BILL ANALYSIS Ó
AB 495
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Date of Hearing: January 6, 2014
ASSEMBLY COMMITTEE ON BANKING AND FINANCE
Roger Dickinson, Chair
AB 495 (Campos) - As Amended: January 6, 2014
SUBJECT : Community investment.
SUMMARY : Establishes the California Community Investment
Program (CCIP) with the Governor's Office of Business and
Economic Development (GOBiz). Specifically, this bill :
1)Defines "poverty" as the supplemental poverty measure,
established by the United States Census Bureau in 2013 to
incorporate cost of living in the established rate of poverty.
2)Defines "triple bottom-line investment funds" as including,
but not limited to, equity and debt investment vehicles that
pursue market and above market rates of financial return while
at the same time producing good jobs, affordable housing, and
other economic, social and environmental benefits for the
residents of the communities where the investments are made.
3)Provides for the following purposes of CCIP:
a) Encourage private sector investment in low-income
neighborhoods to improve the economic, environmental and
social conditions for existing residents.
b) Serve investors, employers, corporate executives,
business owners and site location consultants who are
considering low-income neighborhoods for business
investment and expansion; and
c) Coordinate state programs and funding resources to be
used to address poverty reduction.
4)Requires the director of CCIP to establish and implement a
process for establishing public education programs and
providing technical assistance to private sector investors.
5)Specifies that CCIP shall be governed by a 14 member
California Community Investment Council (Council) comprised of
the following:
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a) Six appointees from the Governor, three members from the
private sector with business or investment expertise, two
members with community development expertise and one
representative of organized labor;
b) Four members of the Legislature, two from the Senate,
one from each political party, appointed by Senate Rules
Committee and two from the Assembly, one from each
political party, appointed by the Speaker. Further
specifies that appointed members of the Legislature will be
non-voting and only participate to the extent that their
participation is compatible with their respective positions
as Members of the Legislature;
c) The Treasurer;
d) The Controller;
e) Secretary of the Business, Consumer Servicers and
Housing Agency; and
f) Director of GOBiz, who shall also serve as chair of the
Council.
6)Requires the CCIP to conduct the following activities:
a) Develop and annually update a database of low-income
neighborhoods in California by county and city with
relevant data about each neighborhood;
b) Compile and maintain a current inventory of California
public sector funding resources and financing mechanisms
that may be allocated to or utilized in low income
communities. Further requires that in compiling this list
the Council shall use the inventory of business incentives,
public sector funding resources, and financing mechanism
maintained by GOBiz; and
c) Provides that the inventory shall be used to assess the
role and impact of all of the following entities and
programs on low income neighborhoods:
i) California Department of Insurance's California
Organized Investment Network;
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ii) Federal and State Low-Income Housing Tax Credit
Program;
iii) California Alternative Energy and Advanced
Transportation Financing Authority;
iv) California Pollution Control Financing Authority;
v) California Transportation Financing Authority;
vi) Industrial Development Finance Authority;
vii) The California Infrastructure and Economic
Development Bank;
viii) Health and Human Services Agency;
ix) Natural Resources Agency;
x) Energy Commission;
xi) Public Utilities Commission;
xii) Local transportation authorities and the
Transportation Agency, including all transportation
funding proposed by the Department of Transportation or
allocated by the California Transportation Commission for
expenditure by state or metropolitan planning
organizations;
xiii) Greenhouse Gas Reductions Fund administered by the
California Environmental Protection Agency;
xiv) California Pollution Control Financing Authority; and
xv) Recycling Market Development Zone administered by
CalRecycle.
7)Communities identified by CCIP will be known as "California
Community Investment Neighborhoods."
