboldt County Supervisor’s Code Enforcement Hearing, Larry Carpenter spoke about his experience with Humboldt County Code Enforcement,
There was a red tag on [my] lean to… we decided we’d go into the Building Department and find out what was happening…we ran into just hassel after hassle. So we said that’s it, we’re not cooperating anymore, take us to jail. We’re not coming back, we’re gonna go ahead and build whatever we want to build. That’s been my advice to all my neighbors– is to not cooperate, because it might be easier for you to bring us to jail, than it would be for us to cooperate with the Building Department.
That sentiment still resonates with many rural Humboldt County residents, who often live in unpermitted homes as a result and it contributes to a thriving black market or, as many growers call it, the underground or traditional market.
Director Ford stated that Planning and Building was directed to no longer (since 2019) send out notices to grows that were less than 6,000 sq. ft. However, 37% of the 292 abated properties that listed sq. ft. cultivation areas were 6,000 sq. ft. and less. Other than being primarily rural in location, there does not seem to be any pattern for which properties are given notices, alleged garden areas ranged from 160 sq. ft. to 95,828 sq. ft. and averaged 11,261 sq. ft. However, there were several abatement recipients who had fallen out of the permit process due mainly to “inactivity” after having paid for a permit to cultivate cannabis.
Planning and Building Department Director John Ford and District Two (SoHum) Supervisor Estelle Fennel were asked by an anonymous speaker at the August 23, 2018 Civil Liberties Monitoring Project (CLMP) Town Hall meeting what authority the Board of Supervisors relied on to vote into law the excessive $10,000 penalty and 10 day abatement period. Ford said, “That is written directly into ordinance 2576, written by County Counsel and adopted by the Board of Supervisors.” District Two Supervisor Fennell said, “The Constitution” and, “It’s basically to get people to abate rather than tag along, because that’s what they would do and usually do in cannabis.”
Supervisor Estelle Fennell stated on March 10, 2018 on a CLMP Kmud Radio Show (M.M. 12), “The abatement goes to people who are not permitted, so it’s people who decided to not get a permit and that’s what happens. As far as the permit goes they have to adhere to a very very strict regulatory process where you deal with a whole lot of agencies.”
Even considering the lack of accessibility of the permit process in Humboldt County; the cannabis cultivation abatement program continues full speed ahead with many farmers not just left out from participating in legal cultivation, but at least 27% of abatement recipients left with cases unresolved, fearing that they owe more than their properties are worth in fines, fees and penalties.
When a property owner receives an abatement notice for cannabis cultivation without a permit and a notice of violation (NOV) there are so far mainly four* potential options:
- Have Notices to Abate and Notices of Violations RESCINDED
- File for an APPEAL HEARING (within 10 days /abate where applicable) and WAIT
- Sign a COMPLIANCE AGREEMENT with County (Listen to Part 1 for more)
- Board of Supervisors approved $900,000 PROPERTY LIEN ($10,000 x 90 days-can be appealed)
(*There could be additional outcomes for people who ignore the notices and more for those who win the appeal hearings or those win in the appeal of their appeal hearing decisions, one could even take their case to the Supreme Court in theory.)
Director Ford stated at the March 3, 2020, Board of Supervisors meeting,
“552 of those [972 abatements] have been completely resolved, 230 of the 972 are in the process of being resolved, the property owners have turned in a compliance agreement. That’s 752 resolved or on their way to being resolved that by my math is 77% of all cases that are sent out are being resolved or in the process of being resolved. This is a statistic I like even more because of the 972, 463 of those were resolved without any fines or penalties. That’s 47% of all notices sent out resolved without fines or penalties.”
When cases “have been resolved without fines and penalties” that does not mean that there is no cost associated with the abatement. A case that is classified as “Case Closed No Admin Civil Penalties” still can have administrative costs and various expert, restoration and legal expenses (Part 2 for more). There are two classifications of expenses at stake for abatement recipients, 1. The fine or penalty (aka $10,000 daily fines) and, 2. The administrative costs, expert costs and Hearing Officer expenses where applicable.
The “Total Admin Recovery Cost Bill” for all 969 abatement recipients listed is $722,287.53. The average administrative cost for 969 cases is $1,489.25. It is not made clear in the FOI request response from the County if this total administrative bill has been paid in full. John Ford was not responsive to this reporter’s attempts for an interview at his convenience.
