CC 2017-03-28_09f TUP_Amgen Tour
MEMORANDUM
TO: CITY COUNCIL
FROM: TERESA MCCLISH, DIRECTOR OF COMMUNITY DEVELOPMENT
BY: MATTHEW DOWNING, PLANNING MANAGER
SUBJECT: CONSIDERATION OF TEMPORARY USE PERMIT NO. 17-002;
REGARDING STREET CLOSURES FOR THE AMGEN TOUR OF
CALIFORNIA BIKE RACE ON TUESDAY, MAY 16, 2017
DATE: MARCH 28, 2017
RECOMMENDATION:
It is recommended the City Council adopt a Resolution approving Temporary Use
Permit 17-002 for the Amgen Tour of California Bike Race on Tuesday, May 16, 2017.
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 cost of police, fire, maintenance and other City services
used to conduct this event. Two (2) years ago, the event organizers were billed
approximately $9,500 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 roughly the same.
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 twelfth consecutive
year, and it will be held May 14-20, 2017 (Attachment 1).
The Amgen Tour passed through the City most recently in 2015. That 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. That
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 9.f. - Page 1
CITY COUNCIL
CONSIDERATION OF TEMPORARY USE PERMIT NO. 17-002
MARCH 28, 2017
PAGE 2
ANALYSIS OF ISSUES:
Project Description
On Tuesday, May 16, 2017, Stage 3 of the Amgen Tour of California Bike Race is
scheduled to pass through the City. The race starts in the City of Pismo Beach and
ends in Morro Bay after traveling approximately 113 miles through San Luis Obispo and
Santa Barbara Counties. According to event organizers, the riders will travel an
average of 26 MPH and be in the City for approximately 5 to 10 minutes. This period of
time is anticipated at approximately 2:20 PM to 2:30 PM depending on the speed of the
riders throughout this stage of the Tour.
Course Route
The race is planned to travel through a large portion of the City (Attachment 2). Riders
will enter the City on Valley Road and the course through the City is as follows:
1. Valley Road north to Fair Oaks Avenue;
2. Right turn on Fair Oaks Avenue, travel east to Traffic Way;
3. Left turn on Traffic Way, travel north to Branch Street;
4. Right turn on Branch Street, travel east through the Village to the Branch
Street/Corbett Canyon Road/Huasna Road intersection;
5. Left turn to Corbett Canyon Road, travel north;
6. Exit the City on Corbett Canyon 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 and Public Works
Department will help to facilitate some of the road closures. All remaining intersections
not staffed by City personnel will be the responsibility of Amgen and California Highway
Patrol (CHP) to properly staff.
Due to the race beginning in Pismo Beach, many of the volunteers or individuals from
other jurisdictions may not be available to assist with traffic control in Arroyo Grande.
According to the organizer’s traffic management plan, the 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.
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
Item 9.f. - Page 2
CITY COUNCIL
CONSIDERATION OF TEMPORARY USE PERMIT NO. 17-002
MARCH 28, 2017
PAGE 3
provide community members a safe area to view the event. Amgen is responsible for
utilizing an outside vendor to place type 1 barricades at all intersections along the race
route, delineators along both sides of Branch Street in the Village, posting “no parking”
signs 48 hours in advance in the Village and an adequate amount of yellow “caution”
tape.
School Dismissal
Due to the race’s schedule through the City, it is not anticipated that a conflict between
street closures and the release of schools will be an issue. Arroyo Grande High School
is released at 2:55 pm on race day, which is twenty-five (25) minutes after the race is
anticipated through the City. As with previous years, the event is seen as a positive
event for students to witness.
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 race containing a sprint
through the Village like previous years, there is the potential for significant crowds to
visit the area on race day.
ALTERNATIVES:
The following alternatives are provided for the Council’s consideration:
- Adopt the attached Resolution approving Temporary Use Permit 17-002;
- Modify as appropriate and adopt the attached Resolution approving Temporary
Use Permit 17-002;
- Do not adopt the attached Resolution and instead provide specific findings for the
denial of Temporary Use Permit 17-002; or
- 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.
