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Home My WebLink AboutAppeal Withdrawn - Franklin School Site - Conditional Use Pe 'GA152 C I Y OF HUNTINGTON BE A C H PA( .)9/17/93 09 : 38 M A T j* I A L REQUI S I T SP N FORM REQ NBR ACCOUNT #R-AA-7-01-00-CK-140 APPROVALS 2eiested by OFFICE OF THE CITY CLERK Accounting %pproved byX3:!yt_� Info System nor additional information call MAE Real Property Phone X5260 Administration DATE 12/15/95 VENDOR # Contact PO # Phone Number SUGGESTED VENDOR: SHIP TO: WESTMINSTER SCHOOL DISTRICT SAME 14121 CEDAR WOOD AVE. 00000-0000 WESTMINSTER, CA 97683 FOB? Delivery days Confirm? Freight? Terms Q\TY UNIT DESCRIPTION UNIT PRICE UNIT TOTAL ----- ---- ---------------------------------------- ------------ ------------- REFUND TO WESTMINSTER SCHOOL DISTRICT FOR APPEAL $1,200.00 FILED SEPTEMBER 1, 1995 REGARDING CONDITIONAL USE PERMIT NO. 95-26 Purchases of non-budgeted items will require the TAX approval as noted in the resolution which adopted the budget. Information Systems approval is .re- TOTAL $1,200.00 quired for all purchases of Data Processing hard- _____________ . Equipment replacement requisitions are to ccompanied by equipment report form. REQ NBR AMOUNT /REQ NBR AMOUNT REQ NBR AMOUNT 1 2 3 4 5 6 7 CASH RECEIPT Fen CITY of huNTiNGToN beAch 2000 MAIN STREET HUNTINGTON BEACH,CA 92648 HUNTINGTON BEACH r DATE ISSUING DEPT. Y TELE.# �" r 7 RECEIVED FROM > T vv.. Y� t e'r l!��qqd�G r_+ ADDRESS7. { E "f. I C f,:.��. fr I,t.1+'! _� l�✓ e ._ / rt. z - FOR � i - AMOIJN F I�ECEIVEQ (]CASH „ RECEIVED BY �14 f � EXPENSE; FINANCEAPPROVAL INITIAL TOTALS �? I I - 32'4 3a 1Siap95 oo l '12 $1200.00 RAA7010O�K 1+0 CAS 786580 ISSUING DEPARTMENT RECEIVED CITY OF HUNTINGTON 13EAd(4CL Y OFRn INTER-DEPARTMENT COMMUNICATMTINGTON BEACH,CALIF. HUNTINGTON BEACH DEC 4 4 02 Pik '95 TO: Connie Brockway, City Clerk FROM: Gail Hutton, City Attorney DATE: December 1, 1995 SUBJECT: Franklin School Site C.U.P. Application RLS 95-587 BACKGROUND The Westminster School District owns the closed Franklin School Site, which is within the City boundaries of Huntington Beach. The District applied for a conditional use permit to establish a church on the site. The Planning Commission denied the application. The District appealed the Planning Commission's decision to the City Council and paid the $1200 appeal fee. Prior to setting the appeal for a hearing, the District withdrew its entire application. ISSUES Whether the appeal fee should be refunded; whether this decision may be applied to other cases. ANSWER The appeal fee should be refunded. Each subsequent case must be analyzed separately, according to its own facts. ANALYSIS 1. Withdrawal of"Application" v. "Appeal" The zoning ordinance provides that in the event of an appeal, the "reviewing body shall hear the appeal as a new matter." (HBMC 248.20(D).) Thus, the code expressly declares that the appellate body shall hear the application de novo, or entirely new. G*Franklin\12/1/95 RLS 95-587 w a Connie Brockway December 1, 1995 Page 2 A normal withdrawal of an appeal results in the confirmation of the last action by the permitting agency. For example: A C.U.P. is granted by the Planning Commission and appealed to the City Council, and the appeal is withdrawn. The result is that the C.U.P. is issued as though no appeal was filed. In the present case, the Planning Commission denied the C.U.P., the applicant appealed, and then withdrew the entire application. Since the appeal resulted in de novo review by the City Council, and since the entire application was withdrawn while on appeal, the result is as if no application was ever filed. For purposes of re-application, the applicant can submit a similar application within one year without violating the code. (Cf. HBMC § 248.12.) 2. Refund of Fee The code requires that each appeal be accompanied by a fee for appeal. (HBMC § 248.26.) The fee is supposed to be applied to the cost of mailing labels and newspaper publication. In the present case, since no publication occurred, and no labels were prepared, a refund of the appeal fee is appropriate. 