commission, must grant an adoption of shadow findings that the shadow on the proposed 11th and natoma park would not be significant or adverse to the use of the park. pursuant to the planning code section 295. additionally the commission must grant conditional use authorization for wireless telecommunication facility taller than 25ft above roof grade or height pursuant to planning code sections two, 10.2, and 303. the department finds that the project is, on balance, consistent with the market and octavia area plan. downtown area plan, and the objectives and policies of the general plan. the proposed facility will enhance the area's public safety infrastructure, but providing improved wireless telecommunication services to the surrounding neighborhood. at all times, as well as during natural disasters or other emergencies. the department also finds the project to be necessary, desirable and compatible with the surrounding neighborhood and not to be detrimental to the persons or adjacent properties in the vicinity. staff recommends approval with conditions. and that concludes my presentatio

quantitatively the memo states that parks smaller than 2% in size with more than 20% existing shadow as is the case for 11th and natoma, they recommend no new shadow, the park is point 4 acres in size, experiencing 26 percent of the shadow and the project would add new shade for a total of 23.265. quantitatively, they also include the time of day shadow, time of year, shadow duration and location and public good as previously described. thank you. this ends my presentation. both planning staff and myself are available for comments and questions. >> thank you, brian. we'll move to public comment on item 11. is there anybody in room 416 that would like to comment on this item? seeing none, and we have none on the webex, so public comment is closed. >> thank you, ashley. do any of my colleagues have any questions or comments? >> i do. >> joe, first. >> just brian, i'm curious, we've had many shadow issues come before us, at least in my three and a half years in my commission. and it's always an existing program with a new structure to come. is this the first time that this has happened in reverse in your career? >> in my