Attachment C - VPC Summary - Z-9-22-4.pdf

City of Phoenix — Formal (2023-09-06)

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City of Phoenix • Planning & Development Department 
200 West Washington Street, 3rd Floor • Phoenix, Arizona  85003-1611 • (602) 262-6882 
 
 
Village Planning Committee Meeting Summary 
Z-9-22-4 
INFORMATION ONLY 
 
 
Date of VPC Meeting 
August 23, 2022 
Request From 
C-2 TOD-1 
Request To 
PUD 
Proposed Use 
PUD to allow mixed use multifamily 
Location 
Southwest corner of Central Avenue and Coolidge Street 
 
VPC DISCUSSION 
 
One virtual speaker card was received from an individual opposed and wishing to 
speak. 
 
Mr. Nick Klimek, staff, provided an overview of the PUD process including the purpose 
of this information only hearing being to solicit directive input from the Alhambra Village 
Planning Committee.  
 
APPLICANT PRESENTATION  
 
Mr. Benjamin Tate introduced himself as the applicant’s representative. The subject 
site is small with only 1.09 net acres located at the southwest corner of Central Avenue 
and Coolidge Street. The site is surrounded by multifamily to the north, west, and south 
across the Grand Canal. The request is for Transect 5:6 which would allow a height of 
80 feet which is one step more intense than the Transect 5:5 which is identified in the 
Uptown TOD Policy Plan. While more intense than recommended, this additional 
intensity comes with enhancements that are aligned with the vision for canal adjacent 
development contained in the Uptown TOD Policy Plan. 
 
The development team is proposing ground floor commercial and 150 residential units 
in a seven story configuration with a wrapped parking structure. The project activates 
the canal with a food/beverage suite, live/work units, and form with multiple elevated 
amenity decks oriented to the canal where the building steps back from the canal. The 
proposal contains all of its required parking within the parking structure which is 
accessed from Central Avenue only. The approach to vehicular circulation and parking 
is in response to concerns from the Pierson Place neighborhood regarding cut-through 
traffic. The proposal includes many sustainability elements and may even include 
geothermal energy. 
ATTACHMENT D

Alhambra Village Planning Committee 
Meeting Summary 
Z-9-22-4 
Page 2 of 3 
 
 
City of Phoenix • Planning & Development Department 
200 West Washington Street, 3rd Floor • Phoenix, Arizona  85003-1611 • (602) 262-6882 
 
The traffic impact statement and trip generation model show that the traffic impact for 
the site will be insignificant at approximately 67 per hour at peak times.  
 
QUESTIONS FROM COMMITTEE 
 
Committee Member Bonilla asked who is designing and constructing the project. Mr. 
Tate responded that Merge Architecture is the designer, and that RAS Development is 
the developer at this time. Committee Member Bonilla asked if RAS had done any 
projects of this scale and type before. Mr. Tate Responded that they have not. 
Committee Member Bonilla stated that the amenity deck above the food/beverage 
suite will allow the restaurant to be vented properly. He expressed support for the 
project. 
 
Committee Member Keyser stated that it is nice to have an applicant come early. He 
expressed support by describing it as the right project, in the right place, at the right 
time.  
 
Committee Member Adams asked if there was neighborhood support for the project, 
specifically to its height. Mr. Tate responded that Withey Morris also represented the 
applicant for Z-56-20-4 which was located west on Coolidge Street and, in that case, 
traffic was a central issue and the neighborhood was clear that height and intensity 
belongs along Central Avenue and key leaders have held to that position. He added that 
cut-through traffic and on-street parking are major issues in the Pierson Place 
neighborhood and that their design eliminates those as potential issues. 
 
Committee Member Adams asked for how the 67 vehicles per hour at peak time was 
calculated. Mr. Tate responded by explaining the internationally accepted methodology 
and regularly updated ITE Trip Generation Manual.  
 
Committee Member Adams asked why the canal is a central feature of the project 
because they are glamorized in the renderings and are not actually very nice. Mr. Tate 
responded that the Uptown TOD Policy Plan sets that vision for the canal. 
 