While 49% of cases are categorized as “closed” of the 969 reviewed, at least 28% of notice recipients are still facing potential daily penalties of $13,315 on average while their cases are left unresolved or those with notices pending. This has left some to wonder why the 470 abatement warning letters went out in November 2019, if the Department still has so many cases left unresolved.
168 property owners or 17% are paying down compliance agreements averaging $14,389, while 59 property owners or 6.1% have finished their compliance agreements and paid penalties averaging $19,754 each.
Blackberry then asked Ford, “Should all these other people in similar situations, should they email you? Ford hesitated and said, “Um, I’m going to say this with great trepidation– yes.” Blackberry responded,
Hopefully they get a response too, because I’ve heard from a number of people that they make calls [to the Planning and Building Department] and nobody calls them back and it gets pretty darn frustrating. I’ll say people are under enough stress going through a pandemic and the recession going on here in Humboldt County…which I attribute to the County’s Marijuana Legalization policies. Having a garden and growing your own food should be encouraged. Instead we have your department targeting small greenhouses, associated with homes–.
Humboldt County Planning Director Ford interrupted, “–I disagree that we are targeting small greenhouses.”
Bonnie Blackberry refuted, “Well, how do we show you that, in fact, you are?”
Blackberry asked Ford, “At one point, about a year ago you said you weren’t going to go after ma [and pa] greenhouses and I’m wondering what’s changed?”
Ford responded, “I am interested in knowing about that because last year’s (2019) direction was nothing under 6,000 sq. ft.”
Blackberry replied, “Well, you’ve got a problem, because that’s what’s going on.”
The Freedom of Information response data supports Blackberry’s claim.
Only 292 properties have cannabis cultivation square footage details listed of the 969 abatements sent out. The data shows that 105 or 37% (of the 284 from 2019/2020) abatement notices were sent to properties that had less than 6,000 sq. ft. garden areas alleged (per satellite imagery). Fourteen or 5% of the properties were noticed with 1,000 sq. ft. or less in just 2019 and the beginning of this year, 2020, alone.
Most properties that had cultivation areas cited were from 2019 and 2020 aside from a handful of exceptions. The other 677 properties without square feet information stated the following in place of figures, “Did Not Keep Digitized Record of Cultivation Size Prior to 2019.”
For all notice dates 2017-2020, there are a total of 292 abatements with sq. ft. details listed. 106 (36%) of properties cite cannabis cultivation area as 6,000 sq. ft. or less. 79 (27%) of the properties are alleged to have between 6,001- 11,000 sq. ft. of garden space. 61 (21%) of the 292 abated properties were between 11,001- 19,910 sq. ft. 28 (9%) properties were 20,000-29,999 sq. ft. And, 18 properties (6%) were for garden areas ranging from 30,000-95,828 sq. ft.
# Of Properties % * Total Sq. Ft. Cultivation Area (per satellite)
(2019 and 2020 Notices only- of 284 Total with sq. ft. listed)
14 5% 1,000 sq. ft. and less
105 37% 6,000 sq. ft. and less
80 28% 6,000- 11,000 sq. ft.
57 20% 11,001- 20,000 sq. ft.
26 9% 20,000-30,000 sq. ft.
16 6% 30,000-95,828 sq. ft.
(2017-2020 All 292 Notices with sq. ft. listed)
34 12% 2,000 sq. ft. and under
55 19% 3200 sq. ft. and under
73 25% 4,000 sq. ft. and under
(Accumulative stats below for 2017-2020 with sq. ft. listed)
106 36% 6,000 sq. ft. and under
79 27% 6,001-11,000 sq. ft.
61 21% 11,001-19910 sq. ft.
28 9% 20,000-30,000 sq. ft.
18 6% 30,001-95,828 sq. ft.
