Loading...
Approved Minutes - 2023-01-18 PM Development Review Commission Minutes January 18, 2023 Page 1 of 10 CITY OF LAKE OSWEGO Development Review Commission Minutes January 18, 2023 The Commissioners convened at 7:00 PM. Members Present: Chair Randy Arthur, Vice Chair Kirk Smith, Jeff Shearer, Bruce Poinsette, Dwight Sangrey, Timothy Lyons, and John Dewes Members Absent: None Staff Present: Jessica Numanoglu, Deputy Community Development Director; Evan Boone, City Attorney Pro Tem; Evan Fransted, Senior Planner; Erica Rooney, Public Works Director and City Engineer; Iris McCaleb, Administrative Assistant; and Kat Kluge, Administrative Support FINDINGS LU 22-0060: A request for a Conditional Use Permit for a preschool in an existing church building. This site is located at 1855 South Shore Blvd (21E10CC03600). The Staff Coordinator is Evan Fransted, Senior Planner. Vice Chair Smith moved to approve the Written Findings, Conclusion, and Order of LU 22-0060, as submitted. Seconded by Commissioner Poinsette and passed 5:0, with 2 abstentions. PUBLIC HEARINGS LU 22-0052: A request for Conditional Use and Development Review Permits for a new transportation depot (LOSD bus barn), a minor variance to increase the maximum fence/wall height from eight feet to 10 feet, and the removal of three trees. This site is located at 6333 Lakeview Blvd (21E18BC03200). The Staff Coordinator is Evan Fransted, Senior Planner. The hearing on this project was continued from January 4, 2023, to allow additional written and oral testimony. Evan Boone, City Attorney Pro Tem, gave an overview of the public hearing process, outlined the applicable criteria and procedures, and gave instructions for verbal testimony, noting the time limit modifications approved by the DRC at the last meeting. Development Review Commission Minutes January 18, 2023 Page 2 of 10 Mr. Boone asked DRC members to declare any ex parte contacts (including site visits), biases, or financial conflicts. All DRC members present declared they have no ex parte contacts, conflicts of interest, and no bias, except as follows: Commissioner Poinsette indicated that he had visited the site; Commissioner Shearer stated that he had reviewed both the written materials and video recording of the last DRC meeting and was a member of the DRC when Brent Ahrend was the Chair of the DRC; Chair Arthur stated that the Seattle branch of his firm had one closed matter (in June 2021) where the Lake Oswego School District (LOSD) was a client of the firm, that there were 8 closed matters where GEO Design was listed as an adverse party/co-party to his firm's clients, and that there were 12 closed matters involving System Design Constants, Inc, (as the firm’s client). He added that he did not work on any of those matters (having no knowledge of them), and that he derived no financial benefit from these matters, as he was no longer a shareholder in the firm (being now an "of counsel" attorney with the firm). He also shared that he drove through the site (this not influencing his analysis of the evidence), that he had contributed to the LO School Foundation in the past and was a member of the DRC (while Brent Ahrend was the Chair of the DRC) when the LOSD came before them previously for the bus depot application (where that application was denied); Vice Chair Smith declared that he was also a member of the DRC during the May 2019 hearing (also serving with Brent Ahrend); Commissioner Sangrey stated that he had reviewed all written testimony and had viewed the video recording of the meeting. He informed the public that he had also contributed to the LO School Foundation but felt this would not influence his decision; and Commissioner Lyons shared that his daughter was a student at Lakeridge Middle School and that he also had contributed to the LO School Foundation (but did not cause bias with regard to his review of the application). There were no challenges to the Commissioners’ rights to consider the application. Staff Report Mr. Fransted summarized the following updates since the last meeting on January 4, 2023: • Staff memos submitted on January 13, 2023 and January 18, 2023 list the testimony received after the last hearing. • 49 new public comments were received. • The Applicant submitted new rebuttal material, Exhibits F-016 to F-021. • The Rosewood Neighborhood Association (RNA) raised 2 new objections not mentioned at the last hearing: o 15% of the required landscaping must be visible off-site [LOC 50.06.004.1.b.i] -- staff finds that landscaping is visible off-site through the chain-link fence on two abutting properties. o A Minor Variance is not allowed to increase the height of a wall or gate [LOC 50.06.004.2] -- staff finds that the text supports the request for an increase to the height of the wall (interchangeable with “fence”) and that the Applicant included the gate in the Minor Variance request. • Comments were received from Clackamas County (Exhibit F-022), which concurred with ODOT’s recommendation. Development Review Commission Minutes January 