EXECUTIVE SUMMARY. April 17, Thor Kaslofsky Common Ground Urban Development

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1 April 17, 2017 TO: Thor Kaslofsky Common Ground Urban Development CC: Alexis Pelosi Pelosi Law Group 560 Mission Street, Suite 2800 San Francisco, CA SUBJECT: 1850 Bryant Shadow Analysis EXECUTIVE SUMMARY CADP has conducted an analysis of the impact on Franklin Square Park of new shadows that would be generated by the construction of a proposed five-story, sixty-eight-foot-tall building located at 1850 Bryant Street in the Mission District neighborhood of San Francisco. This memorandum details the results of that study per the criteria established by Planning Commission and the Recreation and Park Commission to implement the voter-approved Proposition K, the Sunlight Ordinance, codified as Section 295 of the Planning Code. CADP s study found that the proposed project would cast new shadow on Franklin Square park, and that new shadow would represent an increase of.01011% in annual square-foothours (sfh) of shadow as a percentage of available sunlight. The current percentage of annual shadow coverage is % and, with the addition of proposed project, would result in a new total annual shading on Franklin Square Park of %. The new shadow generated by the proposed project would fall on Franklin Square Park in the afternoon hours only from approximately October 18 st until February22 th, with new shadows falling generally in the southwest portion of the park. New shadows would be cast on the southern pathway near the play area and a small portion of the southernmost softscape play area, for no more than 15 minutes at the end of the day. 1

2 I. INTRODUCTION AND OVERVIEW The project sponsor is proposing to construct a five-story, 68-foot tall building at 1850 Bryant Street in San Francisco. The Planning Department prepared an initial shadow fan that indicated the proposed project may cast a shadow on Franklin Square, a property under the jurisdiction of the Recreation and Park Department. Under Planning Code Section 295, a shadow analysis is required to measure and quantify any potential shadow impact of the proposed development on Franklin Square given that the proposed building is over 40 feet in height, and given that Franklin Square is within the jurisdiction of the San Francisco Recreation and Park Commission. The project sponsor has retained CADP to perform the shadow analysis. The proposed project is the construction of a new 5-story, 68-foot-tall, 223,050 gross square foot building that would be used primarily by social service and philanthropic organizations. The project sponsor is 1850 Bryant Land, LLC, and Common Ground Urban Development, LLC, is the project sponsor s representative. The project architect is BDE Architecture. This memorandum presents and evaluates the results of the shadow analysis pursuant to the criteria described in the San Francisco Recreation and Park Department and San Francisco Planning Department s 1989 joint memorandum, Section 295 The Sunlight Ordinance, as well as the Planning Department s Shadow Analysis Procedures and Scope Requirements (2014). This technical memorandum includes a discussion of the proposed project, the affected open space (Franklin Square), as well as a quantitative and qualitative reporting of the new shading generated by the proposed project. II. PROPOSED PROJECT Site Description and Existing Use The proposed project site is located at 1850 Bryant Street in San Francisco, California (Assessor s Block 3970, Lot 006). The site is bounded to the east by Bryant Street, the south by Mariposa Street, to the west by Florida Street, and to the north by 17 th Street. The lot is approximately 36,500 square feet with a foot frontage along both Bryant and Florida Streets. The current site is developed with a 2 story, 13,900 square foot building used for offices and storage by an electrical contractor. The remainder of the lot is used for parking, and outdoor storage. Surrounding Properties and Neighborhood The project site is adjacent to a 48 unit live-work building to the north and a commercial office/art studio building to the south. To the west, across Florida Street is an art 2

