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>> good evening welcome to the may 8, 2019 meeting of the san francisco board of appeals. our former president frank fung has been appointed to the planning commission. vice president rick swig are take over role of president. he's joined by commissioner ann lazarus, commissioner rachael tanner. we expect commissioner darrell -- darryl honda shortly. at the controls of the board legal assistant, -- i'm the board executive director. we'll be joined by representatives of the city department this evening. we expect scott sanchez zoning administrator representing the planning department and planning

commission. the board meeting guidelines as follows. the board request that you turn off all electronic devices so they would not disturb the proceedings. please carry on conversations in the hall way. rules of presentation are as follows. appellants and department respondents are given seven minutes to present their and three minutes for rebu re-- reb. people affiliated with the parties must include their comments seven or three minute period. member of the public have three minutes each to address the board. please speak in the microphone. to assist the board, you're asked but not required to submit a speaker card when you come up to speak. speaker cards are available on the left side the podium.

only three votes are required to grant an appeal or condition. if you have questions. requesting a rehearing the board will rules or hearing schedules please speak to board staff during the break or after the meeting. we are located at 1650 mission street room 304. this meeting is broadcast live on sfgov tv. the video is available on our website and can be downloaded from sfgov tv.org. we'll swear in and affirm all those who intend to testify. any member of the public may speak without taking an oath under the sunshine ordinance. if you intend to testify, and wish to have the board give your testimony weight, please stand, raise your right hand and say i do after you've been sworn in or affirm. do you swear the testimony you about to give will be the truth

and nothing but the truth? thank you. please be seated. item number 1 is general public comment. this is an opportunity for anyone who like to speak on a matter within the board's jurisdiction that is not on the calendar. is there anyone here for general public comment? we'll move on to item number 2. this is commissioners comments and questions. >> president swig: any questions? you like to wish our former president success in his new position. we had a great, frank fung is an amazing person to have on this commission. amazing track record and dedication. i for one feel blessed i was able to sit with him during time i was here. wish him best success. >> i like to second those remarks.

>> any public comment on item 2? thank you. item number three which is the adoption of the minutes. before you for discussion of possible adoption oare the minutes of the april 17, 2019 board meeting. >> president swig: questions or comments? >> we have a motion from commissioner tanner to adopt the minutes. is there any public comment on that motion? seeing none -- [roll call] that motion carries 3-0. we will now move on to item 4. this is appeal -- [agenda item read]

we'll hear from the appellant first. >> thank you for having us. i'm orrit. just a few feet away from -- we like to start with the little story about the window. this 1 doe is just fe -- this ws just few feet away. i like to tell you a short story about this window. around the '60s, someone placed an electric cabinet on

this window. apparently with no consideration, no respect to thes a thet i cato theaesthetic. this building was built in 1880. we finally saved you have enough money to bring back the window to the original state. we had to get permit from the city and approval from the historic planning department. we spent two days in d.p.w., paid $400 for the permit, we pay about $1000 for a specialized carpenter to restore the window to bring it back to what it was. we thought why not just replacing this window with this aluminum very modern looking window. it's much more functional. it's cheap, right? the reason is, because of the

esthetics. this is what we're talking about today. the esthetics of the city, the esthetic of our neighborhood, the victorian, integrity of our neighborhood. we're now -- we want to argue verizon does not comply with the standard which was ordinated by article 25 what was approved but the california supreme court on april 4, 2019. they are not following the same standard that the people required for the residents live in the city. i'm here to argue that the proposal tenant compromised the esthetics of the neighborhood and decrease the value of our property. you want to refer to article 25, other equipment that telecommunicationings providers

installed on the public right-of-way can vary in size and experience. however, the city needs to regulate the placement of such facility in order to prevent telecommunication providers from installing wireless antennas and associated equipment in the city, public, right-of-way either in manners or in locations that will be diminished the city beauty. i'm talking about manners and location. these are two things that we need to consider before providing the permit. i want to talk about esthetics. april 4, 2019 california supreme court ruled the city have the

right to regulate the placement of telephone equipment only utility poles to accommodate esthetic concerns. i want to talk about esthetics. i want to talk about what the city is considering esthetic. kcan i show some images? this is nice. this is what the city considers esthetics and make our city pretty and beautiful. this is what happened just few blocks away from us. looking here, the pole and next to it, the other street light, i think it's pretty obvious one is more esthetic than the other.

