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Planning and Development Services

Planning Division 15151 E. Alameda Parkway, Ste. 2300 Aurora, Colorado 80012 303.739.7250

October 25, 2018

Jason Marcotte Northstar Commercial Partners 1999 Broadway, Suite 770 Denver, CO 80202

Re: First Submission Review – Mixed-Use at Parkside at City Center – Site Plan Application Number: DA-1773-06 Case Number: 2017-6008-03

Dear Mr. Marcotte:

Thank you for your first submittal, which we started to process on October 1, 2018. We reviewed it and attached our comments along with this cover letter. The first section of our review highlights our major comments. The following sections contain more specific comments, including those received from other city departments and adjacent owners.

Since several important issues still remain, you will need to make another submission. Please revise your previous work and send us a new submission on or before Thursday, November 8, 2018.

Note that all our comments are numbered. When you resubmit, include a cover letter specifically responding to each item. The Planning Department reserves the right to reject any resubmissions that fail to these items. If you have made any other changes to your documents other than those requested, be sure to also specifically list them in your letter.

As always, if you have any comments or concerns, please give me a call. I may be reached at 303-739-7857.

Sincerely,

Sarah Wieder, Senior Planner City of Aurora Planning Department cc: Angela Gunn, Oz , 3003 Larimer Street, Denver, CO 80205 Susan Barkman, Neighborhood Liaison Mark Geyer, ODA Filed: K:\$DA\1773-06rev1.rtf

First Submission Review

SUMMARY OF KEY COMMENTS FROM ALL DEPARTMENTS

 Reach out to the adjacent property owner to discuss their concerns (see Item 1)  Make revisions to the Cover Sheet (see Item 2)  Provide additional information in the Data Block (see Item 2)  Include more details on the Site Plan for this building (see Item 3)  Clarify whether direct unit access is being provided for ground floor units (see Item 3)  Provide additional information regarding the functionality of the (see Item 5)  Include cross sections showing the wall areas relative to the main street, sidewalks, and building (see Item 6)  Make improvements to the building architecture per code requirements and staff recommendations (see Item 7)  Revise the Landscape Plan per redline comments (see Item 9)  Provide information about how many apartment units there will be per floor for addressing purposes (see Item 10)  Review PROS requirements regarding land dedication and development (see Item 11)  Address comments regarding sight triangles (see Item 13)  Show FDC and Knox Box locations (see Item 14)  Address Aurora Water comments regarding the gate valve for the fire line (see Item 15)  Make revisions to the tree mitigation chart per Forestry comments (see Item 16)  Respond to Aurora Public Schools and Xcel Energy comments (see Items 18 and 19)  Address all additional redline comments throughout the Site Plan

PLANNING DEPARTMENT COMMENTS

1. Community Questions, Comments and Concerns 1A. Twenty registered neighborhood organizations and four adjacent property owners were notified of the Site Plan application. One comment was received from an adjacent property owner. Please review their comment and reach out to the property owner to discuss their concerns. Ownership met with Darren to discuss their concerns.

Name: Darren Everett Organization: BMC Investments Email: [email protected] Comment: We are concerned about traffic onto our property from the east access/egress drive area to the north of the proposed Site Plan. This area connects to our Landon Park property. We would prefer if this drive area was closed and/or made into a fire gate only. There is no reason traffic from this proposed development should need access to our property and vice versa.

2. Completeness and Clarity of the Application 2A. Make revisions to the Letter of Introduction per redline comments. OZ - Letter of Introduction revised per comments. 2B. Edit the Vicinity Map and Amendment Block per redline comments. OZ - Vicinity Map and Amendment Block revised per comments. 2C. Include additional information in the Data Block such as the number of residential units, the number of retail tenant spaces, the residential gross floor area and the retail gross floor area. OZ - Additional information included per comments. 2D. Please remove labels from the Site Plan that are outside the scope of this building unless they are specifically requested by a reviewer so the plan set is more concise and simple. In addition, if you do show items outside the scope of this building, please ensure that they are updated to reflect the most recent review comments sent to the applicant on October 23, 2018.

