January 18, 2022, Item #13
DATE:
TO:
FROM:
CONTACT:
SUBJECT:
Summary:
AGENDA REPORT CityofPoway
January 18, 2022
Honorable Mayor and Members of the City Council
Robert Manis, Director of Development Services/,A
Melody Rocco, City Engineer µJL
(858) 668-4653 or [email protected]
CITY COUNCIL
A Resolution Approving an All-Way Stop Control at the Intersection of Martincoit Road and Stone Canyon Road
On October 13, 2021, the City's Traffic Safety Committee (TSC) supported staff's recommendation for an all-way stop control at the intersection of Martincoit Road and Stone Canyon Road, which was analyzed after receiving a resident request to re-evaluate the intersection. The proposed all-way stop is recommended pursuant to the California Manual on Uniform Traffic Control Devices (MUTCD) based on corner sight distance and the similar operating traffic conditions on Martincoit Road and Stone Canyon Road.
Recommended Action:
It is recommended that the City Council adopt the Resolution (Attachment A) approving an all-way stop control at the intersection of Martincoit Road and Stone Canyon Road.
Discussion:
A request was received, along with a petition, to re-evaluate the Martincoit Road and Stone Canyon Road intersection for an all-way stop control. The petition received was signed by 14 property owners or residents within 500 feet of the intersection. The same request was considered by the TSC and City Council several years ago.
On May 7, 2013 during discussion on the 2013 Traffic and Engineering Survey, the City Council requested that staff investigate the possibility of an all-way stop control at the intersection of Martincoit Road and Stone Canyon Road. This request was in response to a speeding concern expressed by Martincoit Road residents. The existing intersection control is stop controlled for the Stone Canyon Road approach to the three-way orT-intersection with Martincoit Road. Martincoit Road is currently uncontrolled. Attachment B depicts the subject intersection. 1 of 12
January 18, 2022, Item #13
On June 11, 2013 staff collected traffic volumes approaching all three legs of the subject intersection.
The traffic data was used to evaluate the need for an all-way stop control based on volume criteria.
Intersection site distance was also checked using the 85th percentile speed for Martincoit Road from the 2013 Traffic and Engineering Survey. Based on the results, on August 28, 2013 a recommendation was made to the TSC to install an all-way stop control at the T-intersection for Stone Canyon Road and Martincoit Road. The committee unanimously voted to approve the all-way stop.
On December 3, 2013 staff recommended the installation of an all-way stop control at the intersection to the City Council. After comments from the public, both in favor and opposed, and discussion by the Councilmembers, no action was taken, and the item was referred back to the TSC for further consideration. The City Council was concerned that the measured sight distance had been determined based upon speed survey data taken at a different location other than near the intersection. The Council also asked staff to investigate possible traffic calming measures for Martincoit Road.
At the February 26, 2014 TSC meeting, staff presented the findings from a new speed survey. The traffic calming measures investigated on Martincoit Road were also presented. Staff recommended the installation of an all-way stop control at the intersection with appropriate intersection and advanced warning signs. The committee unanimously approved the recommendation for an all-way stop. Staff presented this recommendation to the City Council on April 1, 2014. They did not approve the all-way stop control and requested staff to analyze the site for other traffic calming measures on Martincoit Road.
On September 2, 2014 staff recommended the restriping of the intersection and the installation of additional striping on the approach to the intersection on Martincoit Road. City Council approved these recommendations. The subject intersection has since been restriped. Additional signage and pavement legends, as well as curve warning signs with a flashing beacon have also been installed along Martincoit Road.
In response to the recent request to consider an all-way stop at this intersection, staff re-evaluated the intersection. On September 9, 2021 staff collected new traffic volumes approaching from all three legs of the subject intersection, see Attachment C. The new traffic data was used to re-evaluate the need for an all-way stop control.
New speed data was also collected at five locations close to the subject intersection. The speed data was recorded in each location for a length of time that provided information on at least 100 unimpeded vehicles. The 85th percentile speeds were measured as follows:
Road Direction Location 85th Percentile
Speed
Martincoit Road Northbound 630' south of Stone Canyon Road 39 mph Martincoit Road Southbound 630' south of Stone Canyon Road 38 mph Martincoit Road Northbound 465' north of Stone Canyon Road 47 mph Martincoit Road Southbound 465' north of Stone Canyon Road 42 mph Stone Canyon Road Eastbound 555' west of Martincoit Road 38 mph Stone Canyon Road Westbound 555' west of Martincoit Road 39 mph Attachment D shows the locations where the speed data was collected and the results of the survey. 2 of 12
January 18, 2022, Item #13
Section
2B.07
"Multi-Way
Stop
Applications"
of
the
California
MUTCD
is
used
as
the
guideline
to
evaluate
intersections
for
all-way
stop
controls.