(*of 292 sq. ft. details listed total of the 969 abatements featured in the FOI request from all years)
Violations, Penalties and Fines
Proposed Admin Daily Civil Penalty*
Property Owners % (of 969) Proposed Admin Daily Civil Penalty
16 1.7% $40,000-$43,000 Daily
69 7.1% $30,000-$39,999 Daily
72 7.4% $20,000-$29,999 Daily
689 71.1% $10,000 Daily
107 11% $10,001-$10,999 Daily
16 1.7% $6,000-$8,000 Daily
Director Ford stated at the March 3rd BOS Meeting,
“The fines aren’t a necessary outcome. If a property owner on a small site can stop cultivating, remove the cannabis infrastructure, and restore the site there are no fines and penalties associated. In some circumstances the amount of grading the amount of infrastructure that’s on the site that cannot be done in 10 days. That’s a situation where a compliance agreement is offered which comes with a one day fine.”
When reviewing the violations for the 227 compliance agreement signers, I discovered that only 175 had alleged “grading without a permit” while 52 people had no grading violations at all. 8 of those 227 property owners were said to have cannabis only as a violation, 12 cases listed using an RV as a residence as an additional violation, 3 had junk vehicles cited, 11 had an outhouse/sewage violations. There were 23 compliance agreement signers who were cited for streamside management area development, 9 for improper disposal of solid waste and 2 had violations for lighting up the night skies (aka not covering a lit greenhouse).
(Note: While there are other instances of various nuisance abatements and building code violations in Humboldt County, these 969/970 abatements discussed here are all related to violations for cannabis cultivation without a permit.)
Abatement Case Status
# Notices % (of 969) Current Status
6 ~0.6% “Appeal Hearing in Process” (6 listed, but 7 discovered 0.7% of 970)
12 1.2% “Board Approved Admin Civil Penalties” of “$900, 000” each “penalty lien served”
32 3.3% “Admin Civil Penalty Assessment in Process”
54 5.6% “Case Closed – Notices Rescinded”
59 6.1% “Case Closed – Compliance Agreement Complete”
168 17.3% “In Compliance Agreement”
236 24.4% “Unresolved Notices/Pending Resolution”
414 42.7% “Case Closed – Abated, No Admin Civil Penalty”
There are 414 or 42.7% with a status of, “Case Closed -Abated, No Admin Civil Penalty” (See Part 1 for one example).
Ford stated at the Board of Supervisors meeting March 3, 2020, “There have been very few cases of false positives, there are only 2 or 3 that I am aware of.” However, of the 969 cases, 54 or 5.6% are labeled “Case Closed – Notices Rescinded.” The FOI request response does not make it clear as to why the notices were rescinded (awaiting a FOI request response).
Blackberry brought up Ford’s claim on her April 8th show saying, “You said you remembered 2 or 3 false positives, is Code Enforcement keeping track of them?” Ford responded, “We haven’t been [keeping track] but that’s actually not necessarily a bad idea.” Blackberry added, “I think it would be a really good idea because I think there are a lot more people than you realize who have had this happen to them,” who received an abatement notice while not cultivating cannabis.
236 or 24.4% of parcels are categorized as having “Unresolved Notices- Pending Resolution.” Which likely means the property owner either did not respond within 10 days; or did respond, in a manner unsatisfactory to the County. This group also includes those who are waiting on the County to begin their appeal hearings often not knowing if the tens of thousands in daily fines are accruing as they wait (See Part 1 for an example).
59 property owners or 6.1% are categorized as “Case Closed- Compliance Agreement Complete” and paid a penalty of $19,754 on average each. “Compliance Agreement Penalty Settlement[s]” ranged from $2,500 to $130,000.
168 compliance agreement signers or 17.3% are “In Compliance Agreement” according to the PBD FOI request response. The total stated amount of “Compliance Agreement Penalty Currently Paid” for all compliance agreement signers is $2,993,093. It is not clear in the FOI request if these figures are for those paid in full or still in process. Compliance agreements are often paid in full or with a 25% down payment and five monthly payments.
32 of the 969 cases or 3.3% were listed under “Admin Civil Penalty Assessment In Process,” nearly all of which had $10,000 daily fine assessment listed. Five of those thirty-two properties were categorized as having $30,000-$40,000s in daily fines. 9 of these 32 properties had cannabis cultivation permits on file, 7 were closed due to inactivity,” one was canceled, another denied. Three of the applicants that received a notice to abate after falling out of the permit process, have $900,000 liens approved by the Board.