WCI – Acknowledged. 2E. When referencing the Retail Site Plan in the subject application, please note the Case Number of the project for records purposes. The Case Number is CN 2017-6008-02. WCI - Acknowledged. Any references to the Retail Site Plan have been annotated to include the Case Number CN 2017-6008-02. 2F. Sheets 3-5, as well as the Signature Block on the Cover Sheet, appear blurry. Please revise so that these sheets are clearer within the plan set. OZ – Sheets revised per comments. 2G. As a reminder, the city has developed CAD Data Submittal Standards for internal and external use to streamline the process of importing AutoCAD information into the city’s Enterprise GIS. Please note that a digital submission meeting the CAD Data Submittal Standards is required before your final Site Plan mylars can be routed for signatures or recorded. Please review the CAD Data Submittal Standards and email your Case Manager the .DWG file before submitting your final Site Plan mylars. Once received, the city’s AutoCAD Operator will run an audit report and your Case Manager will let you know whether the .DWG file meets meet the city’s standards. OZ – Acknowledged. These will be provided at final Site Plan. 2H. Continue working with Roberta Bloom to finalize the Public Art Plan. Staff appreciates the progress that has been made since the last submittal on this. Please note that staff will likely require a note on the Public Art Plan that states that the artwork shall be installed prior to receiving a Certificate of on the final building within the entire Parkside at City Center development. The location of the public art within the scope of this site (west building elevation and south wall) should also be identified on the Site Plan. OZ – Acknowledged.

3. and Land Use Issues 3A. The courtyard area, parking garage, retail spaces, and other ground floor uses like apartment units, lobbies, mail rooms, etc. need to be shown on the Site Plan. It is difficult to review the Site Plan without this information being provided. Only the footprints of these areas need to be provided, not the internal layouts. OZ – Refer to sheets 3-5 for clarification. 3B. Please clearly identify all walls on the Site Plan and use a unique symbology for each type of wall. Consistent naming should be used throughout the plan set as well. WCI - Acknowledged. 3C. Please label all building entrances and identify if they are for retail or resident access. Using a symbol to differentiate between the different types of entrances would help. OZ - Entrances have been identified. 3D. The proposed loading area has never been identified on the Retail Site Plan and is only shown on one sheet (Sheet 12) within the subject Site Plan. This needs to be called out on all applicable sheets and information should be provided about how this area functions. Is this for trucks associated with the retail tenants or for residents moving into the apartment building? Generally, loading areas are required to be screened and shouldn’t be visible from public right-of-ways or main streets. OZ – Refer to sheet 4 for clarification. 3E. Please clarify whether the lot lines on the Site Plan are reflective of the proposed Plat (Filing No. 2) or the existing Subdivision Plat (Filing No. 1). If Filing No. 2 is submitted prior to this Site Plan being finalized, that information will need to be accurate on the subject application. WCI - Acknowledged. 3F. Additional items need to be identified on the Site Plan and added to the Legend on Sheet 3 such as bicycle racks, trash receptacles, benches, the different types of walls and stairs. 3G. Is the building footprint shown on the Site Plan reflective of the balcony projections? OZ – Refer to sheets 3, 4, 5 for clarifications regarding balcony projections. 3H. Is direct apartment unit access being provided on the south and east sides of the building? It appears that you recently removed this from your Design Guidelines, but upon reviewing this Site Plan, staff would not be supportive of this change as this is required by the City Center Station Area Plan. OZ - Direct access is provided at the ground level for units that have direct access to a sidewalk. All units have access

to the east exit door, overlooking the park.

4. Waivers 4A. More information is needed regarding certain elements of the Site Plan (building architecture, apartment unit access, etc.) to determine whether any waivers need to be requested. OZ – The design team does not intend on requesting waivers.

5. Parking Issues 5A. Provide calculations for how the minimum parking requirements in the Transit-Oriented Development District are determined below the Data Block. OZ – Refer to Sheet 1 for TOD parking requirement calculations. 5B. In the Data Block, parking should be divided up into the following categories: Total Parking Spaces Required and Provided (including regular spaces and accessible spaces by use), Regular Parking Spaces Required and Provided (by use) and Handicap Accessible Parking Spaces Required and Provided. It appears that your calculations currently include accessible parking spaces, but accessible parking spaces are always calculated on top of the regular parking spaces being provided. See redline comments. OZ – Refer to sheet 1 for defined parking counts. 5C. More information is needed about the functionality of the parking structure on Sheet 12. Where are the entry / exit doors from the parking structure out to the main street? Where are the entries to the apartment building? What are the preferred pedestrian routes to access the main street from the parking structure? OZ – Refer to sheet 3 for public/resident access clarification. 5D. Provide floor plans for levels 2-5 of the parking structure. OZ – Refer to sheet 14 for additional parking level plans.