The
noted
MUTCD
guidelines
identify
two
groups
of
conditions
where
an
all-way
stop
control
can
be
installed:
Should
Conditions
Conditions
when
all-way
stop
controls
"Should"
be
used
involve
minimum
traffic
volumes,
number
of
accidents,
and
locations
where
traffic
signals
are
justified.
May
Conditions
Conditions
when
all-way
stop
controls
"May"
be
used
involve
a
need
to
control
left-turn
conflicts
and/or
vehicular
and
pedestrian
conflicts,
lack
of
sight
distance,
and
local
collector
intersections
with
similar
design
and
operating
characteristics.
The
subject
intersection
of
Martincoit
Road
and
Stone
Canyon
Road
does
not
meet
any
of
the
criteria
under
the
"Should"
conditions
due
to
its
low
traffic
volumes
and
number
of
accidents
per
year.
Under
the
"May'' conditions,
Martincoit
Road
and
Stone
Canyon
Road
have
the
same
classification
per
the
City's
Transportation
Master
Element,
Local
Collector,
with
approximately
equal
traffic
volumes,
around
2,500
average
daily
trips.
They
also
have
similar
prevailing
(85th
percentile)
speeds
of
approximately
40 mph
and
both
have
the
same
posted
speed
limit
of
35 mph.
These
similarities
in
roadway
characteristics
and
operating
parameters
between
Martincoit
Road
and
Stone
Canyon
Road,
qualify
the
subject
intersection
for
an
all-way
stop
control
pursuant
to
Section
2B.07
of
the
MUTCD.
Additionally,
sight
distance
was
re-evaluated.
The
existing
corner
sight
distance
for
Stone
Canyon
Road
drivers
turning
left
(north)
onto
Martincoit
Road
is
over
500
feet
to
the
north.
According
to
the
recent
speed
survey,
the
southbound
85th
percentile
speed,
taken
at
approximately
465
feet
north
of
the
intersection
(the
measurement
closest
to
the
intersection),
was
42 mph.
Assuming
this
speed
on
the
uncontrolled
approach,
the
California
Highway
Design
Manual
calls
for
a
recommended
corner
sight
distance
of
463
feet
and
a
minimum
corner
sight
distance
of
324
feet.
Since
the
sight
distance
to
the
north
is
over
500
feet,
this
standard
is
met.
The
existing
corner
sight
distance
to
the
south,
for
Stone
Canyon
Road
drivers
turning
left
(north)
onto
Martincoit
Road,
is
approximately
220
feet.
The
northbound
85th
percentile
speed,
taken
at
approximately
630
feet
south
of
the
intersection,
was
39 mph.
Assuming
this
speed
on
the
uncontrolled
approach,
the
California
Highway
Design
Manual
calls
for
a
recommended
corner
sight
distance
of
429
feet
and
a
minimum
corner
sight
distance
of
290
feet.
The
existing
corner
sight
distance
of
220
feet
to
the
south
does
not
meet
either
of
the
two
corner
sight
distances
(recommended
or
minimum)
called
for
in
the
California
Highway
Design
Manual,
using
the
measured
85th
percentile
speed.
Corner
sight
distance
may
also
be
calculated
using
design
speed.
Using
the
posted
speed
limit
of
35 mph,
the
recommended
corner
sight
distance
would
be
386
feet,
and
the
minimum
corner
sight
distance
would
be
250
feet.
The
existing
corner
sight
distance
of
220
feet
to
the
south
is
also
not
met
using
the
design
speed.
Pursuant
to
condition
C,
Paragraph
5 of
Section
2B.07
of
the
MUTCD,
the
intersection
of
Martincoit
Road
and
Stone
Canyon
Road
qualifies
for
an
all-way
stop
control
based
on
the
corner
sight
distance
conditions. At
its
meeting
on
October
13,
2021,
the
TSC
voted
unanimously
to
support
staff's
recommendation
to
install
an
all-way
stop
control
at
the
intersection
of
Martincoit
Road
and
Stone
Canyon
Road,
with
appropriate
markings
and
advance
warning
signs.
