Item 5A - 911 Pine StAgenda Item #5A Page 1
M E M O R A N D U M
July 5, 2017
TO: Landmarks Board
FROM: Lesli Ellis, Comprehensive Planning Manager
Debra Kalish, Senior Assistant City Attorney
James Hewat, Senior Historic Preservation Planner
Marcy Cameron, Historic Preservation Planner
Anthony Wiese, Historic Preservation Intern
SUBJECT: Public hearing and consideration of a Landmark Alteration Certificate
application to demolish a non-contributing 480 sq. ft. two-car garage and,
in its place, construct a new two-car, 640 sq. ft. accessory building at the
northwest corner of the property at 911 Pine St. in the Mapleton Hill
Historic District, pursuant to Section 9-11-18 of the Boulder Revised Code
1981 (HIS2017-00180).
STATISTICS:
1. Site: 911 Pine St.
2. Date of Construction: 1979 (Garage)
3. Zoning: RL-1 (Residential Low-1)
4. Owner: Corey and Karl Strohmeyer
5. Applicant: Joel Smiley
6. Site Area: 10,504 sq. ft.
7. Existing Garage: 480 sq. ft.
8. Proposed Garage: 640 sq. ft.
STAFF RECOMMENDATION
Staff considers the demolition of the non-contributing garage and construction of a new
garage will be generally consistent with the standards for issuance of a Landmark
Alteration Certificate, as specified in Section 9-11-18, B.R.C. 1981, the General Design
Guidelines, and the Mapleton Hill Design Guidelines, provided the conditions below are
met. Staff recommends that the Landmarks Board adopt the following motion:
I move that the Landmarks Board approve a Landmark Alteration Certificate to demolish the
non-contributing garage and in its place, construct a new garage at 911 Pine St., in that,
provided the conditions below are met, the proposed demolition and new construction will meet
Agenda Item #5A Page 2
the requirements of Section 9-11-18, B.R.C. 1981, and adopt the staff memorandum dated July 5,
2017, as findings of the board.
CONDITIONS OF APPROVAL
1. The applicant shall be responsible for constructing the house in compliance with
the approved plans dated June 7, 2017, except as modified by these conditions of
approval.
2. Prior to submitting a building permit application and final issuance of the
Landmark Alteration Certificate, the applicant shall submit to the Landmarks
design review committee (Ldrc), for its final review and approval:
a. Revised plans showing a reduction in the mass and scale of the proposed
new garage to reduce the width to be more in scale with the contributing
accessory building, to provide more permeability into the historic
property, and to prevent the alleyscape from becoming tunnel-like.
b. Final architectural plans that include details for the new building,
including wall and roof materials, door and window details, and
hardscaping on the property to ensure that the final design of the building
is consistent with the General Design Guidelines, the Mapleton Historic
District Design Guideline, and the intent of this approval.
SUMMARY
On June 7, 2017, the Planning, Housing and Sustainability (PH&S) Department
received a Landmark Alteration Certificate application for the demolition of an
existing non-contributing two-car garage and in its place, the construction of a new
640 sq. ft. accessory building at 911 Pine St. in the Mapleton Hill Historic District.
Because the application calls for demolition of a building and new, free-standing
construction over 340 sq. ft. within a historic district, review by the full Landmarks
Board in a quasi-judicial hearing is required pursuant to Section 9-11-14(b), B.R.C.
1981.
In 1979, a permit was issued for the construction of the existing garage on the
property (see Figure 5.). The Historic Building Inventory Form notes that the building
(“Building B”) is non-contributing due to its age of less than 50 years old. See
Attachment A: Historic Building Inventory Form.
Given its 1979 date of construction (well outside the defined 1865-1946 period-of-
significance for the Mapleton Hill Historic District), staff considers the garage to be
non-contributing and finds that its demolition would not diminish the special
historic character of the Mapleton Hill Historic District.
Agenda Item #5A Page 3
PROPERTY DESCRIPTION
Figure 1. Location Map, 911 Pine St.
The property at 911 Pine St. is located on the north side of Pine St. between 9th and 10th
streets. An alley runs along the north side of the property. The original two-story
masonry house was constructed around 1883 and features a steeply pitched roof with
overhanging eaves. The upper gable has paired, tall, narrow, double-hung windows
with paired hoodmolds. An intersecting wing is located on the east elevation and is clad
in wide horizontal siding.
