HomeMy WebLinkAbout25G - AMENDMENT FOR GENERAL PLAN IMPACT REPORTREQUEST FOR
COUNCIL ACTION
CITY COUNCIL MEETING DATE:
APRIL 21, 2020
CLERK OF COUNCIL USE ONLY:
TITLE: APPROVED
❑ As Recommended
APPROVE AN AMENDMENT TO AN ❑ As Amended
AGREEMENT WITH PLACEWORKS FOR ❑ Ordinance on 1s' Reading
CONSULTING SERVICES FOR THE El Ordinance on Reading
❑ Re Implementing Resolution
GENERAL PLAN AND ENVIRONMENTAL ❑ Set Public Hearing For_
IMPACT REPORT ($91,947)
CONTINUED TO
/s/Kristine Ridge
CITY MANAGER
FILE NUMBER
RECOMMENDED ACTION
Authorize the City Manager to execute an amendment to the agreement with Placeworks in the
amount of $91,947 for the General Plan and Environmental Impact Report for the City of Santa
Ana and extend term through March 31, 2021, subject to non -substantive changes approved by
the City Manager and City Attorney, to expand the scope to include additional Circulation Element
analysis.
DISCUSSION
In November 2018, the City Council approved an agreement effective from November 20, 2018
through November 19, 2020 with Placeworks for the preparation of the General Plan and
Environmental Impact Report for the City of Santa Ana. The agreement did not include analysis for
the Circulation Element of the General Plan because a separate agreement (A2011-198) was
governing the Circulation Element work effort in advance of the General Plan.
In June 2019, administrative changes and modifications to the proposed street network caused a
delay in the progression of the Circulation Element. In January 2020, it was determined that the
Circulation Element be consolidated with the General Plan Update process. To coincide with
General Plan Update, the proposed amendment to the agreement with Placeworks will incorporate
the environmental analysis for the Circulation Element and extend the expiration of the agreement
to March 31, 2021 (Exhibit 1). No additional funding is requested, as the funds are available from
existing PBA and PWA accounts. The original contract amount was $607,884. The amendment
request will increase the original contract amount to $699,831.
STRATEGIC PLAN ALIGNMENT
Approval of this item supports the City's effort to meet Goal #3 - Economic Development, Objective
#2 (create new opportunities for business/job growth and encourage private development through
new General Plan and Zoning Ordinance policies), Strategy A (complete a comprehensive update
of the City's General Plan including the development of policies and implementation measures that
directly relate to equitable economic development); and Goal #5 - Community Health, Livability,
25G-1
Placeworks Amendment Agreement
April 21, 2020
Page 2
Engagement & Sustainability, and Objective #6 (focus projects and programs on improving the
health and wellness of all residents).
FISCAL IMPACT
Funds are budgeted and available in the following Planning and Building and Public Works
expenditure accounts:
ACCOUNTING
UNIT
ACCOUNT
FUND DESCRIPTION
FY2019/202
0
FY2020/2021
TOTAL
05016018
62300
PBA General Plan
$22,451.43
$22,451.43
01116510
62300
PBA General Fund
$18,000.00
$18,000.00
03217662
(Project 19-6904
66220
PWA Measure M2
Local Fairshare
$ 5,216.57
$ 5,216.57
05016018
62300
PBA General Plan
$46,279.00
$46,279.00
TOTAL
$45,668.00
$46,279.00
$91,947.00
JA:fg
5'. RFCX\ 21-20\Amendment EIR Contract- Placeworks1. docx
Exhibit: 1. Amendment Agreement with Placeworks
25G-2
EXHIBIT 1
FIRST AMENDMENT TO AGREEMENT WITH PLACEWORKS TO PROVIDE
ENVIRONMENTAL SERVICES FOR THE GENERAL PLAN UPDATE
THIS FIRST AMENDMENT to the above -referenced agreement is entered into on April 21, 2020,
by and between PlaceWorks, Inc. ("Consultant'), and the City of Santa Ana, a charter city and
municipal corporation organized and existing under the Constitution and laws of the State of
California ("City"), collectively referred to as the "Parties".
RECITALS
A. The Parties entered into Agreement No. A-2018-263, dated November 20, 2018, by which
Consultant agreed to prepare environmental documents for the comprehensive general plan
updates ("Agreement'). The original term of the Agreement was for a two-year term until
November 19, 2020, with an option to extend the term of the Agreement. The Agreement is
current and in effect.
