HomeMy WebLinkAboutStaff Report 2410-3600CITY OF PALO ALTO
CITY COUNCIL
Special Meeting
Monday, October 21, 2024
Council Chambers & Hybrid
5:30 PM
Agenda Item
15.Colleagues Memo - Restoration of subjective aesthetic standards to Palo Alto’s Wireless
Communication Facilities (WCF) ordinance. Public Comment
CITY COUNCIL
Colleagues Memo
Sponsors: Council Member Lydia Kou and Vice-Mayor Lauing
Meeting Date: October 21, 2024
Report #: 2410-3600
TITLE
Colleagues Memo - Restoration of subjective aesthetic standards to Palo Alto’s Wireless
Communication Facilities (WCF) ordinance.
RECOMMENDATION
Repeal objective-only aesthetic standards for the siting and design of cell towers (WCFs) and
restore subjective aesthetic standards, public hearings, and Architectural Review Board review.
Support for Recommendation
1. The only reason that the City imposed “objective” standards was because the FCC forced
it in new rules issued in 2018. PTC and others did not think this was the right path. In
fact, Palo Alto’s ordinance anticipated that the Council could quickly repeal the
“objective” standards once it regained the authority to do so, because over 100 cities and
the League of California Cities had already sued the FCC by the time that Palo Alto enacted
the new ordinance in 2019. (PACC § 18.42.110(g)(h).)
Here is what the Ninth Circuit said in August, 2020, when it struck down the FCC’s restriction:
We conclude that the FCC's requirement that all aesthetic regulations be “objective” is
arbitrary and capricious. At the very least, the agency must explain the harm that it is
addressing, and the extent to which it intends to limit regulations meant to serve
traditional zoning objectives of preventing deployments that are unsightly or out of
neighborhood character. . . The requirement that local aesthetic regulations be
“objective” is neither adequately defined nor its purpose adequately explained.
City of Portland v. United States, 969 F.3d 1020, 1042 (9th Cir. 2020).
Before there were “objective-only” standards, there was a thoughtful list of subjective standards,
a list that had been prepared collaboratively by multiple City departments and by the ARB. The
City can seamlessly return to these standards now.
2. Careful and comprehensive review of wireless facilities is particularly necessary because
federal law allows small cell sites that are not entirely hidden to be increased in height
and girth by ten feet not withstanding zoning limits. (47 CFR § 1.6100(b)(7)(i).) This means
that even if a site complies with “objective” standards on the day it is approved, it can be
altered in ways that will not be compliant in the future. No other permit operates this
way.
3. Currently, because of the narrow scope of “objective” aesthetic review, issues with the
site of a proposed cell tower are not even eligible to be considered. Having a robust and
demanding discretionary application review process pushes applicants to self-regulate
and submit the best option in the first place, so there will be less need for appeals.
4. Staff has concern with shot clock compliance. But in practice, the 60-90 day shot clocks
are extended frequently - often because the applicant needs more time to get its own
application organized and complete internal engineering or planning related to trenching
and fiberoptic backhaul for installation.
Moreover, so long as the City makes a Director-level decision before the shot clock period
ends, it will have complied with the FCC regulations. (47 CFR § 1.6003(a).) The impact of
the shot clocks expiring after a decision is made will only be to cut off any subsequent
right to appeal if the applicant does not agree to an extension. In many instances, due to
the importance of cooperation from the City and the collaborative framework created by
the Master License Agreement, cell tower applicants will likely enter into shot clock tolling
agreements to stop the clock, even if it means allowing an appeal (sometimes that appeal
will be for their own benefit). Recently, for example, AT&T agreed to extend the shot
clock to allow a resident in Santa Cruz County to appeal because the County requested
this extension so that their process can play out as intended in their ordinance.
Voluntary shot clock tolling also goes both ways. If the City is approaching the end of the
shot clock and does not have the information needed to approve the application, the City
will deny the application to avoid blowing the shot clock. In those instances, the applicant
needs the City’s approval to extend the shot clock. As the regulations say, a tolling
agreement to stop the shot clock requires “a written agreement between the applicant
and the siting authority [i.e, the City].” (47 C.F.R. § 1.6003(d).) Caselaw confirms that
denying an incomplete application, without offering the applicant further opportunity to
remedy it, is lawful. (ExteNet Sys. v. City of Cambridge, 481 F. Supp. 3d 41, 51 (D. Mass.