In December 2016, the Landmarks Design Review Committee (LDRC) reviewed and
approved a Landmark Alteration Certficate for the rehabilitation of the existing house,
including reconstruction of the front porch based on historic photographs, and
demolition of a non-historic addition and the construction of a new addition (HIS2016-
00364).
Agenda Item #5A Page 4
Figure 2. 911 Pine St., Tax Assessor Photograph, c. 1929.
PROPERTY HISTORY
The Smith Residence was built around 1870, making it one of the earliest remaining
houses in Boulder. Sanford Gladden’s 1883 directory notes that this was the residence of
C. Edgar Smith before 1883. Smith was editor of the Boulder Sentinel and an early mine
operator.
In 1883 Edward, Louis, and Nannette Lowman lived there. Edward and Louis Lowman
were the proprietors of Lowman & Son Excelsior Clothing House at 1215 Pearl St. In
1896, the house was occupied by J. Bergheim, of J. Bergheim & Company Boston
Clothing House Wholesale and Retail, located at 1210 Pearl St.
From 1901 until 1939, the house was rented out to a variety of tenants including miners,
students, school instructors and traveling salesmen. The building was listed as vacant at
least twice during this time. Guy and Ellen Robinson owned the property from 1939
until 1954. Guy Robinson was an interior painting and paperhanging contractor. By
1954, the property was owned by Ruth Miller Cordry of Cordry Real Estate, Loans &
Insurance at 1470 28th Street. Jon Bond purchased the property in 1978 and owned it
until 2016, when it passed to the current owners.
Agenda Item #5A Page 5
Figure 3. 911 Pine St., Main House, 2016.
Figure 4. 911 Pine St., Accessory Building, 2016. Not proposed for demolition.
Two accessory buildings are located at the rear of the lot. A flat-roof frame accessory
building is located at the northeast corner of the lot. The building was constructed pre-
1931 and is considered contributing to the Mapleton Hill Historic District. No changes
are proposed to this accessory building.
Agenda Item #5A Page 6
Figure 5. 911 Pine St. Garage, North Elevation, 2016
Permit records indicate the two-car, one-story garage, at the northwest corner of the lot
was constructed in 1979. The building features a front gable and a wide overhead
garage door. Very simple in design, the building is clad in painted, wide horizontal
siding and its most notable feature is its large wood roof deck.
Figure 6. 911 Pine St. Garage, East Elevation, 2016.
The east face of the garage features a slider window, a single light, paneled pedestrian
door and a wooden staircase that provides access to the roof-top deck.
Agenda Item #5A Page 7
Figure 7. 911 Pine St. Garage, South Elevation, 2016.
The south face of the garage contains a single sliding window. The foundation wall at
the south of the building is supported by a dry-laid stone retaining wall.
Figure 8. 911 Pine St Garage, West Elevation, 2016.
The west elevation has no windows, doors or other features beyond the rooftop deck.
HISTORIC SIGNIFICANCE OF GARAGE PROPOSED FOR DEMOLITION
The General Design Guidelines define contributing buildings as “those buildings built
during the district’s period of significance that exist in comparatively original condition,
Agenda Item #5A Page 8
or that have been appropriately restored, and clearly contribute to the historic
significance of the district. Such buildings may have compatible additions.”
Non-contributing buildings are defined as “those buildings built during the district’s
period of significance that have been altered to such an extent that historic information
is not interpretable and restoration is not possible. This includes buildings erected
outside the period of significance that are not individually significant.”
Because of the documented 1979 date of construction (well out of the defined 1865-1946
period of significance for the Mapleton Hill Historic District), staff considers the garage
at 911 Pine St. does not meet the definition for a contributing building and that it should
be considered non-contributing to the historic character of the Mapleton Hill Historic
District.
PROPOSED NEW CONSTRUCTION
The applicant proposes to demolish the existing 480 sq. ft. garage and construct a new
640 sq. ft. accessory building to house two cars, upstairs storage and a basement
workshop. The provided site plan indicates that the proposed construction will be
rectilinear in plan, measuring 23’ x 22’ with a footprint of 506 sq. ft. The additional floor
area of 134 sq. ft. is shown to be in the lower level.