3 gallery/performing arts building, and to the west, across Bryant Street is a Muni bus storage yards. Other existing development in the area consists primarily of light industrial and commercial uses, with some residential uses existing a block away on Bryant Street between 16 th and 17 th Street. Franklin Square is immediately to the east of these residential uses, approximately a half-block from the project site. No other open space, community gardens or other types of outdoor community-serving facilities are located in the immediate project vicinity. Project Description The project proposes to demolish the existing structures on the site and construct an approximately 223,050 gross square foot (gsf) mixed-use development containing 166,728 gsf of social service uses, 18,407 gsf of PDR uses, 2,281 gsf of retail uses and 92 off-street vehicle parking spaces. The project also includes a 2,280 gsf interior courtyard and a 16,934 gsf roof deck. The proposed project is 68-0 feet measured from benchmark point elevation at Bryant Street of feet above mean sea level (msl) to top of roof at elevation feet msl plus a 4 to 8 foot parapet at perimeter above the roof and a 14 foot penthouse enclosure in the middle of the structure above the roof. The proposed project was modeled based on the building, parapet, and penthouse enclosure dimensions identified on the elevations and roof plan attached Exhibit A. Because the project proposes a structure greater than 40 feet in height, a shadow analysis under Proposition K is required. III. POTENTIALLY AFFECTED OPEN SPACE As part of its response to the Preliminary Project Assessment application for the Project, the Planning Department prepared a preliminary shadow fan analysis, which indicated that the Project could cast shadows on Franklin Square park, which is under the jurisdiction of the Recreation and Park Department. Franklin Square Franklin Square is a acre park located in the Mission neighborhood, near the boundaries of the South of Market Area (SoMa) and the Potrero Hill neighborhood. Franklin Square is bounded by 16th Street to the north, 17th Street to the south and Bryant Street to the west. The park is bounded to the east by Hampshire Street and Assessor s Block 3962, Lots 012, and The dimensions of Franklin Square are based on the most recent GIS data and park boundaries supplied by the City. 3

4 Figure 1 Franklin Square Existing land uses surrounding Franklin Square include the Potrero Shopping Center to the north, the Muni Metro facility to the south, commercial uses to the east, and a mix of residential and retail/commercial uses to the west. The height limits surrounding Franklin Square vary from 85 feet to the north, 65 feet to the south, 65 to 68 feet to the east, and 58 to 85 feet to the west. Franklin Square includes a regulation size soccer field with synthetic turf and a playground at the southwest corner. The park includes a pedestrian pathway that circles the soccer field and provides access to the playground and open spaces. Mature trees that vary in height from approximately 10 to 30 feet exist along the perimeter of the park. Franklin Square is separated from the surrounding right-of-way by an embankment. The usable surface areas of Franklin Square are approximately 5 to 15+ feet higher than the adjacent public sidewalk with the greatest height differential located along 16th Street. Over the past ten years, there have been several significant improvements to Franklin Square. In 2004, the Recreation and Park Department completed a rehabilitation of Franklin Square Field that included installation of an artificial turf surface and related improvements. In 2008, partnering with the City Fields Foundation, the Recreation and Park Department added lights to Franklin Square s synthetic turf field. In 2009, the Recreation and Park Department completed an expanded children s play area. The playground area includes a sand play area, climbing structures, swings, a merry-go-round, slides, and a rubberized play surface. In 2016, Franklin was improved with a renovation of 4

5 the athletic field, the installation of an outdoor adult workout center, and the installation of lighting along the western edge of the park. We are unaware of any additional improvements currently planned for Franklin Square. The stated park hours are from 5:00 a.m. to midnight. The field can be used until 10:15 p.m., after which the lights are turned off, which limits the use of the field. A fence surrounds the field, but there are no gates on site restricting access to the park. All park hours are enforced by Park Patrol. IV. PLANNING CODE SECTION 295 Planning Code Section 295 was adopted in 1985 in response to voter-approved Proposition K which required Planning Commission disapproval of any structure greater than 40 feet in height that cast a shadow on property under the jurisdiction of the Recreation and Park Department, unless the Planning Commission found the shadow would not be significant. To implement Planning Code Section 295 and Proposition K, the Planning Commission and Recreation and Park Commission in 1989 jointly adopted a memorandum establishing qualitative criteria for evaluating shadow impacts as well as Absolute Cumulative Limits ( ACL ) for certain parks. ACLs are shadow budgets that establish absolute cumulative limits for additional shadows expressed as a percentage of Theoretically Available Annual Sunlight ( TAAS ) on a park with no adjacent structures present. To date, ACL standards have been established for fourteen (14) downtown parks. An ACL standard has not been adopted for Franklin Square. The 1989 Memorandum sets forth qualitative criteria to determine when a shadow would be significant as well as information on how to quantitatively measure shadow impact. Qualitatively, shadow impacts are evaluated based on (1) existing shadow profiles, (2) important times of day, (3) important seasons in the year, (4) location of the new shadow, (5) size and duration of new shadows, and (6) public good served by buildings casting a new shadow. Quantitatively, new shadows are to be measured by the additional annual amount of shadow-square foot-hours as a percent of TAAS. Where an ACL has not been adopted for a park, the Planning Commission s decision on whether a structure has a significant impact on property under the jurisdiction of the Recreation and Park Department is based on a review of qualitative and quantitative factors. V. SHADOW METHODOLOGY AND RESULTS CADP prepared a shadow analysis to quantify the amount of new shadow that would be cast by the proposed project on Franklin Square. The analysis was conducted based on a solar year to provide a sample of representative sun angles throughout the entire calendar year. The solar year is from June 21 st through December 20 th. The sun angles during the other side of the calendar year, or December 21 st through June 20 th, mirror the solar year sun angles. Since the angles are mirrored, an analysis of the other time period is not conducted and, instead, a multiplier is used to put the sample results into calendar year 5