3 of
12 January 18, 2022, Item #13
Prior
to
the
TSC
meeting
staff
received
ten
emails
which
were
split
in
favor
and
against
the
installation
of
the
all-way
stop
control.
At
the
TSC
meeting,
residents
in
attendance
were
given
an
opportunity
to
voice
their
opinions
and
concerns.
Of
the
twelve
residents
who
chose
to
speak,
seven
were
in
favor
of
the
stop
sign
and
five
were
against
it.
Of
the
seven
supporting
the
installation,
several
were
in
favor
of
adding
more
than
just
stop
signs.
Environmental
Review:
This
item
is
exempt
from
the
requirements
of
the
California
Environmental
Quality
Act
(CEQA),
pursuant
to
Section
15301
of
the
CEQA
Guidelines
as
it
includes
installation
of
an
all-way
stop
control
on
existing
City
streets
and
there
is
no
expansion
of
existing
use.
Fiscal
Impact:
There
are
sufficient
funds
available
in
the
Street
Striping
Account
(411040-43300)
to
install
new
stop
legends
and
limit
lines
estimated
at
$1,000,
and
in
the
Sign
Maintenance
Materials
Account (411040-
45300)
to
install
new
stop
signs
at
under
$500.
Public
Notification:
Notices
were
mailed
to
residents
living
within
a
500-foot
radius
from
the
intersection,
2,000
feet
from
the
intersection
along
Martincoit
Road
and
Stone
Canyon
Road,
and
all
the
residents
who
attended
the
Traffic
Safety
Committee
meeting
regarding
this
matter.
Notification
signs
were
also
posted
at
the
intersection.
Attachments: A.
Resolution
B.
Location
Map
C.
Traffic
Counts
D.
Speed
Survey
Reviewed/
Approved
By:
Wendy
Kaserman
Assistant
City
Manager
4 of
12 Reviewed
By:
Alan
Fenstermacher
City
Attorney
City
Manager
January 18, 2022, Item #13
RESOLUTION
NO.
22-
A
RESOLUTION
OF
THE
CITY
COUNCIL
OF
THE
CITY
OF
POWAY,
CALIFORNIA,
ESTABLISHING
AN
ALL-WAY
STOP
CONTROL
AT
THE
INTERSECTION
OF
MARTINCOIT
ROAD
AND
STONE
CANYON
ROAD
WHEREAS,
Section
21100
of
the
California
Vehicle
Code
permits
local
authorities
to
adopt
by
resolution
traffic
control
measures
meeting
the
requirements
set
forth
under
Section
21351
of
the
California
Vehicle
Code;
WHEREAS,
Section21351
of
the
California
Vehicle
Code
permits
local
authorities
to
place
and
maintain
such
traffic
signs
upon
streets
and
highways
as
may
be
necessary
to
properly
indicate
and
carry
out
the
provisions
of
the
local
ordinances
and
to
warn
or
guide
traffic;
WHEREAS,
Section
21354
of
the
California
Vehicle
Code
permits
local
authorities
to
designate
any
intersection
under
its
exclusive
jurisdiction
as
a
stop
intersection
and
erect
stop
signs
at
one
or
more
entrances
thereto;
WHEREAS,
Section
10.24.020
of
the
City's
Municipal
Code
permits
installation
of
stop
signs
where
the
City
Council
has
determined
that
there
is
a
special
hazard
to
life
and
property
by
reason
of
lack
of
visibility
to
the
drivers
of
vehicles
approaching
such
intersection;
WHEREAS,
Resolution
No.
05-086,
adopted
by
the
City
Council
on
October
4,
2005,
sets
the
guidelines
to
determine
a
special
hazard
to
life
and
property
condition
in
accordance
with
Sections
28 .05
"STOP
Sign
Applications"
and
28.07 "Multiway
Stop
Applications"
of
the
California
Manual
on
Uniform
Traffic
Control
Devices
(MUTCD);
WHEREAS,
the
City
Council
has
determined
that
the
intersection
of
Martincoit
Road
and
Stone
Canyon
Road
qualifies
for
an
all-way
stop
control
due
to
lack
of
adequate
sight
distance
and
the
need
to
control
vehicle
conflicts
in
accordance
with
the
guidelines
set
forth
in
Section
28.07 of
the
California
MUTCD;
and
WHEREAS,
the
City
Council
has
determined
that
an
all-way
stop
control
and
appropriate
markings
should
be
established
at
the
intersection
of
Martincoit
Road
and
Stone
Canyon
Road.