The Form and Bulk Standards in Section 9-7-8, Accessory Buildings in Residential Zones,
B.R.C., 1981, limits the cumulative coverage for accessory buildings in the rear yard
setback to 500 sq. ft. However, for designated properties, one new accessory building
with a building coverage of up to 500 sq. ft. is allowed in the rear yard setback, in
addition to the existing accessory buildings. This allowance promotes the preservation
of historic accessory buildings by exempting their footprint from the building coverage
limitations in the rear yard setback. As shown, approximately 300 sq. ft. of the
proposed 506 sq. ft. garage will be in the rear setback, in addition to the existing 228 sq.
ft. historic accessory building. The total building coverage in the rear setback is
proposed to be 528 sq. ft. , 28 sq. ft. more than the allowed maximum.
Agenda Item #5A Page 9
Figure 9. Proposed Site Plan (not to Scale)
The new garage is shown to be a flat roof, rectangular building with two levels. The
upper level is at the grade of the alley, while the lower is a walk-in basement, cut into
the slope of the site, with its exposed side on the south.
Figure 10. Existing and proposed north elevations
The only opening on the proposed north elevation are two top-hinged garage doors.
Figure 11. Existing (left) and proposed (right) south elevations
Agenda Item #5A Page 10
Elevations show the south (garden side face) of the building to feature flanking double
doors on the lower level, and two, two-over-two double hung windows above.
Figure 12. Existing (left) and proposed (right) east elevations
The east elevation features an entry door near the north side, with two single light, fixed
picture windows to the south.
Figure 13. Existing (left) and proposed (right) west elevations
There are no openings planned on the west face of the proposed building.
CRITERIA FOR THE BOARD’S DECISION
Subsection 9-11-18(b) and (c), B.R.C. 1981, sets forth the standards the Landmarks Board
must apply when reviewing a request for a Landmark Alteration Certificate.
(b) Neither the Landmarks Board nor the City Council shall approve a Landmark
Alteration Certificate unless it meets the following standards:
Agenda Item #5A Page 11
ANALYSIS
1. Does the proposed application preserve, enhance, or restore, and not damage or destroy
the exterior architectural features of the landmark or the subject property within a
historic district?
Staff considers the existing garage to be non-contributing to the Mapleton Hill
Historic District due to its 1979 date of construction, well outside of the 1865-
1946 period of significance for the Mapleton Hill Historic District, and lack of
individual significance. The second accessory building, constructed pre-1931,
does meet the definition of contributing and will be preserved.
Staff finds that, provided the listed conditions are met, the demolition of the
existing garage and construction of a new accessory building will not damage or
destroy contributing properties in the alley scape and will be generally
compatible and consistent with the General Design Guidelines and the Mapleton
Hill Historic District Guidelines), provided the mass and scale of the new garage
is reduced (see Design Guidelines Analysis section).
2. Does the proposed application adversely affect the special character or special historic,
architectural, or aesthetic interest or value of the district?
Staff considers that the demolition of the non-contributing garage will not
adversely affect the special historic character of the Mapleton Hill Historic
District, but that per the stated conditions the mass and scale of the proposed
garage should be reduced (see Design Guidelines Analysis section).
3. Is the architectural style, arrangement, texture, color, arrangement of color, and
materials used on existing and proposed structures compatible with the character of the
historic district?
Staff considers that provided the stated conditions are met, the proposed
materials proposed for the garage will be consistent with the character of the
contributing buildings on the property and the historic district as a whole.
4. Does the proposal to demolish the building within the Mapleton Hill Historic District
and the proposed new construction to replace the proposed demolished building meet the
requirements of paragraphs 9-11-18(b)(2) and (3) of this section?
Staff finds that, provided the listed conditions are met, the demolition of the
existing non-contributing garage and construction of a new accessory building
Agenda Item #5A Page 12
will not damage or destroy the character of contributing properties in the alley
scape and will be generally compatible and consistent with the General Design
Guidelines and the Mapleton Hill Historic District Guidelines, provided the mass
and scale of the new garage is reduced (see Design Guidelines Analysis section).
DESIGN GUIDELINES
While Section 9-11-18, B.R.C. 1981, sets forth the standards the Landmarks Board must
apply when reviewing a request for a Landmark Alteration Certificate, the Landmarks
Board has adopted the General Design Guidelines and Mapleton Hill Historic District
Design Guidelines to help interpret the ordinance for properties in this district. The
following is an analysis of the submitted proposal with respect to relevant guidelines. It
is important to emphasize that design guidelines are intended to be used as an aid to
appropriate exterior modifications and design, and not as a checklist of items for
compliance.