8)Specifies that CCIP shall coordinate public sector financial
investment and public programs to assist low-income
communities that are eligible California Community Investment
Neighborhoods to become business, development, and investment
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ready and attract private sector triple bottom-line fund
investments. These programs shall include, but not be limited
to, the following purposes:
a) Economic development, including research and
development, manufacturing, small business, and
entrepreneurship growth and real estate development that
generates in jobs;
b) Housing rehabilitation and construction;
c) School construction, education, and academic performance
improvement;
d) Workforce preparation and training;
e) Public safety, community policing, crime prevention,
rehabilitation, and probation;
f) Public health, social services, and other human
services;
g) Mental health services;
h) Alcohol and other drug abuse prevention and treatment;
i) Recreation and community arts and music programs;
j) Transportation and other mobility infrastructure,
including public transit, walkways, and bicycle paths;
aa) Other infrastructure, including water, sewer, solid
waste, recycling, and lighting;
bb) Broadband deployment for high-speed Internet access,
other information technology infrastructure, and smart
grid;
cc) Energy efficiency, weatherization, and renewable energy
resources;
dd) Environmental quality, resource recycling, community
gardens, and local food sourcing services;
ee) Homeless facilities and services; and,
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9)Requires CCIP to develop and adopt criteria for identifying
eligible triple bottom-line investments funds that will serve
as partners and invest in enterprises and employers that
generate permanent jobs, including investments to assist in
starting-up, locating, and expanding employers in low-income
neighborhoods. These criteria shall include the spirit and
intent of the preponderance of the following criteria as
refined and adopted by the California Community Investment
Council:
a) Commitment to locate investments in a low-income
neighborhood;
b) Generation of living wage jobs with benefits for
low-income residents;
c) Projected multiplier effect for generation of additional
employment;
d) Provision of employment benefits, such as health care,
retirement plans, profit sharing, and employee stock
ownership;
e) Commitment to local hiring and job training;
f) Engagement of local, women, and minority business
enterprises as suppliers and contractors;
g) Development and sponsorship of employee training
programs, including job training and financial education;
h) Provision of on site or nearby child care for children
of employees;
i) Use of green building design, construction, renovation,
or operations;
j) Implementation of energy and other resource efficiency,
recycling, or pollution prevention programs;
aa) Deployment of broadband high-speed Internet access and
other information technologies to support and increase
productivity and reduce impacts on the environment;
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bb) Implementation of workplace safety or effective
ergonomic programs;
cc) Engagement with the local community through volunteer
organizations, local school support programs, and other
community initiatives;
dd) Production of economically, socially, or environmentally
beneficial products and services;
ee) Receipt of green business certification; and,
ff) Production of Corporate Social Responsibility (CSR),
Corporate Sustainability, and Creating Shared Value (CSV)
reporting;
10)Requires the CCIP to develop and adopt criteria for eligible
triple bottom-line investment funds that invest in real estate
developments to assist in constructing, expanding, renovating,
and rehabilitating buildings in low-income neighborhoods that
accommodate all allowed land use approved and permitted by the
local government land use regulations. The criteria shall
include the spirit and intent of the preponderance of the
following, as refined and adopted by the California Community
Investment Council:
a) Commitment to locate investments in a low-income
neighborhood that benefit low-income residents;
b) Consistency of development with local government land
use plans and alignment with local government priorities;
c) Generation of construction jobs with living wages and
benefits;
d) Establishment of job training and apprentice programs
for local residents;
e) Ownership or equity participation by a local, woman, or
minority developer or use of local, women, or minority
business enterprises as contractors or subcontractors;
f) Construction of affordable housing, especially as part
of a larger mixed-income, mixed-use project to optimize
synergies among land uses;
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g) Generation of permanent living wage jobs;
h) Retention or generation of permanent living wage jobs;
i) Use of green construction materials and practices;
j) Incorporation of energy efficiencies, waste reduction,
and renewable energy resources;
aa) Implementation of smart development practices deploying
broadband for high-speed Internet access for smart
infrastructure and smart buildings, optimizing the utility
of a smart grid;
bb) Incorporation of a multimodal transportation system that
optimizes walking, bicycling, public transit, and other
strategies to reduce single-occupant vehicle trips;
cc) Design of development consistent with the concept and
principles for livable communities;
dd) Accommodation of green and clean technology employers;
ee) Implementation of low-impact development practices
incorporating native vegetation, soil preservation, water
use conservation, recycling and other efficiencies, and
pervious pavement;
ff) Incorporation of parks, recreational areas, open spaces,
and other environmental amenities;
gg) Accommodation of locations for small and local
businesses;
hh) Establishment of space for neighborhood organizations,
community centers, child care centers, and other nonprofit
community-based organizations;
ii) Use of bio-regional development practices connecting
local and regional sustainable food production with urban
consumption; and,
jj) Acquisition of LEED certification for buildings and
neighborhoods.
