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HomeMy WebLinkAboutPACKET Estes Valley Planning Commission 2009-11-17fl-2 Prepared: November 5,2009 AGENDA ESTES VALLEY PLANNING COMMISSION Tuesday, November 17, 2009 4:30 Study Session, Rooms 201 and 202, Town Hall 6:00 p.m. Meeting, Board Room, Town Hall 1. PUBLIC COMMENT The EVPC will accept public comments regarding items not on the agenda. Comments should not exceed three minutes. 2. CONSENT AGENDA Approval of minutes - November 12, 2009 Special Planning Commission Meeting 3. AMENDMENT TO ESTES VALLEY DEVELOPMENT CODE - WIND TURBINE REGULATIONS The proposed amendments would regulate small-scale residential and commercial wind turbines. 4. REPORTS Board of County Commissioners Hearing on Amendments to the EVDC - Wildlife Habitat Kind Coffee - Notice of Right of Appeal of a Staff Determination of a permitted use in the CH- Heavy Commercial zoning district. 5. ADJOURN The Estes Valley Planning Commission reserves the right to consider other appropriate items not available at the time the agenda was prepared. RECORD OF PROCEEDINGS Special Meeting of the Estes Valley Planning Commission November 12, 2009,1:30 p.m. Board Room, Estes Park Town Hall Commission: Chair Doug Klink; Commissioners Alan Fraundorf, John Tucker, Betty Hull, Steve Lane, Ron Norris, and Rex Poggenpohl Attending: Chair Doug Klink, Commissioners Alan Fraundori, Betty Hull, Steve Lane, Ron Norris, and Rex Poggenpohl »I >,/-3.1%~ . /34 & , 16 .4 Also Attending: Director Joseph, Town Attorney White/Planner.Shirk, Planner Chilcott, Utilities Engineer Bergsten, and Recording Sedrethry Thompson AN* 4,44 . h j ' Absent: Commissioner John Tucker,~Town Board Liaison Homdierl 1 90 The following minutes reflect the order of the agendh Kh*not necessarily tl~e chronological sequence. FIEJN '1 3-7 Chair Klink called the meeting to order at 1230 p.m. h. i / 5 L h 1. PUBLIC COMMENT 2- None. .-U.e-: \\.:Il /6.-. .1 \C .. i y : i i .™ 2. CONSENT AGEND*A< i , 1%-4 Approval of minutes'froin.thes~tober 20,2009 Planning Commission meeting. 4 1 V--- It was mSved<and seconddd (Norrid/Hull) that the consent agenda be approved, and the motion pashed Ongnimously with one absent. \ h 1 3. AMENDMENT TO ESTES VALLEY DEVELOPMENT CODE - WIND TURBINE REGULATIONS i j Chair Klink Weicomed appioximately 50 citizens to the meeting. \01/7 Utilities EngineerR6uben Bergsten reviewed the technical aspects of wind in the Estes Valley, stating thekbest sites for wind turbines would be more than 30 feet high and at least 300 feet from any land structures. He reviewed information compiled with the assistance of a Colorado State University (CSU) researcher, in conjunction with the Governor's Energy Office. He stated that CSU has been monitoring and analyzing data from an anemometer located at Stanley Park for over a year. Based on this data, the wind in Estes Park at a height of sixty feet was established as a Wind Class 2. The worst Wind Class rating is a 1 and the best is a 7. Commercial wind farms are not considered viable unless at least a Class 3. Since Larimer County has a forty-foot height limitation on structures, the Town asked the CSU researcher to estimate the performance of small- scale wind turbines at forty feet. He explained the Average Net Capacity Factor, which shows how often a wind turbine would actually be operating, and the results indicated the wind turbines in Estes Park would operate approximately one day per week. Therefore, with the current wind turbine technology, Utilities Engineer Bergsten believes those results show Estes Park is not a good location for small-scale wind turbines. Utilities Engineer Bergsten stated the local topography interrupts the flow of wind and creates turbulence. It is a common misperception that Estes Park would be a good location for wind turbines due to our high winter winds, where in reality the type of wind is not conducive to such. '4 RECORD OF PROCEEDINGS Estes Valley Planning Commission 2 November 12, 2009 The Town purchases wind energy through the Platte River Power Authority, and any Estes Park Light and Power customer can purchase renewable energy through the Light and Power Department. Funds received through this program are allocated to the operation of current reneWable energy sites and construction of new sites. Utilities Engineer Bergsten stated if a citizen installs a wind turbine, it must pass inspection by the state electrical inspector, and the Town is required by law to provide net-metering. Excess energy produced is released into the power grid and the credit is rolled over on a month- by-month basis. Any excess energy at the end of the 12-month