B. In January 2020, the parties determined that additional data should be incorporated into the
General Plan Update requiring an amendment to the Agreement.
C. The Parties now wish to amend the scope of service for this data, increase the amount to be
expended under the Agreement, and extend the term of the Agreement.
The Parties therefore agree:
1. Section 1, Scope of Services, is amended to include the Scope of Services updated on April
9, 2020, attached hereto to this First Amendment and identified as Exhibit A- 1.
2. Section 2, Compensation, is amended to increase the not -to -exceed amount by $91,947, per
the costs and rates identified in Exhibit A -I to this First Amendment. The total amount to be
expended under the Term of this Agreement shall not exceed $699,831.
3. Section 3, Term, is amended to extend the time period of the Agreement through March 31,
2021. The Term of the Agreement may still be extended for up to an additional one (1) year
period upon a writing executed by the City Manager and the City Attorney.
4. Except as modified by this First Amendment, all terms and conditions of the Agreement shall
remain in full force and effect.
#34657v3
[signature page to follow]
25G-3
IN WRNESS WHEREOF, the parties hereto have executed this First Amendment to the
Agreement on the date and year first written above.
ATTEST
Daisy Gomez
Clerk of the Council
APPROVED AS TO FORM
Sonia R. Carvalho
City Attorney
CITY OF SANTA ANA
Kristine Ridge
City Manager
CONSULTANT
Assistant Uity Attorney Title{w�'
RECOMMENDED FOR APPROVAL
a
Minh Thai
Executive Director
Planning and Building Agency
tfiM57V3
25G-4
PER • 1M TAS• b
February 7, 2020 (updated April 9, 2020)
Verny Carvajal, Principal Planner
Melanie McCann, Senior Planner
City of Santa Ana, Planning Department
20 Civic Center Plaza, M-20
Santa Ana. CA 92702
Subject: Request for Contract Amendment No. 1 for the Technical Studies and Associated
Environmental Impact Report for the Santa Ana General Plan (SNT-20.0)
Dear Mr. Carvajal and Ms. McCann
This letter is to request Contract Amendment No. 1 to Agreement No. A-2018-263, approved by the City November
20, 2018. Per our ongoing discussions, this amendment details the tasks required to expand the scope of the General
Plan Update Environmental Impact Report (GPU EIR) to include the Circulation Element. Merging the Circulation
Element with the overall GPU will also eliminate the duplication and overlap of processing separate EIRs. This
amendment assumes that remaining budget within the Circulation Element and FIR contract (A-2011-198) with IBI
Group would be transferred to the GPU EIR. Included in the scope of work are IBI's efforts to combine the analysis for
both the Circulation Element and GPU and ensure that analysis sufficiently addresses the combined potential traffic
Impacts of the projects. The scope of work that follows details the PlaceWorks and IBI Group efforts covered in this
amendment. Our Cost Estimate is attached. Note that assuming that the remaining budget in the Circulation Element
contract is transferred to the GPU EIR contract, no additional fees are requested.
PlaceWorks
» Supplementing the GPU EIR to cover the Circulation Element, Including expanded project description, impact
analyses, and potential alternative focused on circulation modifications.
» Minimal increase In Notice of Preparation (NOP), Scoping Meeting, and Final EIR related to expanded project
description, graphics, and potential comments related to the Circulation Element.
Expanded project management and coordination due to extended schedule (+36 weeks in comparison to original
schedule).
IBI Group
» Preparing a combined traffic analysis report for the Circulation Element and GPU that includes additional
intersections and roadways, as well as City -requested modifications to some roadway reclassifications.
» Ongoing coordination and meetings with OCTA to facilitate expedited schedule and IBI's use of OCTAM model.
» OCTAM modeling of two land use scenarios.
» Update of existing conditions analysis upon finalization of land use plan.
February 7, 2020 (revised April 9, 2020 1 Page 1
25G-5
Scope of Work
The following scope of work details the additional work covered in this contract amendment and is organized per the
tasks in our original approved contract with the City dated November 20, 2018.