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. The closure of street parking
along Branch Street can be an inconvenience to businesses in the Village area.
However, this impact is anticipated to be offset by the increased number of visitors to
the Village to view the race.
Item 9.f. - Page 3
CITY COUNCIL
CONSIDERATION OF TEMPORARY USE PERMIT NO. 17-002
MARCH 28, 2017
PAGE 4
ENVIRONMENTAL REVIEW:
In compliance with the California Environmental Quality Act (CEQA), it has been
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.
The Agenda was posted at City Hall and on the City’s website in accordance with
Government Code Section 54954.2.
Attachments:
1. Letter from the event organizers
2. Road closure map
3. Traffic management plan
Item 9.f. - Page 4
RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF THE CITY
OF ARROYO GRANDE APPROVING TEMPORARY USE
PERMIT CASE NO. 17-002; AUTHORIZING STREET
CLOSURES AND RELATED ACTIONS FOR THE AMGEN
TOUR OF CALIFORNIA BIKE RACE; APPLIED FOR BY
AEG CYCLING, LLC
WHEREAS, on February 10, 2017, a Temporary Use Permit application was submitted for
the short-term closure of various streets 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. 17-002 and a request to close various City streets on Tuesday, May 16, 2017, in
accordance with the Municipal Code of the City of Arroyo Grande, specifically Section
16.16.090; 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 location proposed and within the time
period specified will not jeopardize, endanger, or otherwise constitute a menace to
the public health, safety or general welfare.
The operation of the bike race 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 proposed site is adequate in size and shape to accommodate the temporary
use without material detriment to the use and enjoyment of other properties located
adjacent to and in the vicinity of the site.
The City streets to be used are adequate in size and shape to accommodate the
bike race due to being paved City roadways constructed to appropriate standards.
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
temporary use will or could reasonably be expected to generate.
The City streets to be used are adequately served by streets to ensure riders enter
and exit the City safely and additional points of access along the course route will
allow spectators adequate opportunity to view and enjoy the race.
Item 9.f. - Page 5
RESOLUTION NO.
PAGE 2
4. Adequate temporary parking to accommodate vehicular traffic to be generated by
the temporary use is available.
The race itself does not require additional parking, as participants and support
vehicles associated with the bike race will be contained within City street right-of-
way along the course. Adequate temporary parking for spectators exists along the
course, particularly in the Village, where the predominance of spectators has been
observed in previous years.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Arroyo Grande
hereby approves Temporary Use Permit Case No. 17-002 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. Valley Road from the City limits to Fair Oaks Avenue;
2. Fair Oaks Avenue from Valley Road to Traffic Way;
3. Traffic Way from Fair Oaks Avenue to Branch Street;
4. Branch Street from Traffic Way to Corbett Canyon; and
5. Corbett Canyon Road from Branch Street to the City limits.
6. “No Parking/Tow Away” shall be enforced along Branch Streets between
Traffic Way and Mason Street during the Event, beginning at 11 AM on race
day.
7. “No Parking/Tow Away” shall be enforced on Fair Oaks Avenue and Traffic
Way near the Fair Oaks Avenue/Traffic Way intersection, beginning at 11 AM
on race day.
On motion by Council Member , seconded by Council Member , and by the
following roll call vote, to wit:
AYES:
NOES:
ABSENT:
the foregoing Resolution was adopted this 28th day of March, 2017.
Item 9.f. - Page 6
RESOLUTION NO.
PAGE 3
______________________________________
JIM HILL, MAYOR
ATTEST:
______________________________________
KELLY WETMORE, CITY CLERK
APPROVED AS TO CONTENT:
______________________________________
ROBERT K. McFALL, INTERIM CITY MANAGER
APPROVED AS TO FORM:
______________________________________
HEATHER K. WHITHAM, CITY ATTORNEY
Item 9.f. - Page 7
RESOLUTION NO.
