CC 2014-04-08_08.d. TUP Amgen TourMEMORANDUM
TO: CITY COUNCIL
FROM:
BY:
TERESA MCCLISH, DIRECTOR OF COM_MUNITY DEVELOPMENT
MATTHEW DOWNING~SISTANT PLANNER
SUBJECT: CONSIDERATION OF TEMPORARY USE PERMIT NO. 14-004
REGARDING STREET CLOSURES FOR THE AMGEN TOUR OF
CALIFORNIA BIKE RACE ON THURSDAY, MAY 15, 2014
DATE: APRIL 8, 2014
RECOMMENDATION:·
It is recommended the City Council adopt a Resolution approving Temporary Use
Permit 14-004 for the Amgen Tour of California Bike Race on Thursday, May 15, 2014.
IMPACT ON FINANCIAL AND PERSONNEL RESOURCES:
There is no direct funding impact as a result of this event. Event organizers are required
to reimburse the City for the costs of police, fire, maintenance and other City services·
used to conduct this event. Last year, the event organizers were billed approximately
$11,000 for the additional personnel and incidental materials used for the event. Based
on personnel available for this year's event, reimbursement is anticipated to be $8,000 -
$9,500.
BACKGROUND:
The Amgen Tour of California is an annual cycling race event that includes world
renowned riders and professional cycling teams. The race covers approximately 750
miles of California's roadways. This year marks the Amgen Tour's ninth consecutive
year, and it will be held May 11-18, 2014 (Attachment 1 ).
The Amgen Tour passed through the City in 2006 and, most recently, in 2013. Last
year's event was viewed as a success thanks in large part to the efforts of the Police
Department, Five Cities Fire Authority, Public Works Department, and many community
volunteers. Last year, residents, business owners, and members of surrounding
communities lined the Tour's route to experience the race and cheer on the cyclists.
Pictures of cyclists racing through the Village on East Branch Street have been used in
Amgen Tour marketing and promotional materials.
Item 8.d. - Page 1
CITY COUNCIL
CONSIDERATION OF STREET CLOSURES FOR THE AMGEN TOUR OF
CALIFORNIA BIKE RACE ON THURSDAY, MAY 15, 2014
APRIL 8, 2014
PAGE2
ANALYSIS OF ISSUES:
Project Description
On Thursday, May 15, 2014, Stage 5 of the Amgen Tour of California Bike Race is
1 scheduled to pass through the City. The race starts in the City of Pismo Beach and
ends in Santa Barbara. According to event organizers, the riders will travel
approximately 26 MPH and be in the City for approximately 5 -10 minutes. This period
of time is anticipated approximately 12:00 PM and 12:15 PM depending on the speed of
the riders throughout this stage of the Tour. Because the race will be starting in Pismo
Beach, it is anticipated that the riders will travel through as one large group fairly close
to the estimated times.
Course Route
The race is planned to travel through a large portion of the City (Attachment 2). Riders
will enter the City on Corbett Canyon Road and the course through the City is as
follows:
1. Corbett Canyon Road southwest to the Branch Street/Corbett Canyon
Road/Huasna Road intersection;
2. Right turn onto East Branch Street, continue on Branch Street through the
Village;
3. Left turn on Traffic Way, travel south to Fair Oaks Avenue;
4. Right turn on Fair Oaks Avenue, travel west to Valley Road;
5. Left turn on Valley Road, follow Valley Road south;
6. Exit the City on Valley Road.
Traffic Control
The control of traffic is an important part of the event's success. Due to the large
number of riders participating in the tour and the amount of support vehicles needed to
facilitate the event, the closure of City streets along the course route is necessary. The
event organizers have completed a traffic management plan (Attachment 3) that
outlines the personnel and course closure methods used to control traffic along the
course route. Additionally, the Arroyo Grande Police Department will help to facilitate
road closures.
One difference from last year's event is the availability of additional personnel and
volunteers from neighboring jurisdictions. For last year's event, the Police Department
utilized the additional personnel to help control traffic and spectators during the event.
However, due to the race beginning in Pismo Beach, many of those individuals will not
be available to control traffic in Arroyo Grande. According to the organizer's traffic
management plan, the California Highway Patrol (CHP) and a group of traveling
volunteers with Amgen are responsible for securing the route. However, the traveling
volunteers do not provide traffic control and instead provide crowd control. This could
result in some intersections having a soft closure with no one there to prevent drivers
from moving barricades and traveling into the course route. If this type of incident were
to occur, the CHP would pull the driver over until the race passes by.