6 units. Using a multiplier does not change the percentages. For purposes of this report, a table of shadow impact results and dates has been prepared and is attached as Exhibit B. Where a particular date is identified in this report, the mirror date is also noted in italics. For purposes of the analysis, time was measured in decimal hours at 15 minute intervals from sunrise plus 1 hour to sunset minus 1 hour. Franklin Square has 719,447, square feet hours of Theoretically Available Annual Sunlight ( TAAS ), which is the amount of theoretically available sunlight on the park, annually, if there were no shadows from structures, trees, or other facilities. Shadows currently exist on Franklin Square, predominately in the morning and evening hours. The existing shadow load for Franklin Square is 9,624, square foot hours annually. 2 This is % of the total TAAS for Franklin Square. The proposed project would add 72, new square foot hours of shadow on the park. This is a % increase in shadow as a percentage of TAAS. A summary of the findings of the shadow analysis is provided below. The complete set of graphical depictions of the shadow on an hourly basis from sunrise +1 hour until sunset -1 for four days; the Summer Solstice (June 21 st ), the Winter Solstice (December 21 st ) and the Spring/Fall Equinox (March 21/September 21), are attached to this report at Exhibit C. The complete data findings are provided under separate cover. 3 Summary of Results Annualized net new shadow 72, Annual Available Sunlight (TAAS), based on City's AAS Factor 719,447, Annual Shadow Increase as a Percentage of AAS % For the purposes of the Section 295 analysis, shadow impacts are calculated based on square foot hours recorded. To ensure a complete and accurate description of the proposed project s potential shadow impacts, this analysis identifies the days when the shadow cast by the proposed project: (1) would be at its largest size by area, and (2) would result in the overall greatest shadow impact in terms of size and duration (i.e., the maximum net new shadow as measured in shadow foot hours). The worst day is the day with the maximum net new shadow. The maximum net new shadow or worst shadow day 4 would occur on December 20 th (See Figures 2a -2c and Exhibit C.) On Dec 20 th, the proposed project would cast new shadow on Franklin Square from 2:45 PM until sunset -1 hour. The new shadow load on Franklin Square 2 This figure differs from previous shadow analyses prepared for Franklin Square as a result of updated park boundaries and enhanced shadow modeling software and programming that more precisely maps and accounts for grade changes and baseline height differentials, both of which can significantly impact shadow. 3 A copy of the graphics and data findings is available for review at the San Francisco Planning Department, 1650 Mission Street, Suite 400, as part of Case File No SHD. 4 The worst shadow day is the day where the shadow fan and duration would result in the longest shading of Franklin Square by the proposed project. 6

7 would be 1, square foot hours and the new shadow area at its maximum would be 4, square feet. The greatest amount of new square foot hours at a single time would occur on December 20 th at 3:45, and the largest new shadow by area (4, square feet) would also occur on December 20 th, at 3:54 p.m. (See Figure 2b, 2c and Exhibit C). Date + Time Duration Total/Day ExSF ExSfHr NewSF NewSFHr NewSFHR/Day :45: :00:00 1, :15:00 3, :30:00 6, , , :45:00 13, , , :54:36 1:17:24 19, , , , As shown in Figures 2a,2b, 2c and Exhibit C, the proposed project would increase the shadow load on Franklin Square during times when the park is already shadowed from existing structures. New shadows cast would occur during the afternoon starting no earlier than 2:45 p.m., and last for no longer than approximately 1 hour 17 minutes on the worst shadow day, and in in all instances would be gone by 4:15 p.m. Because the proposed project would cast new shadow on Franklin Square, under Planning Code Section 295, the Planning Commission can only approve the structure if it finds that the net new shadow is not significant. The 1989 Memorandum sets forth quantitative and qualitative criteria to assist the Planning Commission in reaching their determination as to whether the net new shadow is significant. The quantitative and qualitative criteria are described below. Quantitative Criteria Size of Park The 1989 Memorandum set forth different recommendations for permitted additional shadow load based on the size of the park. Parks greater than two acres are considered larger parks. Franklin Square is 4.44 acres, and this is considered a larger park. Existing Annual Available Sunlight Existing Shadow Profiles Based on the City s TAAS, the park has 719,447, square-foot-hours of sunlight available annually. Under existing conditions, Franklin Square is being shaded % percent of the time and has an existing shadow load of 9,624, square foot hours. These figures for TAAS and existing shadow load differ from previous shadow analyses prepared for Franklin Square as a result of updated park boundaries and enhanced shadow 7