6. Streets and Pedestrian Issues 6A. Please provide cross sections showing the proposed wall areas relative to the building location, sidewalks and main street. It is difficult to understand how these areas look and function currently due to a lack of information. Britina - Acknowledged and shown. 6B. Are there any outdoor seating areas proposed outside of the retail spaces to activate the main street? If so, please identify these areas on the Site Plan. Outdoor seating areas are recommended. Britina - The upper sidewalk (same elevation as retail finished floor) is wider to allow for outdoor seating opportunities for retailers. 6C. Ensure sidewalk widths are called out and consistently labeled. Britina - Acknowledged and shown. 6D. Clarify whether the pavers are concrete (as shown in the Design Guidelines) or . Britina – Pavers are to be concrete. 6E. The pedestrian light fixture on Sheet 14 does not match the required fixture. Please update. OZ - The proposed fixture was selected because the fixtures outlined in the Design Guidelines do not have appropriate light throws for the pedestrian use at the east side of the building. The fixture is intended to compliment the Louis Poulsen fixture in the Guidelines. The fixture will be proposed to be added within the Design Guidelines.

7. Architectural and Issues 7A. As a general comment, the building architecture needs improvements prior to the next submittal. Please incorporate architectural features to break up the building façade, improve the ground floor design and add additional architectural interest. This site is in a highly visible location and is also within an Area and Station Area Plan. High quality design should also occur on all four sides of the building and there should be no “blank” façade areas. There should also be a clear base, middle and top as required by code; the “top” element is missing from the overall building design. See specific recommendations below and on Sheet 11 of the Site Plan. OZ – Building massing, architectural elements, and material transitions have been revised as a result of discussions with city planning on 11/5. Notes have been added to the elevations for clarity. 7B. At least one unifying element that connects the bank, retail and subject building is needed. There do not appear to be any common architectural features, materials or colors as shown in the “Site Perspective” document.

The buildings do not need to match, but this is a master-planned development and unifying elements are essential to making this feel like a cohesive, well-designed place. OZ – Exterior materiality and colors have been revised as a result of discussions with city planning on 11/5. A similar range of neutral/earthtone colors and contemporary style tie all three projects together. Notes have been added to the elevations for clarity. 7C. Please provide more emphasis on the building entries through canopies, sunshades, etc. to active the ground floor of the building, especially along the south and east elevations. OZ – Canopies at retail storefront has been indicated. 7D. Staff has some concerns regarding the proposed stucco colors (whitish, gray and dark gray) as well as the bright green cementitious panel color. The chosen stucco colors are not recommended based on experience with other projects in the city and the green color appears to clash with the other buildings in the Master Plan. OZ – Exterior materiality and colors have been revised as a result of discussions with city planning on 11/5. Notes have been added to the elevations for clarity. 7E. Please alter the balconies to be recessed into the façade of the building or have them be architecturally integrated into the design of the building. The balconies as shown tend to have issues with usability, maintenance and design (i.e. residents storing items outside). They also don’t match the design of the rest of the building. OZ – Due to project budget and available square footage, the balconies cannot be recessed. The prefinished aluminum balconies currently specified are maintenance friendly and rental agreements will prohibit certain items from being stored outside. 7F. Per code requirements in Section 146-729(H), the parking structure should be designed to blend in with the other building elevations, complement pedestrian activity and minimize views of parking. Please review suggestions on Sheet 11 and work to improve the north elevation as well as provide better illustrations of this area. OZ – The north elevation has been revised to include elements that are reminiscent of the retail and residential portions of the mixed-used building but also unique to parking and transportation. Notes have been added to the elevations for clarity. 7G. Please provide calculations showing the percentage of transparent materials for the retail and residential uses as well as the percentage of masonry to ensure compliance with the Design Guidelines and with Section 146-1303. OZ – Transparency and materiality percentages have been added to the elevations. 7I. Please provide colored elevations and /or colored renderings as a separate document with the next submittal as it is difficult to review details with the black and white elevations. OZ – A separate document of colored elevations and renderings has been added to the next submittal. 7J. Provide information regarding the size of the balconies to ensure compliance with the Design Guidelines. OZ - Typical balconies are approx. 4’ x 9’. 7K. Please prepare a materials board. It should be mounted on an 8.5” x 11” foam board and should have samples of the primary materials / colors. Please submit this to staff with the next submittal. OZ – An 11x17 material board will be sent directly to Sarah Weider upon next submission. 7L. It is unclear where rooftop or mechanical equipment and vents are located. Please include a roof plan that calls out and shows the location of any rooftop or mechanical equipment and vents greater than eight inches in diameter. Also show their location on the elevations drawings. All such equipment must be screened per code requirements. Use drawings and notes to explain how this will be accomplished. Screening shall be done with an extended parapet wall. The screening should at least be as high as the equipment it hides. OZ - A roof plan has been added to the submission. Equipment cannot be seen from public street view.