Item 8.d. - Page 2
CITY COUNCIL
CONSIDERATION OF STREET CLOSURES FOR THE AMGEN TOUR OF
CALIFORNIA BIKE RACE ON THURSDAY, MAY 15, 2014
APRIL 8, 2014
PAGE3
Type 1 barricades tied with yellow caution tape will be placed across intersections
adjacent to the race's route through the City to block vehicles from entering into the
course. In the Village, orange delineators and caution tape will be placed on both sides
of Branch Street. This will prohibit street parking in the Village on race day and will
provide community members a safe area to view the event.
School Dismissal
Due to the race's schedule through the City, the potential for conflict between street
closures and the release of schools is not anticipated to be an issue like it was for last
year's event. Staff has been in contact with Lucia Mar Unified School District regarding
the release of students on race day. In particular, staff has proposed the high school
prohibit students from leaving campus at lunch on race day and instead organize
special activities for the students to view the event.
Business Notification
Businesses will be notified in advance of the event. Signage will be placed to warn
customers of closures. Staff is coordinating with the Village Improvement Association to
plan increased entertainment activities aimed at encouraging the spectator crowds to
remain in the commercial area following the race. Due to the event passing through the
City during the lunch hour, there is increased opportunity for the retention of spectators
and an increase in commerce.
ALTERNATIVES:
The following alternatives are provided for the Council's consideration:
-Adopt the attached Resolution;
Modify as appropriate and adopt the attached Resolution;
Do not adopt the attached Resolution;
Provide direction to staff.
ADVANTAGES:
The event will provide community members and others the opportunity to participate in
a unique, international event that only briefly passes through the City. The event will
draw attention to the City and generate activity in the Village commercial area. Since it
will take place during the lunch hour, staff is coordinating with local businesses to
provide special activities to attract lunchtime spectators to local restaurants.
DISADVANTAGES:
The full closure of streets along the course route will impact traffic and circulation
patterns through the City for a brief period on race day. Because the race passes
through the City during the lunch hour, these impacts to traffic and circulation could be
increased from previous years. The closure of street parking along Branch Street can
be an inconvenience to businesses in the Village area. However, this impact is
Item 8.d. - Page 3
CITY COUNCIL
CONSIDERATION OF STREET CLOSURES FOR THE AMGEN TOUR OF
CALIFORNIA BIKE RACE ON THURSDAY, MAY 15, 2014
APRIL 8, 2014
PAGE4
anticipated to be offset by the increased number of visitors to the Village to view the
race.
ENVIRONMENTAL REVIEW:
In compliance with the California Environmental Quality Act (CEQA), the Community
Development Department has determined that this project is categorically exempt per
Section 15304 (e) of the CEQA Guidelines regarding minor temporary uses of land. If
the Council does not think that this determination is appropriate, project approval shall
not be considered.
PUBLIC NOTIFICATION AND COMMENTS:
A condition of approval has been developed, which will require the applicant to notify
property owners and businesses located within the area of street closures and/or
restricted parking. In addition, the Agenda was posted in front of City Hall on Thursday,
April 3, 2014. The Agenda and report were posted on the City's website on Friday, April
4, 2014.
Attachments:
1. Letter from the event organizers
2. Road closure map
3. Traffic management plan
Item 8.d. - Page 4
RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF THE CITY
OF ARROYO GRANDE APPROVING TEMPORARY USE
PERMIT CASE NO. 14-004; AUTHORIZING STREET
CLOSURES AND RELATED ACTIONS FOR THE AMGEN
TOUR OF CALIFORNIA BIKE RACE; APPLIED FOR BY
AEG CYCLING LLC
WHEREAS, on February 7, 2014, a Temporary Use Permit application for the short-term
closure of various streets was received to allow the Amgen Tour of California Bike Race
(event) to pass through the City of Arroyo Grande; and
WHEREAS, event organizers will be responsible for costs associated with traffic control,
cleanup, and payment of all related fees and costs for use of City property and City
employee time related to the event; and
WHEREAS, the City Council has considered the application for Temporary Use Permit
Case No. 14-004 and a request to close various City streets on May 15, 2014, in
accordance with the Municipal Code of the City of Arroyo Grande; and
WHEREAS, the City Council finds, after due study, the following circumstances exist:
FINDINGS FOR APPROVAL
TEMPORARY USE PERMIT:
1. The operation of the requested use at the locations proposed and within the time
period specified will not jeopardize, endanger, or otherwise constitute a menace to
the public health, safety or general welfare due to the use of dedicated local law
enforcement personnel including California Highway Patrol officers and volunteer
marshals.