TASK 1 TECHNICAL STUDIES FOR THE GENERAL PLAN UPDATE
Task 1.1 Traffic Analysis
The City of Santa Ana has proposed to merge the contracts for the Circulation Element Update and the GPU EIR. In
terms of the respective traffic study scopes of work, merging the two projects creates efficiency related to the
production of a single traffic study, but does require additional work to ensure that the scope of the combined traffic
studies —in terms of study intersection and study roadway segments —Is sufficient to adequately analyze the
combined potential traffic impacts of the two projects.
IBI Group's scope of work under PlaceWorks' GPU EIR contract includes analyzing existing and forecast traffic
conditions at up to 40 intersections and 60 roadway segments. IBI Group previously completed the Existing Conditions
analysis portion of the traffic study for the GPU EIR.
The Circulation Element Update traffic study includes analysis of 84 intersections and 52 roadway segments.
Additionally, the locations analyzed for the Circulation Element Update and GPU EIR do not necessarily overlap. This
is a result of these documents proposing changes —either roadway or land use —in different locations in the city. The
Circulation Element analysis locations also reflect input from OCTA, Caltrans, and adjacent cities regarding analysis
locations related to the proposed roadway reclassifications.
In comparing the scopes of work for the two studies, IBI has identified the need to analyze up to 110 intersections
and 85 roadway segments for the combined Circulation Element and General Plan Update. This combined set of
locations considers the original 40 intersections and 60 roadway segments in the base contract, incorporates
additional intersections and roadway segments for the Circulation Element, and includes further additional locations
outside of Santa Ana in Costa Mesa and Irvine that IBI believes are prudent to analyze given the location and
magnitude of the proposed land use changes in selected portions of the city. This updated analysis would also
Incorporate removal of the following proposed roadway reclassifications per the City of Santa Ana's request:
» 5th Street
1st Street
The PE Right -of -Way
» Plaza Drive
Based on these changes, IBI Group's remaining budget under the GPU EIR contract is not sufficient to accommodate
the modeling, LOS, and VMT analysis required for a combined document. IBI's proposed additional scope of work is
detailed below.
OCTA Coordination
With the proposed MPAH roadway reclassifications still requiring OCTA approval, ongoing coordination with OCTA
will be required during the preparation of the traffic study for the combined Circulation Element Update and General
February 7, 2020 (revised April 9, 2020 1 Page 2
25G-6
Plan Update EIR. This coordination will include coordination with OCTA on producing OCTAM traffic model forecasts
and in the MPAH amendment process.
To support the traffic modeling, IBI Group will coordinate with OCTA and be responsible for providing details regarding
the roadway reclassification and land use/socioeconomic data for use in two model runs. OCTA will be responsible for
updating the OCTAM model to include MPAH reclassifications, and IBI will be responsible for inputting land use
changes and running the model for the new land use.
IBI Group will lead the coordination effort with OCTA during the review of the traffic study results, including meetings
(up to 4 meetings) with OCTA and adjacent cities, working with the City of Santa Ana to draft and receive letters of
support from adjacent cities, and attending the OCTA Board meeting for review of the proposed MPAH
reclassifications.
Traffic Modeling and Analysis
Traffic Modeling
This task will involve a review of the City -proposed land uses changes In the General Plan Update (Scenarios 1 and 2),
including any special transportation needs or considerations. IBI Group will coordinate with OCTA to obtain a new
OCTAM model forecast of future traffic conditions in the study area. The coordination will include providing OCTA
with the proposed land use mix (land use type and size) for each of the two scenarios proposed by the City.
Per discussions with OCTA, IBI Group will be responsible for incorporating socioeconomic data forecasts associated
with the future land use scenario into OCTAM. IBI Group will also be responsible for running the OCTAM model to
develop forecasts for traffic volumes with the proposed land use changes. OCTAwill input all proposed MPAH roadway
reclassifications into OCTAM.
IBI Group will be responsible for running OCTAM to generate forecasts for two land use scenarios. Once the forecast
for the higher land use scenario is generated, IBI Group will conduct an initial analysis and review to determine the
potential magnitude and number of significant traffic Impacts. The purpose of this initial review will be to determine
if the second model run with the lower -intensity land use is required. Only a single future General Plan Update land
use scenario will be carried forward through the full traffic analysis and VMT analysis. The purpose of this preliminary,
new review is to determine the scenario that will proceed.