The following is an analysis of the proposal’s compliance with the applicable design
guidelines:
GENERAL DESIGN GUIDELINES FOR GARAGES & OTHER ACCESSORY BUILDINGS
2.3 Site Design: Alleys
The alleys in historic districts were traditionally used for secondary access to the houses, for
deliveries, and as storage places for horses and buggies, and later, for cars. A view of the backyards
from the alleys was maintained. While today’s alleys have evolved into use as pedestrian paths for
jogging, bicycling and dog walking, they still contribute to the historic character of the
neighborhood. They are typically minimally paved.
Along the alleys are historic accessory buildings of various shapes and sizes including barns,
chicken coops, sheds and small garages. This variety contributes to the general feeling of human
scale in the alleys.
Guidelines Analysis Conforms?
.1
Retain and preserve the variety and
character found in the existing historic
accessory buildings along the alleys.
The proposed 1979 garage
considered for demolition is not
part of the pre-1946 character of the
alleys in Mapleton Hill. However,
the adjacent pre-1931 accessory
building does contribute to the
historic character of the district and
is to be retained, thus preserving
the character of the alley.
The proposed new garage is shown
to feature a flat roof clad in
horizontal wood siding and wood
Yes
.2
Buildings that were constructed after the
period of significance but are still more
than 50 years old and contribute to the
variety and character of the alleyway
should be retained.
Yes
.3
The use of historically proportioned
materials for building new accessory
buildings contributes to the human scale
of the alleys. For example, narrower lap
siding and smaller brick are appropriate.
Yes
Agenda Item #5A Page 13
.4
Buildings that were constructed after the
period of significance but are still more
than 50 years old and contribute to the
variety and character of the alleyway
should be retained.
shingles similar to finish and
materials of the original house and
adjacent accessory building. Yes
.5
Maintain adequate spacing between
accessory building so that the view of the
main house is not obscured, and the alley
does not evolve into a tunnel-like
passage.
The proposed building spans 23’
wide across the 50’ wide lot while
the existing building is 20’ wide.
The existing distance between the
garage and historic accessory
building is 9’ while the proposed
design shows this distance reduced
to 6’. Consider reducing width and
mass of building to provide visual
permeability and avoid potential
tunnel-like effect on alley. Resolve
at Ldrc.
Maybe
7.0 Garages & Other Accessory Structures
Accessory buildings include barns, sheds, garages and outbuildings. Originally accessory structures
were used for storage of equipment, animals, or carriages. Generally, these structures have been
adapted for the storage of cars. In most cases, accessory building were located to the rear of the lot and
accessed by alleys. They were subordinate in size and detailing to the primary house. Over time they
have emerged as important elements of many lots and alleys in the district. Efforts should be made to
protect the eclectic character of alleys.
Both additions to existing accessory buildings and new accessory building will be evaluated in terms
of how they affect the historic character of the individual site and the district as a whole. In the past,
larger accessory structures have been allowed than may be appropriate today.
7.1 Existing Historic Accessory Buildings
A primary concern of the Landmarks Board in reviewing proposed changes in historic districts is the
protection of existing historic accessory structures and the character of the site and district.
GUIDELINES: ANALYSIS: CONFORMS
.1
Retain and preserve garages and accessory
buildings that contribute to the overall
character of the site or district. Existing historic accessory
building to be preserved.
See guideline 2.3.1 to 2.3.4
above.
Yes
.2
Retain and preserve the character-defining
materials, features, and architectural details of
historic garages and accessory buildings,
including roofs, exterior materials, windows
Yes
Agenda Item #5A Page 14
and doors.
.3
The use of historically proportioned materials
for building new accessory buildings
contributes to the human scale of the alleys. For
example, narrower lap siding and smaller brick
are appropriate.
Proposed materials will
contribute to the human scale of
the alley. See guideline 2.3.3
above.
Yes
.4
Buildings that were constructed after the period
of significance but are still more than 50 years
old and contribute to the variety and character
of the alleyway should be retained.
Staff considers the 1979 garage
to be non-contributing. See
guideline 2.3.1 to 2.3.4 above.