18, 2023 Page 3 of 10 Recommended Conditions of Approval (COAs): • Condition C(2): All bus traffic to/from the site must be routed to the intersection of 65th Avenue with McEwan Road, as discussed in the traffic study (Exhibit F-003) -- staff recommends adopting this change. • Condition B(9): No changes -- staff recommends retaining the existing verbiage of COA B(9). • No Parking Condition: Not recommended -- staff recommends removing this condition. • Add Condition A(10) for Stormwater Management: If a proprietary water quality system is proposed in the final design, it shall meet the Department of Ecology’s GULD requirements (e.g., A Bay Filter shall be designed with EMC Media). • Add Condition B(11) for Clackamas County’s recommendation: The Applicant shall obtain a Development Permit from Clackamas County Engineering. The permit shall be for realignment of the median and extension of the west bound left turn lane to accommodate the 95th percentile queue, per the project traffic study. In conclusion, staff recommends approval of LU 22-0052, with the modified COAs. Questions of Staff Commissioner Shearer asked if they could condition something for a different jurisdiction. Mr. Boone replied in the affirmative, explaining that this was allowed if members found that the mitigation was necessary to offset the impacts of the project and that denial would cause an issue with the City approving the application. Ms. Numanoglu added that the Applicant would need to request a modification of the COAs if Clackamas County later rescinded their recommendation. Chair Arthur pointed to page 13 of the December 23, 2022 staff report, asking for clarification regarding the analysis used (his own judgement based on the evidence or other factors) to assess the Functional Characteristics/Reasonably Compatible criterion [LOC 50.07.005.3.a.iv]. Mr. Fransted responded that members were to look at the evidence in the record (what the Applicant is proposing on the site and other uses in the vicinity). Ms. Numanoglu acknowledged that this was a subjective criterion, but that staff identified and addressed what they believed were the Functional Characteristics of the use in the staff report after considering the public comments received at that time, and that the Commission may identify other functional characteristics of the use based on additional testimony received. Applicant Testimony Dr. Jennifer Schiele, Superintendent of LOSD, relayed that they provided additional information to further support their application. She shared that the students, their families, and the community relied on the LOSD to provide a reliable and efficient transportation service, opining that the new facility would provide this into the future. She noted that the urban setting in LO limited the supply of property with a large enough footprint and with appropriate zoning, adding that the Development Review Commission Minutes January 18, 2023 Page 4 of 10 new location was approximately 60% larger than the existing property on Beasley Way. She again described the suitability of the proposed site for future plans to change the fleet to electric buses, how the proposed site met the Noise mitigation requirements, and how there would not be a substantial impact on the neighborhood traffic. Questions of Applicant Chair Arthur asked for the lot sizes of each site (existing and new). Stuart Ketzler, Assistant Superintendent of LOSD Business Services, stated that the Beasley property (existing) was approximately 1.6 acres, and the Lakeview property (new) was approximately 2.4 acres. Vice Chair Smith asked the Applicant to consider whether the following modification to the language of COA B(9) was acceptable: "No additional school buses, other than those currently serving the area near the site, will use the intersection of Jean Road/Pilkington Road until the signal at this intersection is operational." Brent Ahrend, Traffic Engineer with Mackenzie, agreed that the modified wording added clarity, adding that no additional buses would be routed to use that intersection, outside those already using that intersection (noting that "...near the site..." could be removed). Vice Chair Smith then requested that they share their thoughts regarding the added COA A(10). Doug Pruitt, Project Lead for BBL Architects, stated that the COA required what they already outlined in the application regarding stormwater mitigation. Commissioner Shearer asked Mr. Ahrend if Lakeview Boulevard was considered a "feeder street." Mr. Ahrend replied that he did not know what was meant by "feeder street.” Commissioner Shearer requested confirmation that the area would see 1 to 5,000 trips per day. Mr. Ahrend confirmed that that was the design standard for that classification. Commissioner Shearer then asked how wide the street should be. Mr. Ahrend acknowledged that it was not built to the full standard, adding that he was not sure of the exact measurement. Commissioner Shearer inquired whether the corner near the intersection of Lakeview Boulevard and 65th Avenue was