Board Approved Property Liens
Blackberry asked Ford on her April 8 CLMP show, “Do you have egregious grows, unpermitted or permitted that are no longer a problem,” Ford replied,
I wouldn’t say that they are no longer a problem. We’re still working on this as part of–as a separate attack– there are folks out there that they do not seem to stop even after they get an abatement notice, or they will stop and restart…we have been identifying those and working with the Sheriff’s Office on those… Some have gone to a place where the Board has authorized entering into lien proceedings [Pursuant to HCC 352-5].
Director John Ford stated in the March 3, 2020 Board of Supervisors meeting that, “There are 28 cases where there has been no contact from the property owner.” It is not clear if all of these 28 properties will result in $900,000 liens, at least 7 have. Brandon Howton at the Planning and Building Department explained that of the twelve 900,000 liens approved by the Board of Supervisors so far, seven of those property owners have not contacted the County at all.
The original abatement notices for the twelve properties with liens were posted from September of 2018 through September of 2019. Each took about 3 months from the notice being served to have the liens approved. This suggests that these recipients did not file for an appeal hearing within 10 days and were charged the maximum one day/one violation fine of $10,000 for 90 days, $900,000.
While there are twelve properties with $900,000 in property liens approved, it is unlikely that the entire 10.8 million-lien amount is collectable as it far exceeds local abated property values at $900,000 each, additionally these abatements can still be appealed. Howton reports that the County is also not likely to ask for the full amount either, the goal is compliance, he says, “We don’t ask for the full amount because we don’t want the property. We’d like the amount to be enough to make a person say I shouldn’t–I’m speaking from the cannabis side–we shouldn’t be cultivating anymore without a permit because it’s really going to hurt us, but at the same time we don’t want to make [the penalty amount] so much that they walk away from property and leave it …possibly causing environmental damage.”
Howton details how the lien process works, saying “In order to get [a lien] assessed there has to be an ongoing case that has not been resolved and it goes to the Board of Supervisors and they approve whether we are allowed to assess it…Once [notices are served] the property owner or whoever has control of the property, they have the ability to contest the assessment to try to take it to an appeal hearing… That is the route we try to go, or get it resolved outside of actually having to assess it. The last thing we really want to do is have to put a lien on the property and take control over the property, because the County– we really do not want the properties…. [If] it ends up being assessed for a lien then that notice goes on the property. If that notice is listed onto the property, for the $900,000 or whatever the amount may be, what that states is basically if the property owner sells the property all the money that they sold the property for has to be paid to all the lien holders, in this case it would be the County, but there maybe more before they receive any money. So [the property owner] would get what’s left over for whatever they sold the property for.”
Howton responds to a question about whether the County could force the sale of the property to collect the lien amount, “I don’t believe so, I’ll be honest I’m not sure. As far as I understand we could not force the sale but that does not mean there are not other avenues that can be taken to remove the property from the owners hands if they do not clean up or take care of the property.”
What if someone had a lien assessed on their property in Humboldt County, could the County attach that lien to another property elsewhere? Howton responded, “Just so you know this whole lien process is pretty new for us on our end… This is very new territory for us. I don’t know if that is a possibility to go against other properties, on top of that I don’t know why we would. We don’t want the property, we’d rather it was just cleaned up and dealt with by the property owner.”
When asked about liability and what happens when the property is sold, Howton replied, “Initially the property owner is the one that is liable for violations. The violations follow the property. So by some chance that the property is sold, and a new property owner buys it, the violations are there, they don’t disappear.”
Abatement Appeal Hearings
While cannabis and food are deemed essential according to CA State Officials, the pandemic’s shelter in place order has the Planning and Building Department taking precautions so their office is closed to the public.
Blackberry’s first caller pointed out on the April 8, 2020 CLMP show, “When someone receives an abatement and your offices are closed, how would they file their appeal?” Ford responded, “Fantastic question, first of all we are not actively sending out abatements right now and we won’t be immediately, but when it does come down to sending out notices we will have clear procedures for people to talk to us and file an appeal… Nobody is in an active appeal period right now.”
The “active appeal period” is the 10 day window given by the County to abate the alleged violations. Blackberry’s caller reported having emailed and called Ford several times, several few weeks ago but still not receiving a response.
While abatement recipients report struggling to make contact with the department during the shelter in place order, the abatement appeal hearings are ongoing for some appellants remotely via Zoom video conferencing.
Blackberry asked Ford, “How many abatement appeals have you had. How have they turned out?” Ford replied, “[There have been] four or five hearings…the hearing officer has found in favor of the County.”