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11)Mandates that CCIP establish overall triple bottom-line goals
and standardized metrics for economic, social, and
environmental outcomes that shall be accepted by all eligible
investment funds.
12)Specifies that CCIP shall gather evidence and conduct public
forums to identify a broad array of incentives that will
encourage triple bottom-line fund investments in low-income
neighborhoods and take the following actions:
a) Prepare a report to the Legislature and Governor;
b) Establish incentives for which there is existing legal
and regulatory authority; and,
c) Recommend appropriate amendments to existing laws and
regulations and work with the Legislature and the Governor
to secure adoption.
13)Requires CCIP to survey counties and cities to identify and
inventory local governments that want to partner with triple
bottom-line investment funds to invest in low-income
neighborhoods. This survey shall determine if the local
government has done any of the following:
a) Approved within the last 10 years a general plan,
specific plan, or other land use plan or zoning regulation
on which an investor can rely to govern and control
development;
b) Identified local public funding or other resources that
have been or will be committed to the low-income
neighborhood to complement a triple bottom-line fund
investment;
c) Designated a person to coordinate alignment of public
resources and implementation of development plans with a
fund manager;
d) Established county and city school integrated human
services teams to serve the low-income neighborhood with
goals and accountability to increase employment, improve
education, reduce poverty, reduce crime, and improve health
status; or,
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e) Committed to cooperate in and assist with monitoring and
tracking performance outcomes in the low-income
neighborhoods;
14)Specifies that CCIP establish and convene regular meetings of
the California Community Investment Network comprised of
organizations and institutions with expertise and resources to
advise the Council and eligible investment fund managers.
15)States that CCIP must report biannually to the Legislature
and the Governor on the status and progress of the CCIP and
performance on goals and triple bottom-line outcomes.
16)Provides that the CCIP shall encourage significant private
sector commitment, cooperation, and collaboration to invest
private capital in low-income neighborhoods through eligible
triple bottom-line equity funds with the goal of obtaining at
least one billion dollars ($1,000,000,000) of new investment
by triple bottom-line investment funds in triple-bottom real
estate developments and businesses located in low-income
California neighborhoods.
17)States that CCIP shall give priority consideration for award
of state assistance from public resources, herein identified,
to low-income neighborhoods that adopt and implement
strategies to become business, development, and investment
ready and collaborate with the California Community Investment
Program to attract investment by triple bottom-line funds.
18)Requires the Council to adopt criteria for an eligible triple
bottom-line equity fund that shall include at least the
following:
a) The fund shall be legally structured to comply with both
the spirit and intent of the preponderance of the relevant
criteria delineated in subdivisions (d) and (e) of Section
12099.2, as refined and adopted by the California Community
Investment Council, including triple bottom-line goals and
outcomes with explicit metrics;
b) The fund shall be managed by a reputable fund manager
with a track record of experience and performance with
triple bottom-line funds;
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c) The fund shall attain a scale of at least one hundred
million dollars ($100,000,000,000) in capital;
d) The fund shall be committed to working with relevant
local government jurisdictions to optimize the alignment of
state public funding and resources and local government
funding and resources;
e) The fund shall include experienced personnel to manage
coordination with appropriate state and local government
public funding or other resources. This shall be
accomplished wither by the fund manager or through a
contractual relationship between the fund manager and an
appropriate nonprofit organization; and
f) The fund shall be organized to track performance and
report metrics for triple bottom-line goals and outcomes;
19)Requires CCIP to give priority consideration to working with
triple bottom-line funds that meet the criteria established by
the California Community Investment Council, with first
attention to those funds with the largest amount of capital.
20)Mandates that CCIP shall assist funds meeting these criteria
to identify and make appropriate investments in investment
ready low-income communities and shall work with these funds
to coordinate all of the appropriate state and local financial
and programmatic resources to assist these investments to
succeed.
EXISTING LAW establishes the Governor's Office of Business and
Economic Development. (Government Code, Section 12096 et seq)
FISCAL EFFECT : Unknown, but specifies that the CCIP must be
staffed by GOBiz using existing resources.
COMMENTS :
According to information provided by the author's office this
bill is necessary for the following:
Poverty is increasing in California, and the state lacks a
coordinated economic development strategy to bring social
equity private investment to low-income neighborhoods.