NOW,
THEREFORE,
BE
IT
RESOLVED
by
the
City
Council
of
the
City
of
Poway
as
follows:
SECTION
1:
In
accordance
with
said
Section
21351
of
the
California
Vehicle
Code,
an
all-way
stop
control
with
appropriate
markings
and
advance
warning
signs
shall
be
installed
at
the
intersection
of
Martincoit
Road
and
Stone
Canyon
Road.
5 of
12 ATTACHMENT
A
January 18, 2022, Item #13
Resolution
No.
22-
Page
2 PASSED,
ADOPTED
AND
APPROVED
at
a
Regular
Meeting
of
the
City
Council
of
the
City
of
Poway,
California
on
the
18th
day
of
January, 2022
by
the
following
vote,
to
wit:
AYES: NOES: ABSENT
:
DISQUALIFIED:
Steve
Vaus,
Mayor
ATTEST
:
Carrie
Gallagher,
CMC,
City
Clerk
6 of
12 January 18, 2022, Item #13
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January 18, 2022, Item #13
Prepared by National Data & Surveying Services
Martincoit Rd & Stone Canyon Rd
Peak Hour Turning Movement Count
ID: 21-040155-001
City: Poway
Martincoit Rd Day: Thursday
Date: 9/9/2021
08:00 AM -09:00 AM AM 100 27 0 0 158 AM 7:00 AM -09:00 AM 0 0
C
z -t
12:45 PM -01 :45 PM NOON 85 35 0 0 119 NOON 11 :00 AM -02:00 PM "'O m :;o
03:00 PM -04:00 PM PM 66 26 0 116 PM 2:00 PM -06:00 PM 0 CJ en
AM NOON PM
134 113 93 ¢:i
0 0 .!) 0
---+------+---
116 83 80 j 0
0 0 0 ➔ 1
15 28 32 ,. 0
AM NOON PM
Totals (AM)
_J3 ~ .'.; L
116,t ~ t.O
0-+ ~+-0
15"\. I' 0
7., t ,.,
8 of 12
W~O
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PM
NOON
AM
0 1
58 63
42 if PM NOON AM
0 0
0 0
267
PM
0.95 1 0
0 t. 0 0
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0 en 0 ::,
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0 28 36 0 NOON
0 33 42 0 AM
Totals (AM)
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15"\, I' 0
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Totals (NOON)
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Totals (PM)
ATTACHMENT C
January 18, 2022, Item #13
9 of 12 ATTACHMENT D
January 18, 2022, Item #13
Prepared by National Data & Surveying Serv ices
SPEED
Martincoit Rd N/0 Stone Canyon Rd
Day: Thursday City: Poway
...a. Date: 9/9/2021 Project#: CA21_040156_001s
0 0
South Bound -ti
...a.