on now i'm going to the proposed antenna and the pole the antenna will be placed on. this is it. this is next door house. this is the antenna. i would just say that we're not against technology. i want to ask a simple question. thithey're going to place a metl box on top of this antenna and basically will decrease anything that looks like it used to be in this area and this corner. the clutter that's there with all the wires and all the boxes, little closeup o where they

propose to put the antenna. i want to quote darwin who talked about esthetics. seeing is stripe of soup in a man's beard is disgusting either though neither soup nor beards are themselves disgusting. you want to show what verizon put in their proposal. this is how it's probably going to look like. this is how it looks now around the city. the propose antenna is out of character and will decrease the property value and will compromise the beauty our neighborhood. we're all concerned what's happening in our streets and the city spend so much money to

clean up the streets. our skyline will look the same. it's clearly a visual pollution and the city has to right and power to stop it. this is an urgent matter before you and we ask you to common datcommondatemandatearticle 25 r appeal. thank you. >> we'll hear from the permit holder. >> good evening president swig and members of the board. i too will miss mr. fung and his wonderful voice. i'm sure he'll do a wonderful job on the planning commission. the appellant mentioned rules about placement of an historic window. those rules are appropriate

protecting the city and those are the rules that verizon wireless has followed in getting this application approved by the department of public works, the department of public health and the planning department. the t-mobile case that she mentioned supreme court approving on april 4th of this year upholds article 25 and upholds its review of the esthetics. those are the rules we are following and the city is using its standards and objective standards that you help develop when you come up with the esthetic design that the verizon wireless is employing to provide 4g service throughout san francisco. the pole top is required by pg&e in order to separate the antenna from the wires. we're replacing the pole in this case, the distance between lines and the antenna will be a new wooden pole on top of the wooden

pole will be a 4-foot fiber glass antenna that is painted to match the pole, 14-inches in diameter to make it look like a continuous gee metric design. the pole will rise from 34 feet to 45 feet. the height of the building is 3. the entire antenna will be above the roof line in a manner that doesn't modify really the view of the building itself, which is the pole is already the height of the building. we've done with the radios that we have designed for the pole have done everything we can to come up with the facility that follows the lines of the pole. not the old boxes that used to be put on the utility poles. it's difficult to provide service in an historic district. this is an historic district in article 25 puts us through

difficult rigors. we have it not significantly impair the esthetics attributes. the planning department in a very thorough analysis, agrees that it does not do that. this is a residential transit-oriented area. it's pedestrian oriented. our equipment is up and away from the sidewalk. but also, i'm sure you'll know, p.e.d.ss in sa-- pedestrians arn their cell phone. we have an important service we're trying to provide. the department of public work reviewed the third party engineering review. because of the height of this antenna and because it's able to project arrow beam, less than one percent at ground level. the planning department, met the

two required standards for both the historic district and for the zoning protected district. department of public works approved the project in this location. as you said, we need to provide service particularly in residential transit oriented districts. weapo-- we need to do the histoc districts. there's no street lights. we're using existing utility pole, trying to follow the lines of that pole and make it with the equipment we have to use as attractive as we can and hopeful it wilit will disappear into the landscape. i will be happy to answer any questions that you have. we encourage you to uphold the decision of the director of the public works and department of public health. thank you very much. >> we'll hear from the

department of public works. >> hello. my name is leo, representing public works. we believe that this permit was issued in compliance with the permitting procedures we find in public works article 25 for personal wireless service facility. the planning department is in attendance and can speak with planning review process. if the board has questions, we're available to take questions and respond through email. thank you. >> mr. sanchez? do you have anything to add? >> thank you, scott sanchez. you don't have anything further. d.p.w. staff and permit holder have the details. noting it is undesignated street. it's a matter of the zoning

district that is went residential district as well as the historic district being within the residential historic district. which is not a district for local purposes and that regula regulated under article 10 and 11 under the permit code. we did properly review the proposal and find it complies with article 25. available for any questions that anyone has questions. swi >> president swig: where is the tipping point? where the impact on an historical district? what will be an example of that? we had one year ago on telegraph road, where we aggregated impact. we know the aggregated impact of