8 modeling software and programming that more precisely maps and accounts for grade changes and baseline height differentials, both of which can significantly impact shadow. The existing shadows are created primarily by three structures located to the east of the park. The 4-story structure facing 16 th Street casting the largest shadow on the park. The 2- story structure facing 17 th Street also casts a shadow, but it is smaller given the lower height of that structure. The recently constructed 9-story residential structure facing Potrero Avenue between 16 th and 17 th Street also cast a small shadow in the morning before 10 a.m. Afternoon shadow profiles are cast by the 2- to 3-story retail, commercial and residential structures located along Bryant Street to the west of Franklin Square. In December, an afternoon shadow is also cast by the 3-story structure located on the north-east corner of Franklin Square across Bryant and 16 th Street. The existing total shadow load on the park used for purposes of the baseline analysis does not include the one recently approved project that will shadow the park. Other than this project, there are no other approved or known proposed project that would create additional shadow on Franklin Square: th Street: This project was approved in June 2016, and is not yet under construction. As noted in its shadow study, the new shadow cast by this project would occur during the afternoon hours, and be limited to a small area in the northwest section of the park. The new shadow would not each the playground area at any time of the year, but would shade some of the open space areas along the pedestrian pathway. Based on the prior park boundary, the shadow study concluded that the project would increase shadow on the park by %. 5 5 Although the 16 th Street project is not yet completed, the shadow that will be created by the project is shown on the set of graphics included as Exhibit C. 8

9 Proposed Annual Available Sunlight The proposed project would reduce the annual available sunlight on Franklin Square by percent. This is a 72, square foot hour reduction of sunlight resulting in a total shadow load on the park of 9,697, square foot hours. The proposed project would result in a total shadow load on the park of percent. These findings are presented in Table 1 below, and summarized in Exhibit B. A complete copy of the findings is included under separate cover. 6 Table 1. SHADOW on FRANKLIN SQUARE Available Existing Shadow New Shadow TOTAL SHADOW SQ. FT. HOURS 719,447, ,624,699,.08 72, ,697, PERCENT Recommended Permitted Additional Shadow The 1989 Memorandum sets potential tolerance levels for increases in shadows levels. For larger parks greater than two acres that are shadowed less than 20% of the time during the year (such as Franklin Square) an additional 1.0% of shadow is potentially permissible, if the specific shadow meets certain additional qualitative criteria. Qualitative Criteria Time of Day (morning, mid-day, afternoon) Important Times of Day The proposed project would cast a shadow on Franklin Square in the afternoon. The shadow would begin, at the earliest, around 2:45 p.m., and would be gone by 5:00 p.m. The range of times when the shadow would begin would be at 2:45 (occurs on December 13 th /December 27 th, and December 20 th ) to 5:00 p.m. (occurs on October 18/ February 22 th ). According to the Recreation and Park Department, reservations for Franklin Square soccer field are taken from 8 a.m. until 10 p.m. daily. Park and field maintenance typically occurs in the morning and custodial maintenance typically occurs in the late afternoon or evenings. 7 The stated park hours are 5:00 a.m. to midnight. Franklin Square is an active recreation park with a regulation size soccer field, pedestrian pathways, a recently renovated playground, and corresponding open space and seating 6 A copy of the data findings is available for review at the San Francisco Planning Department, 1650 Mission Street, Suite 400, as part of Case File No SHD 7 Recreation and Park Department, personal communication with Adam Noble, CADP on November 14, 2013, and electronic correspondence between Kei Zushi, San Francisco Planning Department, and Meghan Hade, Recreation and Park Department on January 17,