period is paid to the customer as a credit on their utility bill. There are currently three privately-owned wind turbines within the Estes Valley area, two are horizontal axis units and one is a double- helix type. With assistance from the owners, these turbines will be monitored for maintenance, energy output, etc. to determine their effectiveness. Chair Klink clarified that although many people may want the Town to place a ban on wind turbines, there could very well be legislation in the near future pre-empting local regulations and prohibiting bans on any kind of renewable/*hergy. Since that is a possibility, he stated it would be better to draft regulations pemitttint) wind turbines while addressing the community's concerns. Commissioner Norris stated that Planning Commissionihas drafted,a problem statement, with feedback from staff and some Town Trusteesjb >d&fine thetommission's task. He stated that one of Commission's tasks is to work,With tR@Town Board aRd.staff to develop code language prior to the December 9,20094*ration of the wind turlbinkm~atorium. If the Commission is not ready to recommeild.sbecific dbde language, they,have been asked to consider recommending extending the hiohtorittin:% W 44% V/, a \· Director Joseph stated that baseflen feedback fromthe last Planning Commission meeting, staff prepared a list of talkind'points about hobv *nail Wind Energy Conversion Systems (SWECS) might be regulat@d: Hetated the goalris totiave regulations that will '9«. apply to all styles of wind turbines avaiIAbleNoday and in the futlire. %. 41,40, Chair Klink suggestecladding a section todeal with sat,ti standards. Based on previous discussions he belietes viterhs "B" dealihd with ma*imum height allowances and "C" concerning setbacU are of barticular interedt:,Director Joseph reviewed three maps of the Estes Valley illditrating which barcels would bejable to site a wind turbine if a 90-foot, 120-foot, or a 150-foot*obdrty-line setbabk' was required. With a 90-foot setback, approximately»21 00 oilt@fftoughly.*00%,ircels would be able to site a turbine. With 120-footletbacks>the nurn8er, of parcels"decreases to approximately 1100, and with a *t . F 150466t setback,lhe number decreases to approximately 735 parcels. Director Joseph notedthese numbek might b~luhhe; reduced for a variety of reasons. For example, the /rekwhere a turbine bolild be sitid may already be occupied by a structure such as a single-farAily home or gArdge. H; stated staff's goal was to begin to provide an illustration of where tvir;dturbines cbuld be sited in the Estes Valley given certain minimum setbacks. As the minimJrn requir48 setback increases, the ability to site turbines in the more urbanized areksif,the<Ektes Valley decreases. I ' Public Comment:>' Gilbert Thomas Greslin/Town Resident believes the allowance of wind turbines would actually increase a person's carbon footprint. He suggests making the purchase of renewable wind energy from the Platte River Power Authority mandatory for all residents. Maryann Karinch/County Resident read a letter submitted to the Planning Commission by county resident Jim McCormick. He believes the survey was under-assessed and designed with faults, and the percentage of respondents who feel that personal wind turbines should be regulated based on height, setbacks, noise, lot size, and color are higher than indicated, had they been allowed to express their opinion. Due to the current 30-foot height restriction, he considers a proposal of a 50-foot height limit indefensible. He feels very strongly about acquiring the consent of impacted property owners whose view or quiet enjoyment of their property may be affected by wind turbines. He encouraged residents to take advantage of immediate access to wind-generated power through the Renewable Energy Purchase Plan. RECORD OF PROCEEDINGS Estes Valley Planning Commission 3 November 12,2009 Gary Coleman/County Resident suggests building a local wind farm where residents could purchase energy for their personal consumption. Bob McCreery/County Resident is concerned about the view impact of a 50-foot turbine with no dependable or economical track record. He thinks the industry is moving toward a different type of wind turbine technology, and if we allow the current types of turbines, they will soon be obsolete. He recommends asking the Town Board to continue the moratorium until the Town has the opportunity to perform a test project for practicality and viability. Harry Hutcherson/Town Resident cannot support wind turbines within the Town limits, but may support a community wind farm. He does not believe a small-scale wind turbine is cost effective, and will have negative impacts on residents and visitors. Wayne Newsom/Town Resident is against having more poles ·lihtown than we already have. He owns and encourages other residents to purch44 wihd energy from the Renewable Energy Purchase Plan. He opposes wind turbirtfs in,Estes Park. Richard Volkstorf/Town Resident stated buried utility line; in TRe Oplands was one of the reasons he purchased property in that area, and isignceh~ed abdut the visual impacts of wind turbines. He questioned the credibility of th#' Aurv@y. He suppo}ts be[sonal property rights that do not adversely affect neighbors,otiommunity. He opposes.win*urbines in general, but supports personal property rights.