Committee Member Harris expressed support for the project and stated that the 
architecture looks nice. She asked if the project will include detached sidewalks. She 
also asked if the parking for the commercial spaces will be located within the parking 
structure, noting that can be confusing for prospective customers. Mr. Tate responded 
that the sidewalks along Central Avenue will not be detached but will instead function as 
a wider pedestrian thoroughfare as required by the “Central Avenue Development 
Standards.” He stated that all parking is located within the parking structure in order to 
respond to the concerns from the Pierson Place neighborhood. 
 
Committee Member McCabe stated that he is a fan of the Canalscape Vision and feels 
this project can be a model for other projects. He stated that he was originally reluctant 
to have the only access from Central Avenue but sees that it is in response to 
neighborhood concerns.

Alhambra Village Planning Committee 
Meeting Summary 
Z-9-22-4 
Page 3 of 3 
 
 
City of Phoenix • Planning & Development Department 
200 West Washington Street, 3rd Floor • Phoenix, Arizona  85003-1611 • (602) 262-6882 
 
Vice Chair Bryck stated that this site is rendered in the Uptown TOD Plan and 
recommended the developer incorporate elements to further align the project with that 
vision. Mr. Tate thanked Vice Chair Bryck for the comments and stated that the biggest 
alignment in the current proposal is the food/beverage suite along the canal that is 
envisioned as a destination for canal users.  
 
PUBLIC COMMENTS 
 
Mr. Jeremy Thacker expressed concern that the project will send traffic south on 
Central Avenue will cut-through traffic going westbound on Campbell Avenue which has 
more than 600 pedestrian crossings per day. The placement of all driveways on Central 
Avenue advantage Pierson Place and disadvantage the Carnation Neighborhood to the 
south. He alleged that Committee Member Jones has conflicts of interest on both Z-56-
20-4 at the southwest corner of 3rd Avenue and Coolidge Street and on the Forty600 
PUD as a former owner. He expressed concern over the proposed 100 percent lot 
coverage as being inconsistent with the Uptown TOD Policy Plan. He stated that the 
developer should engage with the Carnation Neighborhood regarding the project 
because it will impact them most severely. He added that he obtained review comments 
from the City of Phoenix which identify the many problems with the project. 
 
Committee Member Jones responded by stating that he had divested himself of the 
parcel and that there is no conflict of interest. He stated that there was a complaint filed 
for conflict of interest for Z-56-20-4 but that he was quickly cleared by the City of 
Phoenix.  
 
Committee Member Malkoon stated that there should be engagement to the Carnation 
Neighborhood. 
 
Committee discussion regarding traffic in Central Phoenix.  
 
APPLICANT RESPONSE  
 
Mr. Tate reiterated that the projected traffic impact of this project is negligible and that 
the project is located within the Pierson Place neighborhood and those residents have 
therefore been prioritized to reduce impact on their neighborhood.   
 
FLOOR/PUBLIC DISCUSSION CLOSED: COMMITTEE DISCUSSION 
 
Committee discussion regarding traffic in Central Phoenix.

City of Phoenix • Planning & Development Department 
200 West Washington Street, 3rd Floor • Phoenix, Arizona  85003-1611 • (602) 262-6882 
 
 
Village Planning Committee Meeting Summary 
Z-9-22-4 
 
 
 
Date of VPC Meeting 
June 27, 2023 
Request From 
C-2 TOD-1 
Request To 
PUD 
Proposal 
PUD to allow mixed use multifamily 
Location 
Southwest corner of Central Avenue and Coolidge 
Street 
VPC Recommendation 
Approval, per the staff recommendation 
VPC Vote 
8-5 
 
 
VPC DISCUSSION & RECOMMENDED STIPULATIONS: 
 
Three members of the public registered to speak on the item. 
 
STAFF PRESENTATION 
 
Samuel Rogers, staff, reviewed the surrounding land uses, zoning designations, and 
site context. Mr. Rogers displayed the proposed site plan, elevations, recommended 
stipulations, and concluded with staff findings. 
 
APPLICANT PRESENTATION 
 
Benjamin Tate, with Withey Morris Baugh, PLC, described the subject site location and 
surrounding land uses, details about the proposal, and presented the elevation 
renderings, site plan, and landscape plan. Mr. Tate described the project’s features, 
how the project would make enhancements to the Grand Canalscape, a $250,000 
donation to the City of Phoenix for canalscape improvements, how the proposal is 
incorporating sustainability, and concluded with a summary of the proposal.  
 