3. Subsequent cases. This analysis is factually specific and is limited to its own facts. Each subsequent case must be analyzed pursuant to its own facts, and a different result is possible depending on each individual factual scenario. Please contact me if you have any further questions. Gail Hutton City Attorney G:4:Frankl in\12/1/9 5 RLS 95-587 NOTICE OF PPEAL TO PLANNING COMMIPSION ACTION / OF 8/22/95 Date of Planning Commission Action TO: Planning Dept (2 copies) DATE: 9/1/95 City Attorney (l copy) FILED BY Westminster School District (Kenneth A. Fiolka) REGARDING: Denial of Conditional Use Permit No.. 95-26 Tentative Date for Public Hearing: ? Copy of Appeal Letter attached. LEGAL NOTICE AND A.P.MAILING LIST MUST BE RECEIVED IN THE CITY CLERK'S OFFICE 15 DAYS PRIOR TO THE PUBLIC HEARING DATE Connie Brockway City Clerk x5227 I9/1-al 7 95-587 Distribution: White: Requesting Department Yellow: Office Control File Pink: Assigned Staff Member REQUEST FOR LEGAL SERVICES FOLLOW-UP MEMORANDUM To: Connie From: Office of the City Attorney Subject : Your Request for Legal Services Date: 9/25/95 This will acknowledge receipt of your Request for Legal Services, below listed. Dated: c).122./95 Type of Legal Service Requested: [ ] Ordinance [ ] Insurance [ ] Resolution [ ] Bonds [ ] Contract/Agreement [ XX ] Opinion [ ] Other: Description: appeal to Planning Commission denial of CUP 95-26/95-3 ( ND) re Westminster School District and withdrawal of CUP - establishment of church at Franklin School site This Request for Legal Services has been assigned to PAUL D ' AL4SSANDRO for handling. He/she can be reached through extension 5555. The Control Number assigned to this request is: 95-587 Please reference this number when making any inquiries in regard to this matter. Thank you. 0673L i, CITY OF HUN TINGTON BEACH 2000 MAIN STREET CALIFORNIA 92648 OFFICE OF THE CITY CLERK CONNIE BROCKWAY CITY CLERK TO: Paul D'Alessondro, Deputy City Attorney FROM: Connie Brockway, City Clerk Of SUBJECT: Appeal to Planning Commission Denial of CUP 95-26 & ND 95-3 Communication from Westminster School District Re: Withdrawal of Application CUP 95-26 - Establishment of Church at Franklin School Site DATE: September 22, 1995 Please notify the City Clerk's Office of your decision regarding a refund of the appeal fee. If, as previously mentioned, the appellant is requesting to withdraw the application, not the appeal, the Clerk's office requires written direction on how to proceed as the letter states it is the intent to clear the record and to permit the school district to file a new application for similar use to avoid the necessity of waiting a year from the date of Planning Commission denial. I believe the $1,200 appeal fee should be refunded as money has not been expended for newspaper publication or notification to surrounding property owners. Please provide the City Clerk's Office with the opinion your office is currently preparing on this matter. Also, please include in your opinion as to whether the opinion regarding application withdrawal versus appeal withdrawal will apply to other submissions of appeals to the Council that are filed with the City Clerk's Office. Attachments: Communication from Gail Wickstrom, Ed.D, Westminster School District, dated 9/15/95 Communication from Kenneth A. Fiolka, Director, Facilities Planning, Westminster School District, dated 9/1/95 Petition with four signatures of persons expressing opposition to CUP No. 95-26 and Neg. Dec. No. 95-3, dated 9/95 cc: Gail Hutton, City Attorney Melanie Fallon, Community Development Director Mike Uberuaga, City Administrator g:\cbmemos\95cbmem\95-152cc (Telephone: 714-536-5227) 76b5-8o ("estminstez tchool 24strict l �. 14121 Cedarwood Avenue Westminster, CA 92683-4482 (714) 894-7311 superintendent: Gail Wickstrom, Ed.D September 1, 1995 x' Mr. Howard Zelefsky , Secretary, Planning Commission City of Huntington Beach P. O. Box 190 ci 6; Huntington Beach, CA 92648 Re: Appeal of Denial of Conditional Use Permit No. 95-26 The Westminster School District (District) is hereby giving notice of its intention to appeal to the City Council the August 22, 1995 decision by the Planning Commission to deny Conditional Use Permit No.95- 26/Negative Declaration No. 95-3. The District strongly disagrees with the three findings the Planning Commission detailed as reason for denial. These findings, set forth below, are responded to as follows: 1. "The establishment, maintenance and operation of the proposed church use with up to 600 members with services and Bible study every day of the week will be detrimental to the general welfare of persons working or residing in the vicinity and detrimental to the value of the property and improvements in the neighborhood. Access to the site is through narrow residential streets. The estimated number of trips generated by the proposed church exceeds the existing residential trips within the vicinity and the neighborhood. Adequate controls cannot be placed on the church to ensure that a variety of activities, e.g., weddings, summer camps, will protect the residential neighborhood from noise and traffic impacts." Response: Other churches in the area located in residential neighborhoods with little to no problems. The Westminster School District leased a school site in a residential area to Bethany Bible Fellowship for over ten years with no major concerns. The schools, at times, have summer camps and a variety of before- and after-school activities which impact the community with traffic. No concerns regarding the activities were ever received by the District. 