8. Signage Issues 8A. Signage details for the vehicular directional signs and the pedestrian directory signs should be provided within this plan set because some of those signs are within the scope of this particular Site Plan. In the Data Block, they should also be identified as “Master Plan Signs” since they are associated with the overall Master Plan. 8B. In the Data Block, there should be line items for permitted and proposed number of signs and permitted and proposed signage square footage. This would apply to wall signs, projecting signs and other signs allowed in Section 146-1613. Under the “Permitted” categories, you can state “Per Section 146-1613” and under the “Proposed” categories, you can state “TBD” if it’s unknown at this time. OZ – Note revised per comment.

9. Landscaping Issues (Chad Giron / 303-739-7185 / [email protected] / Comments in bright teal) 9A. Identify site walls, block walls and concrete walls on Sheet 3. Britina - Acknowledged and shown. 9B. Please be consistent with labeling throughout the document. Britina - Acknowledged and shown. 9C. Only include items in the Legend that are used on this Site Plan. Britina - Acknowledged and shown. 9D. Clarify why the ADA ramps appear different on Sheet 8. Britina - Acknowledged and shown. 9E. Revise the order of the Tree Mitigation Plan and the Landscape Plan within the plan set. 9F. Update the base map on the Landscape Plan to match the most recent comments on the Retail Site Plan review. Britina - Acknowledged and shown. 9G. Verify the landscape and ground-cover treatment in the areas just north of the building. Britina - The sidewalk centered in the fire lane was eliminated and the sidewalk along the north side of the building was widened and will be used for building and trail access. With the wider sidewalk, there is less than 5 feet between the building and sidewalk and there is not enough room for plant material and irrigation. Due to liability issues with soils and foundations we do not have irrigation within 5 feet (minimum) of building exterior walls. 9H. Please make it clear which walls will be concrete and which walls will be block if they transition in the corner. Britina - Acknowledged and shown. 9I. Show all building entry doors on the Landscape Plan. Britina - Acknowledged and shown. 9J. The native grass areas east of the building may be difficult to establish and maintain based on the location between retaining walls. Please consider switching to shrubs and/or perennials. Britina - Acknowledged and shown. 9K. For clarification on retaining wall size and landscape location, please add three cross-section details. Britina - Acknowledged and shown.

10. Addressing (Andrea Barnes / 303-739-7679 / [email protected]) 10A. Please provide information about how many apartment units there will be per floor for addressing purposes. OZ – There a total of 216 units within the building (1st floor - 29 units, 2nd floor - 47 units, 3rd floor - 47 units, 4th floor – 47 units, 5th floor – 46 units). 10B. Please submit a preliminary digital addressing .SHP or a .DWG file as soon as possible. This digital file is used for street naming, addressing and preliminary GIS analysis. Include the parcel, street line and building footprint (if available) layers at minimum. Please ensure that the digital file is provided in NAD 83 feet, State Plane, Central Colorado projection so it will display correctly within our GIS system. The file should be in a 2013 CAD version. Please eliminate any line work outside of the target area. Email these files to me. OZ – We will follow up with CAD files emails directly to Andrea Barnes.