2020).)
It is also important to keep in mind that while shot clocks were tightened by the FCC small
cell order from 2018, the concept was not new. Since 2009, a 90-day FCC shot clock was
in place for colocations. (FCC, Petition for Declaratory Ruling to Clarify Provisions of
Section 332(c)(7)(B), 24 FCC Rcd 13994 (November 18, 2009),) so the City has had
experience operating the discretionary process under similar time pressure.
5. Other cities have “small cell” cell tower ROW approval processes that include multiple
levels of review, each with a publicly-noticed hearing (e.g.Carmel-by-the-Sea, Malibu,
Martinez, Mill Valley, Pinole, San Francisco).
6. Presently, unless there is an appeal to City Council, there is no opportunity at all for a
public hearing because the Planning Director’s decisions are made in private. (Note that
the cell tower applicant may hold a “community meeting”, but this is a one-sided show
by the applicant. It is no substitute for real public participation, including input to city
officials. (PACC § 18.42.110(d)(7)). )
7. The inclusion of the ARB in the review process should not significantly increase the
workload of Planning staff. It somewhat increases the load on the ARB, but this is
something they want to take on. Moreover, applicants generally use consistent designs,
so it should not be that burdensome for the ARB to review an application. The main
question for them is how facilities can be camouflaged and best positioned to minimize
esthetic impacts.
In particular, the ARB is best qualified to prioritize siting and design goals. Right now,
there is no prioritization going on. Staff evaluates cell tower applications solely on the
basis of how few “exceptions” to objective standards they require, without taking into
account what the exceptions are that are being sought. Hence, proximity to a residence,
which is what residents care most about, is deemed no more important than, for example,
the color of the paint used on the pole.
8. So far, the City has only approved one standard design for cell towers, a design for a tower
located on a decorative metal lamp pole. As things stand now, the “objective” standards
are not actually consistently objective, because applicants frequently request and obtain
exceptions based on their own claims of necessity. (PACC § 18.42.110(k); Design
Standards, p.8.) Since non-objective (that is, subjective) decisions and tradeoffs are being
made all the time anyway, the question is, who should make them: The Planning Director
or the ARB? The ARB is best qualified to do this.
9. More robust review is also important because cities, such as San Mateo, are finding that
small cell applicants are not in fact compliant with permit conditions and are then
resistant to remedying these deficiencies when they are discovered.
10. Staff acknowledge that they lack the expertise to assess the accuracy of any transmission-
related assertions that applicants use to justify exceptions to the City’s standards. The
City should hire a technical expert that does not work for the telecom industry to quickly
make sure applications are complete so that the shot clocks can be halted within the 10
days after receipt of the application, and also to advise on what is or is not technically
feasible. This cost will, by law, be passed on to applicants. There are a few engineering
firms that solely represent municipalities, such as Center for Municipal Solutions
(http://www.telecomsol.com/www2/node/20), which review all applications submitted
to some of its city clients.
BACKGROUND
On September 26, 2018, the Federal Communications Commission (FCC) enacted the Declaratory
Ruling and Third Report and Order, known as the “Small Cell Order,” directing that local
regulation of Small Wireless Facilities in the public right-of-way must be published in advance
and be “(1) reasonable, (2) no more burdensome than those applied to other types of
infrastructure deployments, and (3) objective.”
In response to the Small Cell Order, on June 13, 2019, the City Council adopted Ordinance 5465,
which provided that Tier 2 wireless communication facilities (WCFs) (e.g., adding new equipment
to an existing small wireless facility (“collocation”)) and Tier 3 WCFs (e.g., new small wireless
facilities) would be no longer be subject to site-specific review and approval by the Architectural
Review Board (ARB) under Municipal Code Section 18.76.020, and instead would be required only
to comply with objective standards to be established by resolution. To be clear, the shift to
objective aesthetic standards didn’t simply dispense with subjective standards, it a) eliminated
public hearings for proposed cell towers, and b) left the decision to approve a cell tower solely in
the hands of the Director of Planning & Development.