10 areas. Because a majority of the park is dedicated to an athletic field, the most important times of the day are likely to be when the field is in use. Because of work and school schedules, during the week the most important times of day are likely to afternoons or after school/work when organized activities are most likely to occur (i.e., soccer games and practices). On weekends, because the field is available for reservations from 8:00 a.m. till 10:00 p.m. there is no particular most important time. A survey of park activity from 2:00 to 5:00 PM on September 11, 2016, revealed between 2 and 5 adults and between 2 and 9 children under 12 using the playground and area surrounding the playground. 8 An additional survey of park activity during the same time of day on December 20, 2016 revealed between 2 and 3 adults and between 2 and 6 children under 12 using the playground and area surrounding the playground. 9 Time of Year (Spring, Summer, Fall, Winter) Important Times of Year The proposed project casts a shadow on Franklin Square only during the Fall and Winter months, from October 18 until February 22). 10 The largest shadow cast by area is on December 20 th at Sunset -1 hour (approximately 3:54 PM). (See Figure 1 below). The worst shadow day in terms of size and duration is also December 20 th. According to the Recreation and Park Department, the regulation size soccer field at Franklin Square has a consistent demand throughout the year with a slightly lower demand in summer due to the City-wide prevalence of summer camps. 11 Summer camps tend not to use Franklin Square because it does not have restrooms. San Francisco has a temperate climate that allows recreational spaces to be used year round. The synthetic turf and enhanced drainage on the Franklin Square field allow it to be used even in the winter months and Franklin Square does not close due to rain. Based on San Francisco s historic weather patterns, the important times of year for Franklin Square, when individuals are most likely to use the park, are Spring and Fall which historically have the most sunshine and the lowest levels of rain and/or fog. Size of Shadow The largest shadow cast by the proposed project on Franklin Square is 4, square feet on December 20 th at Sunset -1 hour (3:54 p.m.) At that time, the shadow potentially cast from the project shades approximately 2.13 percent of the overall square footage of Franklin Square. 8 Because the project will only cast new shadow in the afternoon, only a survey of afternoon park activity was conducted. 9 See Exhibit D for a more detailed summary of park activity during these times/days. 10 As noted above under Shadow Methodology, the shadow analysis was based on a solar year using a multiplier to place the results into calendar year units. 11 Recreation and Park Department, personal communication with Adam Noble, CADP on November 14,

11 Duration of Shadow The shadow from the proposed project would occur in the afternoon starting 2:45 p.m. and continues for approximately 1 hour 17 minutes. The average duration of the shadow would be 42 minutes with the range of duration from approximately 2 minutes (occurs on October 25/February 1 ) to approximately 1 hour 17 minutes (occurs on December 20 th ). Location of Shadow The new shadow cast by the proposed project would be located on the southwest edge of Franklin Square. During afternoons in the late fall until the early winter, the shadow would move across the park at an angle from west to east, as shown in the Figures 2a and 2b below. On December 21st at Sunset -1 hour (3:54 p.m.), the proposed project casts the largest shadow by area on Franklin Square. At that time, the shadow would end before covering more than 15 percent of the overall play area, shading not more than 2 percent of the park. (See Figure 2b.) The project would not create new shadow on the soccer field, but would shade the southern pathway near the play area and for a short period of time (last 13 minutes of the day) a portion of the southernmost softscape play area, which includes the small merry-go-round. The new shadow would not reach to most of the main play structures and areas, the slide structure or the softscape area surrounding it, the sand play area, the climbing animals, or swing set structures. (See Figure 2c.) 11

12 Figure 2a Net New Shadow on Franklin Square December 21 at 3:00 pm. Figure 2b Maximum Net Shadow by square foot on Franklin Square December 21 Sunset -1 hour. 12