QUESTIONS FROM THE COMMITTEE 
 
Committee Member Adams asked how the development addresses shaded sidewalks, 
what the species of milkweed shrubs will be required, and how the development will 
mitigate the negative impact of the canal when it is drained and cleaned. Mr. Tate

Alhambra Village Planning Committee 
Meeting Summary 
Z-9-22-4 
Page 2 of 7 
 
 
 
City of Phoenix • Planning & Development Department 
200 West Washington Street, 3rd Floor • Phoenix, Arizona  85003-1611 • (602) 262-6882 
explained that the PUD requires the sidewalks on Coolidge Street and Central Avenue 
be 75% shaded at tree maturity and 50% shaded along the Grand Canal. Mr. Tate 
explained that the shading along the Grand Canal is limited by only being able to 
provide trees and shade structures within the development’s property lines. Mr. Rogers 
stated he would follow up with the milkweed species names. Mr. Tate explained that the 
Grand Canal must be cleaned once a year and it is something that the development will 
need to deal with.  
 
Committee Member Christian Solorio stated that the City of Phoenix is in an 
affordable housing crisis, and he is happy to hear Councilperson Pastor brought up 
housing affordability as one of her top priorities. Committee Member Solorio explained 
that in the 2023 Low Income Housing Tax Credit awards the average cost of an 
affordable housing unit was $380,000 and stated that there seems to a disconnect 
between the amount that would have been donated for affordable housing and the 
$250,000 that will be donated for improvements to the Grand Canal. Mr. Tate explained 
that the donation amount was calculated by using a previous zoning case in 2018 where 
an in-lieu housing contribution was calculated on a square foot basis. Mr. Tate stated 
that the inflation adjusted donation amount for the in-lieu housing contribution would 
have been $237,000 for this project, so the $250,000 canalscape donation is greater 
than the amount the in-lieu fee would have been. Committee Member Solorio stated 
that a better precedent should be set.  
 
Committee Member Pamela Fitzgerald asked if any restaurants are currently 
interested in occupying the canal-oriented restaurant. Mr. Tate stated that the developer 
is in talks with a user but that information has not been made public. Committee 
Member Fitzgerald asked how optimistic the development team is about cooperation 
with the Salt River Project (SRP). Mr. Tate stated he is somewhat optimistic because 
the south side of the canal has a service road which should satisfy SRP’s maintenance 
needs and because SRP has worked with Scottsdale and allowed them to make 
canalscape improvements.  
 
Committee Member Jim DeGraffenreid asked about traffic that will cut through 
neighborhoods, asked if there is sufficient light rail capacity, and stated he would like 
the committee to consider having the $250,000 donation go directly to low-income 
housing now rather than to affordable housing in five years if an agreement between the 
City of Phoenix and SRP cannot be made regarding canalscape improvements. Mr. 
Tate stated that traffic impact analysis found that 150 additional units will not have a 
significant impact on an arterial street such as Central Avenue and stated there is 
sufficient light rail capacity.  
 
Committee Member Jak Keyser stated that traffic along Central Avenue will get better 
once the area reaches a critical mass of mixed-use development and residents have the 
ability to live, work, and play in the area. Committee Member Keyser stated he worked 
on affordable housing between 2006 and 2016 in his area around 27th Avenue and had 
also worked with the Bureau of Reclamation and SRP to do canalscape improvements.

Alhambra Village Planning Committee 
Meeting Summary 
Z-9-22-4 
Page 3 of 7 
 
 
 
City of Phoenix • Planning & Development Department 
200 West Washington Street, 3rd Floor • Phoenix, Arizona  85003-1611 • (602) 262-6882 
Committee Member Keyser stated that some of the fees the City of Phoenix will charge 
the development will go towards art.  
 
Committee Member Elizabeth Sanchez asked for confirmation that no affordable 
housing is proposed as part of the development and stated that some of the 
development surrounding light rail and transit should be affordable. Mr. Tate stated that 
the absence of affordable housing is a result of high land cost and construction costs, 
not because the development team does not want to build affordable units.  
 
Committee Member Pamela Fitzgerald stated that are many affordable housing 
complexes along Camelback Road from Central to 19th and up 17th and 18th.  
 