adequately designed. Mr. Ahrend replied that the width of Lakeview Boulevard along of the frontage, and the west side of the road around that corner were built to standard; however, the east side of the road was not built to standard (no sidewalk or curb) and where additional width would need to be provided. He added that the road would operate better if there were "No Parking" signage posted on that corner. Commissioner Shearer pointed to the public testimony (videos/photos) regarding trains and traffic delays (received at the last hearing), asking what LOSD had planned if a train were blocking McEwan Road. Mr. Ketzler indicated that train delays were found to be exceedingly rare and if they were to occur, the buses would be rerouted west on 65th Avenue to Childs Road, to maintain the schedules. Commissioner Shearer asked staff if the buses would be allowed to travel north on Lakeview Boulevard, on a one-off basis, if stopped by the train at 65th Avenue/McEwan Road, given the COA that prohibited northward travel on Lakeview Boulevard until the light was operational at Jean Road/Pilkington Road. Mary-Kay Larson, LOSD Director of Communications, asked for clarification, as Mr. Ketzler stated that the buses would be routed west on 65th Avenue. Ms. Numanoglu noted that the Applicant would technically be out of compliance were they to reroute north on Lakeview Boulevard; however, the City has prosecutorial discretion whether to enforce this COA during times of emergency. Mr. Boone explained that the Land Use regulations Development Review Commission Minutes January 18, 2023 Page 5 of 10 were to the impacts of this use on the adjacent properties, not to ensure that their operations were efficient or that they could run a scheduled bus service (this would be the risk the Applicant took). He added that this would be outside of the DRC's jurisdiction, just as what happened inside the property with buses moving around. Mr. Boone then expounded on the penultimate question regarding the request for a "No Parking" zone, stating that the regulations for parking on streets was under the jurisdiction of the City Engineer and was not a COA that members could impose. Commissioner Shearer acknowledged that he understood that last point. Chair Arthur pointed to page 8 of the staff report, asking Mr. Ahrend to explain how the change in route was an improvement over the March 2019 application. Mr. Ahrend stated that LOSD agreed to route the buses the shorter distance to McEwan Road, keeping them out of the neighborhood and off of the longer stretch of Lakeview Boulevard, which would help reduce the impact at the Jean Road/Pilkington Road intersection, sharing that his own opinion would be that the buses travel north to provide a traffic-calming effect. Public Testimony In Support Jan Castle, 16181 Parelius Circle, Lake Oswego, OR 97034, shared her professional background but stated that her comments were her own. She spoke to the location chosen in terms of emergency preparedness and how electric buses could be used as rolling battery stations to power schools being used as emergency centers. In Opposition Grant Howell, RNA Chair, 5842 Colby Court, Lake Oswego, OR 97035, showed a slide presentation regarding their concerns over size constraints for suitable bus/vehicle parking (Exhibit G-383). Jenny Davies, RNA Secretary, 18641 SW Benfield Avenue, Lake Oswego, OR 97035, showed a slide presentation regarding their concerns over the provided noise study (Exhibit G-384). Abigail Otaño-Haffner, shared 2 videos regarding traffic safety concerns for pedestrians walking on McEwan Road (Exhibits G-385 and G-386). Casie Schmitz, 18307 SW Longfellow Avenue, Lake Oswego, OR 97035, shared a video regarding traffic safety concerns at the obstructed curve on Lakeview Boulevard (Exhibit G-387). Christine Chenoweth, 18636 Benfield Avenue, Lake Oswego, OR 97035, shared a video regarding traffic safety concerns at the obstructed curve on Lakeview Boulevard (Exhibit G-388). She requested that members vote to deny the application. Grant Howell, speaking on his own behalf, showed a slide presentation, outlining aspects of landscaping requirements (Exhibit G-389). Chair Arthur asked Mr. Howell whether he agreed that the buses routing to the south on Lakeview Boulevard was a significant improvement on the reasonable compatibility with other Development Review Commission Minutes January 18, 2023 Page 6 of 10 uses in the area, when looking at the March 2019 application. Mr. Howell stated that he did not think that it made it any more reasonably compatible with the area, due to the width of the street (citing Clackamas County's construction standard for a 36'-wide roadway). Jason Freauf, 6150 Kenny Street, Lake Oswego, OR, 97035, shared a video regarding traffic safety concerns (Exhibit G-390). Vice Chair Smith asked Mr. Freauf if he prepared the video himself (given the use of the drone to take some of clips). Mr. Freauf replied that he personally did not make the video, but that it was put together by a few different