2. "The proposed church with 600 seat sanctuary and auxiliary[sic]uses will be incompatible with the surrounding low density(Single Family Units) residential neighborhood. The proposed church with activities every day of the week on a proposed vacant public school site will create adverse traffic, circulation and noise impacts to the people living in the vicinity." Response:This is not a reasonable restriction on the 600-member congregation.The school could accommodate over 600 students and staff. The main use by the church would be on Sunday and during the week with much smaller groups (100-150) for Bible study and prayer meetings. 3. "The granting of the conditional use permit is not consistent with the Land Use Element of The Huntington Beach General Plan which recommends that institutional sites, such as a church, be located on an arterial highway. The local residential streets were not intended or designed to serve Board of Trustees: Nancy L. Blumenthal ♦ Lynn Covey ♦ Kathleen Iverson ♦ Sondra Rinker ♦ Michael Verrengia City of Huntington Beach Planning Commission Re: Appeal of Denial of Conditional Use Permit No. 95-26 September 1, 1995 Paae 2 as collector or arterial streets for accessing a church use. The proposed church is located within a residential neighborhood with access on local streets." Response: The Land Use Element of the Huntington Beach General Plan only recommends that churches be on arterial highways. Again, as stated in the Response to Item #1, above, churches have functioned well in a residential community. In addition, the District is appealing the City's staff recommendations as being unreasonable and unwarranted: 1. The Staff Report was received by the District the afternoon of the Planning Commission Hearing. This gave little to no opportunity for the District or the church to review or prepare comments. This also gave no time to contact all the parents who were in support of the church group. 2. The hour limitations are unreasonable. The school was in use much earlier than 6:00 A.M. and, at times, after 10:00 P.M. 3. It is unreasonable to want to review the activities of the church in six months. The church is planning to invest over$500,000 in refurbishments to the site. They do not need the possibility of losing their Conditional Use Permit over some minor details. 4. This has created a negative financial impact to the Westminster School District. Also, the comments made by some of the community members clearly expressed racial discrimination towards the Korean community. This type of behavior is totally unacceptable to the Westminster School District. The Westminster School District feels that the Korean Community Church will be a vital asset to the community. We are in hopes that this issue can be resolved to the mutual satisfaction of the Westminster School District, the Korean Church and the City of Huntington Beach. Very truly your , Kenneth A. Fiolka Director, Facilities Planning Westminster School District KF:bc Y-2 6 3a 7 Weilminster d5chool �Dislricl 14121 Cedarwood Avenue Westminster, CA 92683-4482 (714) 894-7311 Fax: (714) 898-8981 Superintendent: Gail Wickstrom, Ed.D September 15, 1995 X Ms. Connie Brockway City Clerk City of Huntington Beach 2000 Main Street Z" Huntington Beach, CA 92648 Dear Ms. Brockway, The Westminster School District hereby withdraws Conditional Use Permit No. 95-26, an application to establish a church at the Franklin School Site. The District no longer wishes to pursue this application since the Korean Church is no longer interested in establishing a church facility at this location. Our withdrawal of this application is intended to clear the record on this matter and thereby permit the School District to file a new application for a similar use if a suitable applicant is found. If you need additional information or further clarification of this request, please call me at your convenience. Sincer, ly, 'nc e, a kstro4, OEd.D Su eri tendent /if Board of Trustees: Nancy L. Blumenthal ♦ Lynn Covey ♦ Kathleen Iverson ♦ Sondra Rinker ♦ Michael Verrengia y OLL)- �- cop i (An�-Lr) VU CA Sol I Elm& Sep,_.ember, 1995 Gal Com unity Development Department ` � cn t. Cit-; of Huntington Beach Pla;-:ning Department r a - 'I 200.