13 Figure 2c Maximum Net Shadow on December 21 Sunset -1 hour (Zoomed). Zero Shadow Alternative The project sponsor has evaluated potential modifications to the project that would result in a building that would contribute zero net new shadow on Franklin Square. Such modifications would be significant, substantially limiting to the viability of the project. To avoid casting any shadow on the park the building would need to be reduced by one full story along Bryant St, which would represent the loss of approximately 16,900 sq ft if the top floor were removed in its entirety. Pushing the entire top floor of the building back away from Bryant street would encroach upon the code allowed height of the building as measured from Florida Street (which is at a significantly lower elevation than Bryant Street). If the top floor of the Bryant street façade were to be set back approximately 20 feet to avoid casting a shadow this would represent the loss of approximately 3,750 sq ft, but also greatly increase the complexity of the building structure. Both options represent significant impacts to the buildings design and fiscal viability. Proposed Project Related Public Good and Public Outreach In order to fully evaluate the potential impacts associated with the proposed project, decision-makers weigh the amount and duration of shadow cast by the proposed project against the public good or public benefits associated with the proposed project. Factors to consider under this criterion are (1) the public interest in terms of a needed use, (2) building design and urban form, (3) impact fees, and (4) other public benefits. 13

14 Project Benefits The project intends to create approximately 157,000 feet of commercial space for both much needed social services and production distribution and repair (PDR) businesses. It is anticipated that the project will generate up to approximately $4,000,000 in City impact fees between the Eastern Neighborhoods Impact Fees, the Transit Sustainability Fee, and the San Francisco Unified School District Fees. The Eastern Neighborhoods Impact Fees will be used within the Eastern Neighborhoods geography to fund improvements to libraries, transit, parks, and childcare services/facilities. The proposed project will be of the size and scale of the surrounding industrial and warehouse buildings. The building will be five-stories standing at 168 feet high and goes through the block from Bryant Street to Florida Street. and is located between Mariposa and 17th Street. New street trees will be planted per the Planning Code s Mission Area Plan and the Better Streets Guidelines to enhance the pedestrian environment. The project also proposes to have approximately 2,500 square feet of retail and gallery space fronting Bryant Street to activate and enliven the streetscape. The project will be working with the adjacent park affinity group, Friends of the Franklin Square Park to provide support to their efforts to maintain and improve Franklin Square Park. The project could also help mitigate the displacement of nonprofits from San Francisco due to rapidly escalating rents by providing them with ownership opportunities within the building. The development of the building intends to be financed with innovative alternative financing such as tax credits and grants to put ownership within reach of the nonprofits. Finally, to provide additional financial stability to the building s nonprofits the building will feature shared services, further reducing overhead costs and deepening programmatic collaboration within the building. See Exhibit E for more on this aspect of the building/project s program. Public Outreach The project sponsor s outreach for the project is on-going, but to date the project team has hosted a series of public meetings, as well as several other meetings with neighborhood groups and organizations. These meetings include the following October 13 th, Pre-Application Public/Community Meeting. March 21 st, Neighborhood Meeting. The purpose of the Neighborhood meeting was to update the community about the project plans, status of the project, address community concerns, and receive feedback about the streetscape designs for the project. Two major topics were discussed. The first was collaborating with neighbors at 450 Florida Street and 1800 and 1890 Bryant Street on streetscape improvements. The second was whether 14

15 palm trees could be included in the streetscape. The landscape architects are currently determining the feasibility of palm trees in the project and the project sponsor has reached out to the neighbors regarding collaborating on streetscape design. Both these meetings were held across the street from the project site at Z-Space and were attended by approximately people. Notices of the meeting were sent to all properties within a 300 foot radius from the project site. The project sponsor has also met with the boards of both adjacent properties 1800 and 1890 Bryant, as well as numerous other neighborhood meetings. In all, there have been more than 20 large, small, and 1 on 1 meetings, including meetings with Supervisor Malia Cohen and Supervisor Hilary Ronen. Finally, the project sponsor has also met with the Friends of Franklin Square Park, and agreed to provide support to help maintain and improve the park. Specifically, the project sponsor has agreed to (1) contribute $50,000 to help fund maintenance and improvements at Franklin Square; and (2) help organize volunteers to provide over 400 hours of community service toward the clean-up and maintenance of Franklin Square Park, as a part of minimum of two (2) park clean-up days per year during construction during construction of the project. This commitment is reflected in the signed Memorandum of Understanding (MOU), attached as Exhibit F. Please direct questions regarding this report directly to Adam Noble. Regards, Adam Noble President 15

16 EXHIBIT A [PLANS]

17 EXHIBIT B: Summary of Shadow Impacts

18 EXHIBIT C [GRAPHICS]

19 EXHIBIT D [PARK USAGE SURVEYS]

20 EXHIBIT E [ADDITIONAL PROJECT INFORMATION]

21 EXHIBIT F [MOU]