< If.a height limit of more ~than 30 feet is allowed, he suggests code language requiring.®proval «from 100% of'the adjacent »1 +2,7 property owners. ¥,% Mike Headley/Town Resident is a r&ti?ed.engineer that Agroes with the data presented by Utilities Engineer Bergsten. He think'sea< c8}hmunity wind farrA cduld be a good idea. He questions a 50-foot height limit propddal When~30:feet (Town)' and 40-feet (County) are the current height limits. He would suppbrt consinsusof allatjacent property owners. 94>y h / Paul Brown/Town Rebident would like thelplanning CoMmission to consider systems that generate less thati' 400 watis bh exempt frdthany type of review process. These systems would provide akembrgency *stem to powht•appliances, and are not dependent on any other outside source~of bower.-=*.. - 7 Jay Heifibmann/Ck)unty Resident belidves-' wind turbines should be banned in this area. He isfdoncemed<about visdal linpacts, and supports purchasing wind power. He would not* support the 100% ~adjacent brferty owner consent due to the probability of the 6hahge~of property ownerhhip. 1/ Jim Doctor/Town Resideht s a strong proponent of individual property rights, and believes wind turbines Are visually* obtrusive and unattractive. He would support a ban on wind turbines. In lieu·of thatihe would support 100% adjacent property owner consent. Frank Theiss/CouAty Resident believes bladed wind turbines are unsightly. If regulated, he supports a 30-foot height limit, setbacks, and applying the sign code which disallows moving parts. Jim Tawney/Town Resident believes wind turbines should be regulated as little as possible to allow opportunity for experimentation, personal property rights should remain on the forefront, and "C" - setbacks should be downgraded. Also, the allowance of only one per lot could present problems if a wind farm was proposed. Judy Heaston/County Resident believes the setbacks should be decreased to allow for turbines on smaller lots. She supports "K", requiring both manual and automatic controls limiting the rotational speed of the unit. She reminded the Commission to be aware of writing regulations that could limit new technological designs. 4 RECORD OF PROCEEDINGS _ ~ Estes Valley Planning Commission 4 November 12, 2009 Phil Edwards/County Resident is opposed to wind turbines and the negative visual impacts. Bob Ayers/Town Resident opposes wind turbines in the area, and supports the renewable energy program. He encouraged the Commission to disallow wind turbines built with current technology. Utilities Engineer Bergsten stated under current net-metering policy, alternative energy sources connected to the grid are not allowed to operate if the grid goes down due to safety issues for the lineman when that energy is fed back through the system. Equipment to completely disconnect from the grid is available to homeowners but is very expensive. Chair Klink closed the public comment. Chair Klink stated a community wind farm is out of the scope-of this regulation. The Planning Commission's directive is to regulate small-scale .residential wind turbines. Based on public input, Staff and the Commission will draft regulaiGn*to be recommended to Town Board and Board of County Commissioners. who will be the decision-making bodies. :/7.