% Main Street "" `: '7,�• .HuriLington Beach, CA 92648 � r- Gen•.-_lemen: ' x +` a CONDITIONAL USE PERMIT NO. 95-26 NEGATIVE DECLARATION NO. 9 5-3 s a Thi:_J letter is forwarded to express .the opposition of neighboring xr pr.operty owners to the site usage to be allowed by Conditional Use Permit No. 95-26 . We believe significant changes must be made in -the proposed plan for the site. z �' .. As long time neighbors of the school site we have ongoing Con 7erns about how the proposed ` usage could adversely effect our `neighborhood. We recognize that the notice of the Draft Negative > ' " ': .•De.claration was published and that the review period has elapsed, _-'' hog;aver; we believe that the residents of our neighborhood- were:not. ade.�: � • quately notified of their opportunity to comment on the proposed usage. We believe that the significant change being proposed required that the residents should haye been directly contacted about the comment period. We ' J-ook forward to your response . C` CA a Sir.cerely, �r 6eat'l'u • J !t is J 7 IL {>: -- 6 9 8-70 1. {lVT53 2 Far \i' `- - -. f�� -, •- '. / �� / ` / ♦ I � ///'///J! C7114-) 893 -oZ4 Ct , d -44-JI 1 `►3 l 4�I. Q ob n�� } �� 4) $q3, 2 6,�j HEM °d s A QD IleaJ. S` � t - rsti7 a�i / ✓ VV no t : �cXa-7 RT { r 07 UZI �i - r { U- � nb ai a CITY OF HUNTINGTON BEACH 2000 MAIN STREET CALIFORNIA 92648 OFFICE OF THE CITY CLERK CONNIE BROCKWAY CITY CLERK TO: Paul D'Alessondro, Deputy City Attorney4/01 FROM: Connie Brockway, City Clerk LA SUBJECT: Appeal to Planning Commission Denial of CUP 95-26 & ND 95-3 Communication from Westminster School District Re: Withdrawal of Application CUP 95-26 - Establishment of Church at Franklin School Site DATE: September 22, 1995 Please notify the City Clerk's Office of your decision regarding a refund of the appeal fee. If, as previously mentioned, the appellant is requesting to withdraw the application, not the appeal, the Clerk's office requires written direction on how to proceed as the letter states it is the intent to clear the record and to permit the school district to file a new application for similar use to avoid the necessity of waiting a year from the date of Planning Commission denial. I believe the $1,200 appeal fee should be refunded as money has not been expended for newspaper publication or notification to surrounding property owners. Please provide the City Clerk's Office with the opinion your office is currently preparing on this matter. Also, please include in your opinion as to whether the opinion regarding application withdrawal versus appeal withdrawal will apply to other submissions of appeals to the Council that are filed with the City Clerk's Office. Attachments: Communication from Gail Wickstrom, Ed.D, Westminster School District, dated 9/15/95 Communication from Kenneth A. Fiolka, Director, Facilities Planning, Westminster School District, dated 9/1/95 Petition with four signatures of persons expressing opposition to CUP No. 95-26 and Neg. Dec. No. 95-3, dated 9/95 cc: Gail Hutton, City Attorney Melanie Fallon, Community Development Director Mike Ubefuaga, City Administrator g Ac bmemos\95�6bmeml95-152cc (Telephone:714-536-5227) QVestminster SYchool (2)istrict 14121 Cedarwood Avenue Westminster, CA 92683-4482 (714) 894-7311 �1 Fax: (714) 898-8981 Superintendent Gail Wickstrom, Ed D September 15, 1995 —v x +ram z Ms. Connie Brockway w ;" City Clerk City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Dear Ms. Brockway, The Westminster School District hereby withdraws Conditional Use Permit No. 95-26, an application to establish a church at the Franklin School Site. The District no longer wishes to pursue this application since the Korean Church is no longer interested in establishing a church facility at this location. Our withdrawal of this application is intended to clear the record on this matter and thereby permit the School District to file a new application for a similar use if a suitable applicant is found. If you need additional information or further clarification of this request, please call me at your convenience. Sincerely, C � aF kstrortli, Ed.D Su eri tendent 1 /jf Board of Trustees: Nancy L. Blumenthal ♦ Lynn Covey ♦ Kathleen Iverson ♦ Sondra Rinker ♦ Michael Verrengia • 7PCoS1d h �estminstez c�ioo1 strict 14121 Cedarwood Avenue t: Westminster, CA 92683-4482 (714) 894-7311 Superintendent: Gail Wickstrom. Ed.D September 1, 1995 c x c� J c..w rvr 