For both scenarios, IBI Group will post -process forecast intersection volumes using a procedure based on the
Transportation Research Board methodology to generate future forecast turning movements at intersections. Post -
processing refines the model link level forecasts to produce reasonable turning movement volumes at the
intersections. Future roadway segment volumes will be forecast based on growth rates obtained from the model.
IBI Group has assumed that this scope does not include the development of a second VMT forecast. Only one VMT
forecast, consistent with the selected land use scenario, would be generated, consistent with the base scope of work.
Update Existing Conditions Analysis
The Existing Conditions Analysis for the General Plan Update FIR was previously completed by IBI Group. This
document includes analysis of 30 intersections and 50 roadway segments, leaving 10 locations of each type available
for future analysis once planned land use changes were known. With the finalization of the land use plan and
incorporation of the Circulation Element Update roadway changes and study locations, the Existing Conditions
February 7, 2020 (revised April 9, 2020 1 Page 3
25G-7
Analysis will require updating to ensure consistency with the future conditions traffic analysis. IBI Group will prepare
a draft and final version of the updated Existing Conditions Analysis for review by PlaceWorks and the City of Santa
Ana.
Expanded Future Conditions Trafi3cAnalysis
The original traffic study scope of work assumed IBI Group would analyze up to 40 Intersections and 60 roadway
segments. With the expanded list of study intersections resulting from the geographic spread of areas with proposed
land use changes in the General Plan Update coupled with the study area included as part of the Circulation Element
Update, the proposed number of study intersections has expanded to a minimum of 110 locations. This is an increase
of 70 intersections above the base scope of work.
The scope for this amendment task assumes the additional work efforts associated with analyzing 70 more
intersections (110 total) and 25 more roadway segments (85 total) as part of the traffic study conducted for the
General Plan Update EIR. IBI Group has also assumed that only one of the two land use alternatives will be fully
analyzed and documented in the traffic study.
After obtaining and processing the model data, a level of service (LOS) analysis at the additional study area
intersections and roadway segments will be conducted and summarized. IBI Group will identify areas that would not
achieve the City's LOS standards and will determine necessary improvements to achieve those standards. The
Intersections will be field reviewed to verify the preliminary feasibility of the proposed improvements, and the
resulting level of service at the impact locations will be quantified.
Expanded Traffic Study Report
IBI Group's original scope of work assumed preparation of draft and final traffic studies in support of the EIR. With the
expanded number of study intersections and roadway segments, this analysis will require additional effort to prepare
and complete the draft and final versions of the traffic study, including additional text and figures.
Task 1.2 Air Quality/GHG Analysis
No additional scope is required for this task.
Task 1.3 Cultural Resources Analysis
No additional scope is required for this task.
Task 1.4 Noise Analysis
No additional scope is required for this task.
Task 1.5 Hydrology, Water Quality, and Infrastructure
No additional scope is required for this task.
Task 1.6 Potable Water and Sanitary Sewer
No additional scope is required for this task.
February 7, 2020 (revised April 9, 2020 1 Page 4
25G-8
wl)
Task 1.7 Service Level Study for Fire and Police
No additional scope is required for this task.
Task 1.8 Geology, Soils, and Natural Hazards
No additional scope is required for this task
Task 1.9 Biological Resources
No additional scope is required for this task.
TASK 2 ENVIRONMENTAL DOCUMENTATION (PROGRAM EIR)
Task 2.1 Project Initiation
No additional scope is required for this task.
Task 2.2 Preparation of Project Description
Supplement the project description to address the Circulation Element, including appropriate graphics.
Task 2.3 Notice of Preparation and Scoping Meeting
Scoping Meeting materials will be supplemented to include a description of the Circulation Element.
Task 2.4 Prepare Screencheck Administrative Draft EIR
In comparison to our original scope of work, the Screencheck Administrative Draft FIR will need to be supplemented
to address the Circulation Element (including appropriate graphics). Technical analysis will be supplemented as
appropriate to discuss the Circulation Element related to air quality, greenhouse gas emissions, land use and planning,
noise, and transportation/traffic. Project alternatives may be modified to consider potential modifications to the
Circulation Element (roadway classifications, etc.)
Task 2.5 Prepare Second Screencheck Draft EIR
This task has not been initiated and no additional scope is required.
Task2.6 Prepare Draft EIR
This task has not been initiated and no additional scope is required.
Task 2.7 Public Notification
This task has not been initiated and no additional scope is required.