Yes
.5
Maintain adequate spacing between accessory
building so that the view of the main house is
not obscured, and the alley does not evolve into
a tunnel-like passage.
The proposed garage is 3’ wider
than the existing garage. See
guideline 2.3.5 above.
Maybe
7.2 New Accessory Buildings
New accessory buildings should follow the character and pattern of historic accessory buildings. While they
should take design cues from the primary buildings, they must be subordinate in size, massing, and
detailing. Alley buildings should maintain a scale that is pleasant to walk along and comfortable for
pedestrians.
Location and Orientation
.1
It is inappropriate to introduce a new garage
or accessory building if doing so will detract
from the overall historic character of the
principal building, and the site, or if it will
require removal of a significant historic
building element or site feature, such as a
mature tree.
Construction will not require the
removal of a significant historic site
feature. The alleys in the Mapleton Hill
Historic District are character defining
features of the district. Staff considers
that at 640 sq. ft., the mass, scale and
height of the proposed garage will
detract from the historic character of
the 900 block alley between Pine Street
and Mapleton Avenue. Staff considers
that the new construction should be
reduced in width to maintain open
character of this alley and permeability
into the property. Resolve at Ldrc.
No
.2
New garages and accessory buildings should
generally be located at the rear of the lot,
respecting the traditional relationship of such
buildings to the primary structure and the
site.
The new garage is to be located at rear
of the lot. Yes
.3
Maintain adequate spacing between accessory
buildings so alleys do not evolve into tunnel-
like passageways.
Staff considers the alley width of the
proposed garage should be reduced to
be more compatible with the historic
accessory building, to provide more
permeability into the property, and to
avoid a tunnel-like effect. Resolve at
Maybe
Agenda Item #5A Page 15
Ldrc
.4
Preserve a backyard area between the house
and the accessory buildings, maintaining the
general proportion of built mass to open space
found within the area.
Staff considers the general proportion
of built mass to open space found in
the area will be maintained with the
proposal.
Yes
Mass and Scale
.5
New accessory buildings should take design
cues from the primary building on the
property, but be subordinate to it in terms of
size and massing.
Staff considers that the new
construction will be generally
subordinate to the main house but
should be reduced in scale to be more
compatible with the 224 sq. ft.
contributing garage. See guideline
7.2.1 above. Resolve at Ldrc.
No
.6
New garages for single-family residences
should generally be one story tall and shelter
no more than two cars. In some cases, a two-
car garage may be inappropriate.
See guideline 7.2.5 above. No
.7 Roof form and pitch should be complementary
to the primary structure.
Roof form is flat and simpler than and
complementary to that of main house
and contributing accessory building.
Yes
Materials and Detailing
.8 Accessory structures should be simpler in
design and detail than the primary building.
Proposed garage is smaller and
simpler in design than the main house,
but significantly larger and taller than
the contributing accessory building.
See Guideline 7.2.3 above.
No
.9
Materials for new garages and accessory
structures should be compatible with those
found on the primary structure and in the
district. Vinyl siding and prefabricated
structures are inappropriate.
See guideline 2.3.3 above.
Yes
.10
Windows, like all elements of accessory
structures, should be simpler in detailing and
smaller in scale than similar elements on
primary structures.
Windows are shown to be simple in
design. Yes
.12
Garage doors should be consistent with the
historic scale and materials of traditional
accessory structures. Wood is the most
appropriate material and two smaller doors
may be more appropriate than one large door.
Simplify garage doors and consider
two separate doors. Resolve at Ldrc. Maybe
Agenda Item #5A Page 16
Mapleton Hill Historic District Guidelines
The following section is an analysis of the proposal relative to Section VI of the Mapleton
Hill Historic District Design Guidelines. Only those guidelines that further the analysis of
the proposed project are included and those that reflect what has been evaluated in the
previous section are not repeated.
D ALLEYS, EASEMENTS AND ACCESSWAYS
Alleys are a strong visual element of the district, and have much variety of scale and detail. They play
an important part in the development patterns that give the more visible areas their character. Alleys
provide access to rear parking and garages. They have a varied edge quality, with building both on the
property lines and set back. The size and quality of these accessory building varies considerably.
Careful consideration should be given to changes in traditional use.
Guideline Analysis Confor
ms?