90 er Mr. Howard Zelefsky �n 03 Secretary, Planning Commission `" 7 City of Huntington Beach -= P. O. Box 190 Huntington Beach, CA 92648 Re: Appeal of Denial of Conditional Use Permit No. 95-26 The Westminster School District (District) is hereby giving notice of its intention to appeal to the City Council the August 22, 1995 decision by the Planning Commission to deny Conditional-Use Permit No. 95- 26/Negative Declaration No. 95-3. The District strongly disagrees with the three findings the Planning Commission detailed as reason for denial. These findings, set forth below, are responded to as follows: 1. "The establishment, maintenance and operation of the proposed church use with up to 600 members with services and Bible study every day of the week will be detrimental to the general welfare of persons working or residing in the vicinity and detrimental to the value of the property and improvements in the neighborhood. Access to the site is through narrow residential streets. The estimated number of trips generated by the proposed church exceeds the existing residential trips within the vicinity and the neighborhood. Adequate controls cannot be placed on the church to ensure that a variety of activities, e.g., weddings, summer camps, will protect the residential neighborhood from noise and traffic impacts." Resoonse: Other churches in the area located in residential neighborhoods with little to no problems. The Westminster School District leased a school site in a residential area to Bethany Bible Fellowship for over ten years with no major concerns. The schools, at times, have summer camps and a variety of before- and after-school activities which impact the community with traffic. No concerns regarding the activities were ever received by the District. 2. "The proposed church with 600 seat sanctuary and auxiliary[sic]uses will be incompatible with the surrounding low density (Single Family Units) residential neighborhood. The proposed church with activities every day of the week on a proposed vacant public school site will create adverse traffic, circulation and noise impacts to the people living in the vicinity." Response:This is not a reasonable restriction on the 600-member congregation. The school could accommodate over 600 students and staff. The main use by the church would be on Sunday and during the week with much smaller groups (100-150) for Bible study and prayer meetings. 3. "The granting of the conditional use permit is not consistent with the Land Use Element of The Huntington Beach General Plan which recommends that institutional sites, such as a church, be located on an arterial highway. The local residential streets were not intended or designed to serve I Board of Trustees: Nancy L. Blumenthal ♦ Lynn Covey ♦ Kathleen Iverson ♦ Sondra Rinker ♦ Michael Verrengia • i City of Huntington Beach Planning Commission Re: Appeal of Denial of Conditional Use Permit No. 95-26 September 1, 1995 Paoe 2 as collector or arterial streets for accessing a church use. The proposed church is located within a residential neighborhood with access on local streets." Resoonse: The Land Use Element of the Huntington Beach General Plan only recommends that churches be on arterial highways. Again, as stated in the Response to Item #1, above, churches have functioned well in a residential community. In addition, the District is appealing the City's staff recommendations as being unreasonable and unwarranted: 1. The Staff Report was received by the District the afternoon of the Planning Commission Hearing. This gave little to no opportunity for the District or the church to review or prepare comments.This also gave no time to contact all the parents who were in support of the church group. 2. The hour limitations are unreasonable. The school was in use much earlier than 6:00 A.M. and, at times, after 10:00 P.M. 3. It is unreasonable to want to review the activities of the church in six months. The church is planning to invest over$500,000 in refurbishments to the site. They do not need the possibility of losing their Conditional Use Permit over some minor details. 