Task 2.8 Prepare Screencheck Final EIR
This task has not been initiated and no additional scope is required.
February 7, 2020 (revised April 9, 2020 1 Page 5
25G-9
Task 2.9 Prepare Final EIR
This task has not been initiated and no additional scope is required.
Task 2.10 Prepare Findings and Statement of Overriding Considerations
This task has not been initiated and no additional scope is required.
Task 2.11 Prepare Notice of Determination
This task has not been initiated and no additional scope is required.
Task 2.12 Meeting Attendance
Remaining meeting attendance is based on two progress meetings per month through a projected General Plan
Update approval date in November 2020. It is anticipated that our project manager, JoAnn Hadfield, and assistant
project manager, Dina El Chammas Gass will attend the progress meetings. Our attendance/participation in up to
three public hearings is included (per our original scope of work). Remaining budget is available in this task to
accommodate our meeting and public hearing attendance.
Task 2.13 Management and Coordination
The project's original schedule has been extended by 36 weeks, resulting in the need for additional management and
coordination fees. The additional fees are based on 1.5 hours/weekforJoAnn Hadfield and 1.0 hour per week for Dina
El Chammas Gass.
We appreciate your consideration of this requested contract amendment. Please let us know if you need any
additional information to assist you in expediting this request.
Sincerely,
PLACEWORKS
JoAnn C. Hadfield
Principal, Environmental Services
Attachment: Cost Estimate
February 7, 2020 (revised April 9, 2020 I Page 6
25G-10
Cost Estimate
CONTRACT AMENDMENT No. 1 - Cost Estimate (2/7/20, updated 4/4/201
Task
Description
Original Contract
Contingency
1
Total Contract
with
Contingency 1
Contract#1 Ra at
Total Contract
wlAmend 91
PlaceWorks
IBI
Total
Amend 1
TASK 9.
TECHNICAL $TUDESTOR THE,UNERAL;DI:AN'V34AT.- .
1.1
Tmffle Anal sls IBI
General Plan EIR Original Scope
$72,426
$72,426
$0
$0
$0
$72,426
OCTA Coordination
10,160
11,176
11,176
Traffic Modeling and Analysis
36,660
40,326
40,326
Expanded Traffic Report
6,120
6,732
6,732
1.2
Air Quall(yIGHG Analysis
21,191
21,191
0
0
0
21,191
1.3
Cultural heritage Resource Study (Chattel)
43,428
43,428
0
0
0
43,428
1.4
Noise Anal sis
20528
20,528
0
1 0
0
1 20,528
1.5
Hydrology , Water Quality, and Infrastructure FUSCOE
26,118
1,980
28,098
0
0
0
28,098
1.6
Potable Water and Sanitary Sewer
28,897
1,320
30,217
0
0
0
30,217
17
Service Level Study for Fire and Police
0
0
0
0
0
0
1.8
Geology, Soils,. and Natural Hazards
7,711
7,711
0
0
0
7,711
1.9
Biological Resources Carlson
13,332
1,738
15,070
0
0
0
15,070
' Task Subtotal
233831
5,038
238,669
0
52,940
58,234
269903
TASK 2,ENVIRONMENTA6DOOUMENtA:fb6kiBR'024J}AM"40) Cc
'.,..: .. ". .: s
77-7
Subtotal
147
February 7, 2020(revlsed Apr119, 2020) 1 Page 1
25G-11
AMENDMENT No. 1 - Cost Estimate
Total Contract 1 Contract#1 Request
wlth I Total Total Contract
Task I Description I Original Contract 1 Contingency 1 I PlaceWorks IBI Amend 1 I w/Amend 01
TASK 2.3 NOTICE OF PREPARATION AND SCOPING MEETING
2.3.1 Notice of Preparation (expanded, no Inifial Study)
$4,508
$4,508
$0
$0
$0
$4,508