1. The use of alleys to provide access to the
rear of properties should be preserved Access to rear of property preserved. Yes
2.
Efforts should be made to protect the
variety of shape, size, and alignment of
buildings along the alleys. Alleys should
maintain a human scale and be sensitive
to pedestrians.
The garage proposed for demolition is
significantly less than 50 years old and
staff considers it non-contributing to the
historic character and human scale of the
alley. However, alley width of proposed
building is shown to increase by 3’.
Consider reducing width of building on
alley to create more permeability. Resolve
at Ldrc.
No
3.
Building such as garages, sheds, etc.
which contribute to this variety should be
retained in their original form whenever
possible.
The 1979 garage proposed for demolition
does not contribute to the historic
character of the alley. The existing
accessory building is to be retained in its
historic form.
Yes
5. Efforts should be made to maintain
character of the alleys in the district
Staff considers that removal of the 1979
garage will not adversely affect the
historic character of the Mapleton Hill
Historic District but that the mass and
scale of the proposed new accessory
building should be reduced to be more in
scale with the contributing accessory
building, to create more permeability into
the property and avoid a tunnel like
effect on the alley. Resolve at the Ldrc.
Maybe
Agenda Item #5A Page 17
Staff considers that due to its 1979 date of construction (well outside of the 1865-1946
period of significance for the Mapleton Hill Historic District), and because the building
does not meet the definition of contributing as defined in the General Design Guidelines
the existing garage should be considered non-contributing. Staff considers that the
proposed demolition of the existing garage is consistent with the design guidelines for
site design and accessory buildings. Staff recommends the Landmarks Board approve
the Landmark Alteration Certificate request with the conditions outlined above to
reduce the mass and scale of the building to make it more in scale with the historically
contributing building, to maintain permeability into the historic property from the alley
and ensure that the alley does not become more “tunnel-like’ in character.
FINDINGS
Subject to the conditions stated in the recommended motion, staff recommends that the
Landmarks Board approve the application and adopt the following findings:
This decision is consistent with the purposes and standards of the Historic Preservation
Ordinance, in that:
1. The proposed demolition of the non-contributing garage will not
adversely affect the special character or special historic, architectural, or
aesthetic interest or value of the property or the historic district. § 9-11-
18(b)(2), B.R.C. 1981.
2. The proposed demolition will generally comply with Sections 2.3, Site Design, and
7.0, Garages and Other Accessory Buildings, of the General Design Guidelines;
Section S., Alleys, Easements and Accessways, of the Mapleton Hill Historic District
Guidelines; and Section 9-11-18(b)(3) of the Boulder Revised Code 1981.
ATTACHMENTS
A: Cultural Resource Re-evaluation Form: Accessory Building Survey
B: Building Permit Record: Construction of Garage, 1979.
C: Tax Assessor Card
D: Photographs
E: Demolition Plan
F. New Construction Plans
G. Renderings
Agenda Item #5A Page 18
Attachment A: Cultural Resource Re-evaluation Form: Accessory Building Survey
Agenda Item #5A Page 19
Agenda Item #5A Page 20
Agenda Item #5A Page 21
Accessory Building Survey Photograph, 2005.
Agenda Item #5A Page 22
Attachment B: Building Permit Record: Construction of Garage, 1979.
Agenda Item #5A Page 23
Agenda Item #5A Page 24
Attachment C: Tax Assessor’s Card
Agenda Item #5A Page 25
Agenda Item #5A Page 26
Assessor’s Card Photo, C. 1929
Assessor’s Card Photo, C. 1961
Agenda Item #5A Page 27
Attachment D: Photographs
911 Pine St. Front (South) Façade, 2016.
911 Pine St, Garage Proposed for Demolition, Northwest Corner, 2017.
Agenda Item #5A Page 28
911 Pine St., Accessory Buildings, South Elevations, 2017.
911 Pine St., Garage Proposed for Demolition, Southeast Corner, 2017.
Agenda Item #5A Page 29
911 Pine St., Accessory Building to Remain, Northwest Corner, 2017.
911 Pine St., Accessory Building to Remain, South Elevation, 2017.
Agenda Item #5A Page 30
Attachment E: Existing and Proposed Plans
Agenda Item #5A Page 31
Agenda Item #5A Page 32
Attachment G: Renderings
Agenda Item #5A Page 33