Committee Member Melisa Camp asked how many luxury multifamily developments 
are in the area, asked what type of construction will be used, will water be recaptured, 
and is there enough water. Mr. Tate stated that land cost, construction costs, and 
interest rates cause developers to have to build luxury developments, explained that 
development would be concrete on the first two stories and wood frame construction on 
the upper five stories and stated that water recapturing has not been discussed, but 
sustainability is important to the developer and the development team is open to 
continuing the conversation after the meeting. Mr. Tate stated that there is enough 
water to supply the development and stated that multifamily is the most water efficient 
form of housing. Committee Member Camp asked how and if the development will use 
solar and geothermal energy and asked how many basic needs will be provided in the 
commercial spaces. Lorne Wallace, the developer, explained he has had difficulty 
researching geothermal power because there is not much precedent for geothermal 
power in Arizona, and stated he is looking into solar power, but the development is 
restricted by the amount of available roof space. Mr. Tate explained that the commercial 
spaces have not been leased, but any use allowed in the Walkable Urban Code would 
be allowed. Committee Member Camp asked if the live/work units and leasing office are 
included in the 7,100 square feet of commercial space and if the developer is planning 
to sell or hold the property. Mr. Tate stated that the first floor of live/work units and the 
leasing office are counted toward the total square footage of commercial space. Mr. 
Wallace stated that he is planning to hold the property. 
 
Committee Member Keyser stated that affordable housing does not make sense on 
Central Avenue because of the price per square foot and because the State of Arizona 
does not provide subsidies for the construction of affordable housing. Committee 
Member Keyser stated the development will also have to pay impact fees and asked 
about the fee amount that will go towards art and the total project cost. Mr. Tate stated 
that he does know the exact amount, but stated it is a lot of money.  
 
Committee Member Jamaar Williams asked how large the area is where the 
$250,000 donation towards canalscape improvements will be spent. Mr. Tate stated 
that the decision of where the $250,000 donation is spent will be up to the City of 
Phoenix and added that it is in the development’s best interest to have the funds spent 
along the stipulated stretch of canal frontage rather than only in front of the

Alhambra Village Planning Committee 
Meeting Summary 
Z-9-22-4 
Page 4 of 7 
 
 
 
City of Phoenix • Planning & Development Department 
200 West Washington Street, 3rd Floor • Phoenix, Arizona  85003-1611 • (602) 262-6882 
development’s frontage. Committee Member Williams asked how hopeful the 
development team is that SRP will allow the City of Phoenix to make improvements 
along the Grand Canal and asked if any other Council Members other than 
Councilperson Pastor had been involved in discussion with SRP. Mr. Tate stated that he 
thought SRP was interested in working with the City on the canalscape improvements, 
but SRP was not incentivized to move quickly. Mr. Tate explained that the donation 
funds will be spent in Councilperson Pastor’s district between 7th Street and 7th 
Avenue, so only Councilperson Pastor had been involved in discussions with SRP.  
 
Committee Member DeGraffenreid reiterated that he believed that the donation funds 
should be used for affordable housing now, rather than for canalscape improvements 
and explained that with land prices rising, $250,000 will not be much money for 
affordable housing in five years.  
 
Committee Member Keyser stated he does not think the citywide burden of funding 
affordable housing should be placed on one developer and explained that the City of 
Phoenix needs fund from everywhere. Mr. Keyser added that wealthy people need 
places to live as well, stated that wealthy people coming to Phoenix is good for the 
economy, and explained that if there is more money in the economy, there will be higher 
tax revenues that can be spent of affordable housing.  
 
PUBLIC COMMENTS 
 
Jeremy Thacker explained that the half mile between Central to 7th and between 
Indian School to Camelback will triple in population to become the densest 
neighborhood in the City of Phoenix with 4,500 multifamily luxury units coming into the 
area. Mr. Thacker explained that in these new developments there is 0% affordable-
housing, 1% commercial, and 2,000 parking spaces. Mr. Thacker explained that the 
light rail causes all traffic leaving the development to turn south onto Central Avenue 
towards Mr. Thacker’s neighborhood, the Carnation Neighborhood. Mr. Thacker asked 
why all traffic is being directed away from Coolidge Street and towards his 
neighborhood. Mr. Thacker stated that 2,500 square feet of commercial is not enough 
and explained that the restaurant space should be where the commercial is indoors, 
and the proposed location of the restaurant should be a patio. Mr. Thacker stated the 
policy framework provides height incentives if 30% of open space or affordable housing 
is provided and explained that to receive the height incentive the development should 
have to donate the equivalent cost of providing 30% open space towards improving the 
canalscape. Mr. Thacker stated that 30% of the $2.5 million land cost is $750,000, so 
$750,000 should have been donated to improve the canalscape for the development to 
receive the height incentive. Mr. Thacker stated that paid parking should be 
implemented to reduce rents and encourage transit usage.  
 