2. The use of City streets are adequate in size and shape to accommodate the bike
race and will not be a material detriment to the use and enjoyment of other
properties located adjacent to and in the vicinity of the event.
3. The proposed site is adequately served by streets or highways having sufficient
width and improvements to accommodate the kind and quantity of traffic that the
bike race will or could reasonably be expected to generate.
4. Adequate temporary parking to accommodate vehicular traffic to be generated by
the event is available throughout the City.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Arroyo Grande
hereby approves Temporary Use Permit Case No. 14-004 and the closure of the following
City streets to through traffic and parking, with the above findings and subject to the
conditions as set forth in Exhibit "A", attached hereto and incorporated herein by this
reference:
1. Corbett Canyon Road from the City limits to Branch Street;
2. Branch Street from Corbett Canyon Road to Traffic Way;
Item 8.d. - Page 5
RESOLUTION NO.
PAGE2
3. Traffic Way from Branch Street to Fair Oaks Avenue;
4. Fair Oaks Avenue form Traffic Way to Valley Road; and
5. Valley Road from Fair Oaks Avenue to the City limits.
6. "No ParkingfTow Away" shall be enforced along Branch Streets between
Traffic Way and Mason Street during the event.
7. "No ParkingfTow Away" shall be enforced on Fair Oaks Avenue and Traffic
Way near the Fair Oaks AvenuefTraffic Way intersection.
On motion by Council Member
following roll call vote, to wit:
AYES:
NOES:
ABSENT:
, seconded by Council Member
the foregoing Resolution was adopted this 8111 day of April 2014.
, and by the
Item 8.d. - Page 6
RESOLUTION NO.
PAGE3
TONY FERRARA, MAYOR
ATTEST:
KELLY WETMORE, CITY CLERK
APPROVED AS TO CONTENT:
STEVEN ADAMS, CITY MANAGER
APPROVED AS TO FORM:
TIMOTHY J. CARMEL, CITY ATTORNEY
Item 8.d. - Page 7
RESOLUTION NO.
PAGE4
EXHIBIT "A"
CONDITIONS OF APPROVAL
TEMPORARY USE PERMIT CASE NO. 14-004;
THE AMGEN TOUR OF CALIFORNIA BIKE RACE
General Conditions
1. This Temporary Use Permit (TUP) allows the Amgen Tour of California Bike Race
to pass through the City of Arroyo Grande by utilizing various public streets for a
brief period of time on May 15, 2014.
2. The use shall be in substantial conformance with the application materials
submitted to the Community Development Department.
3. The event organizers shall agree to defend at his/her/its sole expense any action
brought against the City, its agents, officers, or employees because of the issuance
of said approval, or in the alternative, to relinquish such approval. The applicant
shall reimburse the City, its agents, officers, or employees, for any court costs and
attorney's fees which the City, its agents, officers or employees may be required by
a court to pay as a result of such action. The City may, at its sole discretion,
participate at its own expense in the defense of any such action but such
participation shall not relieve applicant of his/her obligations under this condition.
4. To the full extent permitted by law, the event organizers shall indemnify, defend
and hold harmless the City, its agents, officers, and employees from and against
any liability (including liability for claims, suits, actions, arbitration proceedings,
administrative proceedings, regulatory proceedings, losses, expenses or costs of
any kind, whether actual, alleged or threatened, including attorney's fees and
costs, court costs, interest, defense costs, and expert witness fees), where the
same arise out of, are a consequence of, or are in any way attributable to, in
whole or in part, this Temporary Use Permit except liability arising out of the
proven sole negligence of the City.
Police Department Conditions
5. The event organizers shall fully reimburse the City for costs associated with the
event, including paid personnel and equipment costs.