people. Jenny Davies, speaking on her own behalf, explained that the last video shown was a montage to show how all of the intersections were linked together. She then showed a slide presentation, outlining her interpretation of the SW Overlay District (SWO) Code requirements (Exhibit G-391). Commissioner Lyons asked Ms. Davies if she felt that the functional characteristics of the proposed use or any industrial use could be made reasonably compatible with uses in the vicinity, relating to the SWO requirements. Ms. Davies shared that she felt that some industrial uses could be compatible (e.g., having no concrete block wall along the sidewalk or having no harsh noise or traffic impacts). Lisa Volpel, 5655 Kenny Street, Lake Oswego, OR 97035, opined that LOSD misstated the size of the Beasley property and that there would be more noise reflected into the neighborhood while the buses refuel. She added that she felt this was not a compatible use. Marco Rizzi, 6155 McEwan Road, Lake Oswego, OR 97035, relayed his interpretations of Exhibits F-007 and F-020 through a slide presentation (Exhibit G-392). Vice Chair Smith asked for confirmation that Mr. Rizzi was basing his distances on a GIS map rather than on a survey. Mr. Rizzi affirmed. Vice Chair Smith relayed that he was presuming that the Applicant used surveys as a basis for the data provided. Mr. Rizzi countered that he felt that the Applicant was not correctly representing the distances between the adjoining property and the proposed site. Mark Kimball, 5655 Kenny Street, Lake Oswego, OR 97035, informed members that he used to be a Failure Analysis Engineer, adding that there were always possibilities for problems to arise, and, in this case, the impacts were to public safety, proper flow of traffic, and unseen impacts to the neighborhood. He opined that there were no mechanisms in place to address the issues that could arise between the transportation facility and the neighborhood (as they were unincorporated and had no representation on the City Council). Marsha Benich, 18922 Kristi Way, Lake Oswego, OR 97035, read her written testimony into the record (Exhibit G-335). Neil James, 18485 SW Don Lee Way, Lake Oswego, OR 97035, shared his research regarding alternative options to the leased buses currently in use. He explained that he had lived in his Development Review Commission Minutes January 18, 2023 Page 7 of 10 home for 47 years and had worked for the Sheriff’s office for 25 years (seeing many tragedies during that time). He voiced his concerns over the safety of pedestrians on the local roadways. He relayed that the DRC’s decision would make a big difference to the neighborhood. Patrick McCarty, 6145 McEwan Road, Lake Oswego, OR 97035, noted that once traffic backed up due to the trains, the buses would be unable to reroute, as the roads were already blocked by that point. He then read his written testimony into the record (Exhibit G-369). He voiced his concerns over air quality. Commissioner Lyons asked if the widening of Lakeview Boulevard and the construction of sidewalks would ameliorate his safety concerns. Mr. McCarty replied that it would not, as he felt that the noise, the air pollution, and the traffic congestion were unacceptable. Sara Freauf, 6150 Kenny Street, Lake Oswego, OR 97035, shared a PowerPoint presentation regarding traffic safety concerns (Exhibit G-393). William Davies, 18641 Benfield Avenue, Lake Oswego, OR 97035, pointed to there being under 2 acres of usable space at the Lakeview property, when the employee parking and landscaping were taken into account. He opined that the proposed site was incapable of meeting the goals of the site. Billy Davis, 5836 Lakeview Court, Lake Oswego, OR 97035, relayed that he observed near accidents occurring every day as the trucks exit the roofing company's parking lot. He opined that there were a number of safety issues not yet seen, sharing that his daughter walks the long way home to avoid the traffic. He asked that they do the moral and ethical thing by voting the application down because the building was nonconforming, and it was not an approved site. Karla Davis, 5836 Lakeview Court, Lake Oswego, OR 97035, stated that they already had enough noise and air pollution coming from the roofing and demolition companies. She asked members to consider how they would feel if something were to happen to one of their children walking or biking to the schools, with more buses on the road in their neighborhood. She opined that LOSD could sell the Lakeview property and move to another place that would not affect their neighborhood. She requested that they not approve the application. Chair Arthur called for a 5-minute recess. The hearing resumed at 9:29 PM. Applicant Rebuttal Lee Leighton, Planner with Mackenzie, noted that many of the concerns raised did not address the approval criteria for a Land Use proposal such as this. He acknowledged that this was a difficult edge in the city, given the Industrial zone backing up to the railroad and whose only access was by way of Lakeview