\14 \ A V Commissioner Norris stated the National Renewable\Energy Laboratory in Golden has discontinued research on small-scale wind turbirAs du#to low efficibnck~Commissioner Hull agrees the survey is not scientific, but oper half of.the commentsrsuppgted height regulations, 46.3% of respondents believe<they:have Regative visual imbact, and 18 comments were directed towards property rightE¢haiG Kiinkkstated althou6h unscientific, the survey provided comments from interested redidentd and visitors that were willing to state their opinions. Commissioner Fraundorf corielukles from public comment that residents do not want widespread Wind .turbines, espedialkon small lots. He hears that wind turbines should be strictly reg'ulate©and possibly 'evhn,*6anned. Commissioner Poggenpohl thinks the Commission shduldbe.16bking at waits to protect the view quality when creating regulations. CommissioWer Lan»staBd.the« Commission should not be reactionary, and thin§s.theyjshould be Able46 draft 'a~ea~sonable set of restrictions that make sense and address needs. Chair Klink poliadQhe boards on items "814-,height limit and "C" - setbacks. The Commissioners agreedthe makimum height i i 'mit should be 30 feet to the top of the blade, and the setback from th©frEperty: lik'shoGId be five times the height of the structure. Commis@oner..1'4genpohljvould alsdlik@ to see flexibility for small personal systems that.afe shorter Than ~30-feet'aR©vould not require a 10-foot ground clearance. Director Jos~el;h%explained tltese'small hystknfs are a subset of this technology and would require ; different regulatory aipptoach. )/' 11 j j There was.general condensus among the Commission not to restrict color and surface treatment. The1prohibiti6ri of lighting, graphics, signs, and other decoration should be written into th@cAe./7 Chair Klink called.a recess at 3:37. The meeting reconvened at 3:50. On proposed item "M" - safety standards, Commissioner Poggenpohl has researched the product safety standards for wind turbines and found international safety standards, but none originating in the United States. He suggests applying the International Electro- Technical Committee standards, coordinated with the International Standards Organization (ISO) and the International Energy Agency until the United States adopts national safety standards for wind turbines. Utilities Engineer Bergsten stated House Bill 1160 requires towns to allow 10 KW systems with no regulations other than what is already in place. The Town could require regular inspections on larger systems, which would be regulated by the Public Works Department. Director Joseph stated this is largely an issue with the state electrical inspector. The Building Department handles the structural component as well as the setback requirements. Commissioner Poggenpohl stated because there are no US standards, he thinks the public should be protected by using the international safety standards. RECORD OF PROCEEDINGS Estes Valley Planning Commission 5 November 12, 2009 Commissioner Poggenpohl suggests writing code language to exempt small systems from regulation. It was moved and seconded (Norris/Fraundorf) to continue the Amendment to the Estes Valley Development Code concerning the regulation of small-scale residential and commercial wind turbines to the next regularly scheduled meeting, and the motion passed unanimously with one absent. 4. REPORTS None. There being no further business, Chair Klink adjourned the meeting at 4:05 p.m. it 6 2 X h. Doug Klink, Ch~ir\1 /47 1 , I I Karenil-honipson, R@cording Secretary 4 nK. 4 1 +4244 -2 \11 /46.'....r'.4. '.1.1.6.,L....-,9.40~ 5.,0 - h/' /1 I : k 44 ,»3 9. :. ~ 1. ...h '. 6, 1 I . 3 'E . 28 £ 2/ e ., Wind Turbines ~ Estes Park Community Development Department Municipal Building, 170 MacGregor Avenue PO Box 1200 ~ Estes Park, CO 80517 ........Ii. Phone: 970-577-3721 Fax: 970-586-0249 www. estesnet.com DATE: = pp A 1,0-4 Estes Valley Planning Commission - - 1 113 r-9:=Ir----'-j / _ USES f . November 12,2009: Initial discussion, set B~ -uR._Z--r~-4-11 -- -2 parameters 1-1 Fi- fr LAJ t-~ • November 17, 2009 R)cky F.=M 1,blrltain USES Itdioral Town Board - F~M< •December 8,2009 a -I Board of County Commissioners - USFS RM\p uy axin® • March 8, 2010 (tentative) - REQUEST: To adopt regulations pertaining to Small Wind Energy Conversion Systems (commonly referred to as "small wind turbines") STAFF CONTACT: Bob Joseph PURPOSE AND INTENT: The purpose of this proposed amendment is to establish use and development regulations for Small Wind Energy Conversion Systems (SWECS) within the Estes Valley. FORMATTING: 1) Existing text in black font. 2) Proposed text in blue underlined text. 3) Text to be removed in Fed-6$Fikethmugh. § 5.2 ACCESSORY USES (INCLUDING HOME OCCUPATIONS) AND ACCESSORY STRUCTURES A. General Standards. [No Changes] B. Accessory Uses/Structures Permitted in the Residential Zoning Districts. 