REFERRAL COMMENTS FROM OTHER DEPARTMENTS AND AGENCIES

11. PROS (Chris Ricciardiello / 303-739-7154 / [email protected] / Comments in purple) Approved Parkside at City Center Master Plan 11A. The Master Plan for Parkside at City Center was formally approved by the city in January of 2018 with a total of 200+ multi-family units. The projected population for the Transit-Oriented Development was 404 persons at 2.02 persons per dwelling unit. Updated Site Plan data shows 216 dwelling units for the Mixed-Use Building. Population Designation 11B. PROS has designated the Parkside at City Center Mixed-Use Building as a Transit-Oriented Development. Population calculations for a TOD utilize an incentive per-unit multiplier of 2.02 persons per unit. For PROS fees assessment, staff calculates an overall development population of 436 persons residing in 216 dwelling units. Land Dedication and Park Development Fees 11C. To provide adequate equipped with appropriate facilities, the City Code enumerates requirements for park

land dedication and park development fees. These allow for PROS to purchase land and to construct new facilities. When a development includes residential units, these requirements are applied. Explanation of Park Land Dedication Requirements 11D. The city’s park land dedication policy is set forth in the City Code. It specifies that park land shall be dedicated in accordance with the following standards: 3.0 acres per 1,000 residents for neighborhood parks and 1.1 acres per 1,000 residents for community parks. No open space land dedication will be required because the subject development is designated as a Transit-Oriented Development and is exempt from the open space land dedication requirement. 11E. Land dedication requirements and the proposed method of how they will be satisfied should be explicitly presented in the Site Plan submittal. 11F. Neighborhood park land dedication for this project shall be provided with a cash-in-lieu payment. Based on a TOD population projection of 436 for 216 dwelling units, the neighborhood park land dedication requirement will be 1.31 acres. 11G. Community park land dedication for this project shall be provided with a cash-in-lieu payment. Based on a TOD population projection of 436 for 216 dwelling units, the community park land dedication requirement will be 0.48 acres. 11H. For subdivisions qualifying as TOD, PROS allows as an incentive the use of a predefined per-acre value for cash-in-lieu payments based on the average cost for city open space acquisitions. This value at the time of application (2018) is $45,800 per acre. Total cash-in-lieu of land dedication for the Parkside at City Center Mixed-Use Building is as illustrated in the following calculation: Land Dedication Total Acreage (1.79 acres) x $45,800 per acre = $81,892.00. 11I. PROS will invoice the applicant for required land dedication cash-in-lieu. The cash-in-lieu payment for land dedication shall be paid prior to approval of this Site Plan. Park Development Fees 11J. Park development fees will be calculated per current City Code requirements. These fees are based on the park land area (land dedication acreage = 1.79 acres) required to serve new residents and a cost per acre for of facilities designated annually by PROS. Park development fees, combined for neighborhood park and community park, shall be $304,415.66 ($1,409.33 per unit). Special Landscape Buffer 11K. The residential development shown on the Parkside at City Center Mixed-Use Building Site Plan is depicted close to the common property boundary between the subject property and City Center Park, a city owned park. All built improvements for the subject application must be setback 25’ from the property line abutting the City Center Park on the east side of the development. See Section 146-1424 for further documentation regarding the Special Landscape Buffer. 11L. Life Safety representatives have directed the applicant to provide a fire lane along the eastern edge of the multi- family residential building for potential emergency and firefighting access. The fire lane, as shown, encroaches into the 25’ Special Landscape Buffer. In coordination with Life Safety representatives, PROS staff have developed an alternative allowing for the fire lane to stay in place as recommended and also allow the Special Landscape Buffer to function properly. The applicant shall construct the 23’ wide fire lane of grasscrete or other approved stabilized lawn product enabling acceptable load bearing capacity and turf lawn growth in accordance with the intent of the Special Landscape Buffer. Along the edges of the fire lane, allow for irrigated shrub plantings to delineate the outer limits of the fire lane corridor. Coordinate the detailed design of this element with PROS and Life Safety. Britina - Acknowledged and shown. PROS Requirements Caveat 11M. The monetary calculations presented herein are estimates based on park construction costs and a per-acre value for TOD development at this time (current year 2018). The timing for implementation of the project may affect the ultimate amount of fees collected and other payments imposed to satisfy park-related obligations. Furthermore, if aspects of your project change, such as the number of dwelling units proposed, the park land dedication requirements may also change.