PAGE 4
EXHIBIT “A”
CONDITIONS OF APPROVAL
TEMPORARY USE PERMIT CASE NO. 17-002;
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 16, 2017.
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 indemnify and 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.
Police Department Conditions
4. The Event organizers shall fully reimburse the City for costs associated with the
Event, including paid personnel and equipment costs.
5. 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.
6. The Event organizers shall provide an adequate amount of yellow caution tape
necessary to close streets and provide a pedestrian barrier in the Village.
7. “No Parking/Tow 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 Tuesday, May 16, 2017 until the conclusion of the Event through the City.
8. All temporary “No Parking/Tow Away” signs shall be posted a minimum of 48 hours
prior to the Event.
9. The Event organizers shall be responsible for coordination with Caltrans regarding
the Event’s impact on State facilities in the City.
10. The Event organizers shall coordinate with the South County Area Transit (SCAT)
to ensure the Event’s impact on public transportation is minimized.
Item 9.f. - Page 8
RESOLUTION NO.
PAGE 5
Public Works Department Conditions
11. 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. Proof of this mailing shall be provided to the City.
12. The Event organizers shall provide “No Outlet” signs to be placed in neighborhood
“islands”.
13. 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.
14. Traffic control devices and “No Parking” signs shall be placed by a private
contractor hired by the Event organizers.
15. The Event organizers shall reimburse the City for Public Works Department
employees used to ensure a safe and successful Event.
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, 2017.
17. The Event organizers shall coordinate with local farms to ensure distribution of
perishable products is not unnecessarily impacted.
18. The Event organizers shall coordinate with the Lucia Mar Unified School District
and specifically Arroyo Grande High School to ensure minimized impacts
associated with release of students.
Item 9.f. - Page 9
ATTACHMENT 1
Event Overview
The 12th Annual 2017 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: 7-days vs. 23-days. The race consists of 16 teams - each with eight riders. The 2017
race will have six point-to-point road stages and one time trial. Each stage is between 12 and
120 miles in length. The race begins in Sacramento on May 14th and concludes in Pasadena on
May 20th.
In addition to the men’s 7-day race, there will also be a 4-day women’s race. This will be a UCI
designated World Tour Event for the women. It is the first ever designation for a race of this high
caliber in North America. The race will be comprised of 15-teams and 90-riders. The women’s
stages will be May 11th and 12th at South Lake Tahoe, May 13th in Elk Grove, and May 20th in
Sacramento.
The 2016 Amgen Tour of California drew over one 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 2017 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 “package”. 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 1.5 miles. It takes
the race about five minutes to pass any given spot on the road.
We require total road closures 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 2016
event, that took place over eight days and 750 miles of roads, there were very few complaints
with the way the traffic was managed.
Item 9.f. - Page 10
The entire 657 miles of the route has been reviewed by both Caltrans and CHP. As it has for the
past 11-years, California Travel and Tourism is a key supporter and Partner of the 2017 Amgen
Tour of California.
Drawing one 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
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 11-years.
We saw little to no trash along the route for the 2016 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.
Item 9.f. - Page 11
Men’s Stage 3
May 16, 2017
Arroyo Grande Route
ATTACHMENT 2
Item 9.f. - Page 12
ATTACHMENT 3
Amgen Tour of California
Traffic Management Plan
Scope
The 2017 Amgen Tour of California will be held May 11 -20th over 657 miles of
California roadways. The race will feature 128 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.
Traffic Control Staffing
Traveling Marshal
(80 total)
Traveling Marshals receive extensive training and travel with the event throughout the
week. These marshals are divided into groups of 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 9.f. - 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 turn along the course. At all of these turns, CHP will be
on site and will have already closed the road.
Motor Marshals
(12 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 9.f. - 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.
General Traffic Control Guidelines
Race Marshals
Marshal Control
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 9.f. - 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 9.f. - 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 9.f. - Page 17
THIS PAGE INTENTIONALLY LEFT BLANK
Item 9.f. - Page 18