many installations had altered the course of the neighborhood. where is that tipping point what will be an example one of these installations would breach the integrity of an historic district? >> excellent question. article 25, it speaks to -- for public right-of-way within a national historic landmark listed or eligible national historic district listed eligible california registered historic district, which this is, local historic or conservation district or local significant district. the standard whether proposed personal wireless service would significantly degrade the esthetic attributes of the district. it's looking at when the district was formed. there's an analysis by

preservation specialists. they set the boundaries and look at the buildings within the boundaries that identify if there's a potential historic district there. it can be kind of spread out. they found it to be grouped together. not speaking to street furniture as we see it there. you could have some districts where development and public right-of-way is more necessary or led to the creation of the district. you can look at where we have historic light poles. this is not a district that is known for its historic light poles or other features. it's also question to the number of facilities and whether it's detracted from the building. additionally it's in front -- a building known as historic

resource. the existing pole as permit holder mentioned, is above the height of that building. it's looking at both the district, the impacts on the district, whether there's some things specifically when the district was created that spoke to the public right-of-way and then also look at the number of such features within the district and then also the impacts on individual resources in this case, finding there was no impact on the adjacent building. >> president swig: when you look at the photos presented by the appellant, due to the poles that are existing, basically, your point of view would be that there's already junk there and

multiinputting few more pieces k there won't make it any worse. let's face it, it looks like a bird's nest of wires already one more piece rising above that especially as the height above the roof really isn't going to damage the estheticny an esthet. >> in part it is looking what the baseline and the relationship to the adjacent building which is a known resource and finding. i prefer to see it lower. but there are separation requirements as i understand it between the high power lines and the equipment. i believe this is as low as could be created here but programs the permit holder can speak to that further. >> president swig: if let's say

that -- there wouldn't be junkie old poles with junkie old power lines. the neighborhood would have been undergrounded, and there would be an elegance historic looking street pole in place and then the place would have been selected by verizon for this space. there already more discussion on this because it would disrupt the environment. >> if they were moving historic rod iron utility pole and replaced with something that's not of that character, then that would be a concern. we have districts maybe not undergrounding but less junk in the public right-of-way. some districts where there isn't as much junk, you have places where there are utility poles for light or for muni.

it's hard to get away from that. we have worked with the carriers to design them. they trying to be minimal as possible. there's an equipment on the pole that services the antenna above. we try to minimize to the extent possible. even where you don't have a lot of junk, it could be appropriate to have these facilities installed. >> president swig: thank you. >> thank you. is there any public comment on ithis item? >> i'm brian brooks. i live 100 feet away. you live on 113 webster street. our building is built in 1899. we look out and see the mint on mint hill. we see their building and you

raised my family. i'm offended that san francisco has been laying down and letting corporations do as they seem. yes, we don't have underground wiring in our neighborhood. to call it junkie kind of hurts me little bit. we live in a historic district. all the victorians in our neighborhood have an esthetic to us, have an esthetic to the city. extending that pole for an antenna, it would ruin my view. it would ruin other neighbor's view because we're up on the hill and looking down. we're just talking esthetickings. esthetics. no one talking health. other cities have 5g power. we can talk about esthetics. i'm not for this.

i'm sad i wasn't here earlier to voice my opinion and other neighbors feel the same way. hopefully you receive for emails to that effect. i would urge you to side with the appellant. thank you. >> president swig: i should use the word clutter instead of junk. >> there are wires. it is clot -- clutter. it doesn't matter. thank you. >> thank you. is there any other public comment on this item? seeing none, we'll move ton rebuttal. we'll hear from the appellant please. you have three minutes. >> i'm yoram wolberger.

we already live in that junk, we live this that clutter. i'm worried about adding some more to it. the plan for verizon and other communication is to do it every 100 feet in the city. we start here with our neighborhood, we care about this building. we bought it and we take care of it. we go through the expense, we spend two days a the preservation committee. we spent $400 on the permit just to replace two windows. i feel little bit offended to the people that talked before me. brushing away the issue of adding more junk or more clutter such a beautiful building. there are other options. you can see that's been done already.

you can see in the background, victorian style. this is a good solution. this is what we should do. we should look around, not look on our phone walking by. we should look upside way and all around us. from the top and neighbor view and see how beautiful the city is and not add more junk or more clutter to the city. then you have also this item, this is the proposition we got in the mail late. you can see how close it is from their viewpoint to the pole. this is how they are proposing to do the new one. first i hear they are reinflationinreplacingthe pole. it's not an iron rod. it is an old pole that was

there. i don't know when they put it in. the same as the people who put the electric box in the window didn't care. we're in a different time now. we know better. we shouldn't do this with all those extension and metal boxes and extend wooden pole, that's what they're planning fopped to. >> president swig: in your original letter, not in the your formal brief dated march 25th, you noted the lack of community outreach and that you were concerned that the community have not been proper notified. you did not put that in your formal brief. is that still lack of notice.