1. Table of Permitted Accessory Uses and Structures. Table 5-1 Accessory Uses and Structures Permitted in the Residential Zoning Districts Residential Zoning District "Yes" = Permitted "No" = Not Permitted Additional Accessory Use RE-1 RE E-1 E R R-1 R-2 RM Requirements Small Wind Enemy Yes Yes Yes Yes Yes Yes Yes Yes §5.2.B.2.h Conversion Svstems 2. Additional Requirements for Specific Accessory Uses/Structures Permitted in the Residential Zoning Districts. h. Small Wind Energy Conversion Systems (SWECS, or "system"). (1) HeiGht. Height shall be measured to the highest point of the SWECS structure movina or fixed, whichever is greatest, and shall not exceed thirty (30) feet. (2) Setbacks from Propertv Lines. Setbacks from property lines shall be five times the structure height. For example: a twenty (20) foot tall system shall have a minimum setback of 100-feet from the nearest property line: a thirty (30) foot tall system shall have a minimum setback of 150-feet from the nearest property line. (3) Ridgeline Protection Areas. SWECS shall not be permitted on land designated as a ridqeline protection area. If the site contains an identified ridqeline protection area, the Applicant mav, bv site-specific analysis, demonstrate that the location of the proposed system is not visible from off- site: this shall require development plan review and approval of the Estes Valley Planning Commission. Such development plan application shall include a visual analysis, including photographic simulations, from viewpoints as determined bv Staff, to verify the system is not visible from off-site. (4) Noise. All svstems outside the Town limits of the Town of Estes Park shall comply with the noise standards found in Larimer Countv Ordinance 97-03 (as amended). All systems located within the Town of Estes Park shall comply with the noise standards found in the Municipal Code of the Town of Estes Park. (5) Shadow Flicker. Systems shall be designed and sited in such a manner to minimize shadow flicker on roadways and on residences located off the property on which the wind machine is constructed. 04 Lighting Prohibited. Lighting, graphics, signs and other decoration are prohibited. (7) Operating Condition. A\\ systems shall be kept in safe operating condition. Inoperative systems, or svstems found to be unsafe bv an official of the Town of Estes Park Light and Power Department, or the Protective Inspection Divisions of the Town of Estes Park or Larimer County, shall be repaired within three (3) months of becoming inoperative or unsafe, or be subsequently entirely removed bv the owner, at the owners expense, within six (6) months of becoming inoperative or unsafe. If the installation ceases to function as intended and designed bv the manufacturer it shall be deemed inoperative. (8) Ground Clearance. The minimum distance between the qround and anv blades or moving parts utilized on a system shall be ten (10) feet as measured at the lowest point of the swept area. (9) Blade Speed. Systems shall be equipped with both manual and automatic controls to limit the rotational speed of the blade within the design limits of the rotor. (10) Safety Standards. S\NECS shall meet or exceed current published safety standards as issued bv the International Electrotechnical Committee (IEC), International Standards Organization (ISO), and International Enqerav Agency (IEA). (11) Permit Required. A building permit shall be required for the installation of all Small Wind Enerav Conversion Systems. (12) Limit on Number. There shall not be more than one (1) system on a lot. (13) Micro-Wind. Systems with a swept area of five (5) square feet or less shall be exempt from the regulations set forth in this section, but shall not be exempt from setback, height, or other general development standards set forth in the Estes Vallev Development Code. C. Accessory Uses and Structures Permitted in the Nonresidential Zoning Districts. 1. Table of Accessory Uses and Structures Permitted in the Nonresidential Zoning Districts. Table 5-2 Accessory Uses Permitted in the Nonresidential Zoning Districts Nonresidential Zoning District "Yes" = Permitted "No" = Not Permitted Accessory Use --- - A- A-1 CD CO O - CH- 1-1'- Additional Conditions Small Wind Energy Yes Yes Yes Yes Yes Yes Yes 5.2.B.2.h --1- Conversion Systems D. General Dimensional and Operational Requirements. The following standards shall apply to all accessory uses and structures in all zoning districts, except for: (1) Satellite antenna dishes accessory to residential uses that are one (1) meter or less in diameter; and (2) Satellite antenna dishes accessory to nonresidential uses that are two (2) meters or less in diameter. (Ord. 15-03 #1) 1. Time of Establishment. No accessory use shall be established and no accessory structures shall be allowed on the subject parcel until after all required permits and approvals for the principal use or activity have been obtained. (Ord. 15-03 #1) 2. Setbacks. No accessory use, structure or activity, except for permitted fences or walls shall be located or take place within