Boulevard, which needed to remain an industrial service street. He indicated that this truck traffic was accounted for in the Land Use Plan and in the Transportation System Plan (TSP). He urged members to evaluate the traffic impacts as compared to the uses allowed outright in the zone. He relayed that the APTA metrics were used as a planning guideline during site selection but were not standards adopted by LO and should not be applied to the Development Review Commission Minutes January 18, 2023 Page 8 of 10 Applicant's proposed site plan. He informed members that their Acoustical Engineer was present to answer any questions members may have. He explained that the propane tank was located in a landscape island, with room to adjust during final development to maintain the 25' minimum setback from the neighboring property. Mr. Ahrend requested that members approve the revised verbiage to COA B(9). He explained that they looked at the safety and noise concerns raised by the neighbors and made concessions and adjustments to make the site as compatible with the adjacent neighborhood as they could. Questions of Applicant Commissioner Dewes requested confirmation that there was no basis for the criteria meeting the APTA standards. Mr. Leighton pointed to the testimony acknowledging that there were averages that came from those statistics, opining that the point being made related to the facility being below its area-average when compared to research on other facilities. He agreed that it was a smaller site that would need to be carefully managed, opining that this did not mean that this site would not work. Mr. Boone asked if the Applicant wished to submit a final written argument. The Applicant responded in the negative. Mr. Boone instructed Chair Arthur to proceed to deliberations. Questions of Staff, Revisited Vice Chair Smith asked Mr. Boone how they were to characterize the video presentations where the citizen provided no other oral testimony. Mr. Boone replied that testimony could consist of evidence and argument, and that photos and videos were all a part of testimony, adding that what Vice Chair Smith spoke of, went to what type of credibility should be given (e.g., expert versus non-expert testimony or authenticating a photograph). Vice Chair Smith voiced his concern over the seeming inequity, where the public was afforded the opportunity to present video after video after video (5 minutes each), but the Applicant was given a limited amount of time to present their evidence. He asked if members could request that the presenter authenticate the video prior to watching it. Mr. Boone noted that the videos presented were made part of the record prior to the hearing and there were no limits to the number of pages for submitted written testimony or to the length of video submissions, indicating that what the person chose to highlight during the public meeting was another matter. Commissioner Shearer requested confirmation that the Fire Marshal approved the location of the propane tank. Mr. Fransted affirmed that the Fire Marshal looked at the site plan and found that the tank's location met the Fire Code and that they must also be in Fire Code compliance at the time of the building permit. Mr. Boone added that members' level of analysis, at this time, was to determine whether the Applicant showed that the plan was feasible. Commissioner Shearer noted that his understanding of the landscaping requirements was that they did not have to see all of the landscaping from off-site, from all angles. Mr. Fransted noted that the Code stated that landscaping must be visible off-site, confirming Commissioner Shearer's understanding. Commissioner Shearer asked if the DEQ or OSHA trumped the City, as they had no noise regulations. Mr. Boone responded in the negative, acknowledging that those were guidelines. Development Review Commission Minutes January 18, 2023 Page 9 of 10 Commissioner Sangrey asked if there was a requirement in the Code that called for articulation or frontal features of a wall, given the concerns raised about the nonconforming, flat, masonry wall proposed. Mr. Fransted replied that there was no requirement for articulation. Ms. Numanoglu added that the Code required landscaping in front of the wall if it were over a certain height, and the articulation in the Southwest Employment Area (SEA) applied to building walls but not to fences or landscape walls. Deliberations Commissioner Dewes acknowledged that this was a difficult decision as the measurement for Reasonable Compatibility was hard to define and that they heard many concerns raised by the neighbors. He stated that the Applicant made a good point during their rebuttal (this was an Industrial-zoned site). Chair Arthur agreed with Commissioner Dewes assessment, indicating that he was in somewhat of a quandary, himself. He pointed to the question he raised during the last meeting regarding the aspirational goals to convert this site to an electric vehicle transportation center and that he was instructed to give this testimony