6. The event organizers shall provide three (3) electronic message board signs to alert
residents of the event and related street closures a minimum of five (5) days prior to
the event.
7. The event organizers shall provide an adequate amount of yellow caution tape
necessary to close streets and provide a pedestrian barrier in the Village.
8. The event organizers shall provide thirty (30) yellow/orange traffic vests to identify
individuals charged with closing down arterial streets along the course.
Item 8.d. - Page 8
RESOLUTION NO.
PAGES
9. "No Parkingffow Away" restrictions along Branch Street in the Village and near the
intersection of Fair Oaks Avenue and Traffic Way shall be enforced from 7:00 am
on Thursday, May 15, 2014 until the conclusion of the event through the City.
10. All temporary "No Parkingffow Away" signs shall be posted a minimum of 48 hours
prior to the event (by 7:00 am, Tuesday, May 13, 2014).
11. The event organizers shall be responsible for coordination with Caltrans regarding
the event's impact on State facilities in the City.
12. The event organizers shall coordinate with the South County Area Transit (SCAT)
to ensure the event's impact on public transportation is minimized.
Public Works Department Conditions
13. The event organizers shall notify all property owners, tenants, and businesses
along the route and in obstructed neighborhood "islands" of the event two weeks
prior to the race.
14. The event organizers shall provide "No Outlef' signs to be placed in neighborhood
"islands".
15. The event organizers shall remove finish line tape placed in the City streets
immediately following the event. The tape shall not be left to wear off on its own.
Community Development Department Conditions
16. The event organizers shall provide a $1,000,000.00 comprehensive general liability
insurance policy naming the City as additional insured by May 1, 2014.
Item 8.d. - Page 9
AMGEN~~TOURot Jf {j CALIFORNIA
Event Overview
ATIACHMENTl
The 2014 Amgen Tour of California is a professional style bike race modeled after the Tour de
France. The race is governed by the same international cycling federation, we follow the same
rules, and we have the same teams and riders as the Tour de France. The principal difference
between the two events is that the Amgen Tour of California is a shorter event: 8-days vs. 21-
days. The race consists of 16 teams -each with eight riders. The 2014 race will have seven
point-to-point road stages and one time trial. Each stage is between 12 and 125 miles in length.
The race begins in Sacramento on May 11th and concludes in Thousand Oaks on May 18th.
The 2013 Amgen Tour of California drew over two million spectators along the 750-mile route
and quickly became the largest sporting event in the history of California. We will broadcast HD
live TV coverage (NBC Sports and NBC Network) on every stage for 2014 to more than 200
countries. We will also being streaming live video on the Internet for the entire race.
The race is self-contained. Aside from the 128 professional racers, we also have approximately
100 vehicles that travel within the race. This includes the California Highway Patrol (CHP), team
cars, medical support, mechanical support, race officials, motorcycle marshals, TV crews, etc.
The entire race moves as one entity at an average speed of approximately 26 MPH. From the
lead CHP car to the follow CHP car, the distance is approximately 1 112 miles. It takes the race
about five minutes to pass any given spot on the road.
We require total road closure that is managed by the CHP. There are four elements to the
closure: cross traffic that flows across the course at an intersection, traffic moving the same
direction and ahead of the race, traffic moving the same direction and behind the race, and
traffic moving towards the race. CHP/Police will allow cross traffic and traffic turning onto the
course and heading away from the race until approximately 5-10 minutes before the race
reaches the intersection but will prevent cars from turning onto the road heading into the race.
Traffic moving the same direction and ahead of the race will be allowed to flow until the race is
approximately 10 minutes behind the traffic. Traffic that is behind the race will not be allowed to
pass. Traffic that is moving into the race will be stopped approximately 20 minutes before the
race reaches any given point.
Traffic management is variable based on the type of road, the amount of traffic, and the type
and number of opportunities where traffic can be pulled off the road for a short period. Where
there are roads that are divided by medians, traffic will be allowed to flow on the side opposite
the race. It may sound slightly onerous, but it is not as bad as it sounds. CHP has been able to
perfect this type of closure and has worked closely with local PD and the sheriffs. For the 2011
event, that took place over eight days and 820 miles of roads, there were very few complaints
with the way the traffic was managed.
The entire 750 miles of the route has been reviewed and approved by both Caltrans and CHP.