>> it is still an issue. this is the main issue. there are other issues. i went through that in the first hearing. >> president swig: would you please talk about your issues on outreach? that is a very big important item. >> i think we expected to get more communication to the neighbors, beside what they did with this part of the procedure. our city -- we didn't get as neighbors anything that came from verizon. i think that -- [indiscernible] the association really reached out to them and never heard back from them to meet with neighbors to discuss with neighbor their concerns. i think there was no small attempt to reach neighbors and

to have community outreach. >> president swig: we'll ask representative from verizon and the d.p.w. to discuss and describe their outreach process in this case. thank you. >> we'll now hear from the permit holder. >> first you want to say that we worked -- the planning department was aggressive in terms the design and required verizon to go back and sharpen their pencil and reduce the height of the pole by foot and a half so it will be shorter. we did work closely with them with respect to esthetics. with respect to the appellant's point, i can go into more depth, public views are protected.

that's what we trying to achieve. terms of undergrounding and light standards, there are many parts of the city that's undergrounded. verizon is putting them in acceptable facilities. we're using the existing infrastructure in order to minimize esthetic impact so the pole is there. we are extending the height and using that as opposed to installing our own pole. part of that t-mobile case to california supreme court end upholding article 25 confirmed that verizon has the right to put telephone equipment on a telephone pole in right-of-way. that's how we provided this critical infrastructure as more and more landlines are going away. this is truly critical infrastructure. we know the state is preparing a system to send a text message to everyone a few moments before an

earthquake. there are public benefits in addition to effort to minimize any esthetic impacts. the noticing followed, noticing that's required 150 noticing. the representative from c.b.r. has the notices and they are in the d.p.w. material. we have number of people requiring through protests in the hearing. there was a protest hearing where protesters were able to speak. there's a subsequent notice with the final determination that's mailed out to neighborhood associations within 300 feet. anyone who signed up for the protest can be heard again by the you appeal. we had community meetings and we had meetings before the board of supervisors. there's been a great deal of effort to communicate with the community. but we are installing hundreds

of these facilities. >> thank you. we'll hear from the department of public works. >> article 25 requires public works refer wireless obligations to the department of public health and planning department. both departments determined this application complies the with article 25. public works issued a approval and post notice of of this approval per article 25 section 1512. following the hearing the director of public works approved the permits and notice of determination was distributed to the public. specifically, we mailed notices to protesters and neighborhood groups. >> thank you. mr. sanchez, anything to add?

commissioners this matter is submitted. >> commissioner tanner: you have not heard anything that would enable me to grant the appeal. >> commissioner lazarus: i agree. >> commissioner tanner: it was considered and issued. it's important for of the public to understand that we have limited discretion in these matters. the federal government and the state government have worked to create a framework under which we have to operate and public works planning created local policies. we have limited discretion in these matters in regards to esthetics and health concerns and that we can make our

decisions based on. given the testimony today, i'm not hearing anything that would suggest permit was not properly issued in cargo t according to e 25. >> president swig: would you like to make a motion? >> commissioner lazarus: move to deny the appeal. >> we have a motion from commissioner lazarus to deny the appeal on the basis of the permit was properly issued on that motion, [roll call] that motion carries. appeal is denied. i will check to see if commissioner honda is here. >> president swig: would you ask him to enter -- oh, he did. we'll take a brief pause while we wait for hum. there he is.

call the next item please. >> welcome commissioner honda.we are now on to item number 5. [agenda item read]

commissioner lazarus and commissioner honda were present may 13, 2019. commissioner tanner you had an opportunity to review the video and materials for the hearing that took place? >> commissioner tanner: i did. >> noted for the record. we will hear from the permit holder. >> good evening. president swig, commissioners. my name is andreas mouarass.

we were hired by vassiliki moulas couple of years ago to legalize this illegal unit in her garage. this project goes back to 2010 looks like. things happen two to three years you guess. i told her as a contractor i can probably get her permit in couple of weeks. it's taken a lot longer. i said i would have the permit tonight. that's why i asked for an extension. she sent us the form to cancel this had we secured a permit.