N
;;;;;;
00:00 AM 0 0 0 0 1 0 1 0 0 0 0 0 0 2
01:00 0 0 0 0 1 0 0 0 0 0 0 0 0 1
02:00 0 0 0 0 0 0 0 0 0 0 0 0 0 0
03:00 0 0 0 0 1 0 0 0 1 0 0 0 0 2
04:00 1 0 0 0 0 1 1 0 0 0 0 0 0 3
05:00 0 0 0 1 1 2 0 0 0 0 0 0 0 4
06:00 0 0 0 6 11 7 3 0 0 0 0 0 0 27
07:00 0 1 3 5 23 33 15 1 0 0 0 0 0 81
08:00 1 0 2 19 45 39 12 4 0 0 0 0 0 122
09:00 0 0 5 9 16 23 7 2 0 0 0 0 0 62
10:00 1 2 2 10 15 17 6 1 1 0 0 0 0 55
11:00 1 1 1 6 11 14 13 3 3 0 0 0 0 53
12:00 PM 0 0 3 9 25 12 8 3 1 0 0 0 0 61
13:00 0 3 3 26 41 27 16 2 0 1 0 0 0 119
14:00 0 2 2 8 22 24 17 6 1 0 0 0 0 82
15:00 0 1 4 15 23 38 9 5 0 1 0 0 0 96
16:00 1 0 3 3 19 32 13 6 1 0 0 0 0 78
17:00 0 3 1 9 18 22 16 5 0 1 0 0 0 75
18:00 0 2 3 5 12 9 14 1 1 0 0 0 0 47
19:00 1 2 0 4 7 8 6 2 0 1 0 0 0 31
20:00 0 0 1 1 8 5 5 2 1 2 0 0 0 25
21:00 0 0 0 0 5 5 1 0 1 0 0 0 0 12
22:00 0 0 1 2 2 0 0 1 1 0 0 0 0 7
23:00 0 0 0 0 2 1 0 0 0 0 0 0 0 3
' : ,. m •~t:,
%I 2%1 3%1 13%1 29%1 30%1 16%1 4%1 1%1 1%1 I I I 100%
AM Volumes 4 4 13 56 125 136 58 11 5 0 0 0 0 412
%AM 0% 0% 1% 5% 12% 13% 6% 1% 0% 39%
AM Peak Hour 04:00 10:00 09 :00 08 :00 08:00 08:00 07:00 08:00 11:00 08:00 Volume 1 2 5 19 45 39 15 4 3 122
PM Volumes 2 13 21 82 184 183 105 33 7 6 0 0 0 636
%PM 0% 1% 2% 8% 18% 17% 10% 3% 1% 1% 61%
PM Peak Hour 16:00 13:00 15:00 13:00 13:00 15:00 14:00 14:00 12:00 20:00 13:00 Volume 1 3 4 26 41 38 17 6 1 2 119
Directional Peak Periods AM7-9 NOON 12-2 PM 4-6 Off Peak Volumes All Speeds Volume % Volume % Volume % Volume %
203 +---+ 19% 180 +-----+ 17% 153 +-----+ 15% 512 +-----+ 49% January 18, 2022, Item #13
Prepared by National Data & Surveying Services
SPEED
Martincoit Rd S/0 Stone Canyon Rd
Day: Thursday City: Poway
-
Date: 9/9/2021 Project#: CA21_040156_002n
-0 North Bound -ti
-N
Will
00:00 AM 0 0 0 0 1 0 0 0 0 0 0 0 0 1
01:00 0 0 0 0 0 1 0 0 0 0 0 0 0 1
02:00 0 0 0 0 0 0 0 0 0 0 0 0 0 0
03:00 0 0 0 0 0 0 0 0 0 0 0 0 0 0
04:00 0 1 0 0 0 0 0 0 0 0 0 0 0 1
05:00 0 0 0 0 0 0 0 0 0 0 0 0 0 0
06:00 0 0 4 1 6 2 1 1 0 0 0 0 0 15
07:00 0 1 1 3 28 28 4 2 0 0 0 0 0 67
08:00 0 1 6 12 33 14 7 1 0 0 0 0 0 74
09:00 0 0 6 2 25 19 4 0 0 0 0 0 0 56
10:00 0 0 1 5 15 9 4 0 0 0 0 0 0 34
11:00 2 0 3 5 19 22 7 2 0 0 0 0 0 60
12:00 PM 0 1 2 10 22 18 6 1 0 0 0 0 0 60
13:00 0 1 2 10 23 13 3 0 0 0 0 0 0 52
14:00 3 3 4 9 18 14 3 1 0 0 0 0 0 55
15:00 2 1 3 7 18 15 9 1 0 0 0 0 0 56
16:00 0 1 4 8 16 17 6 1 0 0 0 0 0 53
17:00 0 0 5 13 12 11 4 2 0 0 0 0 0 47
18:00 0 1 4 5 14 11 2 1 0 0 0 0 0 38