As it has for the past eight years, California Travel and Tourism is a key supporter and sponsor
of the 2014 Amgen Tour of California.
Drawing two million spectators raises a lot of eyebrows ... and concerns. The vast majority of
these crowds came in three areas: start cities, finish cities, and various long and steep climbs
the riders encountered. Aside from some isolated areas, there are relatively few spectators
Item 8.d. - Page 10
AMGEN~~"TOURot Jf {j CALIFORNIA
along the course. Many people would watch from their driveway, but it was rare to find more
than a few hundred in one location. We will be utilizing the same road closure and crowd control
plans that have been effective the past six years.
We saw little to no trash along the route for the 2013 Amgen Tour of California. The fans along
the way were well behaved and took whatever trash they may have generated with them when
they left the area they were viewing the race. We also have a crew that follows the race to
collect our signs and any obvious trash that was left by a spectator.
The Amgen Tour of California will be returning to Arroyo Grande on May 15, 2014. This will be
the part of Stage 5 of the race. Stage 5 will begin in Pismo Beach and finish in Santa Barbara.
The race will leave Pismo Beach on Price Canyon and enter into San Luis Obispo County just
past Hwy 101. From Price Canyon, the race will make a right on Hwy 227. It will then make a
left tum on Corbett Canyon Rd. The race will enter Arroyo Grande on Corbett Canyon Rd. The
route through Arroyo Grande will include Branch Street, Traffic Way, Fair Oaks, Valley, and Los
Berros. Total distance in Arroyo Grande will be approximately 3 miles that the race will complete
in a little over six-minutes.
Item 8.d. - Page 11
101
2014 Amgen Tour of California
May 15, 2014
12:10pm to 12:16m
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Item 8.d. - Page 12
Scope
Amgen Tour of California
Traffic Management Plan
ATTACHMENT 3
The 2014 Amgen Tour of California will be held May I I-18th over 725 miles of
California roadways. The race will feature 144 cyclist plus various support vehicles and
staff. These athletes and vehicles will travel along the course in a "caravan" ender the
escort of the California Highway Patrol (CHP). The "bubble" of this escort is expected to
be 10-20 minutes as it moves along roadways. See the attached caravan diagram for more
information on the quantity and location of vehicles.
Course Information
See the attached course logs and maps for specific route information, including
intersection and arrival information.
This log will be updated to show the positions of volunteer marshal locations at
intersections along the route.
Public Information and Notification
Citizens along the route will be notified through a combination of fixed signage warning
of road delays, and a public awareness campaign. The contract public relation company
contracted by the event organizers will issue press releases and contact local media in the
2-3 weeks before the event and continue through event day.
Traveling Marshal
(75 total)
Traffic Control Staffing
Traveling Marshals receive extensive training and travel with the event throughout the
week. These marshals are divided into groups of 8-10 and take positions along smaller
side roads to assist law enforcement. In addition these marshals are deployed in areas
where there might be a routing or safety concern (turns, entrances to divided sections of
road, steep downhills, etc.)
Each marshal group will deploy on a set section of road ahead of the arrival of the race.
Immediately after the passage of the race, the marshals will be picked up and leapfrog to
another position further down the route using and alternate route. On most cases the
marshals will makes two of these jumps per day, effectively doubling their numbers.
Marshals are equipped with cones, safety vests and flags. In addition their vehicles are
equipped with brooms, shovels and patch material in case of repairable road conditions.
Marshals also receive PR training in order to work with local residents and road users
Item 8.d. - Page 13
who may be inconvenienced. While these course marshals are well versed in supporting
law enforcement personnel, they have not received traffic control training. Therefore,
they will not perform any traffic control duty. Their primary role will be crowd control
and "flagging" the riders at any tum along the course. At all of these turns, CHP will be
on site and will have already closed the road.
Motor Marshals
(20 total)
The race's Motorcycle Marshals work closely with the California Highway Patrol to
assist with security along the route. The marshals are deployed in teams and assigned to
the lead patrol cars. They are responsible for assisting with the closure of any drives or
parking lots not manned by any other staff. These marshals have the ability to rapidly
deploy and quickly move back into position once the front of the race has passed.
In addition motor marshals are able to communicate to both the command car and other
race staff any obstacles or dangerous situations along the route.