san francisco engineers to help us with the process. they've created the drawings that we have here. the permit status is that the planning department has signed off. the building department has signed off but the fire department has not signed off. may 12th of last year, we were sent request from the fire department with a bunch of questions to be answered on the drawings. since then, the person that wrote the letter, has moved from this desk to another desk. as i was diligently calling to communicate with her, i was reaching lieutenant of the fire department. i did not -- we did not come to contact until two weeks ago. those two weeks i was trike to

-- trying to get the permit passed. we would like more time possible, probably two weeks and two weeks. all the questions have been answered. only thing we need is the fire department's signature and then we should be able to pick up the permit. the permit legalizes one bedroom unit behind the garage in this building. this fire department issue where the water is and size of the pipes where the city hydrants are, these have to be addressed last set of questions. i apologize it didn't happen quicker that i had anticipated. we're always relying on people whether it's engineer or fire

department, some time has gone by. i apologize for that. i'm requesting some time and extension if possible. we're almost there. are there any questions? >> president swig: you're participating in the additional dwelling unit? >> that is correct. >> commissioner honda: which is a fairly new program. >> that is correct. any other questions? >> commissioner lazarus: looking at the notice the fire department sent, are you able to comply with all the corrections such as ground flooring, sprinkler and escape opening. >> the owners has been notified we would have to increase the water supply to the property. which is noble. we will comply with sprinklers

on the ground floor. the answer is yes. >> commissioner lazarus: thank you. >> thank you sir. >> i will give you all a five and excellent. thank you. >> wait until they decide. [laughter] mr. sanchez or mr. duffy? >> thank you. i think this is a good story here. we look forward. we did approve that permit more than a year ago in january of 2018. seems like it's been almost a year some commenting comments wy fire. we like to see this move along. if the permit holder needing few

more weeks, that's fine. they can withdraw this permit and would not need to come back to this board. we appreciate the unit is legalized. we want that to happen as soon as possible. we're open to some continuous. we want to get this done quicklied as a possible. it's been a long time in the hands of the permit holder. maybe they have some issues with staffing and communicating back and forth. the board can take action tonight and to deny this permit. that doesn't prevent them from legalizing the unit. this permit needs to go away. thank you. >> thank you. we'll hear from the department

of building inspection. >> joe duffy. you agree with mr. sanchez there. we could cancel the permit. we do need permission from board of appeals to do that. we'll move forward with getting this permit issued and work done. then we can clear the notice of violation as well. that will be the process. >> commissioner honda: that's your recommendation? >> i prefer to -- seems like there's something wrong. i think we can just simple -- that can happen any time. this one so far down the road, once it getting through fire, it pretty much going to get issued.

>> commissioner honda: thank you. >> any public comment on this item? seeing none. commissioners matter is submitted. >> president swig: thoughts? >> commissioner honda: i'm pretty sad looking at that empty seat there. having heard this case before, and having work withed the fire department on a.d. u.s, they're still working out bugs at the the fire department as well. i would go along with the suggestion to cancel the permit and let them do this administratively. >> commissioner tanner: i'm confused about what what actione take? >> it might be cleaner just to continue it. the appeal could be denied.

>> how much time do you guys need? >> we can put them on in june. presumably they'll get their permit and that will withdraw the appeal. why don't we put them on june 26th just to give a buffer. we would need a motion to continue to june 26th. we have a motion from commissioner honda to continue this matter to june 26th. [roll call] that motion carries 4-0. the matter is continued to june 26th. hopefully you can secure the permit before that time. thank you. we are now moving on to item 6. this is appeal number 19-020.

ingrid eggers versus department of building inspection. [agenda item read] we will hear from the appellant first. ms. eggers. >> okay. president swig, members of the board. i was standing here two years

ago appealing the building permit of this house. now i'm here to ask you to delay the to give he time to assess the dangers. i'm trying to get this downsized. i live in the back of the yard facing the project from the front of my doorstep from my kitchen, living room and bedroom. it's an historic district and my house is the oldest on the block. to add footage, you can only do two things. you can build into the yard and dig deep. i'm on the lot with two houses.