4. This has created a negative financial impact to the Westminster School District. Also, the comments made by some of the community members clearly expressed racial discrimination towards the Korean community. This type of behavior is totally unacceptable to the Westminster School District. The Westminster School District feels that the Korean Community Church will be a vital asset to the community. We are in hopes that this issue can be resolved to the mutual satisfaction of the Westminster School District, the Korean Church and the City of Huntington Beach. Very truly your$, Kenneth A. Fiolka Director, Facilities Planning Westminster School District KF:bc City of Huntington Beach Planning Commission Re: Appeal of Denial of Conditional Use Permit No. 95-26 September 1, 1995 Paae 2 as collector or arterial streets for accessing a church use. The proposed church is located within a residential neighborhood with access on local streets." Response: The Land Use Element of the Huntington Beach General Plan only recommends that churches be on arterial highways. Again, as stated in the Response to Item #1, above, churches have functioned well in a residential community. In addition, the District is appealing the City's staff recommendations as being unreasonable and unwarranted: 1. The Staff Report was received by the District the afternoon of the Planning Commission Hearing. This gave little to no opportunity for the District or the church to review or prepare comments.This also gave no time to contact all the parents who were in support of the church group. 2. The hour limitations are unreasonable. The school was in use much earlier than 6:00 A.M. and, at times, after 10:00 P.M. 3. It is unreasonable to want to review the activities of the church in six months. The church is planning to invest over$500,000 in refurbishments to the site. They do not need the possibility of losing their Conditional Use Permit over some minor details. 4. This has created a negative financial impact to the Westminster School District. Also, the comments made by some of the community members clearly expressed racial discrimination towards the Korean community. This type of behavior is totally unacceptable to the Westminster School District. The Westminster School District feels that the Korean Community Church will be a vital asset to the community. We are in hopes that this issue can be resolved to the mutual satisfaction of the Westminster School District, the Korean Church and the City of Huntington Beach. Very truly your$, Kenneth A. Fiolka Director, Facilities Planning Westminster School District KF:bc RECEIVED CITY CLERK C11Y 3F HUNTINGTON %icACH,Z'LIF. SEP 22 2 24 PV1 `99 September, 1995 Community Development Department. City of Huntington Beach Planning Department 2000 Main Street Huntington Beach, CA 92648 Gentlemen: CONDITIONAL USE PERMIT NO. 95-26 NEGATIVE DECLARATION NO. 95-3 This letter is forwarded to express the opposition of neighboring property owners to the site usage to be allowed by Conditional Use Permit No . 95-26 . We believe significant changes must be made in the proposed plan for the sit.e . As long time neighbors of the school site we have ongoing concerns about how the proposed usage could adversely effect our neighborhood. We recognize that the notice of the Draft Negative Declaration was published and that the review period has elapsed, however; we believe that the residents of our neighborhood were not adequately notified of their opportunity to comment on the proposed usage . We believe that the significant change being proposed required that the residents should have been directly contacted about the comment period. We look forward to your response . Sincerely, r ,35 2 Try �caoz-L Y, 14,-B 1�34� ro I C �, A- n - C-r i4) co 1'f -7 ------- ' zzo illm RECEIVED CITY CLERK HUNTINGTt`N a-�r,�-; C.•`•�:f. SEP ZZ Z 25 September, 1995 Community Development Department City of Huntington Beach Planning Department 2000 Main Street Huntington Beach, CA 92648 Gentlemen: CONDITIONAL USE PERMIT NO. 95-26 NEGATIVE DECLARATION NO. 95-3 This letter is forwarded to express the opposition of neighboring property owners to the site usage to be allowed by Conditional Use Permit No . 95-26 . We believe significant changes must be made in the proposed plan for the site . As long time neighbors of the school site we have ongoing concerns about how the proposed usage could adversely effect our neighborhood. We recognize that the notice of the Draft Negative Declaration was published and that the review period has elapsed, however; we believe that the residents of our neighborhood were not adequately notified of their opportunity to comment on the proposed usage . We believe that the significant change being proposed required that the residents should have been directly contacted about the comment period. We look forward to your response . Sincerely, 1 C) , C.,�� 3 a(,t,r a �� 11,�n �e ( n 15, 1435 2 Try � ao a Lary 14"B I�{3 4� ►KID � I C 4-/--) A- �--n C-714 92ZO//,u 0 /'eo /�,7 7� C-)-4� 4ZZZ A, �Z, 7 -21 Z7 / -3Q � ��