12. Civil Engineering (Kristin Tanabe / 303-739-7306 / [email protected] / Comments in green)

12A. Show existing contours on the Grading Plan. WCI - Acknowledged. 12B. Indicate where roof drains tie to the storm sewer. OZ - Roof drainage is collected within the building courtyard and piped to the detention pond on the eastern portion of the site. Refer to civil site plan. 12C. Provide a fence or railing on top of the site wall. WCI - Acknowledged. Railing has been added where there’s a difference greater in 30” between grades along public egress. 12D. Retaining walls greater than 4’ in height require structural calculations with the Civil Plan submittal. WCI - Acknowledged. These will be provided with the Civil Plan submittal.

13. Traffic Engineering (Briana Medema / 303-739-7336 / [email protected] / Comments in orange) 13A. Add the required note to Sheet 2. OZ – Note has been added. 13B. Review the note regarding sight triangles on Sheet 6. WCI - Acknowledged. 13C. Address comments regarding sight triangles as part of the Retail at Parkside at City Center Site Plan. WCI - Acknowledged.

14. Fire / Life Safety (John Van Essen / 303-739-7489 / [email protected] / Comments in blue) 14A. Add the IBC to the Data Block. OZ – Note has been added. 14B. Include the actual height of the building in the Data Block. OZ – Note has been added. 14C. Revise and add notes on Sheet 2. OZ – Notes have been added/revised. 14D. Show FDC and Knox Box locations on all sheets, including the building elevations. OZ - FDC and Knox Box locations have been shown on appropriate sheets. 14E. Revise fire hydrant symbols on the Legend. WCI - Acknowledged. 14F. Dimension the accessible parking spaces and show the accessible signs on Sheet 12. OZ - Accessible parking spaces are dimensioned and accessible signage shown.

15. Aurora Water (Steve Dekoskie / 303-739-7490 / [email protected] / Comments in red) 15A. Dimension all pocket easements for hydrants and meter pits. WCI - Acknowledged. 15B. A Water Fixture Unit Table is required to be submitted with the Civil Plans to verify the water meter’s capacity to serve this site. WCI - Acknowledged. A water fixture unit table has been added to the Civil Plans for the Mixed-Use Building. 15C. A 6” gate valve is needed for the fire line. WCI - Acknowledged. The 6” gate valve has been added.

16. Forestry (Jacque Chomiak / 303-739-7178 / [email protected]) 16A. There will be two trees impacted by of this site. Below is the list of those trees that will require mitigation. Due to the size of trees on the site, relocation is not an option. The use of tree equivalents is not permitted to mitigate for tree loss. Any tree that is removed from this site should either be replaced within the landscape or be mitigated through payment to the Tree Planting Fund. Britina - Acknowledged and shown. 16B. The tree mitigation chart is shown, but needs to be updated for this phase of the project. The inches shown here are reflected in the tree loss for the Retail at Parkside at City Center Site Plan. If payment will be made into the Tree Planting Fund, add another column to the chart indicating the payment amount that will be made. If trees will be

planted on the site, please show a symbol indicating trees that are specific to tree mitigation. Britina - Acknowledged and shown. 16C. The caliper inches that will be lost are 25”, but only 9” would be required for planting back onto the site. The mitigation value is $2,816.00. Mitigation values based on International Society of Arboriculture’s Guide to Plant Appraisal. Species, diameter, condition, and location factors were included in the assessment.

MITIGATION MITIGATION TREE SPECIES DIAMETER COMMENTS VALUE INCHES 18 Blue Spruce 11 $1,212.44 4 19 Blue Spruce 14 $1,603.51 5 Total 25 $2,815.95 9 Britina - These trees have been mitigated on site.

17. (Maurice Brooks / 303-739-7294 / [email protected] / Comments in magenta) 17A. Revise Note #7 on Sheet 2. OZ – Note has been revised. 17B. Dedicate the northern utility easement through separate document or the Subdivision Plat.

18. Aurora Public Schools (Josh Hensley / 303-365-7812 / [email protected]) 18A. The school land dedication obligation for the 216 proposed apartments is .7069 acres in accordance with Section 147-48 of the City Code. Aurora Public Schools will accept cash-in-lieu of land for this obligation. Market value of zoned land with infrastructure in place is determined for the value of all cash-in-lieu of school land requirements, and it should be paid prior to Site Plan recordation. See attached document for additional information.

19. Xcel Energy (Donna George / 303-571-3306 / [email protected]) 19A. See the attached comment letter.