Ken Waters stated that the Uptown TOD Policy Plan states that this site calls for 
Transect T5, while the proposal is for Transect T6 to get an additional 24 feet in height. 
Mr. Waters stated that this is a good project but proposed three items that should be 
different. First, there should be more patio space, second the live/work units should be

Alhambra Village Planning Committee 
Meeting Summary 
Z-9-22-4 
Page 5 of 7 
 
 
 
City of Phoenix • Planning & Development Department 
200 West Washington Street, 3rd Floor • Phoenix, Arizona  85003-1611 • (602) 262-6882 
converted to commercial, and third the leasing office should be moved off Central 
Avenue.  
 
Ron Szematowicz stated he would be in favor of the project if the traffic stays on 
Central Avenue, explained multifamily developments are causing traffic issues in the 
area, and stated it is dangerous to turn onto Central Avenue from Coolidge Street due 
to the abundance of cars parked along Coolidge Street.   
 
APPLICANT RESPONSE 
 
Mr. Tate thanked members of the public for their comments and stated that he hopes 
members of the committee and the public can see the thought, effort, and patience that 
went into addressing community concerns. Mr. Tate stated that there are trade off with 
shuffling the first-floor commercial space and explained that if the restaurant is moved 
inside, commercial space will be lost. Mr. Tate referenced concerns about 
approximately 4,000 new units coming into the area and stated that the staff report 
references the Uptown TOD Policy Plan which projects a shortfall of approximately 
10,000 housing units in the Central corridor alone. Mr. Tate asked where density should 
go if not near light rail and in a location designated for density in City of Phoenix policy 
plans. Mr. Tate stated that the Traffic Impact Analysis showed that the development will 
not have a significant impact on surrounding neighborhoods such as the Carnation 
Neighborhood. Mr. Tate stated that Mr. Waters had expressed a desire for the entirety 
of the project frontage along the Grand Canal to be commercial and explained that the 
developer is already taking a great risk by providing a restaurant with no street frontage.  
 
FLOOR/PUBLIC DISCUSSION CLOSED: MOTION, DUSCUSSION, AND VOTE 
 
Committee Member Maurita Harris asked if the committee is able to alter the amount 
of the donation. Mr. Rogers stated that the committee may make a motion to alter any 
of the stipulations. Committee Member Harris stated that she would like to make a 
motion to increase the donation amount to $500,000 and reduce the time frame before 
funds are transferred to the Housing Department to three years.  
 
Committee Member Solorio stated that the time limit for the City of Phoenix and the 
Salt River Project to reach an agreement before funds are transferred to the Housing 
Department should be decreased to zero years.  
 
Committee Member Harris asked if the funds are given to the Housing Department will 
the developer still make improvements along the Grand Canal. Chair Bryck asked Mr. 
Tate to respond to Committee Member Harris’ question. Mr. Wallace stated that 
donating to the Housing Department and making canalscape improvements had not 
been discussed. Mr. Tate stated that the canal is owned by SRP and not by the 
developer, so improvements should be made by the City of Phoenix through 
cooperation with SRP. Chair Bryck summarized Mr. Tate’s comment that in the current 
proposal either affordable housing will be funded or canal improvements somewhere

Alhambra Village Planning Committee 
Meeting Summary 
Z-9-22-4 
Page 6 of 7 
 
 
 
City of Phoenix • Planning & Development Department 
200 West Washington Street, 3rd Floor • Phoenix, Arizona  85003-1611 • (602) 262-6882 
along the Grand Canal. Mr. Rogers clarified that, per Stipulation No. 2, canalscape 
improvements are required to be made between Central Avenue and 3rd Avenue.  
 
Committee Member Harris asked where the money will go if it is given for affordable 
housing. Mr. Rogers stated that funds are required to be spent on affordable housing 
within Council District 4.  
 