According to the supplemental poverty measure, established
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by the U.S. Census Bureau in 2013 to incorporate cost of
living in the establishment of the rate of poverty, the
rate of poverty in California is 23.5%, which means that
nearly nine million people are poor. Low-income
neighborhoods face challenges in accessing capital. One
way to address poverty is to increase public and private
investment in resource poor neighborhoods through triple
bottom line investing. Triple bottom line investing
promotes a market or above market rate of economic return,
environmental protection, and social equity. However,
private investment won't flow into low-income neighborhoods
unless the state can help underwrite the risk of crime,
poverty, low job skills, and poor infrastructure. While
the state has numerous programs aimed at reducing poverty
and promoting economic development, none of this is
organized or coordinated.
AB 495 seeks to provide a structure within state government
to coordinate public investment so that it complements and
encourages triple bottom line investing into low-income
neighborhoods. The triple bottom line investment sector
consists of funds like the Bay Area Family of Funds
organized by the Bay Area Council. The Bay Area Family of
Funds is a regional effort to attract private capital into
low and moderate income neighborhoods. The Family of Funds
leverages its investments in these communities through
projects that promote smart growth, address poverty,
support local businesses and clean up contaminated sites
with market-based solutions.
It has raised over $215 million for double and triple
bottom line investments through four separate funds: the
Bay Area Smart Growth Funds I & II, the Bay Area Equity
Fund, and the California Environmental Redevelopment Fund.
The Funds' investors consist of banks, foundations, pension
funds, insurance companies, individuals, and other
corporations. The triple bottom line sector of the private
capital market has matured over the past decade and is
positioned to accelerate its investment in low-income
neighborhoods if the state is able to step-up and help
mitigate the risk that social equity investors face.
Triple Bottom Line (TBL) Investing.
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The goal of AB 495 is to encourage greater investment in
communities in need TBL investments. What is TBL investing? In
traditional business accounting, the "bottom line" is the sum of
revenue minus expenses, which is either a loss or a profit. The
term originated from the profit is always shown at the very
bottom of the statement of revenue and expenses. In the last 50
years, social and environmental justice groups have struggled to
bring a broader definition of "bottom line" into public
consciousness. The concept of TBL is designed to bring about
other bottom lines, often paraphrased as "profit, people,
planet." These other bottom lines are social and environmental
concerns that provide a societal benefit. TBL accounting gained
attention in the mid-1990s when John Elkington, an authority on
corporate responsibility and sustainability, came up with TBL as
a way to measure the sustainability outcomes of corporate
America. Andrew W. Savitz, author of The Triple Bottom Line and
formerly a lead partner running PricewaterhouseCoopers'
sustainability consulting practice has said the TBL "captures
the essence of sustainability by measuring the impact of an
organization's activities on the world? including both its
profitability and shareholder values and its social, human and
environmental capital."
While profits can be measured in dollars, how does one measure
social capital? This remains a significant challenge. There is
no universal standard method for calculating the TBL nor is
there a universal standard for the measures that compromise the
three TBL categories. Government and business may view
sustainability in different terms. Stakeholder groups, such as
socially responsible investors, non-governmental organizations,
green consumers, and governmental regulators and agencies are
increasingly calling for information related to the social and
environmental dimensions.
TBL is not without its critics. Notwithstanding the
difficulties of quantification, a report, Triple Bottom Line: A
Business Metaphor for a Social Construct, had a negative view of
TBL as a metaphor for the "bottom line." The author's found,
We conclude that the bottom line as a metaphor for
measuring and reporting business'
contribution to social sustainability is fatally flawed.
The metaphor's application through current triple bottom
line reporting protocols allows businesses to ignore
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critical sustainability concerns for several reasons.
First, businesses attempting to legitimate themselves
without actually addressing sustainability can use the
reporting exercise to co-opt the external pressure for true
sustainability. Due to the lack of mandatory standards,
businesses freely pick and choose which characteristics
they measure, derive their own metrics and standards for
these characteristics, and produce a report that reveals
precisely what they wish to disclose. The bottom line
metaphor implies rigor and objectivity that fail to exist
in these situations. Second, businesses that start with a
genuine commitment to enhancing their sustainability
efforts can be distracted as the inter-relationships among
the dimensions are masked by the apparent independence of
the three "bottom lines". There is neither demand to
analyze inter-relationships nor pressure to consider how
the impacts from one dimension affect the others. The focus
is an atomistic one, a (relatively) easy and uninformed
perspective for addressing sustainability objectives.