I discovered seven appeal hearings in the FOI request responses that were in various stages of the appeals process. One cannabis abatement hearing was not included in the 969 totals from FOI (hence the 0.6% v. 0.7% noted). I found the other in an additional FOI made in 2019. There could potentially be more appeal hearings not considered in these figures.
It is not a surprise that the hearing officer has found in favor of the County for the initial appeal hearings because the hearing officer is hired by the County, working under a contract that can be changed or terminated at the will of Director Ford. Attorney Eugene Denson points out this conflict of interest in one of his client’s abatement appeal hearing closing statements,
“This contract is essentially a contract between Planning and the Contractor, and, of course, the Appeal Hearings are being prosecuted by Planning, who are also the Plaintiff at the hearings… Section 6C says the contract may be terminated by “the Director of the Planning and Building Department or the County Administrative Officer.” Section 7D gives Director Ford the ability to negotiate “minor amendments” to the contract directly with the Contractor.”
Only one of the seven abatement hearings is closed and left un-appealed, but the property owner did not show up or have a lawyer to represent them. This no-show appellant had notices originating in early 2019 and now has a penalty of $150,000 (plus costs, fees and penalties) and a lien in this amount attached to his property if not paid within 90 days.
Upon further investigation I found that this abatement recipient paid $2,577.45 for cannabis cultivation permit in December of 2016. Their permit was valid until September of 2017. Their permit was “Closed Due to Inactivity” and they received the abatement a month later in October 2017. This abatement recipient was originally requested to pay $900,000 but after the appeal hearing owed $150,000, or 17% of the original penalty without any appeal hearing participation (plus an administrative bill of $2,798.92, LLP /Hearing Officer fees, and restoration costs).
Under “Violations Cited” in his hearing exhibit packet it reads,“Violations Cited based on analysis of satellite imagery of the subject property from 1998-2017… as well as County Planning permit records.”
(insert 2 images from hearing exhibit packet)
The abatement appeal hearings are still in various stages of the appeals process for the 6 appellants. One of the seven appeal-hearing defendants (released in the FOI requests) had penalties of $56,000, reduced by a judge from $88,000—though the County is appealing the Superior Court Judge’s decision now. Five others are awaiting the decisions from their appeal hearings (to potentially appeal the decision thereafter) all are being asked for $435,000 each.
Though it is being appealed, one of the appeal Hearing Exhibit Packets showed the following photographs of a home for evidence of “construction without permits,” which along with greenhouses lead to an initial $18,500 fine (later reduced from 88,000 to 56,000), (insert- 3 photos, one of cabin x 2 interior exterior, one of living in an rv)
This notice recipient was also cited for someone living in an RV on their land, though the charge was dropped when the property owner proved no one was living there anymore. This is especially concerning to rural County residents where many (including several elders) live in unpermitted homes. There is also a notable housing shortage in Humboldt County, especially affordable housing and a disproportionate number of folks who are already homelessness when compared to the rest of the Country. Until 2022 we are in the amnesty period for unpermitted homes.
In addition to cannabis, this property owner was cited for improper disposal of solid waste, junk cars, having an outhouse, and grading without a permit. The following photographs were featured in the County’s exhibit packet on the parcel for those violations.
The last abatement hearing was held in January of 2020, Attorney Eugene Denson reports that decisions for his appeal-hearing clients are being processed through the Covid-19 pandemic.
Nichole Norris (aka Shakti)
Full disclosure: I am not a mathematician.
This is part 3 in a series on Humboldt County Planning and Building Department’s Abatement Program –Part 1 is an example of a “Unresolved Notices – Pending Resolution” case here- https://kymkemp.com/2020/03/26/facing-30000-per-day-fines-one-person-who-claims-he-had-no-cannabis-at-the-time-he-was-abated-by-humboldt-county-reports-his-experience/, and Part 2 an example of a notice with “Case Closed – Abated, No Admin Civil Penalty” here- kymkemp.com/2020/04/08/abated-landowner-claims-addressing-countys-concerns-over-legacy-logging-on-property-with-not-a-stick-of-cannabis-cost-286k/?unapproved=1030971&moderation-hash=78b1d74c9b3d24ca46695b419032d16b#comment-1030971.