On December 16, 2019, the City Council adopted Resolution 9873 amending and consolidating
objective aesthetic, noise, and related standards for WCFs on streetlights and wood utility poles
in the public rights of way.
In recognition that the Small Cell Order was being challenged in a lawsuit brought by numerous
municipalities against the FCC—a lawsuit City Council supported—Ordinance 5465 provides that
in the event that “the City Council repeals all objective standards, an application [for a Tier 2 or
3 WCF] shall not be granted unless, in addition to the other requirements of this section, all of
the architectural review findings in Section 18.76.020(d) can be made.”
On August 12, 2020, the Ninth Circuit issued its decision in City of Portland v. Federal
Communications Commission, 969 F.3d 1020, 1041-43,1 ruling that the Small Cell Order’s
requirement that local regulations must “be no more burdensome” and “objective” exceeded
the FCC’s authority and “must be vacated.” (A link to the Ninth Circuit’s ruling is attached below.)
FISCAL/RESOURCE IMPACT
The recommendation to restore prior subjective wireless standards and ARB findings and
processes is a straightforward task. This can be accomplished by directing staff to amend the
Wireless Communications Facility ordinance (PAMC section 18.42.110) in a manner consistent
1 On Petitions for Review of Orders of the Federal Communications Commission, Publication;
https://www.cityofpaloalto.org/files/assets/public/v/1/city-clerk/misc/18-72689.pdf
with this colleagues’ memo. This process requires an ordinance amendment that would be
reviewed by the Planning and Transportation Commission (PTC) which would forward a
recommendation to the City Council for action. Alternatively, for a more expedient process, the
City Council could bypass the PTC in accordance with PAMC section 18.80.090 and amend the
WCF ordinance on a temporary basis, e.g. two years, with the additional direction to refer a
permanent amendment to the PTC.
However, modifying the design standards and review process poses additional resource
impacts. Potentially the most significant impact would be to the ARB and City Council agenda
management. Switching from the current process, in which the Planning Director reviews a
project’s compliance with the objective standards and subjective standards are applied to any
requests for exceptions, to a fully discretionary review by the ARB will increase the amount of
time it takes to process applications. Staff would need to anticipate potential appeals on every
project and schedule final action hearings on the City Council’s agenda prior to the ARB review
hearing, in order to meet the mandated shot clock requirements, some of which are more
stringent than those mentioned in the memo. While the colleagues’ memo authors suggest an
extension for application review or appeals can be granted if agreed upon by the parties, this
approach cannot be mandated or relied upon for application processing. Applicants are unlikely
to choose this approach when presently, state or federal law (or both) provides “deemed
granted” approvals for all types of wireless project if the City fails to approve or deny it within
the limited shot clock period. In short, wireless communications facility applications are
expected to require time on the Council’s agenda to make final subjective determinations on
any appeal from the ARB’s project decision. This would impact the Council’s ability to advance
other Council priorities or discussions without flexibility for rescheduling to a later week for
agendas that are busy or run late.
In addition, changing the design standards and review process will impact staff resources. Staff
from Planning, Utilities, Public Works, Urban Forestry and the City Attorney’s Office already
participate in the application review, and would also need to be available for ARB and City
Council meetings. While staff can engage professional service agencies to respond to
application processing and review, administrative and overhead staff support will be required
to review work products, reports, and to schedule meetings. Initial training on the review
process and legal framework for wireless project decisions would also be required for ARB
members, for work currently performed and coordinated by Planning staff. Public meetings
before the ARB would require attendance from all departments contributing to wireless project
review. A wholly subjective process may impact the quality of applications received, since there
will be less guidance for project applicants on the City’s standards for review. It would also
increase the likelihood of applicant appeals or requests for judicial review if the City does not
approve a project, which would require further legal services to defend.