mr. mcbaine permit holder tried to buy it. but didn't get it. six-year-old ago he bough -- sis ago he bought the house in question. you approved everything two years ago. deep excavation seems to require a shoring permit. this was not announced to the neighbor. i found out when the permit was sent an email in march telling the neighbors that construction will start in early april. it came to us as a big surprise after hearing nothing from him for a long time.

the email was followed by technicians and put in monitory devices two years earlier. they showed us the plans, talked about the excavation to shore up the 25 feet excavation for safety reasons. i was worried when you saw those plans. when the building plans were first shown to me years ago, i was shocked. i never imagined a developer would turn the house next door into three times the size of what it is now. you seen lots of renovations on my block and i've been living there are for more than 20 years. this i thought was outrageous. even more outrageous, you thought what followed that the city say it's okay to it.

after all elderly woman living in the cottage next to this planned project, raises the question how would she survive all this. nobody cares. now comes to shoring which is another dimension to the excavation. i made a few phone calls to investigate and ended up with joe duffy and he said hire your own engineer if you want to have peace of mind. i hoped to get delay from the shoring to find an expert that duffy suggested. i hired an expert who found a mistake in the calculation of the height measurement but nothing was done about it. last time i contact with the permit holder was more than two years ago over coffee and

attempt to go the neighborly because he said he will be living in the dream house. building on that, i certainly had hoped to get more advance notice from him just a few weeks. have an airbnb unit on the garden level mr. mcbaine know about it. i'm retired from a job, i get $2000 in social security a month and about the same from airbnb that is important income for me. i ask mr. mcbaine to reimburse for projected losses for the next two years, although the construction will take much longer, he declined. did not offer anything. just a footnote about my

apartment, it belongs to my daughter. it's 35 square meters or 380 square feet. it's bigger than my airbnb unit. another issue i'm worried about is my health. i'm 75. very recent article in the "new york times" describe there's a big excavation apartment. neighbors moved out, especially the elderly. noises and dust can damage your health. noise seem to affect the brain especially the nervous system. i moved into a house because of it. to sum it up, i'm deeply worried about the safety my house and my health and by his and need abou

business. nobody ever say to mr. mcbaine wake up, build your dream spot somewhere else. i love my house and don't want to move away and with your help, i hope to stay. >> thank you. >> you said i did hire an expert who found an error in calculations. was that provided to us or provided in writing? >> yes, it was provided in writing and it was two years ago when i came here. for the building. it was a height measurement. >> commissioner tanner: thank you. >> you can be seated. we'll now hear from the permit

holder. >> members of the board. good evening i'm justin mcbaine. i'm here tonight with my partner luke. i've been seeking permits to remodel 3751, 20th street. that permit is no longer subject to appeal and i'm not here to relitigate. the permit ms. eggers you appes a shoring permit it does nothing

to change the scope of the property. the property is built on a hill and curren currently lowest flos more than 15 feet. building below the existing structure involves significant excavation. the level of work is not unprecedented in city of san francisco or in this neighborhood. larger property to the west directly next door at 3755, 20th street underwent a similar project about 15 years ago. the shoring plan for this project has been designed by ben lie an experienced shoring engineer with decades experience. i included his brief. this is a conservative plan that provides for the lateral support of my neighbors. the plan will be executed by ken block. mr. block has 32 years of experience working in san francisco and has performed hundreds of jobs similar to this

one including dozens with mr. lye. he's well respected within the san francisco building department. he's also regarded as one of the top foundation contractors in the city. after learning ms. eggers appeal on march 27th i took the following steps. one, on april 3rd i sent an detailed email to ms. eggers answer every question. on april 5th, i held a meeting for ms. eggers on her lot. on my side in addition to myself and the shore engineer and ken block and the general contractor. we presented a large copy of the plan and walked her through the plan in detail. at no time she raise objection to the method. after this meeting, number three, i sent a follow-up letter with a contact information with the implementation of this plan.

this is included in the brief as exhibit e. four, on april 22nd and reading her brief, i again sent her answers to every one of the questions she posed about the project. i included a copy of ben lye c.v. and a link to the shoring plan. if there's a way i could have more transparent about this thoroughing plan, i'm not sure how. you have provided answers to all of her questions. three times including in the brief i submitted last week. at no time she request a shoring plan, you sent them to her anyway. at no time she request a meeting to have mr. lye and mr. block walk her through the plan. i took these steps proactively and still coming in this hearing despite having everything shneide, th -- she needs, she sl has not qualified engineer review these plansor