California Highway Patrol -Entourage
(10 total)
The California Highway Patrol (CHP) will be providing a police escort utilizing the same
units throughout the event. These units will be deployed both ahead of and behind the
race itself as part of the race caravan.
The mobile units will work with fixed-post officers and race marshals to provide security
along the route.
Six to seven units will be staggered between five and ten minutes in front of the event.
The exact spacing will be determined based on road type and terrain in coordination with
local area commanders.
All additional units will be placed at the rear of the entourage to prevent traffic from
passing the race. These units will also protect vehicles and competitors who are outside
the main group.
See the attached caravan diagram for more information on vehicle locations and
functions.
California Highway Patrol -Motos
(Varies by Stage)
The California Highway Patrol (CHP) will provide 10-15 moto officers 2-3 miles ahead
of the race. These units will pull incoming traffic off to the side and instruct them to hold
in place until the race passes them.
Item 8.d. - Page 14
California Highway Patrol -Fixed Units
(Varies by Stage)
The California Highway Patrol (CHP) will provide fixed post traffic control ahead of the
race. These units will work to secure intersections ahead of the race in conjunction with
race marshals and CHP Motos.
Marshal Control
General Traffic Control Guidelines
Race Marshals
Race marshals are positioned on smaller side roads that do not require the full-time
presence of a law enforcement officer. In general these are smaller rural roads and non-
signalized intersections. These marshals work with the advance fixed post CHP units to
ensure that all roads are controlled as the race passes. Side roads are controlled by Type 1
barricades or a similar device.
The purpose of the marshal is to control traffic once the lead elements of the race reach a
position. Once the lead law enforcement unit in the race reaches a location, traffic is not
allowed to move towards the race. Depending on location traffic may be allowed to move
away from the race or cross the course during this time. While these course marshals are
well versed in supporting law enforcement personnel, they have not received traffic
control training. Their primary role will be crowd control and "flagging" the riders at any
turn along the course. At all of these turns, CHP will be on site and will have already
closed the road.
Once the lead elements of the race have passed a location and the race grows closer,
traffic at intersection will not be allowed on course until the race passes.
Once the final law enforcement vehicle passes a location, all intersections are reopened
and traffic flows as normal.
As the race expands and contracts, law enforcement and marshals vehicles are redeployed
to fill any of the small gaps and keep side traffic or traffic pulled off the road from
interfering with the race.
Law Enforcement Control
Law Enforcement will handle traffic control in different ways depending on the terrain
and road type.
Item 8.d. - Page 15
In the case of short sections of road, traffic at intersections controlled by CHP will not be
allowed to advance towards the riders as the race is inbound. This is especially important
in areas with no shoulders, steep descents and limited site distances.
In these cases traffic is held or diverted as a race enters the far intersection on a stretch or
roadway. This has the advantage of providing the race with a clear path of travel while
not forcing people to pull off of on a non-optimal shoulder.
Contingency Plans
Weather
The Amgen Tour of California is generally considered a "Rain or Shine" event; however
there are instances that would cause the neutralization, delay or stoppage of the event.
Delay
The event start may be delayed due to extreme circumstances, usually in the vicinity of
the start area. Although generally avoided due to the careful planning of the timeline it is
an option.
Relocation of Start/Remote Start
In the case of an incident such as a landslide, riders and staff may transfer via auto around
the obstacle and start/restart the race on the other side. This has the advantage of
continuing the event. The start would take place at the same time the race would have
passed on the original route, thus preserving the timing of the event.
Detour
In the case of an incident affecting a short portion of a roadway, the race may be detoured
around if a safe and feasible route is available. Many times in these cases the race is
neutralized and restarted once on the other side of the obstacle.
Neutralization
In the case of a limited closure, the race may be neutralized and restarted once the
obstacle has been cleared or the delaying circumstance has passed.
Cancellation
In some cases the safety of the riders and/or staff is so extreme or the damage to
roadways and infrastructure is so extreme that the event must be cancelled. This is a last
resort option.
Item 8.d. - Page 16
Other Emergency Situations
In the case of emergency situations (house fire, medical emergency, etc.) the CHP
Incident Commander (IC) should be notified immediately. The CHP IC will consult with
event organizers to determine the appropriate course of action.
It may be decided to use the same actions as for a weather emergency with modifications
based on the particular situation.
Item 8.d. - Page 17
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Item 8.d. - Page 18