ATTACHMENTS
Attachment A: DRAFT Resolution Repealing Objective-Only Standards
DRAFT Resolution Repealing Objective Standards DRAFT
The Council of the Charter City of Palo Alto RESOLVES as follows:
SECTION 1. Findings and Declarations.
a. On September 26, 2018, the Federal Communications Commission (FCC) enacted the Declaratory
Ruling and Third Report and Order, known as the “Small Cell Order,” directing that local regulation of
Small Wireless Facilities in the public right-of-way must be published in advance and be “(1) reasonable,
(2) no more burdensome than those applied to other types of infrastructure deployments, and (3)
objective.”
b. In response to the Small Cell Order, on June 13, 2019, the City Council adopted Ordinance 5465,
which provided that Tier 2 wireless communication facilities (WCFs) (e.g., adding new equipment to an
existing small wireless facility (“collocation”)) and Tier 3 WCFs (e.g., new small wireless facilities) would
be no longer be subject to site-specific review and approval by the Architectural Review Board (ARB)
under Municipal Code Section 18.76.020, and instead would be required only to comply with objective
standards to be established by resolution. To be clear, the shift to objective aesthetic standards didn’t
simply dispense with subjective standards, it a) eliminated public hearings for proposed cell towers, and
b) left the decision to approve a cell tower solely in the hands of the Director of Planning &
Development.
c.On December 16, 2019, the City Council adopted Resolution 9873 amending and consolidating
objective aesthetic, noise, and related standards for WCFs on streetlights and wood utility poles in the
public rights of way.
d. In recognition that the Small Cell Order was being challenged in a lawsuit brought by numerous
municipalities against the FCC—a lawsuit City Council supported—Ordinance 5465 provides that in the
event that “the City Council repeals all objective standards, an application [for a Tier 2 or 3 WCF] shall
not be granted unless, in addition to the other requirements of this section, all of the architectural
review findings in Section 18.76.020(d) can be made.”
e. On August 12, 2020, the Ninth Circuit issued its decision in City of Portland v. Federal Communications
Commission, 969 F.3d 1020, 1041-43, ruling that the Small Cell Order’s requirement that local regulations
must “be no more burdensome” and “objective” exceeded the FCC’s authority and “must be vacated.”
f.The City Council now wishes to revoke the objective standards and subject Tier 2 and Tier 3 WCFs to
review by the ARB.
SECTION 2. Repeal of Objective Standards
a. The City Council hereby repeals the “Objective Standards for Wireless Communication Facilities in the
Public Rights of Way on Streetlight Poles and Wood Utility Poles” contained in Exhibits 1, 2 and 3 of
Resolution 9873.
b. The City Council hereby directs that an application for a Tier 2 and Tier 3 WCF permit “shall not be
granted unless, in addition to the other requirements of this section, all of the architectural review
findings in Section 18.76.020(d) can be made” by the ARB as provided in Municipal Code Section
18.42.110(g)(2) and (h)(2).
c. The City Council hereby directs Staff, in Staff’s review of Tier 2 and Tier 3 WCF applications, to apply
the guidelines in place prior to the passage of Resolution 9873—specifically, the guidelines that were
prepared jointly by the ARB, by the Department of Planning & Development, and by the Utility
Department—until such time that Staff brings to Council for consideration a revised list of guidelines,
and Council approves these guidelines.
d. In order to ensure and maintain the safety, property values and aesthetic qualities of Palo Alto streets
and neighborhoods, the City Council hereby directs Staff, in Staff’s review of Tier 2 and Tier 3 WCF
applications, to apply this additional guideline: Locating a WCF within 100 feet of a residential building
or within 300 feet of a public school a) shall be least preferred; b) shall only be permitted when there is
no other technically feasible location; and c) shall only be permitted if an expert, hired by the City and
having no telecommunications industry or telecommunications industry-related clients for at least two
years, has evaluated the WCF applicant’s assertions as to technical feasibility. The City Council hereby
directs Staff that its priority in the siting of WCFs is to maximize the distance between these facilities and
residences.
f. The City Council hereby directs Staff to provide the public with the text of any new or revised
guidelines Staff wishes to propose to City Council at least thirty days before Staff brings these guidelines
to City Council for consideration.
SECTION 3. Savings.
If any section, subsection, clause or phrase of this resolution or the attached standards is for any reason
held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the
resolution and exhibits. The City Council hereby declares that it would have adopted the resolution and
exhibits, and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that
any one or more sections, subsections, sentences, clauses or phrases be declared invalid.
SECTION 4. Environmental Review.