MOTION 
Committee Member Harris made a motion to recommend approval of Z-9-22-4 per the 
staff recommendation with modifications to Stipulation No. 2 to increase the donation 
amount from $250,000 to $500,000 and to decrease the time limit for the City of 
Phoenix and the Salt River Project to reach an agreement before funds are transferred 
to the Housing Department from five years to zero years. Committee Member 
DeGraffenreid seconded the motion.  
 
DISCUSSION 
Committee Member Keyser stated that the proposed motion will not get past Planning 
Commission or City Council and stated that the committee is looking a gift horse in the 
mouth as the developer is offering $250,000. Committee Member Keyser stated that the 
proper way to provide affordable housing should be a City Ordinance that requires a fee 
to be assessed on new developments that shall be used for affordable housing. 
Committee Member Harris stated that she thinks the committee should still try to pass 
the motion even if it will not get past Planning Commission and City Council. 
Committee Member Solorio stated that Committee Member Keyser was describing 
Mandatory Inclusionary Zoning which is illegal in Arizona. Committee Member 
DeGraffenreid stated that whether the proposed motion will get past Planning 
Commission and City Council, it is the responsibility of the committee to push on the 
City of Phoenix. 
 
Committee Member Dina Smith asked how to the Housing Department can spend the 
funds if they receive them. Mr. Rogers stated that the fund must be used for affordable 
housing in Council District 4.  
 
Committee Member Keyser stated that improving the canalscape will be good for the 
City and stated he would like to increase the donation amount and reduce the time 
frame before funds are transferred to the Housing Department to three years. 
 
Chair Bryck stated that he was excited for the project as a former member of the 
ReinventPhx committee where there was a huge push towards canalscape 
improvements. Chair Bryck explained that this project represents a test case for canal 
development and stated he was hopeful that this project would catalyze canal 
development across the City.  
 
Committee Member Keith Ender asked who funded other improvements along the 
Grand Canal. Committee Member Keyser stated that in Scottsdale the City of 
Scottsdale and the Maricopa Association of Governments funded canalscape

Alhambra Village Planning Committee 
Meeting Summary 
Z-9-22-4 
Page 7 of 7 
 
 
 
City of Phoenix • Planning & Development Department 
200 West Washington Street, 3rd Floor • Phoenix, Arizona  85003-1611 • (602) 262-6882 
improvements. Committee Member Keyser echoed Chair Bryck’s hopes that this 
development will catalyze canalscape improvements in other developments.  
 
Committee Member Harris asked if the committee could require a total donation of 
$500,000 with $250,000 going towards canalscape improvements and $250,000 for 
affordable housing. Mr. Rogers stated that the committee can modify or add 
stipulations as they see fit. 
 
Committee Member Harris stated that she would like to make a friendly amendment to 
her motion to modify Stipulation No. 2 to reduce the time frame before funds are 
transferred to the Housing Department to three years and to require an additional 
$250,000 to be donated directly to housing department. Committee Member 
DeGraffenreid accepted the friendly amendment.  
 
Committee Member Ender stated that the developer’s donation of $250,000 is 
generous and stated this is not the right venue to be debating for affordable housing.  
 
Committee Member Adams stated that increased landscaping along the canal will 
draw in more development that can potentially fund affordable housing.  
 
Committee Member Solorio stated that the developer is receiving height allowances 
for providing the donation, so the Village Planning Committee is where the stipulations 
should be debated.  
 
VOTE 
4-9, motion to recommend approval of Z-9-22-4 per the staff recommendation with 
modifications fails with committee members DeGraffenreid, Harris, Solorio, and Williams 
in favor and committee members Adams, Camp, Ender, Fitzgerald, Keyser, Sanchez, 
Smith, Shore, and Bryck opposed.  
 
MOTION 
Committee Member Adams made a motion to recommend approval of Z-9-22-4 per 
the staff recommendation. Committee Member Fitzgerald seconded the motion. 
 
VOTE 
8-5, motion to recommend approval of Z-9-22-4 per the staff recommendation passes 
with committee members Adams, Ender, Fitzgerald, Keyser, Smith, Solorio, Shore, and 
Bryck in favor and committee members Camp, DeGraffenreid, Harris, Sanchez, and 
Williams opposed. 
 
STAFF COMMENTS REGARDING VPC RECOMMENDATION: 
 
 
Staff has no comment.