19:00 0 1 2 3 8 9 2 0 0 0 0 0 0 25
20:00 0 0 0 1 4 3 2 0 0 0 0 0 0 10
21:00 0 0 1 0 3 2 0 0 0 0 0 0 0 6
22:00 0 0 0 0 1 1 0 0 0 0 0 0 0 2
23:00 0 0 0 0 1 0 0 0 0 0 0 0 0 1
.... ,; .. , . •'
% of Totatsl 1%1 2%1 7%1 13%1 37%1 29%1 9%1 2%1 I I I I I 100% AM Volumes 2 3 21 28 127 95 27 6 0 0 0 0 0 309
%AM 0% 0% 3% 4% 18% 13% 4% 1% 43%
AM Peak Hour 11:00 04:00 08:00 08:00 08:00 07 :00 08:00 07:00 08:00 Volume 2 1 6 12 33 28 7 2 74
PM Volumes 5 9 27 66 140 114 37 7 0 0 0 0 0 405
%PM 1% 1% 4% 9% 20% 16% 5% 1% 57%
PM Peak Hour 14:00 14:00 17:00 17:00 13:00 12:00 15:00 17:00 12:00 Volume 3 3 5 13 23 18 9 2 60
Directional Peak Periods AM 7-9 NOON 12-2 PM4-6 Off Peak Volumes All Speeds Volume % Volume % Volume % Volume %
141 +-----+ 20% 112 +-----+ 16% 100 +-----+ 14% 361 +-----+ 51% January 18, 2022, Item #13
Prepared by National Data & Surveying Serv ices
SPEED
Stone Canyon Rd W/0 Martincoit Rd
Day: Thursday City: Poway
....llo Date: 9/9/2021 Project#: CA21_040156_003w
N
0 West Bound -ti
....llo
N
:::::a
00:00 AM 0 0 0 0 0 0 0 0 0 0 0 0 0 0
01:00 0 0 0 0 0 0 0 0 0 0 0 0 0 0
02:00 0 0 0 0 0 0 0 0 0 0 0 0 0 0
03:00 0 0 0 0 0 0 0 0 0 0 0 0 0 0
04:00 0 0 0 0 1 3 0 0 0 0 0 0 0 4
05:00 0 0 0 1 8 3 1 0 0 0 0 0 0 13
06:00 0 0 0 2 10 12 1 0 0 0 0 0 0 25
07:00 0 0 2 12 46 33 1 0 0 0 0 0 0 94
08:00 0 1 4 10 59 42 14 2 0 0 0 0 0 132
09:00 0 0 4 10 33 25 6 0 0 0 0 0 0 78
10:00 0 0 2 4 25 18 2 1 0 0 0 0 0 52
11:00 0 0 2 8 25 24 11 2 0 0 0 0 0 72
12:00 PM 0 2 2 9 25 20 4 0 0 0 0 0 0 62
13:00 0 1 4 12 61 26 3 0 2 0 0 0 0 109
14:00 0 1 1 10 33 28 8 1 0 0 0 0 0 82
15:00 0 0 5 8 44 23 10 2 1 0 0 0 0 93
16:00 0 2 3 10 32 26 5 1 1 0 0 0 0 80
17:00 0 1 2 11 33 31 4 2 0 0 0 0 0 84
18:00 0 0 1 2 21 15 4 0 0 0 0 0 0 43
19:00 0 0 0 2 14 10 2 0 0 0 0 0 0 28
20:00 0 0 0 1 8 4 0 0 0 0 0 0 0 13
21:00 0 0 0 1 3 2 1 0 0 0 0 0 0 7
22:00 0 0 0 0 1 1 0 0 0 0 0 0 0 2
23:00 0 0 0 0 1 1 0 0 0 0 0 0 0 2
a: .,: .,~
%1 3%1 11%1 45%1 32%1 7%1 1%1 0%1 I I I I 100%
AM Volumes 0 1 14 47 207 160 36 5 0 0 0 0 0 470
%AM 0% 1% 4% 19% 15% 3% 0% 44%
AM Peak Hour 08:00 08:00 07:00 08 :00 08 :00 08:00 08:00 08:00 Volume 1 4 12 59 42 14 2 132
PM Volumes 0 7 18 66 276 187 41 6 4 0 0 0 0 605
%PM 1% 2% 6% 26% 17% 4% 1% 0% 56%
PM Peak Hour 12:00 15:00 13:00 13:00 17:00 15:00 15:00 13:00 13:00 Volume 2 5 12 61 31 10 2 2 109
Directional Peak Periods AM7-9 NOON 12-2 PM 4-6 Off Peak Volumes All Speeds Volume % Volume % Volume % Volume %
226 +------+ 21% 171 ~ 16% 164 ~ 15% 514 ~ 48%