2.3.2 Scoping Meeting attendance and prepmaterials
4,916
4,916
205
0
205
5,121
Task 2.3 Subtotal
1 9,425
9,425
205
0
205
9630
TASK 2.4 PREPARE SCREENCHECK ADMINISTRATIVE DRAFT EIR
2.4.1
Screencheck Administrative Draft El
$13,260
$13260
$0
$13,260
Chapters 1-0 (except Pro ect Description)
6,712
6,712
550
550
7,262
Project Description (Chapter 3
1,408
1408
2,990
2990
4,398
Aesthetics
5,345
5,345
0
0
5,345
Agriculture and Forestry Resources'
2,672
2,672
0
0
2672
Air Quality
3,213
3,213
390
390
3,603
Biolo ical Resources
2,672
2,672
0
0
2.672
Cultural Resources
3,611
31611
0
0
3,611
Geology and Soils
3,142
3142
0
0
3,142
Greenhouse Gas Emissions
3,213
3,213
195
195
3,408
Hazards and Hazardous Materials
4,457
4,457
0
0
4,457
Hydrology and Water Quality
4,692
4,692
0
0
4,692
Land Use and Planning
4,366
4,366
230
230
4596
Mineral Resources
2,815
2,815
0
0
2,815
Noise
31550
3550
360
360
3,910
Population and Housing
3,774
3,774
0
0
3,774
Public Services
11,546
11,546
0
0
11,546
Recreation
3,774
3,774
0
0
3,774
Transportation and Traffic
6,365
6,365
920
920
7,285
Tribal Cultural Resources
2,672
2672
0
0
2,672
Utilities and Service Systems
5630
5,630
0
0
5,630
February 7, 2020 (revised April 9, 2020) [Page II
25G-12
CONTRACT AMENDMENT No. 1 - Cost Estimate (2/7/20, updated 4/9/201
Task
Description
Original Contract
Contingency
1
Total Contract
with
Contingency 1
Contract 01 Request
Total Contract
wlAmend #1
PlaceWorks
IBI
Total
Amend 1
Chapters 6-12 (except Alternatives
3,284
3,284
0
0
3,284
Alternatives Chapter?
15,953
15,953
1,035
1,035
16,988
Task 2.4.1 Subtotal
118,126
118,126
6,670
0
6,670
124,796
TOTAL TASK 2.4
1%,126
0
118,126
6,670
52,940
64,904
183030
TASK 2.8 PREPARE SCREENCIFECK FINAL EIR
2.8.1 Pre are Screencheck Final EIR
$16,218
$16,218
$1,380
$0
$1,380
$17,598
2.8.2 1 Prepare Screencheck MMRP
1,173
1,173
0
0
0
1 1173
Task 2.8 Subtotal
17,391
17,391
1,380
0
1,380
1 18771
TASK 2.9 PREPARE FINAL EIR
2 9 11
Final EIR
$3,244
$3,244
$0
$0
$0
- $3,244
2.9.2
1 Final MMRP
546
546
0
0
0
546
Task 2.9 Subtotal
3,789
3,789
0
0
0
3789
February 7, 2020 (revised April 9, 2020) I Page iii
25G-13
CONTRACT AMENDMENT No. 1 - Cost Estimate
Total Contract Contract#1 Request
Contingency with Total Total Contract
Task Description Original Contract 1 Contingency PlaceWorks IBI Amend1 wlAmend#1
TASK 2.12 MEETING ATTENDANCE
2.13.1 Progress Meetin s 38 In -person meetin sand 38 conference calls
$43,145
$43,145
so
$0
$0
$43145
2.132 Public Meetings/Hearings (3), Prep and Attendance
7,390
7,390
0
0
0
7,390
Task 2.12 Subtotal
50,535
50,535
0
0
0
50,535
TASK 2 A 3 MANAGEMENT AND COORDINATION
2.13.1 FPM and Coordination
37,536
37,536
15,985
0
15,985
53,521
Task 2.13 Subtotal
37536
37,536
15,985
0
15,985
53,521
LABOR TOTAL
509391
5,038
514,429
26,515
52,940
84,749
599,178
Subconsultants Reimbursable Expenses
$14,300
$14,300
$0
$0
$0
$14,300
PlaceWorks Reimbursable Expenses
4,904
4,904
0
0
0
4,904
REIMBURSABLE EXPENSES TOTAL
19,204
19,204
0
0
0
19,204
2% of Labor for Office Expenses
6,078
15%Contingency
79,289
.5,038
74251
GRAND TOTAL
$607,884
1 0
1 $607,884
1
1
$692,633
Remalnln Contmct IBI 2011-198, 9113111
91,947
Total Contract Existing Contract w1IBI Transfer
699,831
$699,831
February 7, 2020 (revlsed April 9, 2020) I Page iv
25G-14