The City Council finds that this resolution is exempt from the provisions of the California Environmental
Quality Act (CEQA), pursuant to Section 15061 of the CEQA Guidelines, because it does not authorize the
construction of WCFs in any locations where such facilities are not already permitted; therefore it can be
seen with certainty that there is no possibility that the ordinance will have a significant effect on the
environment. The resolution is further exempt under CEQA Guidelines sections 15301, 15302, 15303 and
15305 because it represents part of a comprehensive regulatory scheme governing minor alterations to
existing facilities or small structures.
From:Phyllis Klein
To:Council, City
Cc:GStone22@gmail.com; LydiaKou@gmail.com; Ed@edlauing.com; Julie@julieforpaloalto.com;
Greg@gregtanaka.org; Vicki@vickiforcouncil.com; Clerk, City
Subject:Please vote to Agendize Kou/Lauing Colleagues Memo for full consideration
Date:Friday, October 18, 2024 10:18:58 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking
on links.
Dear Mayor Stone, Vice Mayor Lauing and Counci lmembers Burt, Kou, Lythcott-Haims, Veenker, and Tanaka,
I am writing to ask you to vote this Monday night in favor of putting Councilmembers Kou and Lauing’s ColleaguesMemo, a Memo titled “Restoration of subjective aesthetic standards to Palo Alto’s Wireless CommunicationFacilities (WCF) ordinance,” on a future Council agenda for full consideration and debate.
The City’s wireless ordinance needs to be updated. For years Palo Alto has been complying with a restrictive,confusing and fundamentally unworkable 2018 FCC Order with respect to standards for cell towers, an Order thatthe Ninth Circuit overturned four years ago.
Please note that both the Palo Alto Weekly and the Daily Post are covering Ms. Kou and Mr. Lauing’s ColleaguesMemo, the Post on the front page of their October 14, 2024 edition. In other words, there is broad interest in theissues the Memo raises, and these issues deserve to be debated by Council.
Thank you for your consideration.
Sincerely,Phyllis Klein
From:Mary Dimit
To:Council, City
Cc:GStone22@gmail.com; Ed@EdLauing.com; LydiaKou@gmail.com; Julie@JulieforPaloAlto.com;
Greg@GregTanaka.org; Vicki@VickiforCouncil.com; Clerk, City
Subject:Vote Yes to add Kou & Lauing Colleagues Memo to a future City Council agenda for discussion
Date:Thursday, October 17, 2024 3:00:26 AM
Some people who received this message don't often get email from marydimit@sonic.net. Learn why this isimportant
Dear Mayor Stone, Vice Mayor Lauing and Councilmembers Burt, Kou, Lythcott-Haims,
Veenker, and Tanaka,
I urge you to vote yes at Monday night’s (10/21/24) Council Meeting to put City Council members
Kou & Lauing’s Colleagues Memo related to adding aesthetic standards to Palo Alto’s wireless
ordinance on the agenda for a future City Council meeting so it can be discussed. This will hopefully
result in revisions to our current wireless ordinance to consider aesthetic standards for cell towers.
Thank you for your service to our community,
Mary Dimit
Palo Alto resident for over 30 years
From:Melinda McGee
To:Council, City
Cc:GStone22@gmail.com; LydiaKou@gmail.com; Ed@EdLauing.com; Julie@JulieforPaloAlto.com;
Greg@GregTanaka.org; Vicki@VickiforCouncil.com; Clerk, City
Subject:Please vote to Agendize Kou/Lauing Colleagues Memo for full consideration
Date:Wednesday, October 16, 2024 7:12:02 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking
on links.
> Dear Mayor Stone, Vice Mayor Lauing and Councilmembers Burt, Kou, Lythcott-Haims, Veenker, and Tanaka,> > I am writing to ask you to vote this Monday night in favor of putting Councilmembers Kou and Lauing’sColleagues Memo, a Memo titled “Restoration of subjective aesthetic standards to Palo Alto’s WirelessCommunication Facilities (WCF) ordinance,” on a future Council agenda for full consideration and debate.> > The City’s wireless ordinance needs to be updated. For years Palo Alto has been complying with a restrictive,confusing and fundamentally unworkable 2018 FCC Order with respect to standards for cell towers, an Order thatthe Ninth Circuit overturned four years ago.> > Please note that both the Palo Alto Weekly and the Daily Post are covering Ms. Kou and Mr. Lauing’s ColleaguesMemo, the Post on the front page of their October 14, 2024 edition. In other words, there is broad interest in theissues the Memo raises, and these issues deserve to be debated by Council.> > Thank you for your consideration.> > Sincerely,> Melinda McGeePalo Alto
From:John Melnychuk
To:Council, City
Cc:Davis Spencer; McGee Melinda; Sampath Harini; Spinelli Giuseppe; LydiaKou@gmail.com; Ed@edlauing.com;
Julie@julieforpaloalto.com; Greg@gregtanaka.org; Vicki@vickiforcouncil.com; Clerk, City
Subject:Please vote to Agendize Kou/Lauing Colleagues Memo for full consideration.