Third, the fundamental differences between the three the
triple bottom line elements make using a single framework
problematic. The major differences are in: the ability to
identify, quantify, and measure these central constructs;
the applicability of being metaphorically designated as
capital; and the metaphorical representations and
conceptual approaches to understand, quantify, and report
the dimensions.
In spite of these academic concerns, TBL investing has gained
legitimacy over the last decade as private investors attempt
align to their investment portfolios with socially responsible
goals. The California Emerging Technology Fund writes in
support of AB 495:
The Community Capital Investment Initiative does not
require any new State
funds nor does it incur any financial liability for the
State government. However,
CCII will help support living-wage jobs, affordable
housing, a healthier
environment and improved community services in low-income
communities.
CCII will be led and managed by the Governor's Office of
Business and
Economic Development (GOBiz) with the assistance of a
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coordinating and
oversight body comprised of Administration Agencies and
public representatives
with expertise to align and support with all other economic
development tools.
Thus, CCII complements augments and leverages the State's
existing economic
development strategies and programs to enhance their
impact.
Over the last decade, socially-responsible TBL investing
has matured as industry, demonstrating that private
investors can achieve market-rate financial returns while
also generating social and environmental benefits.
However, most TBL funds invest in more moderate-income than
low-income communities because of higher risks in the
poorest neighborhoods. AB 495 will help reduce those
private-sector investment risk by mobilizing public
leadership and existing government resources into
low-income neighborhoods where the TBL funds invest. AB
495 fosters the kind of public-private collaboration that
is needed to attract investment into California's poorest
neighborhoods to benefit the most disadvantaged residents.
AB 495 attempts to utilize the state's economic investment
strategies, via GOBiz, to encourage greater investment and
revitalization in California's disadvantaged communities.
This bill, would establish the CCIP and a 14 member Council in
an effort designed to identify low-income communities in
California, as well as, inventory California public sector
funding and investment resources. This inventory would also
include a survey of cities and counties to identify local
governments that may want to partner with TBL investment funds.
The inventory would also be required to assess the role and
impact of various state entities and programs on disadvantaged
communities. Furthermore it requires the Council to govern the
CCIP and identify communities that can be eligible for
assistance and coordination of TBL investments with CCIP.
This process also includes a list of criteria. These criteria
fall into these categories:
1)Programs and public sector financial investments that meet
certain standards. For example, those programs that encourage
economic development, housing, workforce development, etc.
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This list of criteria includes fifteen specific items.
2)Criteria for identifying eligible TBL investments funds that
would serve as partners and investing in enterprises and
employers that generate permanent jobs and expand employment
opportunities in low income communities. This list of
criteria includes sixteen specific items that may be refined
and adopted by the Council.
3)Adopt criteria for TBL investment funds that invest in real
estate developments to assist in constructing, expanding,
renovating, and rehabilitation of buildings in low income
communities. This list of criteria includes 20 specific items
that may be refined and adopted by the Council.
4)The Council will adopt criteria for an eligible TBL equity
fund that includes a list of 6 factors.
Discussion.
The coordination and marshaling of existing state resources and
programs in order to better target services at low-income
communities should be a vital goal of the state's economic
development policies. Including TBL investment funds that wish
to expand their investment in projects that meet TBL goals is an
innovative way to direct policies toward revitalization,
specifically in the post-redevelopment agency era, and with more
questions being raised on the actual economic impact of
enterprise zones. The strategy outlined in AB 495 may well
represent a potential paradigm shift concerning the complicated
issue of how policy makers and community groups address
socio-economic needs of low income communities. Creating a
pipeline for investment capital that can be focused on the
location of the most need can reduce waste and a misdirection of
resources. While the underlying theme and policy direction of
AB 495 is a constructive step forward in bridging state
resources with private capital, it suffers under the burden of
several problematic issues. The following are items that
create unintentional policy issues that need to be addressed:
1)Vague and or confusing terms: It uses terms or phrases that
need greater clarification. The Council is made up of several
appointed members, three of which must have "business or
investment expertise" while two members must have "community
development expertise." The parameters for what would meet
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these requirements are not provided. In establishing the
multiple list of criteria, the bill states the criteria shall
include the "spirit and intent of the preponderance of the
following criteria?" Again, it is unclear what is meant by
this statement that occurs several times throughout the
language. Additionally, personnel and managers of TBL
investment funds that meet the requirements would need to be
"reputable" and "experienced." Again, these terms need
greater explanation. Additional sections also include terms
and phrases that need greater refinement and/or specificity.