a required setback. On residential lots of less than one (1) acre all accessory buildings, excluding detached garages, shall be located no closer to the front property line than the residential dwelling. Small Wind Energy Conversion Systems shall be subiect to setback requirements set forth in Sections 5.2.B. (Ord. 15-03#1) 3. Setbacks from Easements. No accessory structure shall be located within any platted or recorded easement or over any known utility. (Ord. 15-03 #1) 4. Maximum Building or Structure Size for Nonresidential Uses. \No Changesl 5. Maximum Cumulative Gross Floor Area Allowed for all Accessory Uses in Accessory Buildings, Accessory Structures And/or Principal Buildings for Residential Uses. INO Changes] 5. Maximum Number of Freestanding Accessory Buildings and Structures, Including Detached Garages, Per Single-Family Residential Lot. No more than one (1) accessory building or structure less than or equal to one hundred twenty (120) square feet and no more than two (2) accessory buildings or structures greater than one hundred twenty (120) square feet shall be allowed on a lot of two-and-a-half (2.5) acres or less. Small Wind Enerqv Conversion Systems and t'micro-windl systems shall be exempt from this limitation. 7. Building or Structure Height. The height limitations set forth in the underlying zoning districts shall apply to all accessory buildings and structures located therein. (Ord. 15- 03 #1) 8. Dwelling Unit Prohibited. IN~ Changes] 9. Operations. Accessory structures, buildings and uses shall be constructed, maintained and conducted to avoid production of noise, vibration, concussion, dust, dirt, smoke, odors, noxious gases, fly ash, heat or glare from artificial illumination or from reflection of natural light. 10. Limits on Mobile Homes/RVs. INQ Changes] Chapter 13- Definitions Section 13.3 xxx. Small Wind Energy Conversion System (SWECS). A wind enerqv conversion system consisting of a wind turbine, a tower, and associated control and conversion electronics, which has a rated capacity of not more than 25 kW and which is intended to primarily reduce on-site consumption of utilitv power. Such systems are accessory to the principal use or structure on a lot. ~SCEUVEJ Michael C. Headley, PE 1365 Deer Path Court ~~ NOV 1 6 2009 Estes Park, CO 80517 November 16,2009 L TO: Estes Valley Planning Commission SUBJECT: Residential Wind Turbines cc: Estes Town Board Thank you for allowing public comment regarding the Draft Proposal on wind turbines at the special meeting November 12, 2009. As you may recall, I mentioned my surprise at the survey results and questioned the 50' maximum height. But I failed to mention my real surprise was that this issue is even up for debate. Residential wind turbines should be banned within the city limits. Period. With 35 years as a Professional Engineer in the control industry, I conducted various feasibility studies regarding energy. From my background-and what was presented at the meeting-I think it is safe to conclude residential use of wind turbines is not a sound engineering solution. And though I did not keep score, those who spoke at the meeting were at least 2 to 1 against-not the 2 to 1 in favor as the survey reflected. My professional background also included Codes and Standards. After the meeting, I did some research (Estes Valley Development Code, Residential Zoning, and Larimer County Land Use Code) and it did not take long to find several points that the Proposed Draft does not consider, ignores, or simply disagrees with. Though these "engineering issues" are disturbing, that is not why I write this. Here is my story: My wife and I have been coming to Estes and RMNP for 40 years. For 40 years we worked, planned, and dreamed to live in Estes. Our dream has been realized as we moved here in mid-August. We always admired, cherished, and respected RMNP's commitment to environmental stewardship to maintain its beauty for future generations. As a result, RMNP remains preserved and it looks just like it did when we first saw it 40 years ago. Breathless! Let's follow RMNP's lead so future generations can realize the same dream about Estes that my wife and I had. To put it another way, we didn't work, plan, and dream for 40 years to have a wind turbine block the view of Longs Peak. I contend the majority of Estes residents would concur. At a minimum, the ban should be continued. My hope is we can preserve the natural beauty that Estes Park and RMNP are nationally known. Please let me know if I can assist or serve on any subcommittee to help provide a viable engineering solution. Respectfully submitted, Mike Headley, Professional Engineer