no weight since it was not part of the specific criteria for the application before them (even though he had great respect for the Lake Oswego Sustainability Network (LOSN) and its members). He indicated that it came down to whether the LOSD established that this proposal was Reasonably Compatible with other uses in the Area, opining that he was unsure whether this burden was shown, as compared to the first proposal. Commissioner Shearer relayed that, for him, the question was whether the traffic concerns were addressed, opining that the route to the north was better than to the south. He stated that he was unsure what he was going to do, given the traffic impacts that the buses would put on the neighborhood. Commissioner Sangrey noted that he was trying to separate the criteria into a set that could be measured objectively (traffic, groundwater control, distance from the train and noise) and a set that had to be measured subjectively (Reasonable Compatibility), adding that this brought in issues dealing with social and economic equity. He agreed that buses would more likely be a moderator rather than an aggravator of the safety and traffic issues (travelling more slowly, having professional drivers, and flashing lights that slow everyone down). He stated that he found nothing, objectively, that would cause him to lose support for this application; however, the Reasonable Compatibility issue was still a barrier. Vice Chair Smith stated that he was struck by this site being located in an IP zone but having the requirement that a CUP be obtained because buses would be using the site rather than semitrucks. He opined that the Applicant met the criteria; however, they also had to look at the Reasonable Compatibility issue. He voiced his concern over who was enforcing the semitrucks being parked in the middle of the road (as demonstrated in the videos shown), as he also agreed that he drove more slowly when behind a school bus. He shared that his sense, from the first application (May 2019), was that the neighbors did not want buses traveling up and down Lakeview Boulevard. He opined that they were not picking on this neighborhood economically, as there were so many areas of LO that did not have sidewalks or streetlights. He shared that, from his perspective, buses were more compatible to the area than were semitrucks, and that he Development Review Commission Minutes January 18, 2023 Page 10 of 10 would be supporting the application. Vice Chair Smith moved to approve LU 22-005, with the modified verbiage to COAs C(2) and B(9) and removing COAs A(10) and B(11). Seconded by Commissioner Poinsette. Members discussed various aspects of the COAs versus recommendations (i.e., “No Parking”). Erica Rooney, Public Works Director and City Engineer, relayed that the Engineering Department could review on- street parking at the corner on Lakeview Boulevard within a few weeks. Commissioner Lyons asked for clarification regarding criteria LOC 50.07.005.1.a and whether a business using delivery trucks would trigger the CUP requirement. Mr. Boone replied that LOC 50.07.005.1.a dealt with the "Intent and Purpose" and was not considered as criteria, and that the outright permitted uses must be considered, explaining further that negative impacts to the built environment could be mitigated during the Minor Development process. Commissioner Lyons opined that this was a key point to note, as an Industrial user could come in with more traffic and members would have no ability to review whether it would be a compatible use. Commissioner Lyons requested that the modified COAs be clarified. Staff shared the slide showing the COAs. Vice Chair Smith explained that all COAs listed in the staff report would remain, excepting the two changes made to the verbiage in C(2) and B(9), and to recommend that the City Engineer conduct an analysis regarding a "No Parking" zone in the area designated. The motion passed 6:1, with the added recommendation. Mr. Boone directed staff to return with Written Findings, Conclusion, and Order on Monday, February 6, 2023, at 7:00 PM. Commissioner Sangrey moved to recommend that the appropriate City Department address the following: Parking restrictions/enforcement be considered in the area of Lakeview Boulevard, 65th Avenue, and McEwan Road; Coordination with Clackamas County be implemented immediately to address the Boones Ferry Road/65th Avenue improvements; and Prioritization be increased for improvements of streets and sidewalks impacted by this project. Seconded by Commissioner Shearer and passed 7:0. Ms. Numanoglu will draft a memo to the City Engineer for members to review prior to submission. SCHEDULE REVIEW AND MANAGEMENT UPDATE Ms. Numanoglu, updated DRC members on upcoming meetings: February 6, 2023 has the Findings from this hearing and the requested Work Session. February 22, 2023 (on Wednesday because of the Federal Holiday) has 2 items scheduled. ADJOURNMENT Chair Arthur adjourned the meeting at 10:36 PM. Respectfully submitted, /s/ Kat Kluge, Administrative Support