2)Multiple list of criteria: As discussed earlier, this bill
includes multiple and seperate list of criteria designed to
provide guidance for the CCIP and the Council, but may in fact
become constraining over the long term. For example, the list
of criteria does not address issues relating to assisting the
underbanked and unbanked through access to asset building
strategies. Additionally, many of these communities are
challenged by a saturation of high-cost and risky credit
products that create cycles of debt. These issues are lacking
from the criteria list, yet it may not be appropriate to add
more to the list. Thus, the problem is highlighted in that
once we list numerous goals, even if they are parameters and
not a total list, the absence of other factors will provide
invisible boundaries for what the CCIP can accomplish. It is
recommended that rather than a specific list of items (even if
they are only a minimum, not a maximum) that instead the goals
of the CCIP be expressed via general statements on assisting
low income communities and empower the Council and CCIP to
work with TBL investment funds and community groups to refine
their own organic list of criteria.
3)Flexibility. In the modern economy as developments in
technology and commerce come and go overnight, investment
funds need partners that quickly react to provide investment
opportunities or development of new projects. The various
parameters proscribed by AB 495 would appear to take away the
flexibility and reaction time needed for the state to have a
positive contribution in working with TBL investors. With
several reports, surveys and inventory lists required, the
CCIP may be burdened with an overload of administrative work
required to be accomplished with the existing resources of
GoBiz. Staff recommends that efforts should be made to
reduce the administrative burdens required under this bill and
instead focus on the policy goals that should be met.
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4)Though not intentional, AB 495 would give CCIP authority to
redirect state resources and programs creating a confusing
contradiction between various state departments and agencies.
This confusion arises with CCIP given the authority to "give
priority consideration for award of state assistance from
public resources and programs?" Additionally, the bill
requires CCIP and GoBiz to offer assistance to funds meeting
the various criteria, but it is unclear to what this
assistance would entail, or the potential budgetary costs such
assistance could create.
5)Creation of special fund. Requires the Council to adopt
criteria for an eligible TBL equity fund. Is this a state
operated fund? The language is not specific as to where
capital for such a fund would come from. Typically,
legislative proposals that do not specify a source of funds
put cost pressures on the state's General Fund. The criteria
call for the fund to have a fund manager. Does this mean that
private fund manager would be in charge of a publically
created and administered equity fund? This concept needs
further detail and clarification on its intent, operation and
costs. Staff recommends that references to such fund be
struck out of the bill.
Due to the aforementioned issues, it is recommended that future
amendments are necessary to correct these issues. AB 495 goes
to Assembly Housing Committee should it pass from this committee
so any amendments suggested here would need to be adopted either
in Housing or Appropriations Committee. For now, staff
suggests the following amendments:
1)Page 6, line 7, delete "with."
2)Page 6 delete lines 8-40;
3)Page 7, delete lines 1-2 inclusive;
4)Page 7, delete lines 8-33 inclusive;
5)Page 7, line 39 delete "these criteria."
6)Page 8, delete lines 1-35 inclusive;
7)Page 9, line 1 delete "The criteria shall include the spirit
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and intent."
8)Page 9, delete lines 2-39 inclusive;
9)Page 10, delete lines 1-7 inclusive;
10)Page 10, delete lines 15-40 inclusive;
11)Page 11, line 8 delete "Initiative" and insert "Program."
12)Page 11, delete lines 18-31 inclusive;
13)Page 11, line 34 delete "That shall include at least the
following."
14)Page 11, delete lines 35-40 inclusive;
15)Page 12, delete lines 1-37 inclusive.
REGISTERED SUPPORT / OPPOSITION :
Support
Bay Area Impact Investing Initiative
Breakthrough Communities
Bronze Investments
California Emerging Technology Fund
Double Bottom Line Venture Capital
Seal Cove Financial
Strategic Development Solutions
Sustainable Systems
Transom Capitol Group
Opposition
The American Wood Council (AWC)
Analysis Prepared by : Mark Farouk / B. & F. / (916) 319-3081