Date:Wednesday, October 16, 2024 1:29:16 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking
on links.
Dear Mayor Stone, Vice Mayor Lauing and Councilmembers Burt, Kou, Lythcott-Haims, Veenker, and Tanaka,
I am writing to ask you to vote this Monday night in favor of putting Councilmembers Kou and Lauing’s ColleaguesMemo, a Memo titled “Restoration of subjective aesthetic standards to Palo Alto’s Wireless CommunicationFacilities (WCF) ordinance,” on a future Council agenda for full consideration and debate.
The City’s wireless ordinance needs to be updated. For years Palo Alto has been complying with a restrictive,confusing and fundamentally unworkable 2018 FCC Order with respect to standards for cell towers, an Order thatthe Ninth Circuit overturned four years ago.
Please note that both the Palo Alto Weekly and the Daily Post are covering Ms. Kou and Mr. Lauing’s ColleaguesMemo, the Post on the front page of their October 14, 2024 edition. In other words, there is broad interest in theissues the Memo raises, and these issues deserve to be debated by Council.
Thank you for your consideration.
Sincerely,
John Melnychuk
Palo Alto, CA 94306
From:J. Brugler
To:Council, City
Cc:GStone22@gmail.com; LydiaKou@gmail.com; Ed@edlauing.com; Julie@julieforpaloalto.com;
Greg@gregtanaka.org; Vicki@vickiforcouncil.com; Clerk, City
Subject:Please vote to agendize Kou/Lauing memo, for full consideration
Date:Wednesday, October 16, 2024 10:26:50 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking
on links.
Dear Mayor Stone and City Council members,
Please vote this Monday night in favor of putting "Restoration of subjective aesthetics standards to Palo Alto'swireless communication facilities", (WCF), on a future council agenda for consideration and debate.From the articles both in the Palo Alto Weekly and the Daily Post, you can see that there is a broad interest in theissues that the Memo raises. These issues deserve to be debated by counsel.Thank you for your consideration.Sincerely,Gayle Brugler.
From:Francesca Kautz
To:Council, City
Cc:GStone22@gmail.com; LydiaKou@gmail.com; Ed@edlauing.com; Julie@julieforpaloalto.com;
Greg@gregtanaka.org; Burt, Patrick; Vicki@vickiforcouncil.com; Clerk, City
Subject:Please vote to Agendize Kou/Lauing Colleagues Memo for full consideration.
Date:Tuesday, October 15, 2024 6:32:51 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking
on links.
Dear Mayor Stone, Vice Mayor Lauing and Councilmembers Burt, Kou, Lythcott-Haims, Veenker, and Tanaka,
I am writing to ask you to vote this Monday night in favor of putting Councilmembers Kou and Lauing’s ColleaguesMemo, a Memo titled “Restoration of subjective aesthetic standards to Palo Alto’s Wireless CommunicationFacilities (WCF) ordinance,” on a future Council agenda for full consideration and debate.
The City’s wireless ordinance needs to be updated. For years Palo Alto has been complying with a restrictive,confusing and fundamentally unworkable 2018 FCC Order with respect to standards for cell towers, an Order thatthe Ninth Circuit overturned four years ago.
Please note that both the Palo Alto Weekly and the Daily Post are covering Ms. Kou and Mr. Lauing’s ColleaguesMemo, the Post on the front page of their October 14, 2024 edition. In other words, there is broad interest in theissues the Memo raises, and these issues deserve to be debated by Council.
Thank you for your consideration.
Sincerely,
Francesca and David Kautz